Corrective Action Plans

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.

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 non-compliance. 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 third-party 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. Mr. Ezequiel Nieves - PREPA Disaster Funding Management Office July 2025

Finding 2020-003: 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

Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding No 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 process, submission to the funding agency, and the recording 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

Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding No 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 process, submission to the funding agency, and the recording 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

2020-002 – INTERNAL CONTROLS OVER COMPLIANCE MATERIAL WEAKNESS 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

The fiscal coding system implemented in the accounting software includes specific codes for subrecipient expenditures, enabling clear tracking and reconciliation of subaward amounts. The new bookkeeping firm with ensure subrecipient expenditures are reconciled to reimbursement request amounts by February 28, 2026. Implement a standardized reconciliation process and maintain supporting documentation in a centralized location, including detailed reconciliation worksheets by March 31, 2026. Train staff involved in subrecipient monitoring and reimbursement submissions on Uniform Guidance requirements, including 2 CFR 200.332 pass-through entity responsibilities by April 30, 2026. Perform periodic internal reviews to ensure compliance and documentation completeness, with monthly reconciliation reviews during active subaward periods beginning May 2026. Develop comprehensive subrecipient monitoring procedures manual documenting all required monitoring activities, reporting requirements, and documentation standards by June 30, 2026. Establish annual risk assessments of subrecipients and implement risk-based monitoring approaches, including site visits for high-risk subrecipients by July 31, 2026.

MANAGEMENT’S CORRECTIVE ACTION PLAN 2019-005 Matching Federal Program: Aging Cluster – 93.044/93.045/93.053 Criteria: Per 7 CFR Section 200.302 (b)(4) the Organization is required to maintain records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Condition: During our testing, we noted of the 3 months tested that the volunteer sign-in sheets tested were not properly approved. Questioned Costs: None Context: Volunteer forms were completed by the volunteers but did not have proper approval by on-site supervisory personnel. Effect: An ineffective control system related to the review and approval of volunteer sign-in sheets. Repeat finding: This is not a repeat finding. Recommendation: We recommend the Organization implement a procedure to ensure all volunteer sign-in sheets are approved. Views of responsible officials and planned corrective actions: The Finance & Administrative Director will implement a new procedure to ensure all volunteer sign-in sheets are approved by the staff, supervisors, and directors at each location when submitted. An “Approved By” line will be included on all sheets. Individuals responsible for corrective action: Josette Shuey, Finance & Administrative Director; Marianne Ybarra, Director Stephanie Galloway, Director; Pat Austin, Director Brittany Harper, Nutrition Director; Tammy Williams, Nutrition Director Anticipated Completion Date: July 31, 2021

MANAGEMENT’S CORRECTIVE ACTION PLAN 2019-004 Allowable Costs Federal Program: Aging Cluster – 93.044/93.045/93.053 Criteria: Per 7 CFR Section 200.302 (b)(4) the Organization is required to maintain records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Condition: During our testing, we noted 2 instances out of 18 where expenses did not have proper approval on invoices. Questioned Costs: None Context: 18 expenses were selected during 2019 and we noted 2 instances of noncompliance. The sample is a statistically valid sample. Effect: An ineffective control system related to the review and approval of grant expenses. Repeat finding: This is not a repeat finding. Recommendation: The Organization should implement the appropriate controls to ensure all expenses are individually reviewed and approved by appropriate personnel. Views of responsible officials and planned corrective actions: The Finance & Administrative Director will implement an electronic workflow for expense review and approval by staff, supervisors, and directors as necessary. The process will be approved by the President & CEO. Individuals responsible for corrective action: Josette Shuey, Finance & Administrative Director Anticipated Completion Date: July 1, 2021

Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Description of Finding: The City does not have policies and procedures in place to accurately and completely account for federally funded activities separately from non-federally funded activities in their financial management system. Section 2 CFR 200.302 of the Uniform Guidance states that the financial management system must provide for identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the AL title and number, federal award identification and year, name of the federal agency, and the name of the pass-through entity, if any. Recommendation: We recommend the City implement procedures to ensure consistent and accurate accounting for federal grant expenditures in accordance with section 2 CFR 200.302 of the Uniform Guidance. Statement of Concurrence: The City of York, Pennsylvania agrees with audit finding 2019-014. Corrective Action: The City of York has implemented a new financial management system, OpenGov, to allow for identification of these awards. This allows the City to provide accurate data for all awards received and expended under these federal programs. The new procurement suite allows for tracking of titles, AL numbers, and agency tracking. Name of Contact Person Responsible for the Corrective Action: Contact Full Name: Kimberly Robertson Contact title: Business Administrator for Finance Address: 101 South George Street City: York State: Pennsylvania Zip Code: 17401 Phone: (717) 849-2883 E-mail: KRobertson@yorkcity.org Timetable for Correction: The anticipated date for resolving the audit finding is December 31, 2024.