Corrective Action Plans

Finding No. 2024-001 NONCOMPLIANCE WITH US GAAP – VARIABLE INTEREST ENTITIES (VIE) We acknowledge the audit finding and appreciate the auditor’s diligence in identifying the issue. After evaluating the matter, we agree that the effect on the consolidated financial statements is immaterial and does not impact the fair presentation of our financial position, results of operations, or cash flows. Additionally, after assessing the costs and benefits of remediation, we have determined that the corrective action required to fully address this issue is not cost-effective at this time. The resources required would outweigh the potential benefits, particularly given the immaterial nature of the issue and the lack of impact on users of the financial statements. We, will continue to monitor this area as part of our internal controls framework and will reassess if conditions change or if the issue becomes material in future periods.

CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 2) accurate, current and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in sections 200.328 and 200.329 of the Uniform Guidance.CORRECTIVE ACTION PLAN: The School District concurs with the above noted finding. The School District has employed a new Business Manager whose responsibilities include the oversight of the financial management system and the posting of all transactions into that system. Procedures will be put into place during the remaining months of the 2024-2025 fiscal year, and all subsequent years, for ensuring federal program expenditures are properly coded within the District’s financial management system so as allow for proper reporting related to those expenditures.

Action Taken: HEA's leadership team, including our Director of Finance, will develop an updated version of our accounting and procedures manual that includes written policies related to all applicable compliance areas under Uniform Guidance. This will be a priority for the leadership team and will be developed by May 30, 2025 and reviewed by HEA board members by June 30, 2025. HEA's leadership team will work with staff to ensure all policies and procedures are implemented in our new fiscal year (beginning in July 2025). Contact Person: Sarah Metzler, HEA President/CEO; Aliah Carolan-Silva, HEA VP of Research; Cindi Dixon, HEA Director of Finance Expected Completion Date: July 2025

FINDING 2024-003 Finding Subject: COVID- 19 – Education Stabilization Fund – Reporting Summary of Finding: The School Corporation submitted one ESSER III report where the expenses per the report did not tie to the ledger or the Schedule of Expenditures of Federal Awards by approximately $300,000. Contact Person Responsible for Corrective Action: Matt Miles Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will ensure ESSER reports are saved and tie to the accounting records and will improve record keeping of supporting documentation. If any edits are made to the reports, the Curriculum and Accounting Departments will document the reason for all changes. Management in each department will review all ESSER reports and sign off on all documentation. Anticipated Completion Date: Corrective action steps have been implemented and will be refreshed.

Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures. Management expects to present the policies to the board for approval at the May 2025 board meeting.

Contact Person – Krista Martin, Director of Finance and Administration, and Ryan Riesinger, Executive Director Corrective Action Plan – Review and update procedures to ensure accurate reporting. Completion Date –December 31, 2025

After the September 2023 quarter, controls were put in place to ensure accurate Federal quarterly reports. These controls included preparing the report based on our accounting records, e.g. the general ledger. Another control is that the Chief Financial Officer or her designee reviews all reports and compares them to the general ledger prior to signature, approval and our submission to the grantor. Furthermore, periodic reviews by program fiscal staff during the performance period take place to closely monitor activity. GDOL will continue to follow the updated procedures and internal controls. As we transition to GA@Work, the system itself will control overspending and provide alerts.

Georgia Tech management agrees that internal audit reports demonstrated departmental deficiencies in knowledge of policies and procedures that needed to be addressed. Upon disclosure of Internal Audit’s recommendations, the departments and central offices immediately responded with additional training, proactive compliance reviews, and re-enforcement of existing policies and procedures via Institute wide communications and enhanced reviews of support. New system controls regarding spend authorizations were put in place, with Georgia Tech’s Internal Audit department continuing to test these controls through the month of February. Central and departmental units within Georgia Tech will continue to work together to further enhance guidance and training to faculty and staff and to identify and test controls in our systems that will mitigate these issues.

Friday, April 11, 2025 Dear Sir(s): CORRECTIVE ACTION PLAN In prior years the accounting of Pyramid Learning Corp. was executed externally by a contracted accounting company. During the year ended June 30, 2024 we acquired a specialized accounting software. After the acquisition of the new software, we recorded the data from the beginning of the year to the present, which required significant staff effort and made it impossible to maintain accounting and financial reports on a month-to-month basis. At the present, the data is already being recorded, and the accounting is up to dates. This allows us to keep our accounting and interim financial reports such as Balance Sheet, Statement of Activities, Bank Reconciliations, and monthly analysis of accounts, up to date and on a current month-to-month basis to be more transparent, and any errors are corrected on a timely manner.

Finding 2024-001—Significant Deficiency in Internal Controls over Compliance: Research and Development Cluster Contact Person: Jennifer Sabbagh Peirce, Senior Director Research Operations, Sponsored Programs Administration and Dr. Andrew Artenstein, Chief Physician Executive and Chief Academic Officer, Baystate Health, Inc. Views of Responsible Officials: Management agrees and acknowledges that controls over compliance and documentation of these controls should be assessed and improved. Management highlights that no unallowable charges were incurred and there was no evidence that sponsors were overcharged as a result of the identified deficiencies. Corrective Action Plan and Expected Completion Date: Policies and Procedures – Baystate has already begun a review and revision of policies and procedures that govern sponsored activity in fiscal year 2025. As policies and procedures are revised and finalized, training is provided to the research community, as necessary. This includes effort reporting, subrecipient monitoring and calculations related to salary cap and indirect cost rates. Documentation and Document Maintenance – Baystate is in the process of implementing a pre-award grants system. This electronic system will be the institutional record of all award documentation and award actions. Built into the system are a number of internal controls including workflow approval, tracking and management of award actions and modifications, and management of subrecipient monitoring activities. Salary Cap – Baystate has implemented a number of immediate solutions for salary cap including additional reports to flag salary cap issues. Guidance has been developed and training is underway for individuals that certify effort. In fiscal year 2025, Baystate will consider implementing system delivered functionality in Lawson to manage salary cap calculations. Indirect Rates and Grant Attributes – Implementation of the pre-award grants system will provide an internal control to ensure accurate setup of indirect cost rates and other grant related attributes. These attributes are maintained in the pre-award system based on the sponsor documentation. With each award action and at least annually, Baystate will reconcile attributes between the pre-award system and Lawson to ensure accuracy and completeness. The Corrective Action Plan is expected to be completed by December 2025.

The City is in agreement with the finding and noted and will consider formally documenting policies and procedures. Heather Shippey, City Clerk will be responsible for the corrective action and anticipated completion of corrective action is undetermined.

Views of Responsible Officials and Planned Corrective Action The County has a written policy regarding Federal Grants that was passed by the Grant County Commissioners in January 2025. Finding resolution timeline: Resolved. Designation of employee position responsible for meeting this deadline: Andrea Montoya, Deputy County Manager

2024-033 Oregon Housing and Community Services Department Federal reports should contain accurate information Management Response: The agency agrees with this finding. A dedicated staff resource has been trained and has brought grant reconciliations and reporting current. Additional training has been provided for awareness of the obligation requirements as well. Anticipated Completion Date: June 30, 2025 Contact person: Beth Brown, Controller

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Management Response: We agree with this recommendation. In February of 2025, the agency’s accountant assigned to this program began a full reconciliation of the CDBG program from FY 2020 to FY 2024. We have identified the differences between our accounting records in SFMA and what has been recorded through IDIS, our portal to request funds from the federal government. As of March 2025, we are beginning to finalize our reconciliation of administrative funds and our own agency’s matching contributions. Once incorporating this first step, our accounting staff will continue with a full project reconciliation for the current fiscal year, 2025. Any errors or adjustments identified will be corrected in this current fiscal year. This reconciliation between accounting records in SFMA and IDIS is expected to be complete in May of 2025. Anticipated Completion Date: May 31, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager, Jon Unger, CDBG Program Manager

2024-033 Oregon Housing and Community Services Department Federal reports should contain accurate information Management Response: The agency agrees with this finding. A dedicated staff resource has been trained and has brought grant reconciliations and reporting current. Additional training has been provided for awareness of the obligation requirements as well. Anticipated Completion Date: June 30, 2025 Contact person: Beth Brown, Controller

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Management Response: We agree with this recommendation. In February of 2025, the agency’s accountant assigned to this program began a full reconciliation of the CDBG program from FY 2020 to FY 2024. We have identified the differences between our accounting records in SFMA and what has been recorded through IDIS, our portal to request funds from the federal government. As of March 2025, we are beginning to finalize our reconciliation of administrative funds and our own agency’s matching contributions. Once incorporating this first step, our accounting staff will continue with a full project reconciliation for the current fiscal year, 2025. Any errors or adjustments identified will be corrected in this current fiscal year. This reconciliation between accounting records in SFMA and IDIS is expected to be complete in May of 2025. Anticipated Completion Date: May 31, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager, Jon Unger, CDBG Program Manager

The Finance staff has already begun to regularly review grant budgets to ensure that expenses are allowable for reimbursement. Indirect costs for the federal grants are charged to a separate Indirect Cost ledger to ensure accurate tracking and reporting.

COSA implemented a new timesheet process in June 2024 that aligns with payroll and provides a more accurate alignment with employee time, time and grant expense allocations.

Corrective Action Plan We are in the process of updating the Organization’s written policies and procedures to include the requirements of the Uniform Guidance. Completion Date Fiscal year end 2025

Invest in Kids updated its policies and procedures in October 2024. The updated language states “Disbursements to subrecipients of federal funds: The Director(s) and Finance & Administrative Manager will review all relevant documentation to confirm that funds were used for the approved amount and intended activity, goods, or services, and that only allowable expenses are charged. Invoice payments will be delayed until the necessary supporting documentation is received and verified.” Additionally, all staff participated in the organization's annual financial management and internal controls training in October 2024 with a focus on the accounts payable and invoicing process.

Finding: 2024-004 Written Financial Policies- Activitities Allowable, Allowable Cost Name of responsible official: Melissa Spear -Treasurer Corrective action: Adopt suggested policies as outlined by auditor. Anticipated completion date: June 30, 2025

Action in response to finding: The Organization will either add internal resources to address the matters noted in the finding or outsource its accounting function to a third party with these capabilities. Name of the contact person responsible for corrective action: Yvonne MacDonald Hames Planned completion date for corrective action plan: June 30, 2025

Identifying Number: SA 2024-001 Description of Finding: MARTA does not have comprehensive written policies and procedures concerning the following key compliance areas which are required by the Uniform Guidance: Equipment and Real Property Management MARTA has an Asset Inventory Policy and Procedures, however, it does not clearly define the policies and procedures that are in place for the use, management and disposition of equipment acquired under a Federal award in accordance with 2 CFR sections 200.313(c) through (e). Cash Management MARTA does not have written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. Procurement, Suspension and Debarment MARTA has a Procurement policy, however, documented procedures are not well- defined regarding the purchase process for different types of procurement, obtaining quotations, bidding, and procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Corrective Actions Taken or Planned: We have an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. We also have Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing resources available. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. We are in the process of updating our Procurement Policy. We will review and update these policies and/or create new policies to make sure we are compliant with the Uniform Guidance. The updated or newly created policies will be brought to our October 2025 Board of Directors meeting for Board review or approval. Personnel responsible for implementation: Sean Gillingham, Finance Manager Anticipated completion date: October 2025

2024-018. USU Extension Extra Services Compensation Program Non-Compliance with Uniform Guidance State Agency: Utah State University Research & Development Federal Agency: Various 1) Potential Financial Impact USU retained Huron Higher Education Consulting to conduct a Uniform Guidance compliance review of compensation costs charged to federal sponsors. Huron Consulting routinely works with Carnegie R1 institutions to review research compliance issues. Huron conducted a detailed review of an extensive data set for ESC payments made to USU employees, focusing on employees who had salary charged to federal grants or designated as a grant cost share. This review identified limited instances (1) when salaries directly charged to sponsored projects included extra service compensation in the institutional base salary and (2) when extra service compensation was charged to federal sponsors. Overall, the review found that the vast majority of USU ESC payments (referred to as secondary payments in the internal audit) were not charged to federal sponsored awards. Out of a total population of $5.8 million ESC payments reviewed, the unallowed compensation costs related to ESC is approximately $140,000. USU is in the process of addressing the unallowable compensation costs by removing unallowable charges on open awards and refunding unallowable charges on closed awards. 2) Policies and required documentation for ESC. ESC Policies: USU is reviewing its policies associated with ESC and institutional base salary (IBS) (both currently defined in USU Policy 376: Extra Service Compensation). A working group has been established that includes the Provost’s Office, the President’s Office, the Office of Research and Human Resources to develop updated procedures for requesting ESC. Once in place, a new Extra Service Compensation website will be rolled out that will provide guidance on the policy, acceptable uses of extra-service Compensation, and training materials. In conjunction with the website development, a communication plan to inform stakeholders, especially approving department heads and administrators, will be developed. Institutional Base Salary Policy and Procedures: USU will create and implement an Institutional Base Salary policy that aligns with federal requirements and industry best practices and specifically defines salary components and the associated pay codes that are included and excluded from an employee’s institutional base salary. USU will also update its time and effort certification system with correct institutional base salary mapping. 3) Internal controls for sponsored program compensation USU will implement the following improvements in its internal controls: Revised ESC Form. USU has revised its ESC Form to include documentation / calculation demonstrating payment is commensurate with institutional base salary. Revised ESC Application and Approval Process: USU has already updated the internal ESC review process to include appropriate controls to ensure that all ESC requests are reviewed for Uniform Guidance and USU policy requirements. In this regard, all ESC requests at USU are now reviewed by the Office of Sponsored Programs in the context of all funding sources associated with the applicant (including cost share indexes). This change directly addresses prior routing based on the source of funding which resulted in the Office of Research/Sponsored Programs being bypassed for state-funded ESC requests. Certification language has been inserted at appropriate approval levels to ensure that employees are not receiving ESC related to their primary position/workload. Improved Definitions of Primary Work Statement: USU has initiated a collaborative effort between Human Resources, the Provost’s Office, and the Office of Research to clearly define the primary work assignment for faculty via the role statement or annual work plans to clarify the full workload associated with the IBS. Increased Compliance Monitoring: After-the-fact monthly review of ESC payments is being collaboratively performed between the Office of Research and Provost’s Office. Additionally, USU has reorganized its operations to house post-award research administrators within the Office of Research and added an additional supervisory position to manage post award compliance and management. USU will charge central-post award research administrators with monitoring salary charges to sponsored awards and cost share accounts as a secondary internal control. Research Incentive Programs: The Office of Research will establish permissible conditions and components for research incentive programs and any and all proposed programs will be reviewed and approved by the Office of Research before implementation. 4) Adequate training to university personnel regarding sponsored programs compensation compliance. Uniform Guidance training for faculty and staff: USU is building and incorporating new training modules for those managing federal awards which will include guidance on allowable compensation costs and determining institutional base salary. ESC Training: USU has developed a new required annual training for anyone requesting or approving ESC from all types of funding sources at USU (delivered via USU’s Learn Blue system). This training addresses requirements for ESC and employees’ role and responsibilities for compliance requirements. Additional training regarding time and effort certification will be developed. Pay Code Training: USU will provide additional training and education for departmental and payroll staff responsible for coding and processing salary across the institution. Responsible Person: Lisa M. Berreau Vice President for Research Utah State University 435-797-3509 Anticipated completion date of corrective action plan: Actively in progress and full completion by Jan. 1, 2026.

Finding 2024-003 – Fiscal Management (Material Weakness) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District, and potential refunding of reimbursements received. Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation for each report was not possible because original data was not relied upon by management, to complete the reports and reimbursement requests. Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned. Questioned Cost: No Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities in the form of refunds due to ODOT.  Repeat of a Prior-Year Finding: Yes Recommendation: The District should design and implement internal control policies and procedures for cash management, including fiscal management and financial reporting. Monitoring, information and communication control activities should also be designed and implemented as part of the effort the reduce the risk of continued matters of noncompliance related to cash management. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving these deficiencies has been offered by ODOT and accepted by the Board. Planned Implementation Date: October 31, 2024 Responsible Persons: District Board, Umpqua Public Transit District