Corrective Action Plans

The Municipality will proceed to train the Section 8 program personnel so that they can record all the transactions through the system in order to maintain complete and accurate accounting record.

FINDING 2022-002 Finding Subject: Child Support Enforcement - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not in place at the County to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The payment of the Deputy Court Clerk?s wages and benefits out of the Clerk?s Incentive Fund supplanted not supplemented the employee?s salary which is unallowable. Contractual payment did not match the amount stated in the contract. The County did not have an allowable cost policy. Contact Person Responsible for Corrective Action: James W. Bramble Contact Phone Number and Email Address: 812-462-3361 james.bramble@vigocounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal control procedures will be evaluated to determine needed changes to correct the above noted compliance requirements over Child Support. Changes will be made to the 2024 budget to correct the payroll related issue so the Clerk?s Incentive Fund. Contracts will be reviewed to ensure the contract amounts are current. The County will develop an allowable cost policy. Anticipated Completion Date: January 1, 2024

All federal Project and Expenditure reports were filed timely and all actual expenditures were also reported correctly according to the report overview page. This finding deals with the body of the report which incorrectly listed the Justice Center Project twice, with the obligation amount of $880,00 listed for the project. This duplicated project has been removed from future reports. The finding noted for $175,741, once again has all the correct totals in project overview report, which should be the summation of the report. We have been rehiring staff with American Rescue Plan funds since 2021, and this has been an ongoing project. Once again, the report overview page lists the correct expenditures, however the body of the report has the project listed twice. This duplicated project has been removed from future reports. The reporting software gives a total of expenditures before you hit submit on each report, this total has always displayed the correct cumulative expenditure total. If projects were entered twice, the total expenditures should of been over by these dollar amounts, and they were not.

#2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance -Administrative Policies Recommendations: Grand Rapids Christian Schools should consider the following written policy additions or updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following : ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access - define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Organization's procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Organization must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Organization ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 - 200.326) The Organization must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ? Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ? GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ? GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.

FINDING 2022-001: THE CITY OF CULLMAN, ALABAMA WILL DEVELOP A GRANTS MANUAL OR WRITTEN POLICIES TO INCORPORATE ALL REQUIREMENTS OF 2 CFR 200 AND ENSURE COMPLIANCE WITH GRANT REQUIREMENTS.

2022-016 Finding: Program Income - ALN 14.239 ? Home Investment Partnerships Program / Department of Housing and Urban Development / Award Number: M22-MC080204 / Award Year: 2022 Status: Corrective action in progress Corrective Action: The City agrees with the finding as this was a simple oversight for the finance team due to the extreme staff shortages we?ve encountered over the last year. HOST has a process of reviewing and approving program income in Workday and associated grantor entries. We are filling vacancies to support the general ledger transactions and currently onboarding a new staff accountant to support this effort. Del Norte Loan # 34-36-01 had cash flow in 2021, and a subsequent payment due in 2022. An interest payment of $48,500 was completed credited correctly. The interest was booked in the General Ledger (GL) under HOME/GR2437 instead of NSP2/GR98, causing the NR to be inaccurately overstated in HOME/GR2437 and understated NSP2/GR98. This has been remediated going forward by practicing a process of reconciling each fund with each revenue category. Person(s) Responsible for Implementing: HOST ? Ami Webb Implementation Date: August 2023

Audit Finding 2022-002 Finding Lack of Written Policies and Procedures over Federal Awards ALN Number 21.027 ALN Name Coronavirus State & Local Fiscal Recovery Funds Questioned Costs $0 County Response Concur Status Corrective action plan in progress Corrective Action Plan In response to the finding, the County is in the process of developing written policies and procedures relative to internal controls over federal awards, to help achieve: - County wide consistency over compliance regulations and standards - Decrease the risk of grant agreement noncompliance - Reduce the risk of undetected errors in processing of financial transactions relative to federal awards. Steps taken include: - Familiarization of requirements in 2 CFR 200.303 - Obtain draft examples of policies and procedures adopted by other Counties - Discussion with governance and county attorney regarding development and adoption of policies and procedures In addition, the County is continuing to suggest departments implement effective internal control structures to - Protect assets against theft and waste - Ensure accurate and reliable operating and accounting data The conditions noted in this finding were previously reported in finding 2021-002 Completion Date Estimated June 2023 - policy written, approved by Commissioners, and disseminated ot departments Training - ongoing County Contact Becky Kersten, County Clerk

The transit will implement a standard operating procedure and do training on how to properly calculate the SEFA amounts for future audits.

Contact Person Jolene Palme, Finance Manager Corrective Action Plan We are in the process of updating the Center?s written policies and procedures to include the requirements of the Uniform Guidance. Completion Date Fiscal year end 2023

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.

Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, 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.

Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, 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.

Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, 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.

Following the Auditor’s recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, 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.

Views of Responsible Officials and Planned Corrective Actions: Management understands the importance of defining and following the necessary policies and procedures to remain in compliance with the requirements under 2 CFR 200.302 and have sufficient staff to comply. We will follow the recommendation of the Audit. Action Taken: Horsham will adopt new policies that address CFR 200.302 requirements. Anticipated Completion: January 2023

Assistance listing number and program name: N/A Agency: Department of Education Name of contact person and title: Mark Belanger, Budget Director Anticipated completion date: October 31, 2023 Agency’s Response: Concur The Department agrees with this finding and will implement the following: • Train designated staff responsible for preparing the Schedule of Expenditures of Federal Awards (SEFA) on State of Arizona Accounting Manual (SAAM) requirements. • Establish a reconciliation process to validate expenditures prior to submitting report • Staff will review federal resources for Assistance Listing Numbers (formerly CFDAs) to ensure proper title reporting • Designated staff will stay current on all federal regulations and SAAM requirements for reporting

Beginning immediately on the date of the single audit report, management will recalculate expenses monthly as well as on a YTD grant year basis after the month has closed and request reimbursement for only those expenditures.

Finding 2022-004: Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Finding: The SEFA as prepared by management did not originally include one federal grant with federal expenditures during the year and one grant for which the Assistance Listing Number (ALN) did not match the grant documents. Corrective Action: Compare all contract or award letters for accurate information reported on the SEFA prior to submission. Contact: Carmen Stevens, Finance Director Expected Completion Date: 11/30/2023 If you have any questions, please contact Carmen Stevens at 713-472-0753 or by email at cstevens@tbotw.org.

Finding Number 2022-004 Planned Corrective Action: CAMcare has already updated its existing purchasing process to make the funding source a requirement. Anticipated Completion Date: July 1, 2023 Responsible Contact Persons: Jillian Hudspeth, CEO Christopher Bernardi, CFO

Hood River County has developed procedures for determining the allowability of costs for each award. A cost is allowable only if reasonable; it reflects what a prudent person might pay. In detail, allowability can differ from project to project. A Grant committee of finance, administrative, and program staff is now meeting regularly to centralize the focus on each award. This committee will meet monthly to manage the Grant's Life Cycle. The Grants Life Cycle has three major stages: pre-award, award, and post-award. The applicant/recipient and awarding agency have unique roles in each step. The duration of an award may vary depending on the nature of the project. An allowable cost is a cost that your contract or grant can pay. The Grant committee will set documentation standards. This new process for the County should is up and running, but it is expected to take time to pull the County together on the subject of grants, and to improve application, management, and reporting.

Agree with the finding. We will implement the segregation of duties matrix as part of SOPs. We will ensure that authorization and review of cash draws of fedral funds are done by some one other than the individual who initiates and records the transaction . We have implemented the same and Dr EIli (pi) is reviewing and approving the report before each withdrawal. The Finance Head ( Nafih) is withdrawing the fund .Anticipated Completion Date : 12/31/2022 Actual date of implementation :01/24/2023

The agency developed a corrective action plan that included creating a new policy and training staff in its use. Bank reconciliations are completed by the Finance Director within 5 to 10 days after receipt of bank statements. After completion of reconciliations, the finance director must provide the executive director with the bank reconciliation and supporting general ledger for reverification.

Views of Responsible Officials: Mary's Center Finance team has revised our Financial Policies and Procedures Manual to further outline our standard operating procedures (SOPs) and created additional supporting documentation that details SOPs for current processes/procedures. We have also defined in this supporting documentation contingency plans to combat the lack of knowledge transfer that can occur with unexpected staff attrition. Lastly, our Director of Grants has begun reconciling our SEFA report monthly to ensure we are accurate in our reporting and can proactively address any issues.

2022-005 Material Weakness and Material Noncompliance: Grant and Reporting Compliance View of Responsible Officials: The City agrees with the finding. Corrective Action Plan: The Finance Director will prepare and/or review all reimbursement requests before they are submitted to verify their accuracy. At the time of the reimbursement request, the grant activity will be reconciled to the general ledger to eliminate either missed expenses or duplicate requests. Anticipated Completion Date: This is currently being implemented as of October 2023.