Corrective Action Plans

Responsible: Thomas Hoover, CFO Corrective Actions: Update Finance policies to specify that documentation of review and approval of both the costs charged and the allocation methods of costs charged to federal grants be maintained. Completion Date: March 29, 2023 Explanation: Policies have been in place over the coding of costs allocated to federal grants in compliance with CFR 200 and were enhanced in 2023 in response to an OJJDP/OCFO recommendation. Review and approval of costs after being approved by an authorized signer takes place in multiple steps and concludes with preparation of reimbursements and financial grant reports (FFR). In order to further demonstrate compliance as recommended, Management has updated Finance policies to capture the documentation and maintenance of such documentation of Supervisory review and approval.

Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersRecommendation:We recommend that the Board review its policies and procedures to verify that controls are inplace to ensure expenditures are not reimbursed under more than one Federal Program.Explanation of disagreement with audit finding: There is no disagreement with the auditfinding.Action taken in response to finding: ESSER funds will no longer be used for Food and NutritionServices.Name(s) of the contact person(s) responsible for corrective action: BCPS grant managers,and Fiscal Services staff.Planned completion date for corrective action plan: For immediate implementation andongoing

2022-003 Formal Policies for Federal Awards Auditor Recommendation: We recommend management attend federal award trainings to ensure the documented policies and procedures can be performed as necessary. This will ensure the Center is in compliance with compliance requirements surrounding Federal awards. Corrective Action: The year ended August 31, 2022 was the first year in which the Center expended federal awards in excess of the limit that requires a Single Audit. Management with the Center?s Audit Committee will review and document policies and procedures for managing federal awards to supplement existing policies and procedures associated with awards from non-federal funders. Name of Responsible Contacts: Larry Goodpaster, Director of Finance & Operations, and Kelly Martin, Accounting Manager Projected Implementation Date: August 31, 2023

CORRECTIVE ACTION PLAN JUNE 30, 2022 REFERENCE: 2022-101 CFDA NUMBER 84.425D ? COVID 19 ? EDUCATION STABILIZATION FUND CFDA NUMBER 84.425U ? COVID 19 ? EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION ? 2021 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 & S425U210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Wendi Allardice - Superintendent Karen Hancock - Title I/ESSER Grants Manager 2. Corrective action planned: A. Protocols developed to obtain at least 3 vendor quotes for any items over 10,000 with an analysis and justification of vendor chosen. B. Protocol in place for checking for vendor suspensions or debarment prior to purchase approval. C. Monthly meeting for comparison of proposed and estimated purchases and actual purchases and charges to the Grant. 3. Anticipated completion date: Anticipated completion date for above listed plan: 08/31/2022

The City of Boston?s Age Strong Commission has revised the addendum that is attached to their award letters to include whether or not the award is R&D and a section on indirect cost rate. Anticipated Completion Date: June 30, 2022 Responsible Contact Person: Scott Finn, Assistant City Auditor, Grants Monitoring Unit scott.finn@boston.gov

Finding 2022-003: Allowability of Costs (Research & Development Cluster) Name of Contact Person: David Thomas, Group Vice President & Controller Corrective Action Plan: To address the current year finding, Academic Project Portfolio Management (PPM) Labor team has implemented internal control improvements to ensure all requirements that limit the salary cap allowability of costs are completed and documented appropriately including communication and education of salary cap requirements with the business administrator, plus additional review from the Academic PPM Labor team. Proposed Completion Date: Management will complete the corrective action plan by December 2023.

Responsible Contact Person(s): Angela Wright, Director of Finance Corrective Action Planned: The Director of Finance has provided additional training to staff and is performing a detailed review of all reports to ensure accuracy. Estimated Completion Date: 2/15/2023

Responsible Contact Person(s): Timothy O. Kestner, EIA Director Corrective Action Planned: EIA Management has developed a reporting schedule outlining the frequency, responsible party, and due date of all required reports. This is a collaborative effort across several business units; therefore, policies and procedures have been updated and communicated to all users to ensure compliance. Estimated Completion Date: 2/15/2023

Management agrees with the recommendation and has incorporated policy updates within the September 2023 updated policies and procedures to ensure compliance with required regulations. AALV will continue to update its policies to meet regulatory requirements.

Identifying Number: 2022-001 Audit Finding: Reporting Criteria: The Organization is required to comply with 2 CFR Subpart D 200.300 (b) which indicates that a non-Federal entity is responsible for complying with Federal Funding Accountability and Transparency Act (FFATA). FFATA requires prime grant recipients to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition: During our testing of the reporting requirements, we noted subawards to seven subrecipients where the FFATA sub-award report was not filed timely. The amount of subawards required to be reported were $874,045. Subsequent to year end, the Organization prepared and submitted the FFATA sub-award reports. Cause: The Organization was unaware of the FFATA reporting requirement as the requirement was not explicit in the grant agreement. Effect: Potential loss or suspension of grant funding. Questioned costs: None. Prevalence: The population of first-tier subawards subject to reporting requirements included seven subawards. The sample size of seven was determined using guidance in the American Institute of Certified Public Accountants (AICPA) Audit and Accounting Guide - Government Auditing Standards and Single Audit. Our sample was not a statistical sample. Recommendation: We recommend the Organization implement procedures to comply with the requirements of FFATA. Corrective Actions Taken or Planned: Corrective action has been taken as of April 2023. The Chief Financial Officer (CFO) Gina Brown has written a procedure on when and how the FFATA report should be completed and will add it to the new updated Accounting and Procedures Manual. A copy of the procedure was emailed to RSM on April 18th, 2023 and is attached for reference. As of the reporting period ending for March 2023, we, Great Lakes Inter-Tribal Council (GLITC), have submitted the required FFATA reports for the current grants awarded in fiscal year 2023. Contact person(s) responsible for corrective action: Gina Brown, CFO

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is in the process of implementing a new procedure to ensure it is reviewed by accounting and grant managers to ensure accurate reporting. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: March 2024

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is in the process of implementing a new procedure to ensure it is reviewed by accounting and grant managers to ensure accurate reporting. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: March 2024

Finding No. 2022-007 -Activities Allowed or Unallowed, Eligible Uses - FEMA Condition During the closeout procedures, the Cenh·al Office of Recovery, Reconstruction and Resiliency (COR3) office performed a 100% validation on Rental Equipment, supporting documents including conh"act smmnary record, invoices, and proofs of payment. As a result of the validation, the total validated amount is $979,259 from an original amount of $1,260,775 submitted by the Corporation for reimbursement. Corporation response The Corporation agrees with the finding. Corrective Action Plan Upon receiving the audit findings, we initiated an immediate review of our FEMA-funded projects and expenditures. We are implementing immediate corrective actions to address the identified deficiencies and ensure strict compliance with FEMA guidelines regarding eligible uses. • Policies and Procedures Review - Simultaneously, the Corporation is reviewing our existing policies and procedures related to FEMA funds, with a specific focus on eligible activities. Any necessary revisions will be made to strengthen our policies and ensure rigorous adherence to FEMA guidelines and regulations. • Enhance Internal Controls - We are enhancing our internal controls related to FEMA fund utilization. This includes implementing additional checks and balances to improve the accuracy and reliability of our project management processes, ensuring they align with FEMA guidelines. ■ Communication Protocols Enhancements - We understand the importance of transparent communication regarding the use of FEMA funds. To address this, we are enhancing our communication protocols to ensure that all relevant stakeholders are informed of FEMA guidelines, project eligibility requirements, and any changes to procedures. • Return of Funds - Initiate the communication process with the Central Office of Recovery, Reconstruction, and Resiliency to obtain instructions for returning the funds to FEMA. Follow FEMA's specific guidelines on the return of funds, including the appropriate documentation, timelines, and c01mnunication procedures. ■ Finance Team - The Corporation has made changes to its management staff structure in the finance and budget department, with the mission of improving the monitoring process and compliance with federal and local regulations and the support of independent consultants. A new Finance and Budget Director and the Associate Director of Finance and Budget have been appointed. Names of the contact persons responsible for corrective action plan Jesus A. Rodrfguez Aviles - Financial Planning and Analysis Associate Director Cecilia Robles Kakiuchi - Financial Planning and Analysis Director Anticipated Completion Date Fiscal Year 2024

Name of the Contact Person Responsible for the Corrective Action Plan: Gia Scruggs, City Manager Corrective Action Plan: The private contractor engaged in 2017 to provide government management and operations services staffed the engagement with less than 40 staff including 5 consultants. The City, since the termination of the services contract effective December 31, 2021, has 79 staff involved in City management and operations roles including 5 elected officials. The additional staff, including an additional 5 in accounting/finance, affords the City the capacity to effectively account for and report on restricted funds received in connection with state and federal grant programs. The City Manager staff has grown by an additional 3 staff persons from the contractor level that was assigned in 2021 to monitor grants providing sufficient City staff for current grant programs to be monitored and grant conditions complied with. As the City continues to be eligible for additional state and federal grants, a Grants Administrator position has been added to staff organization and the plan is to organize a grants management team devoted to reporting and compliance assurance as well as seeking to apply for state and federal grant and program funds. Anticipated Completion Date: City Finance Department staff, together with the City Manager, are presently monitoring compliance and reporting relating to state and federal grants and program support. Third-party contractors will no longer be used for these tasks, and as more restricted funds are received by the City, the grants management team will be organized. Presently, the City has only one federal grant program and one state program. The corrective actions have been implemented and are presently operative and in place

Corrective action has been immediately implemented in response to the auditors' recommendation. As financial reporting is still in process of getting to current, the City anticipates findings to be reduced in future fiscal years.

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