Corrective Action Plans

2023-012-Subrecipient Monitoring Suggested Action: Enhanced contractual requirements that ensure greater subrecipient monitoring around greater support for any requests or assertions from our subrecipients. Responsible Official: Chief Operations Officer Completion Date: 6/30/2026

VIEWS OF RESPONSIBLE OFFICIALS In response to the single audit finding we will take the following actions. We will establish internal controls that provide certainty, effective monitoring data validation and accountability for those employees who approved expenditures. We will prepare written process in accordance with both state and federal regulations. We will prepare written process in accordance with both state and federal regulations. We will require relevant staff (Staff interacting with procurement, expenditures approval) a comprehensive training program on the requirements of CFR 200. IMPLEMENTATION DATE September 30, 2026 RESPONSIBLE PERSON Ivan Rentas, President

2023-012 Financial Statement Reconciliations/Tie-In Procedures Material Weakness Recommendation: The Housing Authority should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. These policies should require timely reconciliations to take place as defined under policy. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

Cash Management The College acknowledges the finding and will enhance its cash management practices by developing formal procedures outlining responsibilities, authorization requirements, and timelines related to federal drawdown and disbursements. In addition, the College will implement routine reconciliations of drawdown activity against recorded expenditures on a monthly or quarterly basis to improve monitoring and ensure compliance with federal requirements.

Recommendation We recommend that management: ▪ Implement procedures requiring complete supporting documentation for all costs charged to federal awards ▪ Ensure costs are reviewed for allowability, reasonableness, and allocability prior to recording ▪ Establish and document formal cost allocation methodologies ▪ Require approval and documentation of all journal entries affecting federal programs ▪ Provide training to staff on Uniform Guidance cost principles (2 CFR 200 Subpart E) ▪ Conduct periodic internal reviews to ensure compliance

"Recommendation We recommend that management: ▪ Implement formal procedures to ensure complete documentation of all program activities ▪ Maintain records demonstrating that activities are authorized and aligned with program objectives ▪ Establish centralized recordkeeping and retention policies ▪ Perform ongoing monitoring and review of program activities ▪ Train staff on federal compliance requirements and documentation expectations"

The City of Cascade Locks has an allowable cost procedure that was approved by Council on March 26, 2026. The City Administrator is responsible for adhering to this policy.

CORRECTIVE ACTION PLAN (Concerning Finding 2023-006) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Town Manager and Select Board will take the following actions to address finding 2023-006 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted, had approved and has implemented the new Internal Controls Policy that addresses this deficiency. This policy will includes sections on risk assessment and management, annual audit, chart of account, general ledger, reconciliation and verification, reserve funds and reserve accounts, investments, financial reporting, fraud, accounting software, online transactions and banking, documentation daily cash-ups, grants and projects, AR process, AP process, and payroll. Anticipated Completion Date: This was completed February 20, 2024.

Corrective Action Plan: Addressing Lack of Controls Due to Staffing Shortages Organization: Safe Harbor Crisis Center Date: December 3, 2025 Audit Finding: 2023-001 Non-Material Non-Compliance – Allowable Costs and Activities Corrective Actions: This plan outlines the steps to address the staffing shortage and implement necessary controls to ensure financial statement accuracy and compliance. Phase 1: Immediate Actions Prioritize Key Hires: The immediate priority is to recruit and hire a Controller with significant non-profit accounting experience. This individual will be crucial in designing and implementing the necessary internal controls. 1. Interim Support (If Needed): While searching for permanent staff, explore options for interim accounting support through a consulting firm or temporary staffing agency specializing in non-profit organizations. This can provide immediate assistance with critical tasks and help bridge the gap until permanent staff are in place and sufficiently trained. 2. Documented Job Descriptions: Develop detailed job descriptions for the Controller, Senior Accountant, and Staff Accountant positions. These descriptions should clearly outline the required qualifications, responsibilities, and reporting lines. Emphasis should be placed on experience with non-profit accounting principles (GAAP), fund accounting, and relevant regulations. 3. Recruitment Strategy: Implement a robust recruitment strategy that includes: ○ Posting job openings on relevant job boards (e.g., Idealist, LinkedIn, specialized non-profit job sites). ○ Networking with professional organizations (e.g., state non-profit associations, accounting professional groups). ○ Partnering with recruitment agencies specializing in non-profit finance. Phase 2: Staffing and Implementation 1. Hire Controller: Complete the recruitment process and hire a qualified Controller with proven non-profit accounting experience. 2. Hire Senior Accountant: Once the Controller is in place, begin the recruitment process for a Senior Accountant to support the Controller and manage day-to-day accounting operations. Experience with fund accounting and grant management is highly desirable. 3. Hire Staff Accountants: Recruit and hire the necessary number of Staff Accountants to handle transaction processing, reconciliations, and other accounting tasks. 4. Control Design and Implementation: The Controller, in collaboration with the Senior Accountant, will be responsible for designing and implementing the necessary internal controls. This includes: ○ Segregation of duties (e.g., authorization, custody, recording). ○ Approval processes for expenditures and journal entries. ○ Regular reconciliations of bank accounts and other key accounts. ○ Documentation of accounting policies and procedures. Phase 3: Review and Monitoring (Ongoing) 1. Training: Provide comprehensive training to all finance staff on non-profit accounting principles, internal controls, and the organization's specific policies and procedures. 2. External Review (Optional): Consider engaging an external accounting firm to review the implemented controls and provide recommendations for improvement. This can provide an independent assessment of the effectiveness of the controls. 3. Regular Monitoring: The Controller will be responsible for regularly monitoring the effectiveness of the internal controls and reporting any deficiencies to the Executive Director and the Board of Directors. 4. Policy Updates: The Controller will ensure that accounting policies and procedures are reviewed and updated regularly to reflect changes in regulations and best practices. Responsible Parties: ● Executive Director (Todd Hixson) : Overall responsibility for implementation of the plan. ● Board of Directors: Oversight and approval of the plan and budget. ● Controller: Responsible for designing, implementing, and monitoring internal controls. Timeline: Phases 1 and 2 were completed as of January 2025. As noted above, phase 3 is an ongoing process. Regular progress updates have been and will continue to be provided to the Executive Director, Finance Steering Committee, and the Board of Directors as appropriate. This Corrective Action Plan demonstrates Safe Harbor Crisis Center’s commitment to addressing the identified control deficiencies and strengthening its financial management practices. By implementing this plan, the agency will be better positioned to ensure financial accountability, transparency, and compliance in service of the mission.

2023-005 Indirect Cost Rate Agreement (NICRA) Recommendation: Auditors recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed. Specifically, auditors recommend that CIES modify internal controls to include a review and approval process for submission of all invoices submitted to grantors, including showing the indirect cost rate calculations. Criteria: 2 CFR 200.414(c) – Federal award recipients must negotiate an indirect cost rate with the cognizant agency for indirect costs, which is typically the federal agency that provides the most funding to the recipient. 2 CFR 200.403(d) – The negotiated rate must be applied consistently across all federal awards to ensure uniformity in cost allocation. 2 CFR 200.302(b)(3) – Recipients must maintain adequate documentation to support indirect costs charged to federal awards, ensuring compliance with the cost principles outlined in the regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Project invoices will be prepared by a member of the CIES administrative staff with enough details to show direct and indirect cost rate calculations. Invoices will be reviewed and approved by either the Chief Operations Officer or the Executive Director. Review and Signature approvals will be added to all invoices to meet the criteria identified in this finding. Name(s) of the contact person(s) responsible for corrective action: Michael Parker, Executive Director Planned completion date for corrective action plan: April 2026

FINDING 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Required IDOE templates (JotForm) are completed using AS400 budget detail reports and Position Control data, with revisions submitted during the September window to correct classifications and remove ineligible set-aside amounts. Adjustments were made to align ESSER I reporting and to avoid timing discrepancies by using budget detail rather than summary reports. The completed report will be reviewed for accuracy and approved prior to submission. Beginning in fall 2023, the reimbursement process was updated to include all required supporting documentation, such as transaction detail and summary reports. Each request is also reviewed and signed by the supervisor to document approval. On a recurring basis, the Director of Federal Grants generates the detailed expenditure report and budget summary. The detailed report is filtered to capture only the transactions occurring since the previous reimbursement request, making new expenditures easy to identify. These amounts are added to the cumulative reimbursement totals, which are then compared to the total disbursements shown on the summary report to ensure they align. Once the totals match, the reimbursement request is reviewed by the Chief Financial Officer and submitted to the awarding agency. Completion Date 6/30/25

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Beginning in fall 2023, reimbursement requests have included all required supporting documentation, such as transaction detail and summary reports. Each request is also reviewed and signed by the supervisor to document approval. On a regular basis, the Director of Federal Grants will generate the detailed expenditure report and budget summary. The detailed report will be filtered to capture only the transactions occurring since the previous reimbursement request, making it easy to identify new expenditures. These amounts will be added to the cumulative reimbursement totals. The updated total will then be compared to the total disbursements shown on the summary report to ensure they align. Once the totals match, the reimbursement request will be reviewed by the Chief Financial Officer and subsequently submitted to the awarding agency. Correction Date 06/30/2025

FINDING 2023-005 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Earmarking All expenditures related to parental involvement are tracked using a designated expenditure code. The required homeless set-aside is monitored using department-level data. The same expenditure code is applied to both the mandatory parental involvement set-aside and any additional parental involvement funds. This allows the district to track the spend-down of the mandatory set-aside and determine how much must be carried over into the next grant year. Schools are expected to use the mandatory set-aside funds first, following a FIFO (first-in, first-out) approach, before accessing any parental involvement funds beyond the required amount. We are actively coordinating with the homeless liaison to ensure that fund balances remain current and transparent to all stakeholders. This collaboration supports more effective planning and helps ensure that the funds are spent down appropriately and on schedule. Correction Date 6/30/2025

FINDING 2023-002 Finding Subject: CDBG - Entitlement Grants Cluster - Program Income Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 brownta@lakecountyin.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This same finding was part of the 2022 audit in Finding 2022-003. The department was aware that this same finding would be arising in the 2023 audit again due to multiple year errors of previous staff. The corrective action plan proposed and adopted as part of the Corrective Action Plan for finding 2022-003 is still in force and is working to eliminate such findings in the future. The Lake County Redevelopment Commission adopted Resolution 001-2025 on January 16th, 2025 amending the Policy and Procedures Manual of the Department concerning Program Income (PI) internal controls for proper reporting in the IDIS system to address and correct the finding going forward. Anticipated Completion Date: Done

Colfax County agreed to be the fiscal agent for a collaborative project involving several state and federal agencies within NM, CO, and KS along with private corporations including BNSF and AMTRAK. Colfax County did not have the staffing or cash flow necessary to facilitate such a large project. County Manager and Financial Specialist were not trained in Railroad project management. Changes in staff within the County Manager’s Office and private corporations as well as state and federal agencies resulted in change in requirements, poor communication, and delay in reporting ultimately resulting in disruption of reimbursement to the County. Colfax County worked with NM Department of Transportation and Federal Railroad Administration to collect project status information and submit all outstanding progress reports. To date Colfax County has been successful in maintaining open communication and receiving support from NMDOT and FRA. All reporting requirements are current and reimbursement has been issued to the County.

The department will adopt written policies with the Uniform Guidance for Federally Funded Grant Programs accepted by the department.

2023 – 005: Reporting (Compliance; Internal Controls Over Compliance) (Repeat Finding: 2021-005 and 2022-005) Material Weakness – 93.U01 Title V Condition: The Organization was unable to provide any of the required reports for the Title V program, including the financial report, activity narrative, third-party income report, GPRA/GPRAMA, urban data standards, and property inventory. Without these reports, we were unable to perform the necessary audit procedures to assess compliance with federal requirements. Corrective Action Plan: As of October 1, 2024, the start of FY25 QuickBooks has been the only software used and Revenue and Disbursements are being classed by Fund. General ledgers are reconciled monthly. Management has implemented procedures and training to assure financial report, activity narrative, third-party income report, GPRA/GPRAMA, urban data standards, and property inventory are completed and retained.

2023 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance) (Repeat Finding: 2021-004 and 2022-004) Material Weakness – 93.U01 Title V Condition: The Organization was unable to provide sufficient documentation to support compliance with federal procurement and suspension and debarment requirements for purchases made under the Title V program. The general ledger did not allow for sufficient identification of transactions related to the Title V program as all expenditures were recorded through journal entries without supporting transaction-level detail. Due to this limitation, we were unable to select procurement transactions for testing or verify whether vendors had been screened for suspension and debarment before contracts were awarded. Corrective Action Plan: As of October 1, 2024, the start of FY25 QuickBooks has been the only software used, and Revenue and Disbursements are being classed by Fund. General ledgers are reconciled monthly. The following are updated procedures that are now in place: All purchases must come with a purchase order request and be signed by the supervisor prior to purchase. All purchases over $1,000 must be CEO approved too. All purchases over $5,000 must have 3 bids and be Board approved. All purchase orders must be completed completely in all fields to know what grant/funding source is covering the cost for draw downs. Anyone who uses the SDUIH credit cards must sign a credit card statement. Vendor suspension and debarment status will be verified and documented prior to awarding federally funded contracts.

2023 – 003: Activities Allowed and Unallowed, Allowable Costs, Period of Performance (Compliance; Internal Controls Over Compliance) (Repeat Finding: 2021-003 and 2022-003) Material Weakness – 93.U01 Title V Condition: The Organization’s general ledger did not allow for sufficient identification of transactions related to the major program, Title V. Title V expenditures were recorded through journal entries without supporting transaction-level detail. Because of this, the population of expenditures could not be tied to individual transactions, and pulling samples from this population would not provide a reasonable basis for drawing conclusions about the population tested. As a result, we were unable to select transactions for testing or perform the necessary audit procedures to assess compliance with federal requirements. Corrective Action Plan: As of October 1, 2024, the start of FY25, QuickBooks has been the only software used, and Revenue and Disbursements are being classed by Fund. General ledgers are reconciled monthly. Management is strengthening documentation and recordkeeping procedures to ensure compliance with federal record retention requirements, including improved tracking of Title V expenditures and retention of transaction-level support.

Contact Person – Benjamin Schafer, Executive Director Corrective Action Plan – Training will be provided for all employees involved with the grant if the Cooperative receives a similar grant in the future. Completion Date – As needed.

View ofResponsible Officials and Planned CorrectiveActions:Managementacknowledges this findingrelated to federalaward financialmanagementduringfiscalyear 2023.Drawdownswere previouslymanaged by theorganization’s externalaccounting firm,and internalreviewbystaffnolongerwith theorganization was notsufficiently consistent.These issues were a keyfactorin management’sdecisionto endtherelationship with theprioraccounting firm. We transitioned all drawdown and reimbursement responsibilities internally. We required management review and initialing of all drawdowns prior to submission. We implemented standardized reconciliation processes tying drawdowns to the general ledger by reporting period. We retained all drawdown support directly within QuickBooks to document how totals were calculated. We developed grant-specific allocation roadmaps. We established a centralized grant file system for all federal financial documentation. We engaged a new accounting firm for compliance support and oversight. All drawdowns and reimbursements are reviewed and approved by the Executive Director prior to submission, with ongoing oversight from the accounting firm. Corrective actions have been implemented and are operating on an ongoing basis.

FINDING 2023-004 – Cash Management: Significant Deficiency over Internal Controls over Compliance Condition/context – The Organization draws down funds based on a profit and loss report to signify the excess expenses incurred over the grant revenue. The Organization identifies themselves as on the reimbursement method. The request for reimbursements are not reviewed to ensure amounts have been paid with the Organization’s funds prior to the reimbursement request because certain expense codes do not relate to expenses paid but rather expenses incurred. Additionally, the frequency of draws during mid-months creates potential for errors when the reporting period has not been reconciled and therefore coded expenses are subject to change. Corrective Action Plan: Policy & Procedure adjustments within Cash Management: • Reimbursement requests will be based solely on expenditures that have been paid using the Organization’s funds. • Financial reports used to prepare draw requests are reconciled to ensure expense coding accuracy. • Expense codes distinguish clearly between paid and accrued expenditures. • Mid-month draws are avoided or subject to additional reconciliation controls prior to submission. Name of Contact Person: Chris Flaherty, Chief Executive Officer 707.890.6491 Laura Williams, Chief Financial Officer 707.335.0010 Projected Completion Date: December 31, 2026

The City will work to ensure all reports for grant funding are completed.

The City has will develop written procedures for determining the allowability of costs in accordance with 2 CFR 200, Subpart E—Cost Principles and the terms and conditions of the Federal award.

The City will develop written procedures to implement the requirements of 2 CFR § 200.305 Payment.