Corrective Action Plans

Department of Housing and Urban Development Program Name: Continuum of Care Program Federal Assistance Listing Number: 14.267 Significant Deficiency, Nonmaterial Noncompliance – Period of Performance Finding 2024-002 Criteria: Period of performance is defined in 2 CFR 200.1 as “the time interval between the start and end date of a federal award, which may include one or more budget periods.” Condition: For one award, the 2023 grant award project was not closed timely in the general ledger system and the County erroneously recorded fiscal year 2024 grant costs of $1,059 to the project, which was beyond the approved period of performance of the award. Additionally, for one award, the County recorded grant costs of $28,685 to the project, which was beyond the approved period of performance of the award. Effect: By not having the grant project codes properly closed at the end of the period of performance, the County could potentially request reimbursement for costs incurred and recorded beyond the grants approved period of performance from the Federal government. Questioned Costs: $29,744 Cause: The County did not have a formal policy to ensure grant project codes were properly closed and expenditures were not being recorded beyond the grant award’s stated period of performance. Recommendation: We recommend the County should implement a formal policy to ensure all grants are properly closed and no costs are incurred on grants after their period of performance. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: See below Corrective Action Plan prepared by the County. Following the end of grant term, June 30th, Shelter Plus Care (SPC) program will ensure all final payments are made out of the grant by mid-August to ensure timely reconciliation. • Grant Management /Revenue Reimbursement Team will send final draw for review and approval by SPC Supervisor and upon confirmation, email communication will be made with Accountant III (within the Budget Team) for final review. • Accountant III will provide Purchase Order by Unit report (PD615) report to SPC program to ensure all POs are closed out. • Accountant III will review PD615 report to ensure deactivation. Ongoing review will take place at least 2 months following the 90-day close-out period. •The SPC/Finance Team will work with staff, supervisors and payroll to ensure all applicable payroll is allocated to proper (active) grant unit and respective entries are processed timely. • When new grant is established, the SPC team will ensure that time posted and approved for SPC admin costs in PeopleSoft are for the correct grant unit/ grant fiscal period as well as ensure that funds are encumbered and paid from correct grant/grant fiscal period. In addition to these steps, ongoing review and monitoring of grant will occur monthly during SPC’s Finance Meeting on the 4th Thursdays of the month and during the CSS Grants Meeting on the 4th Tuesdays of the month. Completion Date: June 30, 2025 Responsible Person(s): Adia Robinson, Clinical Supervisor

CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2024 FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Program, School Summer Food Service Program Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement and Suspension and Debarment compliance requirements. Context: Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-Federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $50,000 or under, and small purchase procedures for those purchases above the micropurchase threshold, but below the simplified acquisition threshold. The School Corporation's policy states that the small purchase threshold is between $10,000 and $150,000. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For fiscal year 2023, two vendors, totaling $109,657 and $53,441, were selected for testing at the small purchase threshold. The School Corporation did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the SAMs exclusions, collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. During the audit period, there were ten vendors identified which exceeded $25,000 in disbursements on an annual basis. Six vendors were selected for testing. In one instance, the School Corporation's contract with the vendor did not include any suspension and debarment clause and the School Corporation did not verify the vendor's suspension and debarment status prior to payment. The lack of internal controls and noncompliance was isolated to fiscal year 2023. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure that the School Corporation's procurement policy is being followed for all procurement thresholds. Management will perform a periodic check of federal fund disbursements to see if any vendors exceed procurement or suspension and debarment thresholds on an annual basis to ensure compliance with federal and state procurement guidelines. The School Corporation will ensure that all contracts exceeding $25,000 include a suspension and debarment clause and will verify that the vendor is not suspended or debarred prior to entering into the contract. Responsible Party and Timeline for Completion: The Food Service Department has already implemented these changes as the issue was not present in fiscal year 2024.

Finding No.: 2023-038 AL Program: COVID-19 84.425H – Education Stabilization Fund – Governors (Outlying Areas) (ESF-Governor) Area: Subrecipient Monitoring Questioned Costs: $6,641,757 Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: Condition 1-2: The CNMI Department of Finance agrees with this finding. CNMI submitted risk assessment and monitoring compliance documentation to the auditor on February 26, 2026, after the agreed February 19, 2026, deadline, resulting in evidence timing deficiency. CNMI established Standard Operating Procedures for subrecipient monitoring effective October 28, 2026. Management will implement standardized file labeling and retention procedures in accordance with the SOP so that each subrecipient file contains the subrecipient determination, required subaward clauses, the unique entity identifier, documented SAM.gov exclusion checks, and verification of audit requirements. In alignment with 2 CFR §200.332, CNMI will review financial and performance reports quarterly, conduct an annual performance assessment using a standardized checklist (updated annually or upon project completion), maintain documentation of all monitoring activities, and verify audit status for entities subject to the Single Audit Act. The risk assessment and monitoring compliance documentation for this grant is available to the auditor upon request. Proposed Completion Date: Completed

Finding No.: 2023-030 AL Program: COVID-19 21.027 – Coronavirus State and Local Fiscal Recovery Funds Area: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Questioned Costs: $17,671,782 Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: Condition 1-2: The CNMI Department of Finance agrees with this finding. These transactions were subsequently closed and finalized and CNMI can provide documents upon request. CNMI was still familiarizing itself with the financial management system implemented in FY 2022, as well as a new mechanism of “travel cards” for employee travel. Effective in February 2023, the CNMI ceased using the travel cards as we had determined that it was difficult to maintain effective monitoring. Also, Finding No.: 2023-030, continued AL Program: COVID-19 21.027 – Coronavirus State and Local Fiscal Recovery Funds Area: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Questioned Costs: $17,671,782 Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: subsequently in 2025, SOPs were formally effective. Throughout the SOP development, we learned best practices to effectively monitor travel transactions. No further action is needed. Proposed Completion Date: Completed Condition 3-6: The CNMI Department of Finance agrees with this finding. Due to operational inefficiencies present in FY 2023, document archives were not maintained, and effectively were not provided to auditors in the time allotted. In addition, this transaction related to a purchasing card mechanism, and the CNMI did not maintain proper controls and monitoring. We have since stopped using purchasing cards broadly across the CNMI government—it is allowed on a case-by-case basis—so that the CNMI can monitor purchases more effectively. With standardization of processes and additional training, CNMI has since maintained its records and documents for improved financial accountability and transparency. CNMI can provide documents upon request. No action is needed at this time. Proposed Completion Date: Completed Condition 7-8: The CNMI Department of Finance agrees with this finding. The Payroll and HR management modules of Munis went live in October 2022, and early implementation challenges affected payroll distribution reporting and documentation gaps. CNMI worked with Munis implementation consultants to correct issues and has since implemented SOPs to ensure proper payroll documentation, reporting, and reconciliation. This prevents recurrence. Proposed Completion Date: Completed Condition 9-11: The CNMI Department of Finance agrees with this finding. Due to the large nature of the transaction, and the limited time available during the audit review, CNMI was unable to provide details of the transaction. CNMI can provide documents upon request. Proposed Completion Date: Completed

The Creek County Clerk’s Office will work with the SEFA preparer to ensure that the correct paid dates are being used when reporting. This should eliminate the actual expenditures differences. We will work to educate all offices involved in the reporting process on financial statement and SEFA utilizing the paid date, instead of warrant date.

FINDING 2023-004 Contact Person Responsible for Corrective Action: Craig Zandstra Contact Phone Number: 219-945-0543 Ext 234 Contact Email: craigz@lakecountyparks.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan As this finding is shared between The Lake County Board of Commissioners and the Lake County Parks & Recreation Department, both departments will develop procedures to ensure the appropriate procurement methods are used for vendors that are within the Small Purchase Threshold. Both departments will also ensure that vendors are not suspended or debarred when expanding federal funds. Lastly, appropriate documentation will be maintained to ensure compliance with procurement, suspension and debarment in the future. Completion Date: June 2026

FINDING 2023-002 Finding Subject: CDBG - Entitlement Grants Cluster - Program Income Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 brownta@lakecountyin.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This same finding was part of the 2022 audit in Finding 2022-003. The department was aware that this same finding would be arising in the 2023 audit again due to multiple year errors of previous staff. The corrective action plan proposed and adopted as part of the Corrective Action Plan for finding 2022-003 is still in force and is working to eliminate such findings in the future. The Lake County Redevelopment Commission adopted Resolution 001-2025 on January 16th, 2025 amending the Policy and Procedures Manual of the Department concerning Program Income (PI) internal controls for proper reporting in the IDIS system to address and correct the finding going forward. Anticipated Completion Date: Done

Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence. County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on federal funds. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners. County Treasurer: The County was under the understanding that once we established we were reporting as revenue loss, we would not have to submit the report annually. The final reporting was submitted prior to deadline.

• Implement procedural reviews and standardized templates to enhance subrecipient oversight, monitoring, and documentation. • Note: Questioned costs unwarranted as no tests conducted on state-level expenditures. 9/30/2026 Mr. Marcus Samo, Secretary of FSMNG Health Email: marcus.samu@fsmhealth.gov.fm

Benjie Read CFO and Felecia Read Staff Accountant, will develop a policy and establish procedures for calculating the MTDC in accordance with Uniform Guidance for federal contracts and reviwing the indirect cost allocations. We will also educate ourselves and all financial staff on these requirements. These efforts will be complete within 90 days of audit completion.

FINDING 2023-004 Finding Subject: Drinking Water State Revolving Fund (DWSRF) Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will develop and implement a formal process for verifying that vendors are not suspended, debarred, or otherwise excluded from receiving federal funds before entering into contracts or transactions that meet or exceed the $25,000 threshold. The City will develop a purchasing policy that reflects the applicable state laws and regulations related to procurement. The City will also maintain proper documentation to support the appropriate procurement method. Anticipated Completion Date: December 31, 2025

Finding Number 2023-006 Subject Heading (Financial) or AL no. and program name (Federal) 93.658 – Foster Care Planned Corrective Action The risk assessment cannot be completed until we have actual data and performance needed to make that assessment. Subrecipient risk assessments are completed at the beginning of the fiscal year based on prior year data and performance. The changes to all of the subrecipient agreements identified have been in process and were completed during State fiscal years 2024 and 2025. Additional findings are expected for the 2024 audit since the audit timing is currently almost two years in arrears. Anticipated Completion Date February 2025 Responsible Contact Person Kevin Haddock

Finding Number 2023-098 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action OMES Finance has implemented proper controls for their SEFA process to ensure costs are reported on the correct basis of accounting. OMES agrees with this finding and has put measures in place to correct this issue. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls which includes a process for reviewing funding requests to ensure expenditures are allowable under the federal guidelines. The State agrees. Although the delivery of the software occurred during the covered period, the invoice was paid outside of the liquidation period. The State agrees with this finding and has put measures in place to correct this issue. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls which includes a process for reviewing funding requests to ensure expenditures are allowable under the federal guidelines. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

Finding Number 2023-094 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action The State agrees in part and the State disagrees in part. In regard to payments made to Jill Geiger Consulting in the amounts of $39,957.00 and $28,272.00, please see attached documentation of time and effort of services provided during FY2023 which were also paid with by CRF funds in FY2023. Please scroll down on the timesheet reports and refer to the Notes column for descriptions. Additionally, the CRF weekly update log is from JGC and gives more details for services provided. For the payments made to Jill Geiger Consulting for the other amounts ($27,083.33 and $34,650), these reimbursements occurred in FY2023 but were not for services provided in FY2023, but for FY2022. If you review the “Summary of requested vouchers Jill Geiger,” the payment of $34,650 occurred on 8/1/2022 but was paid to cover services in May and June 2022. For invoice v00160672 in the amount of $27,083.33, the payment was made July 5, 2022 (FY23) but covered services for April 22 (FY22). You will be able to see more instances of this in the Summary and attached invoices for that same amount. Therefore, the State requests these be taken out of the audit review and findings for FY2023 as the services were not provided in FY2023. The State of Oklahoma agrees in part and disagrees in part. The State agrees that a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures, will help ensure allowability, accuracy, and assist in the detection of fraud. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO). The OMES-GMO is staffed with individuals, who have several years of grant experience implementing these internal controls and procedures. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

Finding Number 2023-035 Subject Heading (Financial) or AL no. and program name (Federal) #17.225 Unemployment Insurance Planned Corrective Action The agency concurs with the findings and agrees with the recommendation. The agency acknowledges our responsibility for program integrity and proper controls for the RESEA program. As we referenced in our response last year, the agency has undertaken modernization efforts to provide better solutions for the RESEA program. EmployOklahoma is the first result of this effort in the workforce employment area and it launched in January 2025 as the replacement for OKJM. The majority of the findings above were related to cases pulled for the period between July 2022 and December 2022; there was improvement in the period from January 2023 to June 2023. We anticipate continued progress and improvement going forward, but there will continue to be elevated risk for inaccuracies until the agency’s modernization efforts are successful in implementing solutions to address both the case management and data reporting requirements needed to fully resolve these findings. Anticipated Completion Date Ongoing until modernization of RESEA tools is complete Responsible Contact Person Tammy Wood, RESEA/TAA Program Manager

Finding Number 2023-033 Subject Heading (Financial) or AL no. and program name (Federal) #17.225 Unemployment Insurance Planned Corrective Action OESC concurs with the audit finding and agrees with the recommendation. The decrease in the total dollars associated with this finding in comparison to the prior year demonstrates that the issue has been addressed with the programming that was completed in February 2023. The agency will continue to monitor ongoing results of the new programming to address any further adjustments needed for edge-case scenarios or to appropriately handle other system changes. Anticipated Completion Date Completed in February 2023 Responsible Contact Person Christopher O’Brien, Vice President - OESC UI

CONDITION: The City of McKeesport inadvertently charged as eligible expenditures two (2) purchases totaling $144,000 on the third quarter financial report required to be filed with the Department of Treasury that had already been claimed as eligible expenditures in the second quarter financial report. CRITERIA: Section 2 CFR 200.1 of the Uniform Guidance defines a disallowed cost as a charge to a Federal Award that is determined to be unallowable under the Award’s terms, which would include duplicate payments. Section 2 CFR 200.339 of the Uniform Guidance gives the federal agency the authority to disallow costs if the recipient fails to comply with the aforementioned Award terms and conditions. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will reallocate the two vendor payments totaling $144,000 which were inadvertently duplicated in the financial reports required to be submitted to the Department of Treasury. The $144,000 in duplicate payments will be reallocated for eligible road salt purchases made during calendar year 2023.

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration.

FINDING 2023-004 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Mindy McGee Contact Phone Number and Email Address: 812-265-8300, mmcgee@madison-in.gov Views of Responsible Officials: We concur with the finding regarding errors in Coronavirus Fund reporting. Description of Corrective Action Plan: Historically, the city has not had a centralized position who would be responsible for grant compliance and reporting. Individual department heads were responsible for comp0lying with each awarded grant for their own area of responsibility. In spring of 2025, a new Project & Grant Manager position was created and filled by a qualified individual. The responsibilities of the position include data collection and analysis, project management, grant coordination, information management and compliance monitoring and reporting. Anticipated Completion Date: The new position referenced above has been filled and is in operation as of April 8th 2025.

FINDING 2023-006 Finding Subject: Child Nutrition Cluster – Procurement, Suspension and Debarment Summary of Finding: A School Nutrition Cooperative (Co-ops, Education Service Center, Group Purchasing Organization, etc.) that would like to be classified as a School Food Authority (SFA) Cooperative must complete a questionnaire and submit it to the Indiana Department of Education (IDOE). Once a questionnaire is received IDOE will review the answers to determine a Cooperative’s classification. Only Cooperatives that submit the questionnaire and receive a SFA-only Cooperative classification from IDOE in writing will be considered a SFA only Cooperative for the purposes of the procurement process and procurement reviews. INDIANA STATE BOARD OF ACCOUNTS 41 􀀃 “Meeting􀀃students􀀃where􀀃they􀀃are􀀃and􀀃leading􀀃them􀀃forward…every􀀃student,􀀃every􀀃day”􀀃 When the value of goods or services exceeds the simplified acquisition threshold, the proper purchasing method would be the bidding process, unless the purchase meets certain other qualifications. Federal regulations allow for informal procurement methods when the value of the procurement for goods or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. If it is determined a single source provider can be used for a small purchase, documentation must be retained supporting the determination. The School Corporation could not provide supporting documentation that an adequate number of price or rate quotations was obtained to ensure full and open competition for two vendors procured under the small purchase threshold. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The procurement method used to purchase equipment costing over $10,000 will be documented and archived with the purchase order. Anticipated Completion Date: July 31, 2024

Finding 2023-003 – Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Coventry and Coventry Public School’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.303, and 200.318 through 200.326 within Uniform Guidance. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management of the Town of Coventry and the Coventry Public Schools will review the current purchasing policies and update them to make sure that the Town and School Department is following the criteria as set out in the 2 CFR sections 200.303 and 200.318 through 200.326. The policy will then be updated and communicated to all personnel involved in the procurement process. Name of Contact Person Robert J. Civetti, CPA, Town Finance Director; Christopher Deverna, CPA, Director of Finance, Coventry Public Schools Projected Completion Date June 30, 2025

Public Health agrees with the recommendation. Public Health will develop a process for conducting risk assessments of subrecipient funding, develop and implement procedures for obtaining single audit reports from subrecipients, as well as a system to monitor and track compliance with the single audit mandate among subrecipients. Public Health will ensure each subaward includes all requirements imposed on the subrecipient so that the federal award is used in accordance with Federal Statutes, regulations, and terms of conditions of the federal award. Estimated Implementation Date: May 2025 Contact: Melissa Relles, Assistant Deputy Director Division of Operations, Center for Preparedness and Response California Department of Public Health

California Department of Transportation (Caltrans) has determined that federal award information is not always disseminated to the project managers. Caltrans will review current policies and procedures of each division and revise, if necessary, so that best practices are followed. Caltrans Internal Audits Office will be working with Local Assistance’s single audit report monitoring process and take on the responsibility to monitor for all Caltrans divisions. Estimated Implementation Date: June 2025 Contact: Ben Shelton, Chief – Caltrans Internal Audits Office Division of Risk and Strategic Management

Finding #2023-015 Title of Finding Reporting Contact Person Kimberly Benson Anticipated Completion Date 6/30/2025 Corrective Action planned to be taken: We will ensure that all expenditures of COVID-19 funds are reported in the proper period.

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.