Corrective Action Plans

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.

The Organization should implement additional procedures and controls to accurately capture all activity under federal awards in preparing the SEFA.New contracts and source of funding are now being identified and recorded in the accounting system.

Department of Housing and Urban Development and Department of Veterans Affairs Federal Program Name: Emergency Solutions Grant Program and VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 14.231 and 64.024 Recommendation: We recommend the Organization develop a system of internal controls to ensure that salaries and related payroll expenses are tracked to reasonably reflect the actual time spent working on the programs. In addition we recommend that management retain all documents including evidence of review and approval for all expenditures of federal funds until the latter of the legally required retention period or completion of required audits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented internal control procedures to strengthen payroll allocation practices and documentation retention for federally funded expenditures. The Organization has established a process to ensure that salaries and payroll-related costs charged to federal programs are supported by appropriate time tracking and allocation documentation that reasonably reflects actual time worked on each program. Supervisory review and approval requirements have been implemented to validate payroll allocations and supporting documentation. Additionally, the Organization has reinforced documentation retention standards by requiring retention of all federal expenditure support, including invoices, approvals, reconciliations, and evidence of review, in accordance with federal retention requirements and audit availability standards. Name(s) of the contact person(s) responsible for corrective action: Ryan Ross, Executive Director Planned completion date for corrective action plan: March 31, 2026

2021-012 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.

Corrective Action Plan: PREMA will establish and document formal procedures for the preparation, review, reconciliation, and timely submission of SF-425 Federal Financial Reports for EMPG grants by implementing a report reconciliation checklist requiring agreement of reported data to PRIFAS and SEFA records, ensuring each report includes federal and recipient share, drawdown activity, and unliquidated obligations, designating an official responsible for report review and approval prior to submission with evidence of filing retained, and providing staff training on federal reporting requirements under 2 CFR 200.327–200.329 to improve accuracy, completeness, and compliance in federal financial reporting. Lead Person: Maritza Torres, Fiscal Area Director, and Contractors (Robles & Assoc.). Anticipated Completion Date: December 2025.

Corrective Action Plan: PREMA will establish and enforce procedures to ensure that quarterly SF-425 or equivalent COR3 financial reports are prepared, reviewed, reconciled to PRIFAS and SEFA records, and submitted within required deadlines; PREMA will create reconciliation checklists, ensure reports include federal and recipient share, drawdown activity, and unliquidated obligations, designate responsible personnel for review and approval prior to filing with evidence of submission retained, and provide staff training on federal reporting requirements under 2 CFR 200.327–200.329 to strengthen compliance and accuracy in financial reporting. Lead Person: Maritza Torres, Fiscal Area Director, and Contractors (Robles & Assoc.). Anticipated Completion Date: December 2025.

Corrective Action Plan: PREMA will strengthen internal controls over financial management and reporting by improving the maintenance of subsidiary records, enhancing PRIFAS reconciliations, increasing coordination among fiscal, program, and grants personnel, and establishing written procedures to ensure timely, accurate, and complete financial information for the Statement, SEFA, and required federal reports; PREMA will also evaluate staffing needs, provide training on PRIFAS and federal reporting requirements, and conduct periodic reviews to ensure compliance with reporting deadlines and data accuracy. Lead Person: Maritza Torres, Fiscal Area Director, and Contractors (Robles & Assoc.). Anticipated Completion Date: December 2025.

Management will ensure that all nongrant expenditures are kept to a minimum until the cash balance of NVT is in excess of the unearned grant revenue and restricted fund balance. A large part of this problem in the current year was the amount of money paid to the Village’s accountants/consultant in prior years. This has been resolved and the new accountant’s fees are much more in line with reasonable amounts.

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to be Taken: Management has worked with outside consultants and updated the accounting system and implemented written procedures on direct and indirect cost identification and the allowability of costs. Allowable and unallowable costs are distinctly designated by category in our accounting program. This will ensure easy identification in the Chart of Accounts and allow transactions to be broken into easily recognizable sections. By including STEM program activity fields and unique identifiers in our accounting system for each entry, a consistent format is achieved that allows a comparison of estimated or forecasted expenses to actual costs. The new link between the two allows us to easily pull the data into the technical report. DoD has reviewed the matters covered in the audit report thoroughly, and the grant was closed out without any repayment of funds to DoD. Upon subsequent review and reconciliation, amounts were not overcharged.

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.

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.