Corrective Action Plans

Item 2021.006 – Cash Management Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding Yes Action Taken Island Health Care will take the following actions to address this recommendation: • Prepare written procedures to document the process for Drawdown requests, including the initial review, documented approval proves, submission to the funding agency, and the recoding of the drawdown in the accounting system immediately after submission. • Maintain detailed records of all drawdown requests, supporting documentation, approvals, and correspondence. • Conduct regular internal reviews of drawdown activities to ensure compliance with procedures and maintain audit trail. • Review drawdown procedures annually to ensure they remain current with funding agency guidelines and best practices.

Item 2021.006 – Cash Management Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding Yes Action Taken Island Health Care will take the following actions to address this recommendation: • Prepare written procedures to document the process for Drawdown requests, including the initial review, documented approval proves, submission to the funding agency, and the recoding of the drawdown in the accounting system immediately after submission. • Maintain detailed records of all drawdown requests, supporting documentation, approvals, and correspondence. • Conduct regular internal reviews of drawdown activities to ensure compliance with procedures and maintain audit trail. • Review drawdown procedures annually to ensure they remain current with funding agency guidelines and best practices.

Finding 2021-003: Reconciliation of Accounts Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1524963 (11/1/2015 – 9/30/2021), 1812860 (9/1/2018 – 8/31/2020) Condition: The year-end schedules for federal grants receivable, for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $80,978 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 10/15/2024 Responsible Official: Michael Brosnan, CFO

FINDING 2021-002 – Lack of Written Policies for Federal Grants (Repeated from Prior Year Findings 20-003, 19-004, 18-003, and 17-002) CONDITION: As of April 2021, Regional Office developed, but did not implement written procedures concerning cash management, the determination of allowability of costs in accordance with Subpart E – Cost Principles of the Uniform Guidance and the terms and conditions of the federal award. For the period of July 2020 through March 2021 the Regional Office utilized informal procedures in which each purchase made or cost allocated to the IDEA – Improvement Grant - Part D was reviewed for allowability by an individual with knowledge of the budget, allowable costs and activities, and the cash management requirements. The allowability determinations were based on the amounts included in the budgets for the IDEA – Improvement Grant - Part D approved by, and the grant periods set by, the Illinois State Board of Education. PLAN: The Regional Office has developed written policies and procedures related to the Uniform Guidance. ANTICIPATED DATE OF COMPLETION: Fiscal Year 2021 CONTACT PERSON: Mr. Chris Tennyson, Regional Superintendent for Lee, Ogle, and Whiteside Counties.

Management acknowledges the findings and has implemented a corrective action plan to enhance compliance with Federal awards. This plan includes developing Standard Operating Procedures (SOPs) for grant management activities, identifying and documenting existing internal controls, and maintaining constant communication with stakeholders to prevent material noncompliance. Additionally, PREPA will provide training to staff on the new SOPs and establish a monitoring mechanism to continuously assess and improve the effectiveness of these controls. The corrective action plan, supervised by Mr. Ezequiel Nieves from the PREPA Disaster Funding Management Office, is expected to be completed by July 2025. Management is committed to addressing deficiencies, ensuring that processes and controls are robust and effective, and that Federal awards are managed transparently and in full compliance with all regulatory requirements. Effective June 1, 2021, the Authority transitioned the management and operation of its transmission and distribution network as well as certain back- office functions, including billing, collections and accounting, to a third party. The third-party operator is reviewing operating procedures and controls within its responsibilities to make the necessary improvements. Management will work to address these findings with the assistance of the third-party operators, where applicable. Also, effective July 1, 2023, the Authority transitioned the management and operation of its generation assets as well as certain back- office functions to a third party. The thirdparty operator is reviewing operating procedures and controls within its responsibilities to make the necessary improvements. In addition, the Authority will also be implementing and monitoring corrective actions taken by the new generation segment operator. Contact Name Responsible for Corrective Action Plan - Ezequiel Nieves Estimated Completion Date - July 2025

Finding 2021-003: Reconciliation of Accounts Federal Program: Research and Development Cluster: 47.076 Condition: The year-end schedules for federal grants receivable, for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $73,057 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by April, 30,2024 The remaining balance was earned in 2021. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO

CONDITION: During my sample review of the District’s completion of its federal grant program ‘Quarterly Cash On Hand Reconciliations’ for the 3rd and 4th fiscal quarters for the GEER grant and the 4th fiscal quarter for the ESSER II grant, that the amounts reported to date for ‘total disbursements’ could not be ascertained from the coding of these expenditures in the District’s general ledger (See Finding 2021-005) and did not reconcile to the separate spreadsheets maintained by the School District. CRITERIA: Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance, to allow for the proper completion of the ‘quarterly cash on hand reconciliations’. MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is in the process of revising its chart of accounts in the general ledger to properly reflect the funding source codes for federal program expenditures, and other available funding source codes (state and local) as applicable to the District. It is anticipated that the updated chart of accounts will be utilized by the District starting with the 2024-2025 fiscal year to enable the District to effectively access the necessary federal expenditure totals, by individual grant program, to document and support amounts reported as ‘total cash disbursed’ on the quarterly cash on hand reconciliations. This procedure will enable the District to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations.

CONDITION: The District did not properly record its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs using the various federal 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. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is in the process of revising its chart of accounts in the general ledger to properly reflect the funding source codes for federal program expenditures, and other available funding source codes (state and local) as applicable to the District. It is anticipated that the updated chart of accounts will be utilized by the District starting with the 2024-2025 fiscal year to enable the District to enhance its internal controls for tracking and monitoring federal program expenditures and to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations.

Auditee’s Response and Planned Corrective Action The Authority hired a new Executive Director in November 2023. Under new management, the Authority will maintain proper monitoring, communication and control activities to ensure adherence to the Authority’s key administrative policies including procurement, occupancy and the HCV administrative plan. Additionally, management will have the Board approve all policies and procedures adopted and communicate them with the third party company that manages the Authority’s Housing Choice Voucher and Mainstream Voucher programs. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Kayla Potter, Executive Director

Finding 2021-007 Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Program Director Jacy Hyde, Executive Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Program Director Corrective Action Plan: • Clark Nuber has reviewed the current closing and reporting policies and procedures. Clark Nuber’s proposed updates and revisions will be reviewed and approved by CFSC Management and thereafter implemented by CFSC staff. • CFSC will be considering an automated AP and approval processes through Bill.com or another similar provider to determine whether a provider of this nature will assist in more timely expenditure recognition workflows. • CFSC will update its fiscal reporting policies and procedures to direct that all reports are reviewed by both the grant manager and finance manager to ensure all known expenses are included and that the Schedule of Expenditures of Federal Awards is properly prepared in accordance with the Uniform Guidance. • CFSC will be doing a full review of policies and procedures to ensure they are compliant with GAAP and Uniform Guidance requirements. • The Board of Directors has approved hiring three additional Financial Staff to improve capacity for reporting. Anticipated Completion Date: CFSC will establish and implement the enhanced policies and procedures by the end of Q2 of 2024. CFSC aims to fully onboard additional Finance Staff in Q2 of 2024.

We are working with our Net Suite consultants to correct the historical transactions and on-going system procedures and processes to ensure that the accounting software provides that all financial transactions are properly allocated to programs and properties funded with federal funds.Anticipated Completion Date April 30,2024.Responsible Contact Person-Kathleen Boyce, CFAO.

We concur with the finding. The pandemic caused by the outbreak of COVID-19 disrupted and delayed many accounting and reporting processes during the fiscal years 2020 and 2021 since the Municipality had to shut down operations for various months. Consequently, several projects and tasks calendarized were postponed or delayed, including certain reports and controls required by the Federal Regulations. As of the date of this Corrective Action Plan, the transaction detail of the Disaster Grant costs incurred on fiscal year ending on June 30, 2021 was produced, under alternate methods, from the Finance Department’s accounting system and submitted to the external auditor. Expected Implementation Date: The transaction details applicable to financial statements of fiscal periods ended June 30, 2021 were completed. Transactions detail analysis during the following fiscal years were already completed. Responsible Person: Finance Department Director and Federal Program Director.

We concur with the finding. The pandemic caused by the outbreak of COVID-19 disrupted and delayed many accounting and reporting processes during the fiscal years 2020 and 2021 since the Municipality had to shut down operations for various months. Consequently, several projects and tasks calendarized were postponed or delayed, including certain reports and controls required by the Federal Regulations. As of the date of this Corrective Action Plan, the transaction detail of CDL costs incurred on fiscal year ending on June 30, 2021 was produced, under alternate methods, from the Finance Department’s accounting system and submitted to the external auditor. Expected Implementation Date: The transaction details applicable to financial statements of fiscal periods ended June 30, 2021 were completed. Transactions detail analysis during the following fiscal years were already completed.Responsible Person: Finance Department Director and Federal Program Director.

Controls Over Financial Statement Preparation and Reconciliation Procedures Should be Improved. Corrective action: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards. Person responsible: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration Anticipated Completion Date: June 30, 2024

The Town Manager and Select Board will take the following actions to address finding 2021-006 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 is drafting a new Internal Controls Policy that will address this deficiency. The Select Board will review this draft at their meeting in February or March 2024, edits will be made and then it will be sent to legal for final review before adoption. This policy will include 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.

Policies will be placed and adopted by the agency that meet the UG code. These policies will be placed in the fiscal manual. The fiscal manual will be created by using federal guidelines and by using the DDAP fiscal manual as guidance.

Management Response to Audit Comment # 2021-004 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PERPARATION, PROPER APPROVAL OF DISBURSEMENTS, GRANT CLOSE-OUT PROCEDURES AND REQUIRED REGULATORY REPORTING. POLICIES AND PROCEDURES SHOULD BE IMPROVED LOW INCOME HOME ENERGY ASSISTANCE PROGRAM HEAD START AND EARLY HEAD START PROGRAMS Federal Assistance Listing: 93.568 and 93.600 Responsible Person: G. Keith Williams Anticipated Completion Date: December 31, 2023 / On-Going Corrective Action: The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and fully agrees with the need for improved internal controls over financial statement preparation. Management believes that the proper approval of disbursements was adhered to during the reporting period with minimal deviation and continues to ensure proper policies are followed. Federal reports (SF425’s, LIHEAP) were filed during this period and may not have been properly reviewed during the course of this audit. For example, the LIHEAP reports were reconciled with the assistance of the State Program Specialist to ensure proper return of funds as requested by the funding agency. Management reserves the right to discuss this further as needed for the purpose of this finding. Adequate fiscal personnel staff has continued to be a challenge for the agency as management has done an exhaustive search for additional fiscal personnel and made job offers to qualified individuals only to have them decline the offer at the last moment. We have just offered the position of General Ledger Accountant to an individual and they are expected to start in two weeks. This will assist the CFO in the area of financial controls and reporting. It should also be noted that all bank reconciliations are current and being completed in a timely manner as dictated by our policies and procedures. Management continues to ensure all federal, state, and local and local regulatory reports and completed and submitted in a timely manner. As stated previously, the CFO worked directly with the State LIHEAP Program Staff to ensure proper reporting and reconciliation before returning unused funds.

Training finance staff assigned on management and reports preparation, as required by this federal award. stablish adequate internal control regarding documents, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds. Key Task / Action Items Locate and document all required reports and reconciliations as required. We are implementing a supervision process and instructions will be given to finance’s staff and personnel to increase the ability to search, identify and produce financial documents and reports. Resources Coronavirus Relief Fund (CRF) PHE-Testing and Contact Tracing 2 CFR Section 200.302 (a) of the Uniform Guidance 2 CFR Section 200.403 Puerto Rico Department of Health; Guidelines for the Writing of Proposals and Request for Funds Directed to the Research System Project for the Municipal Case Investigation and Contact Case Investigation and Municipal Contact Tracing System Project Response to COVID-19. Lead Staff Finance’s Director Federal Program Directors Completion date Estimated completion date of December 31, 2023. Actual Completion Date In progress Implementation Progress/Comments The Municipality used the funds in accordance with the proposal and the guidelines established by AAFAF and PR Department of Health for these purposes. Coronavirus Relief Fund (CRF) Public Health Emergency (PHE) (Testing and Contact Tracing). According to the information obtained from Mr. Carlos R. Nazario Barreto, Senior Business Consultant of the SAB Consulting, regarding the compliance of the Municipality, we were provided with the table of the monitoring of the Proposed Municipal System of Investigation of Cases and Tracking of Contact (SMIRC) of the Municipality of Añasco. The referred table of the monitoring of the Proposed Municipal System of Investigation of Cases and Tracking of Contact of the Municipality of Añasco was send to the external auditor as part of this Corrective Action Plan. The detailed table is maintained by the Municipality as part of the federal program supporting documentation. These funds were initially administered and disbursed by former municipal administration personnel. At the time of the audit, we did not find the documents and reports as the files were not available. Following the Auditor's recommendations and as a corrective action, we are currently working on the review of the fiscal documents submitted by the Municipality to determine if there are any reports that need to be worked on and to submit them to AFFAF, PR-OMB or the agencies concerned.

Training finance staff assigned on management and reports preparation, as required by this federal award. Establish adequate internal control regarding the activity, filing and custody of reports, as required by the federal awards and the pass-through entity, and in a way that documents and supports the compliance with reporting requirements Locate and document all required reports and reconciliations as required. We are implementing a supervision process and instructions will be given to finance’s staff and personnel to increase the ability to search, identify and produce financial documents and reports. The Municipality used the funds in accordance with the proposal and the guidelines established by AAFAF for these purposes according to Coronavirus Relief Fund (CRF) Transfer Application Assistance Program to Municipalities. The detailed report, “Assistance Program to Municipalities Program Closure Report-Añasco” dated 4/11/2023 was send to the external auditor as part of this Corrrective Action Plan. The detailed report is maintained by the Municipality as part of the federal program supporting documentation. These funds were initially administered and disbursed by former municipal administration personnel. At the time of the audit, we did not find the documents and reports as the files were not available. Following the Auditor's recommendations and as a corrective action, we are currently working on the review of the fiscal documents submitted by the Municipality to determine if there are any reports that need to be worked on and to submit them to AFFAF, PR-OMB or the agencies concerned.

2020-012 Financial Statement Reconciliations/Tie-In Procedures Material Weakness Recommendation: The Housing Authority should adopt written reconciliation and tiein 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.

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.

FINDING 2020-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities – Reporting Summary of Finding: The Town did not prepare or file the required reports, submit financial data on other forms, or submit an annual audit in lieu of the forms to the USDA. As such, there was no evidence to substantiate the financial operations or the financial status of the project. Contact Person Responsible for Corrective Action: Bobbi Elston (Clerk-Treasurer) Contact Phone Number and Email Address: (260) 433-4800, 104 Allen St, Monroeville, IN 46773 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Town will implement internal controls over the reporting compliance requirement related to the Water and Waste Disposal Systems federal program based on the State Board of Accounts Uniform Internal Controls Standards for Indiana Political Subdivisions. This will include involving the Town Council to assist in verifying the Town has met reporting requirement. Anticipated Completion Date: January 1, 2025

We are in the process of reviewing all aspects of the department’s policies and procedures. The Kohala Center will provide training to adhere to the updated policies and procedures as it relates to the appropriate guidelines to ensure compliance with the requirements in accordance with 2 CFR 200, Subparts D and E. The Kohala Center has already began providing training to enhance the knowledge of Federal requirement as it relates to programs. We are improving our procedures related to the validation of expenses to ensure all cost have the proper supporting documentation before being allocated and paid.

Finding 2020-003: Reconciliation of Accounts Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023) Condition: The year-end schedules for federal grants receivable, for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $73,057 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by April, 30,2024 The remaining balance was earned in 2021. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: October 15, 2024 Responsible Official: Michael Brosnan, CFO

The Organization estalished polocies regarding boththe receipt of advances in accordance with 2CFR Section 200.302 and the documentation of communications regarding this area.