Corrective Action Plans

We continue to review and update our procedures and process to insure that all financial transactions are properly allocated to programs/ properties funded with federal funds - Anticipated Completion Date-April 30, 2025.Responsible Contact Person-Kathleen Boyce, CFAO

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Moving forward treasurer will provide even more information to the reviewer specifically pertaining to the findings and any other pertinent information for that person to have a better idea of what they are looking for and will keep documentation of the review being done and signed off on. Anticipated Completion Date: This will be corrected with the next round of ESSER reporting due January 2025.

Anticipated Completion Date: January 31, 2025 Responsible Contact Person: Andrew Szalay The root of this “significant finding” has been among the Program staff capturing receipts for small expenditures, such as water and ice, and such, from convenient stores, during construction with Habitat volunteers. These were all credit card receipts. In the fall of 2024, Habitat management have conducted two types of meetings to ensure source documentation is collected and submitted with financial records: 1. Individual conversations with every credit card holder about the importance of turning in receipts, no matter how small, documentation is critical. 2. Goup meeting with the “frequent offenders” and further emphasized the importance of turning in receipts. Credit card holders were warned that credit card privileges may be revoked if the problem continues. In addition, additional tools may be put into place to capture and retain documentation. This may include vendor apps and digital upload tools. Policies will also be reviewed to ensure practices and terms are consistent and clear for both credit card holders and other staff that submit expense reimbursement forms.

Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. recently added capacity and experience to the finance department by hiring two new staff members, a Payroll Specialist and an AP and Procurement Specialist. In addition, best practices and reconciliation timelines and guidance are being captured in financial policies and procedures being updated at this time. UMHS has also implemented new software tools that will assist in automating the department, providing additional time for staff members to implement a monthly review that includes reconciliations and tracking. This "internal auditing" process is relatively new to the department and will add a layer of accountability and accuracy in the recording and processing of the organization's financial activity. In addition, UMHS initiated recruitment for a permanent Director of Finance in summer 2024 and the search to hire for this position is open and ongoing. To supplement and support the current staff, UMHS will continue to provide additional training and guidance to the finance team to stay ahead of changes to federal and state guidelines, and to build on the knowledge and experience of the team. Adding a permanent Director of Finance will be essential as that staff member will be a member of the Senior Leadership Team and working in supporting and staffing the monthly Finance Committee meetings and supporting the UMHS Board of Directors' Treasurer. UMHS Senior Leadership Team will review and approve year-end financial schedules being provided to the auditors, as well as provide additional oversight and approval of year-end entries and closing processes. Timing for Implementation: Immediate and Ongoing Person(s) Responsible: Executive Director, Director of Finance, or Designee

Auditor recommendation: We recommend that the City establish policies and procedures for requesting reimbursement of grant expenditures on a monthly basis, including reconciliation of the expenditures and reimbursements under each grant. Views of Responsible Officials and Planned Correc􀀁ve Ac􀀁on: The City agrees with this finding. Vacancies in key posi􀀁ons including the Airport Manager and the Transit Director of Administra􀀁on meant that there was not sufficient exper􀀁se in the program areas to ensure that reimbursement requests were prepared and submi􀀂ed 􀀁mely. These key posi􀀁ons have now been filled. The City now has an Airport Manager with substan􀀁al experience managing municipal airports and overseeing federal funding for airports. The City also hired a Transit Director of Administra􀀁on with extensive federal and state grant management experience, and exper􀀁se in Transit programs. The Accoun􀀁ng Officer, Grants Manager and Accoun􀀁ng Financial Analyst posi􀀁ons in the Finance Department have been filled, and the Grants Division is now fully staffed. More robust staffing is allowing Finance to perform more oversight in addi􀀁on to working more closely with Transit and Airport program staff. Filling these key posi􀀁ons and retaining qualified staff is essen􀀁al to establishing a process for 􀀁mely requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursement under each grant. The Transit Division is working with a contractor provided by the FTA on establishing policies and procedures to ensure compliance with federal grant requirements. This contractor is also providing training and technical assistance to the Transit program. The scope of this work includes ensuring requests for reimbursement of grant expenditures are submi􀀂ed 􀀁mely, and reconcilia􀀁ons of grant expenditures and reimbursements are completed 􀀁mely and accurately. The Airport Department is in the process of contrac􀀁ng with a vendor to assist with federal compliance and provide training for Airport staff on relevant Uniform Guidance requirements. The vendor’s scope of work will include helping with developing and documen􀀁ng policies and standard opera􀀁ng procedures for requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursements. Addi􀀁onally, the Airport Department plans to create a Grant Accountant posi􀀁on which will be responsible for reconciling grant expenditures monthly and processing reimbursement requests quarterly. In CY25 the City plans to provide Uniform Guidance training for staff which will include internal controls related to cash management. Responsible Official:Emily Oster, Finance Director, James Harris, Airport Manager, Airport Heavy Equipment Mechanic, Gabrielle Chavez, Transit Director of Administration, Matthew Bonifer, Accounting Officer, Erika Lujan, Grants Manager Timeline and Es􀀁mated Comple􀀁on Date: June 30, 2025

Recommendation: Reconciliation of not only the total federal expenditures reported to the general ledger, but by budget line item and general ledger accounts. A review process of the reconciliation should be designed and implemented to ensure that both expenditures in total and by budget line item are reported accurately and are supported by the accounting records. Award budgets should be prepared and approved with the actual costs expected per the general ledger accounts to be incurred. Action Taken: Boys & Girls Clubs of Dane County will establish grant budgets at the time of a grant application. If awarded, this is the budget a PI/Program Manager will be trained on with instruction from Finance as to the respective general ledger codes that coincide with each budget line. If a diversion is necessary, budget modifications will be sought out. The individuals responsible are: Sr. Director of Grants & Compliance, Grant Writers, Controller, Finance Operations Administrator, PI’s/Program Managers over respective grants. The anticipated completion date is March 31, 2025.

WHPCA has hired a third-party accountant as well as implemented additional monitoring and review and approval procedures to strengthen its financial management.

WHPCA has hired a third-party accountant as well as implemented additional monitoring and review and approval procedures to strengthen its financial management.

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported on the Year 3 report ($572,289) did not agree to the underlying expenditure records ($558,956) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER I, ESSER II, and ESSER III amounts reported on the Year 4 report ($105,506, $510,158, and $1,156,254, respectively) did not agree to the underlying expenditure records ($138,662, $316,236, and $1,158,054, respectively) for the period of July 1, 2022 through June 30, 2023. Contact Person Responsible for Corrective Action: David Rowe, Business Manager Contact Phone Number: 765-298-6505 Views of Responsible Official: We concur with the finding, while noting that all expenditures and revenue from reimbursements balance within our system. Description of Corrective Action Plan: Verify that all expenditure account numbers match those utilized by AFR and Gateway reporting. Anticipated Completion Date: Begin immediately, ongoing.

2024-002 Filing of Federal Financial Reports Federal Departments: Department of Justice, Office on Violence Against Women Assistance Listing #: 16.526 Compliance and Internal Controls Significant Deficiency Category of Finding – Reporting Name of contact person: Vivian Huelgo, President and CEO Corrective Action: Esperanza has assigned the contract accountant to be responsible for preparing these reports and implemented review processes to ensure these reports are accurate. Completion Date: The Organization has already adopted this corrective action.

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($397,392 and $294,138, respectively) did not agree to the underlying expenditure records ($498,259 and $1,509,413, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II and ESSER III amounts reported on the Year 4 report ($400,501 and $294,129, respectively) did not agree to the underlying expenditure records ($412,324 and $287,065, respectively, for the period of July 1, 2022 through June 30, 2023). We noted that the 195 number of Full-time equivalent (FTE) positions on September 30, 2023 on the second report did not agree to the underlying records supporting number of 274 Full-time equivalent (FTE) positions on September 30, 2023. Contact Person Responsible for Corrective Action: Dawn Ray Contact Phone Number: 812.988.6601 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will have someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Anticipated Completion Date: Immediately upon the completion of the audit.

The Corporation will have a secondary review process in place to assure the information and timeline are correct before submission.

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($347,591 and $337,851 respectively) did not agree to the underlying expenditure records ($135,355 and $159,811 respectively). Additionally, we noted that the ESSER II amount reported on the Year 4 report ($233,093) did not agree to the underlying expenditure records ($267,310) of the School Corporation. Contact Person Responsible for Corrective Action: Vicki Jones Contact Phone Number: 765-793-4877 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Annual report data will be submitted with the requested information and will be verified with a sign-off by the Superintendent. Anticipated Completion Date: July 2025

Finding Number: 2024-004 Condition: The College does not have a written cash management policy related to federal awards. Planned Corrective Action: In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards in order to implement the requirements of 200.305. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: As soon as possible moving forward starting December 18, 2024.

As part of the 2023-2024 FY audit, there was a finding of non-compliance on financial reporting for a late filing. The corrective action plan is to implement new policies to ensure timely financial compliance with all grant requirements. For questions, please contact Katie Harris, the Director of Finance. The board plans to enact these new policies as of June 30th, 2025.

In response to the findings on the andit of federal programs the district will implement the following: Each month when reporting our financials all federal grant accounts will be separated and will be reviewed for accuracy and to insure proper project codes are correct also expenditures for 1 % professional development will be reviewed for accuracy. All payment request for federal fund grants will be approved prior to submission by the Superintendent. Ann Wallace will provide this listing to the Superintendent for approval each month. Corrective Action Plan has been implemented July 25, 2024.

December 27, 2024 Finding Number: 2024-004 Material Weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) (Workforce Innovation and Opportunity Act- WIOA) Finding Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Planned Corrective Action: The Consortium has carefully reviewed our policies and procedures and have made the necessary changes to ensure that cash draws are based on expenditures already incurred and that they are supported by transactions recorded in the general ledger. Cash draws continue to be “necessary and reasonable”. We strive to improve the timing of our cash draws, our grant reconciliations and to continually monitor our cash management to ultimately eliminate this issue. Responsible Contact Person: Shamar Herron (Executive Director) Sherron@mwse.org Anticipated Completion Date: March 2025 Respectfully, Shamar Herron

December 27, 2024 Finding Number: 2024-003 Material Weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) (Wagner Peyser) Finding Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Planned Corrective Action: The Consortium has carefully reviewed our policies and procedures and have made the necessary changes to ensure that cash draws are based on expenditures already incurred and that they are supported by transactions recorded in the general ledger. Cash draws continue to be “necessary and reasonable”. We strive to improve the timing of our cash draws, our grant reconciliations and to continually monitor our cash management to ultimately eliminate this issue. Responsible Contact Person: Shamar Herron (Executive Director) Sherron@mwse.org Anticipated Completion Date: March 2025 Respectfully, Shamar Herron

All funds have been refunded to state agency and expense reports amended appropriately.

CORRECTIVE ACTION PLAN October 23, 2024 Kansas State Department of Education and Kansas State Department of Administration Unified School District Number 374 respectfully submits the following corrective action plan for the year ended June 30, 2024. Medill & Thooft, CPA Po Box 885 Ulysses, KS 67880 Audit Period: June 30, 2024 FINDINGS – FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Education Stabilization Fund Cluster Federal Assistance Listing Numbers: 84.425U Finding 2024-001 Recommendations: The District should have an employee compare the Board Clerk’s supporting documentation and the Education Stabilization Fund spreadsheet report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the report submitted should be printed, initialed by the secondary reviewer, stapled with the information used to compile the report and combined with all financial records for the fiscal year. Action Taken: We agree with the recommendation. Our targeted implementation date is November 2024. If the Kansas State Department of Education and/or Kansas State Department of Administration has questions regarding this plan, please call Rex Richardson at 620-675-2277. Sincerely yours, Rex Richardson Superintendent

Corrective Action: Management will continue to stress the importance of following the detailed procedures for preparation and review of the SEFA. The SEFA checklist is updated to include a thorough review of expenditure details to ensure no prior-year expenses are reported. Responsibility for compiling the SEFA was assigned to a Senior Program Accounting Manager who is tasked with assuring the schedule and all the support reconciliation are complete and accurate. Both the Director of Program Accounting and the Executive Director of Finance/Controller will review the SEFA for completeness, accuracy, and compliance with CFR Section §200.510(b). Estimated completion date: June 30, 2025 Individual Responsible for Corrective Action Plan: Contact: Reginald Gregory Title: Executive Director/Controller Phone Number: 202-772-4300

FINDINGS- MAJOR FEDERAL AWARD PROGRAMS Material Weakness U.S. DEPARTMENT OF EDUCATION- 2023 Elementary and Secondary School Emergency Relief Fund- AL Number 84.425 Finding No.: 2024-006 Condition: The District did not maintain records that contain information necessary to identify Federal expenditures supported by source documentation. Recommendation: The District should always maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal expenditures. All records must be supported by source documentation. Action Taken: The District concurs with the recommendation. The District will work to ensure that records are maintained that sufficiently identify the amount, source and expenditure of Federal funds for Federal awards. Grant expenditure reports will be reviewed to make sure Federal award expenditures are not double-reported. Anticipated Date of Completion: Ongoing

FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School District in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in 2 place to prevent, or detect and correct, errors. During tie out of the Year 3 report, a variance between the underlying records and reported expenditures of $187,649 was noted due to the lack of effective controls surrounding annual data reporting. 84.425U expenditures submitted within the Year 3 report were overstated by $187,649. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will implement a formal review process over data reporting to ensure compliance with reporting requirements for federal awards. A Grant Coordinator has been hired and is already in place. Both the Grant Coordinator and Treasurer will review and sign off of required reporting and ensure it is completed in a timely manner. Responsible Party and Timeline for Completion: Andrew Grismore - Grant Coordinator and Moriah Crane - Treasurer will be responsible. These corrective measures are already in place.

Corrective Action Plan: AlaHA will accomplish the following: 1) Send guidance to hospital systems with multiple facilities reported on their 941s that they should retain general ledger detail reconciliations to support the funds received. 2) Request the hospital involved in the exception cited for not having submitted general ledger evidence submit additional support for the reconciliation they submitted. 3) Should a similar tranche of funds become available in the future, AlaHA will ensure disbursements are not made before receipt of general ledger evidence to support the amount reported by the hospital. Target Date: For items 1 & 2 in the corrective action plan, November 6, 2023.

Corrective Action Plan: The District has developed and implemented a Federal Funds Manual. Anticipated Corrective Action Plan Completion Date: November 18, 2024 Contact Information: For additional information regarding this finding please contact Blaise Paul, Chief Business & Finance Officer, at 414-768-6140.