Corrective Action Plans

Management agrees with the finding. Our current federal project is substantially completed, however, should the Township receive additional federal grants, the Township will adopt the required written procedures. The anticipated completion date is prior to receiving another federal award.

Responsible Party: JCCS PC & Sara Hudson Anticipated Completion Date: February 29, 2024 Corrective Action Plan: For the fiscal year ending June 30, 2023, the organization prepared a draft of the SEFA with the intent of finalizing it with the assistance of the auditor. We were unaware this would result in a finding in the audit. The organization will work with JCCS PC going forward to independently prepare the annual SEFA.

Additional preventive internal control procedures will be implemented, including an additional level of review of the reimbursement requests prior to submission. These procedures and internal controls have been implemented as of the date of this report.

Views of Responsible Officials: During our FY22 audit, GRF expressly noted that for an organization our size, tracking grant expenses outside of Quickbooks was understandable and acceptable. During this FY23 audit, GRF changed its stance and said we had to report grant expenses in Quickbooks. This should be removed as a finding, as District Bridges was following the advice of GRF from the FY22 audit. It is unconscionable to discredit an organization after they followed the firm's advice. Additionally, over the last few months, we have consulted several other nonprofit finance experts, as well as peer organizations that receive federal funds, to see tracking templates and procedures, and understand best practices. We are currently exploring more robust grant expense tracking softwares based on their recommendations, but they all noted that spreadsheet tracking was acceptable for an organization of our size.

MANAGEMENT WILL WORK WITH THEIR CONSULTANT AND DEVELOP WRITTEN POLICIES AND PROCEDURES OVER THEIR FEDERAL AWARDS IN ACCORDANCE WITH THE REQUIREMENTS OF THE UNIFORM GUIDANCE

Item 2023‐002 Written policies, procedures, and standards of conduct Recommendation: Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non‐Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: § 200.302 Financial management  § 200.305 Payment  § 200.319 Competition  § 200.320 Methods of procurement to be followed  § 200.430 Compensation—personal services  § 200.431 Compensation—fringe benefits We recommend that the City implement the required written policies and procedures. Action Taken: Management, namely Jan Boutwell, City Clerk, agrees with the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2024.

The Office of the State Superintendent (OSSE) agrees with the conditions and recommendations of this finding. The OSSE corrective action plan includes the following: • The OCFO budget team will ensure that every budgeted federal award has a corresponding equivalent Federal Notice of Grant Award (NOGA). • Grant reconciliations done to determine carryover balances and subsequent budget modifications will incorporate cash as well as accrued expenditures. • Quarterly financial reviews will be conducted to properly review and support expenditures. • During the year-end close process, the accounting team will compare total awarded amount and total expenditures. Contact - Keith Fletcher, Agency Fiscal Officer, OSSE, Crosby Boyd, Controller, Education Cluster Estimated Completion Date - February 1, 2025 See Corrective Action Plan for chart/table

The Department of Human Services (DHS) OCFO concurs with the finding. Expenditures were inadvertently categorized to the incorrect fund. Moving forward, a meeting will be scheduled with the HSSC Comptroller, the Accounting Officer, the AFO and the Budget Staff for a detailed review and walk through of the SEFA to confirm the expenditures are correctly categorized by fund and grant, and expenditures reconcile to reports from the financial system. Contact - Barbara Roberson, Accounting Officer Estimated Completion Date - September 30, 2024 See Corrective Action Plan for chart/table

Federal Aid Policies Finding 2023-002 Auditor Description of Condition and Effect: The Authority’s management has completely turned over and been restructured. However, the Authority’s policies for federal aid approved in 2021 have not been revised to update for the current management structure. The policies have also not been updated for changes in the 2 CFR 200 that have occurred. As a result, the Authority is noncompliant with 2 CFR 200. Auditor Recommendation: We direct the Authority review and update all federal aid policies and implement procedures to ensure that they are being reviewed at least once a year for changes in the Authority’s management structure or changes that occur in the 2 CFR 200. Corrective Action Plan: The Authority will update their federal policies to comply with 2 CFR 200 and will review all policies on an annual basis going forward. Responsible Official: Contact person is Rufus Adams, Executive Director,275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. Due Date: September 30, 2024

2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: December 2024 Management’s Corrective Action Plan NGA has begun to produce quarterly versions of the Statement of Federal Awards (SEFA). This routine process has enabled staff to proactively identify new awards and lapsed agreements to keep the SEFA current. Given the importance of this schedule to NGA’s continued management of federal funds, we have emphasized and trained staff to follow all applicable federal requirements when managing funds on this schedule. We expect our action plan to continue until December 2024 as we have encountered several issues this fiscal year that required reconciliation of prior years.

Finding 2023-023 Pandemic EBT Food Benefits, ALN 10.542 - Accuracy of Financial Reports Management Views MDHHS agrees with the finding. Planned Corrective Action The Food and Nutrition Service has ended the P-EBT program and there will be no additional expenses after February 2024. However, for the last report submitted during May 2024, MDHHS implemented a report review process prior to certification to ensure the P-EBT financial report information is accurate. Anticipated Completion Date Completed Responsible Individual(s) Bethany Cabanaw, MDHHS

All Final Expenditure Reports will include the appropriate expenditure amounts associated with the grant year.

We agree with the finding and provide below the corrective action plan. Corrective action plan: We will provide additional training to staff responsible for tracking federal and state awards and utilize another member of management to review and approve the grant tracking spreadsheets routinely. Additionally, reconciliations will be performed monthly between the grant spreadsheets and the financial reporting software.

Views of Responsible Officials: As of 6/1/2024, NEW's accounting has been outsourced and a new accounting system will be utilized.

Views of Responsible Officials: As of 7/1/204, NEW's accounting has been outsourced and a new accounting system will be utilized. The accounting department has been restructured to ensure accounts are properly reconciled each month.

Action Taken: Management agrees with the finding and adopted the appropriate policies and procedures in December 2023.

Recommendation: We recommend that the Organization should ensure that program managers compare all program reports to the reporting requirements within the grant documents to ensure all quantitative and qualitative information is appropriately included prior to submittal to the oversight Organization. Views of responsible officials: There is no disagreement with the audit finding.

Condition: The District overstated their claim by $302. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: 6/30/2024. Name of Contact Person: Justin Whitten, Business Manager. Management Response: Management will work together with staff to ensure that grant budgets are periodically reviewed and amended as necessary.

Finance staff will review grant budget simultaneously as costs are invoiced for reimbursement. Additionally, Finance staff will receive training on grant budgeting including federal grant regulations and requirements. Expected completion date: July 2024

The Council will move to the Time & Effort method of reporting to allow employees to sign off on their time allocation for each pay period which will subsequently be approved by the supervisor and Executive Director. Expected completion date: May 2024

Health Center Infrastructure Support Financial Reporting Management’s Views and Corrective Action Plan Management’s View and Opinion Sunset Park agrees that the Federal Financial Reports (FFRs) were filed on a cash basis, however the accrual method was selected in error. Corrective Action Plan Sunset Park is dedicated to upholding full compliance with all federal regulations and guidelines. Sunset Park will contact the funding agency's Project Officer and Grants Management Specialists to verify Sunset Park’s understanding of federal reporting standards and the specific reporting requirements for equipment expenditures on the FFRs. This verification will ensure clarity and adherence to federal guidelines, including distinguishing between cash and accrual basis reporting requirements. Sunset Park will also implement enhance its control procedures to ensure that FFRs submitted are reconciled to the underlying accounting records. Timeline for Action Plan Date of Completion: 08/31/2024 Responsible Individual Leonardo Arias Email: Leonardo.Arias@nyulangone.org

2023-002 Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: We recommend the County establish internal control procedures to ensure that all amounts charged to grant programs for employee payroll costs be reconciled to the specific employee payroll records and that supporting documentation be maintained throughout the grant award period and beyond. Views of responsible officials: Management concurs with the finding. There were minimal variances in the number of employees tested and the County believes the wage report discrepancies are isolated due to the complexity of the EMS salary structure. The County claimed $26,038,852 of the $37,618,256 total eligible expenses available. Action planned/taken in response to finding: Effective fiscal year 2024, Management will implement the following corrective action: The County will create a process to ensure the payroll wage reports generated by Human Resources agrees to support documentation. Name of the contact person responsible for corrective action plan: Pete Winton Planned completion date for corrective action plan: The above action plan will be implemented in fiscal year 2024.

Recommendation: Internal controls over reporting should be designed, implemented, and documented to ensure compliance with 2 CFR section 200.302(b)(2), including who is responsible, what they are reviewing for, when reviews are to take place, and how documentation of the controls will be maintained. The general ledger should be set up to properly capture and track expenses as well as budgets prepared and approved with the actual costs expected to be incurred. Reports should be reconciled to the general ledger. Budgets should be complete and include all line items and not just include all expenses under supplies. Ac􀆟on Taken: This is a project Finance team is currently working on. The new Compliance Director will manage the grant writing process. During the grant and award process, Compliance, the Program with award, and Finance will establish an appropriate budget which, in turn, will be reflected in general ledger and monitored by the team. The contact persons responsible for this corrective action plan are Alan Branch, Sr VP of Compliance and Workforce Development, the new Compliance Director, Wendi Speed, CFO, and the entire Finance Team. The anticipated completion date is June 30, 2025.

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, 2024

Person Responsible: Chief Operating Officer, Deirdre Bagley, will coordinate with the finance team Implementation Date: By August 30, 2024 Management’s response: In response to the recommendation that the Organization properly apply allowed indirect cost rates across its Federal awards, we concur with the recommendation and are in the process of creating a single, succinct schedule and the supporting documentation on indirect cost rates and rationale to allow the auditors to easily verify that the costs have been charged appropriately.