Corrective Action Plans

2022‐009 Cash Disbursements (Material Weakness) Recommendation: We recommend policies and procedures over the segregation of duties between the accounting and banking functions be strengthened. In addition, policies and procedures should be implemented to ensure support for expenditures is retained and includes evidence of approval. Additional oversight should be provided by those charged with governance. Action Taken (Unaudited): Management has updated its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. Dan Watkins is responsible for this corrective action. Implementation of updated policies was completed November 2024. Accounting and banking functions are segregated.

2022‐008 Grant Expenditures (Material Weakness) Recommendation: The Organization’s accounting system should be modified to accommodate expense tracking by individual grant and policies and procedures should be implemented to require direct expenses be assigned to specific grants. A method should be established to allocate indirect costs in accordance with federal regulations. Policies and procedures are also needed to provide appropriate oversight of all grant accounting including reporting. Action Taken (Unaudited): Management has updated its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. Dan Watkins is responsible for this corrective action. A review process and coding within the accounting system was completed in January 2025. All invoices and staff time are evaluated for the level of effort towards each grant.

2022 – 005: Reporting (Compliance; Internal Controls Over Compliance) 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 so this should take care of this issue. Management has worked on procedures and training to assure financial report, activity narrative, third-party income report, GPRA/GPRAMA, urban data standards, and property inventory are completed.

2022 – 004: Procurement and Suspension and Debarment (Compliance; Internal Controls Over Compliance) 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 uused,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 $1000 must be CEO approved too. All purchases over $5000 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

2022 – 003: Activities Allowed and Unallowed, Allowable Costs, Period of Performance (Compliance; Internal Controls Over Compliance 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.

The funds from the project came from several different grant sources. Bills were due and our consultant DLZ advised us on how to pay these bills even if they were paid from grants other than from the correct grant sources.

View of Responsible Officials and Corrective Action Plan The excess drawdown may have occurred due to the carry fund balance being included as a debit balance on the trial balance during review of drawdown expenses and not adjusted to reduce the amount of the drawdown(s). The error was discovered when the Accounting Manager was in the process of preparing the SEFA schedule. The Accounting Manager disclosed this error to the auditor during the course of the audit. Corrective Action Plan Timeline AAIHB will consult with the Program Manager and awarding agency to determine the appropriate resolution of the excess drawdown within 30 days. AAIHB finance office has a process in place of reviewing drawdowns and monitoring expenses as grants approach the end of the project funding period. Designation of Employee Position Responsible for Meeting Deadline Accounting Manager and Finance Director

Management concurs with the finding and will implement a proper expenditure reporting process, reconciled monthly, to avoid recurrence during future audits.

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 2022-003 Information on federal program: Subject: Water and Waste Disposal Systems for Rural Communities - Reporting Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.760 Federal Award Number: 92-02 92-03 Pass-Through Entity: N/A Compliance Requirements: Reporting Audit Findings: Significant Deficiency Condition: The City did not have proper controls in place to ensure that the annual report was accurately filled out and agreed to underlying detail. Context: Variances to key line items were noted when comparing the Form RD442-2 and Form RD442-3 to supporting documents. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will ensure that reports agree to underlying detail. Responsible Party and Timeline for Completion: The Clerk-Treasurer is the responsible party. The completion will go into effect during 2025.

Management’s Planned Corrective Action: Disagree: We have established a cost center or “Department” for each federal program that clearly identifies federal expenditures. Our funders request monthly copies of receipts and payment issued to verify expenses. Responsible Party: Beaulieu Accountancy Corporation, Accountant Completion Date: 9/25/2024

NMC has formal internal controls and policies and procedures for cash drawn downs. Our drawn downs are not on a reimbursement base, but advance basis. Funds were drawn down to pay the invoice in question. The mobile unit was being repaired, and when we notified it was ready to be picked up the funds were drawn down. Once we were at the vendor to pick up the unit, it was discovered that it had not been properly repaired. The funds were not given to the vendor until the unit was properly repaired. We held the funds until such time.

Finding no.: 2022-003 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: The SEFA was assigned to be prepared internally, but unfortunately was not submitted due to staff turnover during the course of the audit. This oversight will be corrected by improving procedures around internal task assign-ments when employee turnover is experienced in the Fiscal department during the course of the audit. Anticipated completion date: December 2023

ORCCA is aware of the lack of documentation and internal control during the audit period due to various reasons, mainly short staffing and staff turnover, and has been working hard to prevent such occurrences. The Finance staff (Finance Director, Accounting Manager, Program Fiscal Compliance Coordinator) have already started communicating with program directors if any such issues are observed. Responsible party: Bonnie Foroudi, Finance Director Estimated completion date: December 31, 2025

RECOMMENDATION: The School should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. Action Taken: The School agrees with this finding and will implement this recommendation within 120 days of this audit report.

2022-002 – Internal Control Over Compliance Auditee’s Response and Planned Corrective Action The Authority is now under the management of the Quincy Housing Authority and all controls and processes have been updated to account for the needs of the Holbrook Housing Authority, including internal controls over financial reporting, documentation retention, and timeliness of reporting. Planned Implementation Date of Corrective Action: June 30, 2024 Person Responsible for Corrective Action: James Marathas, Executive Director

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Jessica Martinez, Deputy Director Joel Rusco, Chief Financial and Administrative Officer Corrective Action Plan: In response to FY21 Corrective Action Plan, CFSC implemented an updated Reporting Policy in June 2024 to strengthen internal controls prior to review and submission of invoices and drawdown/payment requests to funders. To ensure further compliance with 2 CFR 200.414(c), 2 CFR 200.403(d), and 2 CFR 200.302(b)(3), CFSC will implement the following corrective actions: 1.Verification of Indirect Cost Rate Before Submission: a.CFSC will require that all invoices, including indirect costs, be reviewed by the CFAO to confirm that the rate used is in accordance with an approved provisional or final NICRA agreement. b.Any invoice for federal funding lacking an approved indirect cost rate will be flagged and returned for correction before submission. 2.Pre-Submission Approval Process for Invoicing Indirect Costs: a.All invoice requests containing indirect costs must be reviewed and approved by the CFAO prior to submission. b.The Finance Department will verify and document that the rate applied is consistent across all federal awards and matches the NICRA. 3.Indirect Cost Rate Agreement Tracking & Documentation: a.CFSC Finance will establish an Indirect Cost Rate Agreement tracker to ensure that: i.All provisional and final indirect cost rate agreements are maintained on file. ii.Indirect cost rates used on invoices are consistently aligned with approved agreements. 4.Quarterly Internal Audits of Indirect Cost Rate Compliance: CFSC Finance Department will conduct quarterly reviews of a sample of drawdown/payment request invoices to confirm: a.The correct indirect cost rate was applied b.The rate was consistently applied across all federal awards Anticipated Completion Date: These corrective actions will be fully implemented by the end of Quarter 2 of FY25

The City has identified federal grants subject to the Uniform Guidance and 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 has identified federal grants subject to the Uniform Guidance and will develop written procedures to implement the requirements of 2 CFR § 200.305 Payment.

FA 2022-004 Strengthen Controls over Financial Reporting Compliance Requirement: Reporting Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: SO10A200010 (Year: 2021) SO10A210010-21A (Year: 2022) Questioned Costs: $37,644 Description: The School District did not file accurate completion reports for the Title I Grants to Local Educational Agencies program. Corrective Action Plans: District office has put procedures in action to make sure that all drawdowns are in line with expenditures. All draw down packets will be viewed and signed off by federal program director. This packet will include detail expenditure sheet for the month, year to date expenditure report and a cover sheet. Estimated Completion Date: December 31, 2024 Contact Person: Terrance H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

FA 2022-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: SO10A200010 (Year: 2021) SO10A210010-21A (Year: 2022) Questioned Costs: None Identified Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund, COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D210012 (Year: 2021) S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Finding: FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and School Emergency Relief Fund programs. Corrective Action Plans: District office has put procedures in action to make sure that all drawdowns are in line with expenditures. All draw down packets will be viewed and singed off by federal programs director. This packet will include detail expenditure sheet for the month, year to date expenditure report and a cover sheet. Estimated Completion Date: December 31, 2024 Contact Person: Terrance H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

Management acknowledges the issue and will establish and document reconciliation procedures to  ensure reports are consistent with the general ledger and trial balance for all future Federal programs.  This includes periodic review and approval by management.

The organization has established financial policies and procedures. However, we recognize that these policies do not fully address all areas specific to federal grant requirements. As a relatively new organization, we understand the importance of enhancing these frameworks to ensure full compliance with federal guidelines and properly manage federal funds. We are committed to addressing this gap and will take immediate action to develop and implement comprehensive policies and procedures that fully comply with all applicable federal grant requirements. We anticipate that this process will be completed within three months, with oversight from senior management to ensure its thoroughness and effectiveness. In addition, key financial processes, including disbursements, payroll, and grants management, will be updated and aligned with these new policies to ensure sound fiscal management and maintain ongoing compliance with federal standards

Finding 2022-001: The Central Alabama Regional Planning & Development Commission (the Commission) will develop a grants manual or additional written policies to incorporate all the requirements of 2 CFR 200 and ensure compliance with grant requirements.

Action Taken: Management is in the process of instituting additional procedures to ensure all awards are assessed not only to identify whether sources of funds are Federal, requiring inclusion on the SEFA, but also to identify continuing compliance period when applicable. Management has also conducted internal training relative to applicable 2 CFR 200 regulations and requirements and will continue to provide periodic staff training to ensure continued compliance. Anticipated Completion Date: Management estimates that additional processes will be in place by December 31, 2024.