Corrective Action Plans

With the implementation of the new software, Yardi Voyager 7s, a plan is in place to develop Standard Operating Procedures that are consistent with the City of Pittsburg’s Standard Operating Procedures. The Housing Authority Staff is updating the Administrative Plan to address operational procedures and the Finance Department Staff are developing procedures for internal control and transactional review. The Housing Authority has and will continue to provide resources for training and education. The budget for Fiscal Year 2023-2024 includes an increased allocation for Staff Training. Source documents have been collected and data is under review. We have engaged our former Accountant II to assist with corrections for December 2021-June 2022. The current Accountant II is finalizing an open ticket with Yardi to correct errors to the software-generated VMS report for July 2022-November 2022. The reporting errors have been identified as originating from an improper account set up during initial implementation. We have opened a ticket with the software vendor and the Yardi Development team is reviewing our findings.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Arlene Laughter, Business Supervisor Anticipated Completion Date: December 31, 2024 Planned Corrective Action: The District has created an assistant manager position that will oversee all mandatory and required reports as requested by the Department of Education and Grants management. The District has also reached out to Jon Chase with Grants management to determine the required status of the report. In the future, the District will create a calendar to determine all timelines are met.

The Finance Department and Grants Management will train additional staff to mitigate the effect of staff turnover.

2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the Designated Employees in charge of overseeing the GLBA policy. Corrective Action Planned During the audit, it was noted that Tusculum did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. In fall 2023, IT, the Registrar, and the Director of Financial Aid met to discuss making sure that all of the new pieces of the GLBA policy were being implemented properly. In December of 2023, IT began the latest vulnerability scan and risk assessment to be in compliance with the risk assessment requirements of the GLBA Policy. This assessment should be completed by the end of spring 2024. The University is also working on updating its GLBA policies and procedures to align with the GLBA Policy. Anticipated Completion Date This process is currently ongoing and it is the University's goal to have ongoing GLBA policies updated and the risk assessment completed before the end of the 2023-2024 academic year.

Corrective Action Planned: Community Action Center of Northfield (CAC) is working with our food sourcing partners to investigate better accounting practices from their end to more accurately facilitate USDA food inventory before the food stuffs are delivered to CAC. Additionally, CAC will investigate cost-efficient models of physical inventory for in-kind donated (free) food. Name(s) of Contact Person(s) Responsible for Corrective Action: Scott Wopata, Executive Director, will be responsible for leading correct actions Anticipated Completion Date: While CAC is hopeful to receive more accurate inventory records from our food sources, this is outside of our control. Additionally, initial research into inventory management systems have proven extremely cost prohibitive as they relate to technology and/or labor, especially related to in-kind donated (free) food. We will pilot manual weekly inventory counts in the 2024/25 fiscal year with full corrective actions to reflect the outcome of those pilot studies.

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Mortgage Insurance Rental Housing Federal Financial Assistance Listing: #14.134 Finding Summary: Testing performed by the auditors relating to testing of property, operations, and distributions detected one instance where a disbursement of Project funds was not supported with a detailed receipt. Responsible Individuals: Sue Lund, Administrator Corrective Action Plan: The Project will implement new form for invoice approval completion which includes ensuring proper documentation is obtained and retained before disbursement of funds occurs. Anticipated Completion Date: May 31, 2024

Finding: 2023-002 Reporting – Internal Control and Compliance over Reporting City’s Corrective Action Plan: As a direct outcome of the FY23 single audit findings, it was determined that we were not in compliance with filing the annual reports. Consequently, we did not file by the deadline of 12/31/2023 in anticipation of the SEFA for FY24. We acknowledge the non-compliance and are committed to rectifying the situation by submitting the annual reports by April 4, 2024. The Airport has addressed this finding by implementing stricter internal deadlines and enhancing oversight procedures. The Airport hired a dedicated Accountant in February 2024 to enhance the airport’s capacity to manage grant-related tasks effectively, ensuring timely submissions moving forward. Responsible Person: Executive Director of Aviation Expected Implementation: April 4, 2024 Finding: 2023-002 Reporting – Internal Control and Compliance over Reporting City’s Corrective Action Plan: The City has implemented new policies and procedures verifying timely submissions, including verification provided by the City’s Consultant to City Staff of the timely submissions. Responsible Person: Director of Housing & Community Development Expected Implementation: July 1, 2024

CORRECTIVE ACTION PLAN March 26, 2024 City of Roanoke, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2023 The findings from the June 30, 2023 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2023-001: Workforce Investment Opportunity Cluster - Assistance Listing #17.258117.259 / 17.277 / 17.278, Subrecipient Monitoring Condition: During our review of subrecipient monitoring, we noted that the City's monitoring was not being performed according to the formal written policy. While monitoring was performed and documented during the second half of fiscal year 2023, there was a lack of evidence of testing and suggestions to the subrecipient during the first half of fiscal year 2023. Criteria: According to 2CFR 200.33l(a) of the 0MB Compliance Supplement, the City should make subrecipients aware of award information. According to the City's Program Participant Monitoring Plan, the City is supposed to conduct subrecipient monitoring on a semi-annual basis which should include desk reviews of payroll, disbursements, and other financial items. Cause: Staff turnover, particularly for the role of grant accountant, caused these procedures to be overlooked. Management prioritized core operating activities with staffing vacancies in lieu of monitoring activities. Management asserts staff went onsite to review key documents, as documented by email activities, but did not document specific items subject to review. Effect: Noncompliance with federal grant requirements with regard to subrecipient monitoring as well as an increased risk of subrecip1ent misusing funds. Questioned Cost Amount: Not applicable. Perspective Information: One out of two awards Recommendation: We recommend performing subrecipient monitoring in accordance with the City's guidelines and following the procedures laid out in the Program Participant Monitoring Plan. Corrective Action: Management concurs with the recommendation and will ensure that follow-up occurs regarding information provided by business owners. Loss of staff in this accountability area resulted in inquiry and reviews conducted by varying personnel the past few fiscal years. The Accounting Supervisor and the Accounts Payable coordinator, in the absence of a Grant Accountant, conducted the first semi-annual visit for fiscal year 2023. A grant accountant was hired in Spring 2023 along with an Accounting Manager, who were able to conduct the second visit in June 2023. Revisions to the policies and procedures were made following the June visit along with developing formalized documentation templates that show what was subject to monito ring. Fiscal year 2024 monitoring in January 2024 has been completed with follow-up to occur in June 2024. 2023-002: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's disbursements related to the program, it was noted that procurement policies were not being followed. In 3 of 25 instances, credit card purchases were not properly approved. Criteria: CSLFRF funds may be used for eligible expenses subject to restrictions set forth in Treasury's Interim Final Rule and Final Rule at 31 CFR Part 35. Also, 2 CFR Part 200 section 303 requires effective control over, and accountability for, all funds. According to the City's procurement policy, department managers and directors are supposed to review and approve credit card purchases on a monthly basis. Review includes ensuring appropriate supporting documentation is included. Documentation should support that transactions are for allowable expenses. Cause: Though the City has controls that push compliance, monitoring and enforcement by Finance is lacking. Additionally, the volume of transactions make monitoring challenging. Some transaction support and approval are routed electronically through US Bank for automation, but there are thousands of monthly transactions. Effect: Noncompliance with federal grant requirements with regard to disbursements. Questioned Costs: Not applicable. Perspective Information: Three out twenty-five transactions Recommendation: We recommend disbursing funds in accordance with the City's procurement policy including a process that requires approval of all credit card purchases. Corrective Action: Management concurs with the recommendation and will ensure that procurement policies including those over credit card purchases will be adhered to. Starting in fiscal year 2023 communication to department directors occurred reinforcing that reviewing and approving financial transactions is necessary under City policy. The City's Department of Finance on a monthly basis is monitoring P-Card compliance and has enhanced communication of internal deadline dates for coding and approving transactions. Follow-up is performed by the Accounts Payable coordinator to address issues with individual users and departments who have unapproved transactions. This practice will continue moving forward with issues of continued non-compliance by users and directors potentially resulting in revoking privileges of using city purchasing cards. 2023-003: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's revenue loss calculation, it was noted that one revenue figure was not supported by the City's transmittal form causing the lost revenue available for the City to claim to be understated by approximately $4.8 million. Criteria: Under the Final Rule, recipients can elect a one-time "standard allowance" of $10 million (not to exceed the recipient's award amount) to spend on the "provision of government services" during the period of performance. Alternatively, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the Final Rule to determine the amount of SLFRF funds that can be used for the "provision of government services." According to the 0MB Compliance Supplement section 4-21.027 section III B, recipients can choose whether to use calendar or fiscal year dates but must be consistent through the period of the performance and must provide auditors with evidence supporting their revenue loss calculation. Cause: The calculation of revenue loss was performed by staff who was new to their role with the City. All figures agreed with the Auditor of Public Accounts (APA) transmittal except for one section. Supervisory review was performed but did not detect the inconsistency in the calculation with reported figures on the APA transmittal form. Effect: Noncompliance with federal grant requirements with regard to lost revenue, understating the available revenue loss the City can utilize. Questioned Cost Amount: Not applicable. Perspective Information: Three out of twenty-five transactions Recommendation: We recommend that a process be put in place that ties out all amounts used on the lost revenue calculation to amounts on the transmittal form. Corrective Action: Management concurs with the recommendation and will ensure that the APA transmittal is used for future calculations as necessary. The calculation will be subject to multiple reviews. A final ARPA revenue loss calculation is planned for the spring that will incorporate the updated revenue loss figures from fiscal year 2023 ACFR and update the reporting figures in the fiscal year 2022 ACFR. The City's plan for ARPA spending currently does not plan to utilize the entire revenue loss funds but instead seeks to spend on specific projects that are ARPA eligible. If the Federal Audit Clearinghouse has questions regarding this plan, please call Andrea Trent, Financial Management Consultant at 540-853-5224. Sincerely yours, Andrea F. Trent Financial Management Consultant

CORRECTIVE ACTION PLAN March 26, 2024 City of Roanoke, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2023 The findings from the June 30, 2023 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2023-001: Workforce Investment Opportunity Cluster - Assistance Listing #17.258117.259 / 17.277 / 17.278, Subrecipient Monitoring Condition: During our review of subrecipient monitoring, we noted that the City's monitoring was not being performed according to the formal written policy. While monitoring was performed and documented during the second half of fiscal year 2023, there was a lack of evidence of testing and suggestions to the subrecipient during the first half of fiscal year 2023. Criteria: According to 2CFR 200.33l(a) of the 0MB Compliance Supplement, the City should make subrecipients aware of award information. According to the City's Program Participant Monitoring Plan, the City is supposed to conduct subrecipient monitoring on a semi-annual basis which should include desk reviews of payroll, disbursements, and other financial items. Cause: Staff turnover, particularly for the role of grant accountant, caused these procedures to be overlooked. Management prioritized core operating activities with staffing vacancies in lieu of monitoring activities. Management asserts staff went onsite to review key documents, as documented by email activities, but did not document specific items subject to review. Effect: Noncompliance with federal grant requirements with regard to subrecipient monitoring as well as an increased risk of subrecip1ent misusing funds. Questioned Cost Amount: Not applicable. Perspective Information: One out of two awards Recommendation: We recommend performing subrecipient monitoring in accordance with the City's guidelines and following the procedures laid out in the Program Participant Monitoring Plan. Corrective Action: Management concurs with the recommendation and will ensure that follow-up occurs regarding information provided by business owners. Loss of staff in this accountability area resulted in inquiry and reviews conducted by varying personnel the past few fiscal years. The Accounting Supervisor and the Accounts Payable coordinator, in the absence of a Grant Accountant, conducted the first semi-annual visit for fiscal year 2023. A grant accountant was hired in Spring 2023 along with an Accounting Manager, who were able to conduct the second visit in June 2023. Revisions to the policies and procedures were made following the June visit along with developing formalized documentation templates that show what was subject to monito ring. Fiscal year 2024 monitoring in January 2024 has been completed with follow-up to occur in June 2024. 2023-002: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's disbursements related to the program, it was noted that procurement policies were not being followed. In 3 of 25 instances, credit card purchases were not properly approved. Criteria: CSLFRF funds may be used for eligible expenses subject to restrictions set forth in Treasury's Interim Final Rule and Final Rule at 31 CFR Part 35. Also, 2 CFR Part 200 section 303 requires effective control over, and accountability for, all funds. According to the City's procurement policy, department managers and directors are supposed to review and approve credit card purchases on a monthly basis. Review includes ensuring appropriate supporting documentation is included. Documentation should support that transactions are for allowable expenses. Cause: Though the City has controls that push compliance, monitoring and enforcement by Finance is lacking. Additionally, the volume of transactions make monitoring challenging. Some transaction support and approval are routed electronically through US Bank for automation, but there are thousands of monthly transactions. Effect: Noncompliance with federal grant requirements with regard to disbursements. Questioned Costs: Not applicable. Perspective Information: Three out twenty-five transactions Recommendation: We recommend disbursing funds in accordance with the City's procurement policy including a process that requires approval of all credit card purchases. Corrective Action: Management concurs with the recommendation and will ensure that procurement policies including those over credit card purchases will be adhered to. Starting in fiscal year 2023 communication to department directors occurred reinforcing that reviewing and approving financial transactions is necessary under City policy. The City's Department of Finance on a monthly basis is monitoring P-Card compliance and has enhanced communication of internal deadline dates for coding and approving transactions. Follow-up is performed by the Accounts Payable coordinator to address issues with individual users and departments who have unapproved transactions. This practice will continue moving forward with issues of continued non-compliance by users and directors potentially resulting in revoking privileges of using city purchasing cards. 2023-003: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's revenue loss calculation, it was noted that one revenue figure was not supported by the City's transmittal form causing the lost revenue available for the City to claim to be understated by approximately $4.8 million. Criteria: Under the Final Rule, recipients can elect a one-time "standard allowance" of $10 million (not to exceed the recipient's award amount) to spend on the "provision of government services" during the period of performance. Alternatively, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the Final Rule to determine the amount of SLFRF funds that can be used for the "provision of government services." According to the 0MB Compliance Supplement section 4-21.027 section III B, recipients can choose whether to use calendar or fiscal year dates but must be consistent through the period of the performance and must provide auditors with evidence supporting their revenue loss calculation. Cause: The calculation of revenue loss was performed by staff who was new to their role with the City. All figures agreed with the Auditor of Public Accounts (APA) transmittal except for one section. Supervisory review was performed but did not detect the inconsistency in the calculation with reported figures on the APA transmittal form. Effect: Noncompliance with federal grant requirements with regard to lost revenue, understating the available revenue loss the City can utilize. Questioned Cost Amount: Not applicable. Perspective Information: Three out of twenty-five transactions Recommendation: We recommend that a process be put in place that ties out all amounts used on the lost revenue calculation to amounts on the transmittal form. Corrective Action: Management concurs with the recommendation and will ensure that the APA transmittal is used for future calculations as necessary. The calculation will be subject to multiple reviews. A final ARPA revenue loss calculation is planned for the spring that will incorporate the updated revenue loss figures from fiscal year 2023 ACFR and update the reporting figures in the fiscal year 2022 ACFR. The City's plan for ARPA spending currently does not plan to utilize the entire revenue loss funds but instead seeks to spend on specific projects that are ARPA eligible. If the Federal Audit Clearinghouse has questions regarding this plan, please call Andrea Trent, Financial Management Consultant at 540-853-5224. Sincerely yours, Andrea F. Trent Financial Management Consultant

AUDITEE’S CORRECTIVE ACTION PLAN As required by Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost principles, and Audit Requirements for Federal Awards (UG), the Jackson Public School District has prepared and hereby submits the following corrective action plan for the findings included in the Schedule of Findings and Questioned Cost for the year ended June 30, 2023: Finding 2023-001 Corrective Action Plan Details A.    Contact person responsible for corrective action: Name: Marc Rowe Title: Executive Director B.    Description of corrective action planned: The district will implement and strengthen its internal control systems over reporting and submitting its monthly claims for reimbursement to ensure claims are submitted within established reporting deadlines. C.    Anticipated completion date of corrective action: 6/30/2024

The City Director of Finance, Martha Garcia, has implemented a Finance Staff review process when processing invoicing to ensure federally funded purchases are supported with proper backup documents including SAM.Gov verification.

Finding 2023-002-Subrecipient Monitoring Finding: The Foundation did not have a subrecipient monitoring policy under 2 CFR 300, .331 and 501(h), however it was noted that monitoring is occurring. Corrective Actions Taken or Planned: The Foundation will develop a formal subrecipient monitoring policy to conform to 2 CFR 200.300, .331 and 501(h). Further, the National Association of Social Workers, the supported affiliate of the Foundation has posted a position to hire a senior grants accountant who will be assisting in the development and implementation of policies and procedures around grants. The position will be reporting to the Accounting Manager and ultimately the Chief Financial Officer. Sekou Murphy, Chief Financial Officer, will be responsible for the corrective action plan that is anticipated to be completed by October 2024.

Finding 2023-001-Procurement, Suspension and Debarment Finding: The Foundation does not have a formal procurement policy under requirements of 2 CFR 200.317 through 200.327. The Foundation established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. We noted as part of our testing that there was no documentation that these policies and procedures were being followed. Corrective Actions Taken or Planned: The Foundation is in the process of developing a formal procurement policy to conform to 2 CFR 200.317 through 200.327. Further, the National Association of Social Workers, the supported affiliate of the Foundation has posted a position to hire a senior grants accountant who will be assisting in the development and implementation of policies and procedures around grants. The position will be reporting to the Accounting Manager and ultimately the Chief Financial Officer. Sekou Murphy, Chief Financial Officer, will be responsible for the corrective action plan that is anticipated to be completed by October 2024.

This was noted in last year's audit but was identified late in the fiscal year. The time required to do the due diligence and implementation was part of our timesheet review system was not fixed until after June 2023. As noted in last year's goal, Sewall administration completed a review of payroll companies and committed on a new system that began in October 2023. Along with that, we have organized a new internal system of tracking staff's time given the complexities of the many blended funding sources. We have also implemented a regular review and supervision of time sheet allocations.

Finding 2023-003 –Special Education Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Nathaniel Day and Robin LeClaire Contact Phone Number: 317-462-4434 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will complete semi-annual certifications. We will also document more fully formal secondary review of vouchers Anticipated Completion Date: Already completed for the 2023-24 audit year

Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non- Compliance Department’s Management Response: The Area Agency on Aging (AAA) management agrees that all required award information needs to be communicated to subrecipients at the time of the subaward and a subrecipient’s risk assessment needs to be completed and documented in accordance with 2 CFR section 200. View of Responsible Officials and Corrective Action: Beginning July 1, 2023, AAA merged with Human Services Agency (HSA). Administrative and fiscal functions have been integrated into HSA's administrative and fiscal management. The fiscal team has been working with AAA management to identify and address internal control and non-compliance issues, implementing procedures and policies to improve operational efficiency and internal controls. Risk assessment of subrecipients was performed in December 2023 to determine the level of monitoring needed. Federal award identification number (FAIN) will be provided to subrecipients, and the unique entity identifier (UEI) will be obtained from subrecipients by March 31, 2024. Once monitoring is complete, a monitoring report will be issued, any findings with be communicated with subrecipients. In the future, the FAIN and subrecipient’s UEI will be included in contract agreements. Name of Responsible Persons: Bernadette Heredia, Accounting Manager II Helina Wu, Chief Financial Officer, Human Services Agency Implementation Date: December 1, 2023, related to documenting risk assessments March 31, 2024, related to providing require award information to the subrecipient

When the Transportation and Public Works Department (TPWD) receives certified payroll from the contractor, the project manager writes the contract number and sends this to the Department of Finance (Finance). The problem with this method is the project manager never receives confirmation from Finance about receiving these documents and storage of these documents are unknown. To correct this problem, TPWD plans to have the project manager send an email to the receiver in Finance indicating that TPWD has sent it and then have the receiver send an email back once they receive the certified payroll documents. Responsible Party: Gregory Mariscal Supervising Engineer Transportation and Public Works Department Anticipated Implementation Date: April 1, 2024

FINDING 2023-002 – Special Tests and Provisions-Enrollment Reporting- Significant Deficiency Over Internal Controls Over Compliance Recommendation: We recommend the University develop additional procedures to monitor the accuracy of information reported to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate and that permanent address changes were processed. Each institution has access to correct information directly within NSLDS at any time. Corrective Action Plan: The University will contract with a third-party servicer the National Student Clearinghouse to ensure accuracy and timely reporting of the Enrollment Reporting function also known as the SSCR Report to NSLDS. The National Student Clearinghouse will work with both the Executive Director of Financial Aid and Registrar to ensure accuracy of student status reporting and dates needed for reporting (including but not limited to effective dates and graduation dates) that will be reported on behalf of the California University of Science and Medicine. In collaboration with the National Student Clearinghouse, we will change the file roster schedule to every 30 days immediately to report within the 60-day requirement as recommended. The Registrar moving forward will have access to NSLDS and receive the appropriate training on how to use NSLDS and update and enter student permanent addresses. Responsible Party Contact: Regina Maldonado National Student Clearinghouse Senior Implementation Coordinator rmaldona@studentclearinghouse.org Anna Cosio California University of Science and Medicine Executive Director of Financial Aid Anna.cosio@cusm.edu (909) 490 -5906 Don Nguyen California University of Science and Medicine Registrar Don.Nguyen@cusm.edu (909) 966- 5085 Expected date of corrective action: The corrective action will be implemented in April 2024

Management Response and Planned Corrective Action On occasion, given holidays, vacations, meeting schedules, etc., and the tight payroll submission timeline, it can happen that a timecard may be verbally approved but not signed and scanned when submitted for payroll processing and recording in the GL. Given the growth of the agency and the capacity of our administrative and accounting teams, we are in the process of transitioning to an online timecard process with a more robust payroll processing company. This should eliminate all timecard manual signature approval issues. This will be implemented by June 30, 2024. Views of Responsible Officials and Corrective Actions Management of NBCC agrees with the finding noted above, and will implement proper internal controls to correct the issue noted. Contact Information for Responsible Officials Kristine Schwarz, Executive Director, 805-963-7777

Education Stabilization Fund – Higher Education Emergency Relief Fund – Institutional Portion – Assistance Listing No. 84.425L, 84.031C Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for procurement and suspension and debarment to ensure the University is following requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Finance department implemented the procurement policy for the Federal Grants projects. Name(s) of the contact person(s) responsible for corrective action: Shalini Patel Planned completion date for a corrective action plan: June 30, 2023

Finding Number: 2023-007 Condition: Northeastern Illinois University (University) did not have adequate procedures in place to ensure the Education Stabilization Fund - Higher Education Emergency Relief Fund (HEERF) reports were accurate and timely submitted to the U.S. Department of Education and posted to NEIU’s website. Planned Corrective Action: The Grants and Contracts Office will frequently review funding agency websites to ensure reports are up to date with changes in reporting requirements. The published reports will be revised to meet the requirements of the funding agency. The Grants and Contracts Office will also ensure that reports will be submitted and published as required by the funding agency in a timely manner. Contact person responsible for corrective action: Jannica Rae Quintana, Director of Controller’s Office and Ruthann Griffith, Grants and Contracts Manager Anticipated Completion Date: 06/30/2024

FINDING NO. 2022-004 Statement of Condition: Management had developed activity level controls over compliance that included compliance review of all tenant certifications of income used in determining the amount of rent amounts due from eligible PRAC 202 participants (tenants) by the Coast compliance department. However, during our testing, management had no documentation evidencing such reviews had occurred; further, during our interview process of site staff (community managers), staff asserted that no such reviews had occurred, and that no feedback on tenant certifications was provided by the compliance department. Auditor Recommendation: Management should have a process to review and approve all tenant certifications being prepared by site staff (community managers). The approval process should include an approval stamp or some other evidence that each file has been reviewed by the compliance department and is approved for processing. Further, senior management should have an ongoing monitoring process to ensure that the compliance department is carrying out the review process. Action Taken: Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.

FINDING NO. 2023-002 Statement of Condition: Management only made nine (9) of the twelve (12) monthly required reserve deposits, leaving the account underfunded by $4,053 at June 30, 2022; for the year ended june 30, 2023, only $2,702 of the required $16,212 in deposits were made, leaving the account behind schedule by another $13,510, for a total deficiency of $17,563. Auditor Recommendation: Management agrees with the finding, and has taken corrective actions which include communication with the Project Accountant and Regional Manager. All future deposits the replacement reserve will be made as required in the regulatory agreement. Action Taken: Senior management has discussed the deficiency with the Project Accountant and Regional Manager. All future deposits the replacement reserve will be made as required in the regulatory agreement assuming there is sufficient cash in the operating account to make the deposit. -

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-302: Social Services Block Grant – FFATA Reporting. This is the department’s Corrective Action Plan.  Recommendation (2023-302): Social Services Block Grant – FFATA Reporting We recommend the Wisconsin Department of Health Services: • Revise its procedures for Federal Funding Accountability and Transparency Act reporting to ensure all subawards funded by federal grants are included in reports used to identify subawards for reporting; and • Develop procedures to identify and report subawards made by the state agencies to which it has transferred federal funding. Wisconsin Department of Health Services Planned Corrective Action: DHS will update FFATA procedures to ensure all DHS federal programs are included in FFATA reporting. DHS will also develop procedures to report the subawards made by other state agencies to whom DHS has transferred federal funding. Anticipated Completion Date: August 31, 2024 Person responsible for corrective action: Vanessa Salata, Section Chief Expenditure Accounting, Bureau of Fiscal Services, Division of Enterprise Services vanessaa.salata@dhs.wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-301: Social Services Block Grant – Subrecipient Contracts. This is the department’s Corrective Action Plan.  Recommendation (2023-301): Social Services Block Grant – Subrecipient Contracts We recommend the Wisconsin Department of Health Services update its procedures for contract development to ensure information provided in its subrecipient contracts identifies the Social Services Block Grant as the federal funding source for the basic county allocation of the community aids program related to the transferred Temporary Assistance for Needy Families funds. Wisconsin Department of Health Services Planned Corrective Action: DHS will change the Assistance Listing Number (ALN) for Temporary Assistance for Needy Families funds transferred to the Social Services Block Grant (SSBG) to the SSBG’s ALN, 93.667, for future Basic County Allocation contracts. Anticipated Completion Date: July 31, 2024 Person responsible for corrective action: Rebecca Mogensen, Section Chief Managerial Accounting, Bureau of Fiscal Services, Division of Enterprise Services rebeccaj.mogensen@dhs.wisconsin.gov