Corrective Action Plans

Management's Views and Corrective Action Plan 2025-001- Compliance with Federal Funding Accountability and Transparency Act (FFATA) Reporting Sponsoring Agency: National Endowment for the Humanities Award Name: American Experience, A Man Called White Award Number: TR-297125-24 Assistance Listing Title: Promotion of the Humanities Public Programs Assistance Listing Number: 45.164 Award Year: 2024-2025 Management's Views and Corrective Action Plan WGBH Educational Foundation (“the Foundation”) concurs with this finding. During fiscal year 2025, the Foundation identified a control failure with their established FFATA reporting control. After thorough review of active subaward agreements, the Foundation identified one contract that was not reported timely. Due to the grant's termination date of April 2, 2025, the Foundation was not able to file the report through SAM.gov. However, the Foundation promptly reached out to the National Endowment for Humanities (NEH) for assistance with filing. At this time, the Foundation has not received a response from NEH on next steps. The Foundation has since enhanced its control to include a three-way reconciliation using system generated reports to validate completeness of the Foundation’s monthly list of executed subaward agreements prior to reporting deadline. In addition to the reconciliation, the Foundation has implemented a FFATA process checklist which captures the process steps, applicable contract execution date(s), report submission date(s) and sign off/approval of the monthly process. A secondary review and approval of the process have been included in the updated control. The enhanced control was implemented for the September 2025 FFATA reporting. Contact person: Katie Dillon Managing Director, Production Finance and Grants Compliance 617-300-3829

FINDING 2024-001 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: There were no controls in place to ensure that the School Corporation complied with the reporting requirements. The reimbursement request reports were prepared and submitted by the Food Service Director without any oversight, review or approval process to ensure accuracy of the reports. There was no oversight to make sure that the number of meals served matched the report filed. The lack of internal controls was systemic throughout the audit period. Contact Person Responsible for Corrective Action: Amanda Myers Contact Phone Number and Email Address: 765-832-3551/amyers@svcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Amanda Myers, Food Services Director, will continue to receive the information for the monthly meals served from the cafeteria managers at each school. Once she enters the information, the HS cafeteria manager will review the numbers to ensure that the information was entered correctly. The reimbursement forms and information that was entered will be submitted to the finance department to ensure the reimbursement process is correctly receipted. Anticipated Completion Date: Immediate.

The Morgan County Economic Development Office acknowledges status reports submitted by the required due date for the CDBG program.

Assistance listing numbers and program names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021 – Emergency Assistance to Non-Public Schools (CRSSA EANS) Agency: Arizona Department of Education (ADE) Name of contact persons and titles: Michelle Udall, ADE Associate Superintendent Dr. Sarka White, ADE Deputy Associate Superintendent Anticipated completion date: November 30, 2024 Agency’s response: Concur ESSER Reporting will be validated by at least 2 people before submitting to U.S. Department of Education. This validation will include the reconciliation of data from the LEA to ADE's report. ADE is finalizing policies and procedures for validating the data prior to submission. ADE has already begun implementing a reconciliation system to ensure accurate reporting in the EANS annual performance report. This system tracks obligations by category, expenses, and appropriate earmarking of nonpublic schools (e.g., DUNS/UEI, grades served). ADE is finalizing general policies and procedures for how this data is compiled, interpreted, and reported based on the initial implementation and corrections of the EANS program.

This is repeat Finding from 2022. Key personnel have since been replaced at the RPC and those in in the new positions understand the importance of proper and timely reporting and accurate financial records. The Auditor’s Office will meet with the new executive director, the current (new) finance director, and board members to emphasize the importance of deadlines and financial accountability when working with Grants. Additional Controls will be emphasized to assist with timely filing, as well as Invoice Entry to ensure duplicate payments are not made.

Views of Responsible Officials: The Center will create a technology system so that Finance Managers can ensure the timeliness of reporting and correct documentation when reporting deadlines are unable to be met. Name and Title of Responsible Official(s): Vibha Bhatia, Vice President of Finance and Operations Anticipated Completion Date: October 31, 2024

Views of Responsible Officials: NFHA has a process for review of programmatic reports that can be discerned by review of emails and documents. However, NFHA will ensure that all Federal award grant reports, both financial and programmatic, have documented evidence of review and approval prior to submission to the relevant agencies.

The City agrees with the finding. The City will improve internal controls over the Performance and Expenditure report review process and ensure this review addresses all aspects of the reports and is completed prior to submission. Corrective action was taken in spring of 2024 when the issue was identified during the 2023 audit. Responsible Official: Catrina Asher, Finance Director Planned completion date for corrective action plan: March 31, 2024.

Views of Responsible Officials: Management acknowledges the importance of timely reporting. RFE/RL is committed to improving timeliness by engaging an outside accounting firm to bring the company into compliance with current reporting requirements, increasing staff capacity, implementing a new reporting software tool, documenting sustainable reporting procedures and working with our funder on agreed upon reports and deadlines.

Assistance Listings number and program name: 10.691 Good Neighbor Authority Contact person: Lucinda Andreani, Deputy County Manager and Flood Control District Administrator Anticipated completion date: June 30, 2024 Concur. The Coconino County Flood Control District (FCD) acknowledges the annual financial and performance reports were not filed in accordance with the contract. The cash draw reports were completed for the award according to the contractual requirements. Therefore, the federal agency was aware of all expenditures made under the award. The FCD will submit all missing annual financial and performance reports. With assistance from the Finance Department, the FCD will develop procedures to ensure all reporting requirements are met. These procedures will include internal timelines, designated roles and responsibilities, and a tracking mechanism. Additionally, fiscal capacity will be created through the training of an additional staff member in reporting to serve as backup so contractual reporting requirements can be fulfilled when unforeseen challenges arise such as declared emergencies and flood events.

Views of Responsible Officials: Management agrees with the finding and the following action will be taken to improve the situation. Management will review and update the reporting tracker monthly to ensure all reports are submitted on time. To ensure additional controls, the reviewer of the tracker will be independent of the report preparer. Name and Title of Responsible Official: Barbara Ledyard, Vice President of Finance and Administration Anticipated Completion Date: December 29, 2023

The Morgan County Economic Development Office acknowledges status reports submitted by the required due date for the CDBG program.

Corrective Action: The University Procurement office will develop specific procurement policies to be utilized when Federal funds are used. Procurement staff will also be trained on how to procure goods and services when Federal funds are utilized. UCM staff and faculty will be trained on the approved Federal procurement process. Anticipated Completion Date: February 1, 2023 Contact Person: Robert Walla, Procurement Director

CORRECTIVE ACTION PLAN Institutional Response to 2022-001: Significant Deficiency ? Procurement Federal Assistance Listing No. 84.425F ? 84.425M US Department of Education, ESF Section 2 -Higher Education (Higher Education Emergency Relief Fund HEERF) University Response: The University concurs with the above-mentioned finding that proper procurement practices were not followed for two purchases utilizing HEERF funds. Corrective Action: The University Procurement office will develop specific procurement policies to be utilized when Federal funds are used. Procurement staff will also be trained on how to procure goods and services when Federal funds are utilized. UCM staff and faculty will be trained on the approved Federal procurement process. Anticipated Completion Date: February 1, 2023 Contact Person: Robert Walla ? Procurement Director

Finding No. 2022-001 Corrective Action Plan University Response: The University concurs with the finding that proper procurement practices were not followed for one of the three purchases identified as non-compliant. For one of the other two purchases identified as non-compliant, the University sourced the expenditure from the largest provider for higher education audio and visual products nationally, which competitively offer special discounting and pricing to private and public institutions of higher education when possible. On the other purchase, the University sourced with one of three vendors previously used for this type of work that was able to provide the services needed in the required timeframe during the pandemic, when other vendors could not meet the demand. These services were needed for additional cleaning and sanitizing to avoid contacting a life threatening virus. Corrective Action: The University will develop specific procurement policies to be utilized when Federal funds are used and appropriate staff will be trained on these policies. Responsible Official: Kris Pace, Controller Anticipated Completion Date: June 30, 2023

Finding No. 2022-003 Significant Deficiency Personnel Responsible for Corrective Action: Anthony D?Agostino, CEO of St. Patrick Center Anticipated Completion Date: March 31, 2023 Corrective Action Plan: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.

Views of Responsible Officials: Mary's Center is currently formalizing the existing checklist of all Programmatic Reports required for each of our Federal Grants. This checklist is being reviewed and updated by our Director of Grants. In addition, there is now a bi-weekly meeting in place between the Programmatic and Finance teams to address any changes or updates to grants. Lastly, a Grants liaison was recently employed at Mary's Center. This person will act as the conduit between our Programmatic and Finance teams and help maintain this checklist on a going forward basis.

Regional Planning Commission (RPC) has hired a new Executive Director effective March, 2023. RPC also hired a new Finance Director effective September, 2023, who is experienced in public finance and general reporting requirements. Both staff members are dedicated to ensuring proper procedures and performance going forward. Both staff members will review and sign off on the timely and accurate filing of all grant reporting documentation and requirements.