Corrective Action Plans

The Board agrees with this deficiency. However, the Board has not received Federal financial assistance in over 20 years that would require the Board to be subject to a Single Audit. The Board will internally develop written financial management system requirements or hire an outside grant writing manager to assist in developing written fiscal policies.

FINDING 2025-002 Finding Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: The School Corporation was unable to provide proper documentation for 5 out of the 25 claims selected for control testing. The School Corporation was unable to provide proper documentation to support the determination of the amount of the teachers total salary that was allocated to the federal award. Contact Person Responsible for Corrective Action: Melissa Raaf Contact Phone Number and Email Address: (812) 649-2591 / missy.raaf@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In the future the School Corporation will ensure that all proper documentation is saved in a binder or electronically. Anticipated Completion Date: Effective FY 2025/2026

The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 1 6, 2022, to administer the federal grants to ensure that the Town would comply with all federal program requirements. The Town was led to believe that they were in compliance with all federal program requirements. The Town will develop, formally adopt, and implement written policies and procedures to comply with Uniform Guidance (2 CFR 200).

Significant Deficiency Item 2025-007 - Cash Management - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 H80CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 HBHCS46163-03-01 During our audit, we noted that there is no evidence of review and approval of drawdowns from the Health Center Program Cluster and the supporting records. Recommendation: We recommend that LBUCC implement a policy that requires all drawdowns and supporting documents to be reviewed and that such review and approval be documented. Action Taken: LBUCC revised the drawdown policy which now includes a review and approval from the CFO and the process is documented. Effectivity Date: Implemented 12/3/2025.

2025-001 Reporting US Department of Education – AL #s10.553, 10.555, 10.559 and 10.582 Child Nutrition Cluster Condition: The District submitted monthly child nutrition reimbursement claims that contained inaccurate meal counts for multiple months during the fiscal year. Specifically, the District overstated reimbursable meal counts due to errors in including non-reimbursable meals served. Additionally, the claims were not subject to an independent review prior to submission to ensure accuracy and completeness. Name of Contact Person: Ann Berman, Business Manager Plan of Action: The District will revisit the internal control processes surrounding the grant reporting and reimbursement process to ensure meal count information submitted is within program requirements of Child Nutrition Cluster programs. In the event there are questions surrounding meal count and other information subject to reporting, the District will continue to rely on timely guidance from external governmental accounting consultants, the Oregon Department of Revenue, and the Oregon Department of Education.

Management's Response/Planned Corrective Action: The Controller will ensure a process of dual review/approval on reporting is followed going forward to aid in identifying any reporting inconsistencies or misunderstanding of reporting instructions. This will be undertaken immediately.

Finance department will set up the coding process and begin including Departments that match project codes for all federal programs. Corrective Action Owner: Lisa Peacock, Comptroller with assistance from the Senior Accountant, and report to Francesca Rattray, CEO

Corrective Action Plan for Federal Award Audit Finding 2025-001 Finding Title: Allowable Costs/Cost Principles – Improper expenditure recognition Federal Program: Title II, Part A, Teacher & Principal Training and Recruiting Assistant Listing Number: 84.367A Federal Agency Name: U.S. Department of Education Passed-Through Agency Name: Texas Department of Education Type of Finding: Significant Deficiency in Internal Control over Compliance Description of Corrective Action The District acknowledges the internal control system did not timely detect the improper recognition of expenditures in the incorrect fiscal period. It is important to emphasize that the expenditures identified were ultimately removed from the current year activity and were excluded from the year-end reimbursement request. The District commits to strengthening its year-end closing procedures and providing comprehensive training to address the noted deficiency in monitoring and review. The following actions will be taken: Mandatory Staff Training on Expenditure Cut-off and Accruals The District will develop and implement mandatory, targeted training for all personnel responsible for processing, recording, reconciling, and reviewing federal grant expenditures, with a specific focus on year-end cut-off procedures and proper expense recognition (accruals versus prepaid expenses). Implementation of Formal Grant Expenditure Cut-off Review Procedure A formalized closing procedure will be implemented for all federal awards, ensuring a mandatory, documented review of expenditures and payables near the fiscal year-end. Persons Responsible Timothy Momanyi, Chief Financial Officer Thania Gonzalez, Assistant Superintendent of Business and Finance Anticipated Completion Date The initial staff training will occur by May 31, 2026. The full implementation of the new procedures, with documented adherence by all responsible staff, will be complete by June 30, 2026, ensuring the new controls are fully operational before the close of the 2025-2026 fiscal year.

Finding: 2025-001 Incomplete Tenant Records - Section 8 HCV Program (ALN 14.871) Condition: 1. For one (I) tenant, income verification was not performed for the current During our review of forty ( 40) tenant files under the Section 8 Housing Choice Voucher (HCV) Program, we identified multiple instances of missing documentation and compliance lapses: year, and prior year income was rolled forward. The HUD-50058 (Family Report) form was reviewed in the PIC system but was not present in the tenant file. 2. For one (I) tenant, the Approved Lease, HUD-52517 (Request for Tenancy Approval), and HUD-52641 (HAP Contract) forms were not present in the tenant file. Recommendation: We recommend that the Housing Authority strengthen internal controls over tenant file documentation by implementing a standardized checklist to ensure all required forms and records are consistently retained. Staff should receive periodic training on HUD documentation and compliance requirements to reinforce expectations and reduce errors. Management should also conduct routine internal reviews to verify that income verification and lease documentation are properly completed and maintained. These measures will help ensure that tenant eligibility and payment determinations are adequately supported and compliant with federal regulations. Planned Corrective Action: To address these findings, the Housing Authority will implement a standardized checklist for all tenant file changes, ensuring that all required forms and records are consistently retained. The Program Administrator and staff will conduct monthly reviews of completed re-examinations to verify that all necessary documentation is present and properly filed. All paperwork related to annual re­exams, transfers, move-ins, and interims will be scanned into the Lindsey software system within five working days of receipt, prior to physical filing. The Program Administrator will organize monthly training sessions on HCY/S8 program requirements, with participation tracked to ensure all staff attend. Weekly spot checks will be performed to confirm that the checklist is being used appropriately. These actions will be supported by updated training materials, access to the Lindsey software, and dedicated staff time for audits and training. To mitigate risks such as incomplete documentation, missed scanning deadlines, or low training attendance, the Housing Authority will implement pre-audit checklists, set automated reminders for staff, and make training mandatory. Management will monitor the implementation of these corrective actions and conduct follow-up reviews to ensure sustained compliance with HUD regulations.

2025-002 – Lack of Written Policies and Procedures. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Village. As a result of this condition, the Village did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Village review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Village has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Village Council before the end of fiscal year 2026. Responsible Person. Vicki Burrell, Village Clerk. Anticipated Completion Date: February 2026.

Pohnpei has agreed to the findings and is committed to implementing the recommendations. Ongoing Director of Treasury and Administration Sihna N. Lawrence sihna.lawrence@pohnpeidota.fm

Pohnpei has agreed to the findings and is committed to implementing the recommendations. Ongoing Director of Treasury and Administration Sihna N. Lawrence sihna.lawrence@pohnpeidota.fm

Management agrees with the finding and is in the process of revising internal controls to address SEFA preparation

Finding: 2024-005 - Inadequate Controls Over Federal Grant Reporting and Record Retention Finding Type: Material weakness in internal control over compliance. Repeat Finding: Yes; prior-year finding 2023-004. Federal Award: ALN 21.027 — Coronavirus State and Local Fiscal Recovery Funds (SLFRF). Auditor Description of Condition and Effect: During the audit, we noted that the Organization had not established and implemented sufficient controls over the preparation, review, submission, and retention of required federal grant reports. Specifically, the Organization could not provide sufficient documentation demonstrating that: • Financial and programmatic information in required reports was reconciled to the underlying accounting and project records; • All applicable reporting elements, including capital expenditures and contractor or subaward information, were evaluated for completeness; • Reports were reviewed and approved by appropriate personnel before certification and submission; • Reports were submitted by the applicable deadlines and evidence of submission was retained; and • Corrections or resubmissions were appropriately documented and supported. The absence of appropriately designed and implemented controls creates a reasonable possibility that materially inaccurate, incomplete, or untimely reports could be submitted, or that material noncompliance with federal reporting and record-retention requirements could occur and not be prevented, or detected and corrected, on a timely basis. Insufficient records may also prevent the Organization from substantiating reported information or demonstrating compliance during an audit, monitoring review, or other oversight. Auditor Recommendation: Management should adopt written federal grant reporting procedures and implement a standardized process for preparing, reconciling, reviewing, approving, submitting, and retaining required reports. The process should address all applicable financial and programmatic reporting elements, including capital expenditures and contractor or subaward information, and should require retention of the reports, submission confirmations, supporting records, and documentation of any corrections or resubmissions for the period required by the award. Management Response and Corrective Action Planned: The Organization agrees with the finding. Management will adopt written federal grant reporting and record-retention procedures, maintain a reporting calendar, and assign responsibility for preparation and review. Reported financial and programmatic information will be reconciled to the underlying accounting and project records, and a standardized checklist will be used to evaluate all applicable reporting elements. Management will document review and approval, retain evidence of timely submission, and maintain the reports, supporting records, and documentation of corrections or resubmissions in a centralized grant file for the retention period required by the award.

The District Office will work directly with the Federal Programs Coordinator to ensure more timely submissions of Reconciliation of Cash on Hand Quarterly Reports and Final Expenditure Reports are prepared accurately and submitted timely in accordance with grant requirements. The Business Manager will do this by creating reminders on the Business Manager’s calendar that include due dates each quarter and reminding the Federal Programs Coordinator when their respective reports are due. The District will implement and form a review and monitoring process and provide any necessary training to staff responsible for grant reporting to ensure ongoing compliance.

• The Compliance Director will be responsible for maintaining updated records and ensuring accessibility during audits. • Implement checklists for each compliance area (reporting, Eligibility, Procurement) to confirm all documents are gathered before deadlines. • Schedule quarterly internal mini audits to test readiness and correct gaps before the annual audit. • Maintain written standard operating procedures for how documentation should be completed, stored and updated. • Assign responsibility for each compliance area (waiting lists, who oversees procurement, who handles reporting) • Implement the use of audit readiness templates that outline exactly what needs to be prepared for each compliance requirement. Name of Responsible Person: Housing Director, Compliance Director Projected Completion Date: By the end of the current fiscal year.

Management agrees with the finding. Management has downloaded 2 CFR Part 200 for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

Depository Agreement Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Public Housing Operating Fund – Assistance Listing No. 14.850 Recommendation: We recommend that the Authority designate an individual to obtain and execute a General Depository Agreement (HUD-51999) with each financial institution holding HCVP and Public Housing program funds, ensure that collateral is pledged for amounts on deposit in excess of FDIC insurance limits, and maintain the executed agreements in a centralized file for ongoing monitoring. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In April 2025, the HA hired the financial consulting firm of Kubas Keller and Associates. They have vast experience with HA’s all around the country and will work with staff to ensure that the HA obtains and executes a General Depository Agreement with each financial institution holding HCVP and Public Housing program funds. Name(s) of the contact person(s) responsible for corrective action: Tony Palmer, CPA Kubas Keller and Associates Planned completion date for corrective action plan: June 2025

Allowable Costs - HCVP Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority designate an individual to review both cash disbursements and payroll disbursements for all program expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In April 2025, the HA hired the financial consulting firm of Kubas Keller and Associates. They have vast experience with HA’s all around the country and will work with staff and possibly a new CFO to ensure that all program expenditures are recorded and allocated in an appropriate manner based on actual work performed. Name(s) of the contact person(s) responsible for corrective action: Tony Palmer, CPA Kubas Keller and Associates Planned completion date for corrective action plan: April 2025.

Interfund Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Public Housing Operating Fund – Assistance Listing No. 14.850 Recommendation: We recommend management should create processes to track interfunds and transfers as well as designate an individual to review and approve these transactions. Additionally, the Authority should begin the process of reimbursing the respective programs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In April 2025, the HA hired the financial consulting firm of Kubas Keller and Associates. They have vast experience with HA’s all around the country and will work with staff and possibly a new CFO to ensure if interfunds and transfers are properly tracked and eliminated on the financials. This includes reviewing past transactions and correcting them in FY 2026. Name(s) of the contact person(s) responsible for corrective action: Tony Palmer, CPA Kubas Keller and Associates Planned completion date for corrective action plan: June 2026.

Finding 2024-004: Financial Reporting The club did not maintain proper documentation in support of financial reporting requirements for the two SF-425 reports that were tested. Corrective Action Plan The program will implement immediate corrective measures to strengthen federal financial reporting and ensure full compliance with SF-425 documentation requirements. Within the first 30 days, supporting documentation for the SF-425 reports tested will be recreated and retained to the extent possible, and a standardized SF-425 Documentation Packet will be established to include all required backup materials. A designated staff member will be assigned responsibility for preparing and retaining all SF-425 support documentation, and finance staff will receive refresher training on federal reporting requirements and documentation standards. Between 30 and 60 days, the program will implement a Financial Reporting Documentation Policy requiring supporting schedules for each SF-425 line item, retention of all source documentation, and clear identification of preparers and reviewers. SF-425 preparation and documentation tasks will be integrated into the monthly and quarterly fiscal compliance calendar, and dual review and sign-off will be required for each submission to ensure accuracy and completeness. From 60 to 90 days, the program will strengthen reporting processes by implementing a SF-425 Preparation Checklist, establishing a centralized digital folder structure with restricted access and audit-ready program, cross-training additional staff to ensure continuity, and updating fiscal policies to reflect strengthened documentation and review procedures. Long-term oversight will include quarterly reporting compliance updates from the Finance Officer to the Head Start Director, Policy Council, and Executive Board; annual internal monitoring of SF-425 documentation packets; and maintenance of all federal reporting documentation for the required retention period under Uniform Guidance. Financial reporting procedures will be reviewed and updated annually. Full implementation will occur within 90 days, quarterly monitoring will remain ongoing, and annual policy review will occur each fiscal year. Evidence of completion will include completed SF-425 documentation packets, signed preparation and review checklists, updated fiscal policies and procedures, and quarterly compliance reports submitted to the Policy Council and Executive Board. Responsible Personnel: Cynthia Cooper – Chief Finance Officer: Oversight, review, and compliance monitoring Sharon Jordan - Head Start Director: Accountability and reporting Estimated Date of Completion: December 2026

Reference Number: 2024-007 Finding Title: Reimbursable Expenditures Assistance Listing Number/Program: 20.205 – Highway Planning and Construction Agency / Pass-Through: U.S. Department of Transportation, passed through the California Department of Transportation Compliance Requirement: Allowable Costs and Activities Management's Response Management concurs with the finding and acknowledges that improvements are necessary to strengthen StanCOG's internal controls over grant expenditure documentation, review, and reimbursement processes. The condition identified resulted from deficiencies in historical grant expenditure documentation and review procedures. During the period under audit, StanCOG did not have sufficiently documented processes in place to ensure that all costs charged to federal awards were supported by adequate documentation demonstrating the nature, amount, timing, allowability, and allocability of the expenditure prior to reimbursement submission. The unsupported expenditure identified during testing relates to a reimbursement claimed under the Highway Planning and Construction program. Management recognizes the importance of maintaining complete supporting documentation for all federal award expenditures and will work with the appropriate parties, including the grantor as necessary, to evaluate and resolve the questioned cost in accordance with applicable federal requirements. Since the period under audit, StanCOG has undergone significant changes within its Finance Department and has recently hired new management focused on strengthening financial controls, improving grant compliance practices, and rebuilding sustainable financial processes. Management is currently reviewing existing grant accounting and reimbursement procedures and is implementing enhanced controls to ensure federal expenditures are properly supported and reviewed prior to reimbursement requests. Management is implementing, or plans to implement, the following corrective actions: • Establish standardized grant expenditure review procedures requiring supporting documentation before costs are charged to federal awards or submitted for reimbursement. • Develop documentation requirements for grant-related expenditures, including invoices, contracts, payroll documentation, time records, and other supporting records necessary to demonstrate allowability and allocability. • Implement documented supervisory review procedures to verify that expenditures charged to federal programs are appropriate, supported, and comply with applicable federal requirements. • Improve coordination between Finance and program/project staff to ensure required supporting documentation is collected and retained timely. • Establish consistent grant file organization and retention procedures to ensure documentation supporting federal expenditures is readily available for monitoring and audit purposes. • Provide guidance and training to staff involved in grant administration, project management, and expenditure processing regarding federal cost principles and documentation requirements. • Review the questioned cost identified in the audit and coordinate with the appropriate grantor representatives regarding resolution, as necessary. Management recognizes the importance of strong grant management practices and maintaining adequate documentation to support the use of federal funds. StanCOG is committed to strengthening its internal control environment, improving grant expenditure review procedures, and ensuring that future reimbursement requests are supported by complete and appropriate documentation in accordance with federal requirements.

This problem only applied to the HHS program that was eliminated in December 2023. All other programs that we contract with are paid in arrears and there are no advances. We have proposed a settlement agreement with HHS to eliminate the overpayment and interest. Benjie Read will be responsible for the settlement agreement, by October 31, 2026.

1. Responsible Person: Auditor-Controller 2. Corrective action plan: The County agrees with the finding and recommendation. The County Auditor’s office will work with department heads to establish a formalized policy of tracking timely reporting and correspondence procedures with grantors in the case of delayed reporting. In addition, the County will appropriately allocate employee resources to ensure compliance with deadlines. 3. Anticipated implementation date: June 30, 2027

The reporting for these has been updated and submitted. In 2024, I was not a part of the e-mail directing these to me - corrected and now processed timely.