Corrective Action Plans

Views of responsible officials and planned corrective actions: The documentation supporting program check requests is maintained by the program staff in the client files. When requesting a disbursement for a client, the case manager prepares a check request after following the process prescribed by the program and contract for determining an allowable disbursement. The check request is then reviewed and approved by a supervisor who also checks for eligibility and allowability of the disbursement. Only the approved check request is provided to the finance office to create the disbursement to avoid duplication of records. The client files and these records have been reviewed during site visits and previous audits without exception and with no delay in providing requested information. To further improve this process, however, the program has added a new form to be completed for each new client’s rental costs clearly identifying the costs to be paid and the source information for those costs. The supervisor reviewing disbursement requests will also affirmatively indicate on the check request that they have verified this documentation in the client file. Responsible Official: Molly Archer, Chief Operating Officer and Valorie Crout, Chief Program Officer Anticipated Completion Date: 6/1/2025

Action: Set Fridays as a standard recurring day to pay invoices. Date completed: May 2025 Responsible Person: Accounting Technician, Kary Smith Action: Set Monday as the day to make capital grant drawdowns. HUD deposits the draws via ACH on Wednesdays. The PHA releases the payment on Friday Date completed: May 2025 Responsible Person: Senior Accounting Technician, Stacy Verrinder Action: At the time of the request for capital grant transfers from the Moving to Work account to the operating account, include the Accounts Payable tech in the email distribution and include information about which invoice A/P must pay by Friday Date completed: May 2025 Responsible Person: Senior Accounting Technician, Stacy Verrinder

Finding Number: 2024-005 Title: Missing Receipt Support for MTW Public Housing Tenant Transactions Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: A review of tenant files under the Moving to Work (MTW) Public Housing program found that while the tenant files themselves were complete, the Authority did not provide supporting documentation for certain rent receipts. In several instances, the rent amounts recorded in the receipt or rent register did not agree with the amounts reported on HUD Form 50058, and no receipt documentation was available to reconcile the difference. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to improve tenant file management, ensure complete supporting documentation, and address disbursement variances.

Finding Number: 2024-004 Title: Incomplete Tenant File Documentation and Disbursement Variances for MTW Housing Assistance Payments Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: A review of tenant files and disbursement activity under the Moving to Work (MTW) Housing Assistance Payments (HAP) program identified multiple deficiencies in documentation and compliance. For six out of the sixteen tenants tested, the Authority was unable to provide the tenant file for review. Among the files that were available, several lacked required documentations for the required period to support continued occupancy, rent adjustments, reexaminations, income verification, and inspections. Additionally, variances were noted between the amounts reported on HUD Form 50058 and the actual HAP/UAP disbursements made. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to improve tenant file management, ensure complete documentation, and address disbursement variances.

Title: Missing Required Moving to Work (MTW) Demonstration Program Documentation Program Name: Moving to Work Program ALN: 14.881 Description: During our review of the Authority's administration of the MTW Program, the Authority was unable to provide several critical documents required to support its eligibility and compliance under the MTW framework: 1. The Authority did not provide a copy of its Annual Contributions Contract (ACC), which serves as the foundational agreement between the Authority and HUD for the receipt and use of federal funds. 2. The Authority failed to provide a signed MTW Certification of Compliance for the most recent fiscal year, which affirms board approval of the MTW Plan and Report and verifies the Authority's adherence to MTW statutory objectives and HUD program requirements. 3. The Authority did not provide the required supplement to the annual MTW Plan, which outlines planned uses of MTW funds and activities for the fiscal year. 4. The Authority also failed to provide the HUD-issued approval letter for the supplement to the annual MTW Plan, which is necessary to validate HU D's acceptance of the Authority's proposed activities.Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to locate and archive the ACC, required supplement to the annual MTW Plan, the HUD issued approval letter for the supplement to the annual MTW Plan, and to complete the MTW Certification of Compliance.

Mov ing to Work Demonstra tion Program - Capital Fund ProgramALN: 14.881 Description: During testing of the Mov ing to Work Demonstration Program - Capital Fund Progra m, we selected a sample of eight elOCCS drawdown vouchers for rev iew. Of these, the Authority was unable to provide sufficient supporting documentation to substantia te the eligibility, timing, or purpose of the draw d owns for four v ouchers. For another v oucher, the Authority could only partially support the a mount dra wn. These issues reflect a lack of a dequate documentation necessary to substantiate the allowability and propriety of the expenditure charged to the CFP grants. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to ensure that every drawdown request is accompanied by the required supporting documentation. In addition, the supporting documentation will be reviewed to ensure that it meets eligibility and "just-in-time" requirements prior to the Executive Director signing the request.

Title: Inadequate Tenant File Documentation and Inconsistencies in MTW Housing Assistance and Public Housing Records Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: During tenant file testing for both the Housing Choice Voucher (HCV) and Public Housing (PH) components of the Moving to Work (MTW) Demonstration Program, we identified multiple deficiencies in the Authority's documentation and reporting practices: 1. For the MTW HAP (HCV) sample, the Authority did not properly complete the "Summary Decision on the Unit" section of the HUD Form 52580-A, which documents the final pass or fail outcome of the Housing Quality Standards {HQS) inspection. As a result, it could not be confirmed whether the unit met HQS requirements at the time of assistance. 2. In six out of twenty-three HCV tenant files tested, housing assistance payments did not agree with the amounts reported on HUD Form 50058, and no reconciliations or explanations were provided. 3. For one out of twenty-three HCV tenants, the Authority was unable to provide a Form 50058 covering the period for which the HAP payment was selected, leaving the payment unsupported. 4. In the MTW Public Housing sample, five out of seventeen tenant files contained discrepancies between tenant receipts or rent register balances and the amounts reported on HUD Form 50058, without adequate explanation or reconciliation. 5. For one out of seventeen Public Housing tenants, the Authority was unable to provide any support for either the receipt from or payment to the tenant for the period tested. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a (a) process to ensure that Hud Form 52580-A is fully completed for all HQS inspections, documenting pass or fail outcomes, (b) establish procedures for reconciling housing assistance payments (HAP) and tenant rent payments with amounts reported on HUD Form 50058, documenting any

Title: Missing Required Moving to Work (MTW) Demonstration Program Documentation Program Name: Moving to Work Demonstration Program ALN: 14.881 Description: During our review of the Authority's administration of the MTW Program, the Authority was unable to provide two critical documents required to support its eligibility and compliance under the MTW framework: he Authority did not provide a copy of its Annual Contributions Contract (ACC), which serves as the foundational agreement between the Authority and HUD for the receipt and use of federal funds. 2. The Authority also failed to provide a signed MTW Certification of Compliance for the most recent fiscal year, which affirms board approval of the MTW Plan and Report and verifies the Authority's adherence to MTW statutory objectives and HUD program requirements.Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to locate and archive the ACC and to complete an MTW Certification of Compliance.

Title: Incomplete Support for Capital Fund Program (CFP) Drawdown Sample Program Name: Capital Fund Program ALN: 14.872 Description: As part of the testing of the Capital Fund Program (CFP) major program, a sample of six drawdown vouchers were selected for review. The Authority was unable to provide adequate supporting documentation for one voucher in the sample. The missing documentation prevented verification of the eligibility, timing, and allowability of the associated expenditures. Planned Corrective Action: Fiscal Vear 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to ensure that every drawdown request is accompanied by the required supporting documentation. In addition, the supporting documentation will be reviewed to ensure that it meets eligibility, timing, and allowability of the associated expenditures.

Title: Unsupported MTW Capital Fund Program (CFP) Drawdowns Program Name: Moving to Work Demonstration Program - Capital Fund Program ALN: 14.881 Description: During testing of the Moving to Work Demonstration Program - Capital Fund Program, we selected a sample of eight eLOCCS drawdown vouchers for review. Of these, the Authority was unable to provide sufficient supporting documentation to substantiate the eligibility, timing, or purpose of the drawdowns for two vouchers. In addition, for one voucher, the Authority did not provide evidence of immediate obligations or expenditures to support the drawdown, indicating a potential violation of the federal "just-in-time" funding requirement. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to ensure that every drawdown request is accompanied by the required supporting documentation. In addition, the supporting documentation will be reviewed to ensure that it meets eligibility and "just-in-time" requirements prior to the Executive Director signing the request.

The Department of Behavioral Health (DBH) Office of the Chief Financial Officer (OCFO) concurs with this finding. Prior to the submission of the SEFA, the grant expenditures will be reviewed with the Accounting Officer, the AFO, and the Grants program manager for a detailed review of the SEFA to confirm expenditures are correctly categorized by fund and grant, reconciles to the financial system and reflects the amount expended for subrecipients. Contact: Barbara S. Roberson, Accounting Officer, Human Support Services Cluster Estimated Completion Date: September 2025 See Corrective Action Plan for chart/table

DMPED The Office of the Deputy Mayor for Planning and Economic Development (DMPED)concurs with the finding and understands that going forward grants to the DC Housing Finance Authority should be excluded from the subrecipient listing because it is a component unit. The AFO will review the SEFA prior to submission to confirm that no component units of the District government are listed as subrecipients. Curtis Lewis, Agency Fiscal Officer, Economic Development and Regulation Cluster December 31, 2025 OSSE The Office of the State Superintendent of Education (OSSE) concurs with the finding. OCFO prepares the SEFA. As a corrective action plan, OCFO will coordinate with the program to ensure all entities are identified as either vendors or subrecipient accurately on the SEFA by having the program management review and verify the correctness of the entities’ designation before providing the subrecipient data to OCFO to address the underlying issues and prevent the recurrence of this finding. Carol D’Avilar-Etkins, Program Officer, Office of Grants Management and Compliance March 1, 2026 DOES The Department of Employment Services (DOES) concurs with the finding. The original SEFA cost reported was based on the subrecipient payments that were recorded interchangeably within several accounting codes in DIFS Account Parent Level (Government Subsidies and Grants – 714100C). OCFO and Program Staff will ensure that the subrecipient costs are recorded using the DIFS Account Code (7141009- Subsidies) identified for the Subrecipient costs. Monthly reviews will be conducted to ensure compliance. Shilonda Wiggins, Agency Fiscal Officer, DOES September 30, 2025 DOEE The Department of Energy and Environment (DOEE) concurs with the finding related to inaccurate reporting of passed through amount to subrecipients in SEFA. DOEE will review the details of subrecipients’ amount generated from the system and perform a vendor or subrecipient analysis to ensure accuracy of amounts to be reported in SEFA. Olga Provotorova, Cluster Controller, Government Services Cluster September 30, 2025 DBH The Department of Behavioral Health (DBH) Office of the Chief Financial Officer (OCFO) concurs with this finding. Prior to the submission of the SEFA, the grant expenditures will be reviewed with the Accounting Officer, the AFO, and the Grants program manager for a detailed review of the SEFA to confirm expenditures are correctly categorized by fund and grant, reconciles to the financial system and reflects the amount expended for subrecipients. Barbara S. Roberson, Accounting Officer, Human Support Services Cluster September 2025 ONSE The Office of Neighborhood Safety and Engagement (ONSE) concurs with the finding. Having concurred with the finding on incorrect subrecipient expenditures in the SEFA, ONSE will implement a secondary review process for expenditure entries involving subrecipient. We will also review the details of the subrecipient amounts generated from the system (DIFS) and perform a vendor or subrecipient analysis as an added layer of scrutiny to ensure that the SEFA reflects accurate amounts. Contact: Samuel Robertson, Cluster Controller, Public Safety and Justice Cluster Estimated Completion Date: September 30, 2025 See Corrective Action Plan for chart/table

The Department of Human Services (DHS) Office of the Chief Financial Officer (OCFO) concurs with the finding. Prior to the submission of the SEFA, the grant expenditures will be reviewed with the Accounting Officer, the Accounting Finance Officer, and the program manager for a detailed review of the SEFA to confirm expenditures are correctly categorized by fund and grant, reconciles to the financial system and reflects the amount expended for subrecipients. Contact: Barbara S. Roberson, Accounting Officer, Human Support Services Cluster Estimated Completion Date: June 2025 See Corrective Action Plan for chart/table

Condition: The Organization did not have a formal cash management policy in place for the period under audit. Planned Corrective Action: The Organization implemented a Federal Awards Administration Policy which includes a formal cash management policy in February 2025. Contact person responsible for corrective action: Valeria Watson Anticipated Completion Date: February 2025

Title: Capital Fund Program Grant Draws Program Name: Public Housing Capital Fund ALN:14.872 Description: During our audit procedures over revenue recognition for the Capital Fund Program (CFP), we identified drawdowns of federal funds for which the client was unable to provide adequate supporting documentation. Specifically, the expenditures associated with the draw requests lacked invoices, contracts, or other substantiating records to demonstrate that the costs were allowable, allocable, and incurred in accordance with applicable federal requirements. Planned Corrective Action: Today’s Marlboro County Housing Authority management acknowledges the auditor’s finding that documentation to support certain CFP drawdowns was incomplete or missing and concurs that this represents a failure to comply with Uniform Guidance documentation requirements under 2 CFR §200.302 and §200.403. The Authority recognizes the importance of maintaining complete and accurate supporting records—such as invoices, contracts, and payment documentation—to substantiate costs charged to federal programs and ensure allowability and allocability under the Capital Fund Program. Effective October 1st, 2024, all draw requests under the Capital Fund Program ARE supported by: • Approved contracts or purchase orders • Invoices or other source documents • Proof of payment (e.g., canceled checks, ACH confirmations) • Documentation clearly linking each expense to an approved activity in the CFP Annual Statement

Re: FY23-24 Federal Single Audit Finding (2024-001) Name(s) of Contact Person(s) Responsible for Corrective Action: Sean Perez, Finance Director; Jeff Gilbreath, Executive Director Hawaiʻi Community Lending (HCL) is diligent and ensures all grant requirements are met for Federal, State, and private funding awards. Due to the transitioning of its Finance Directors upon the start of the FY23-24 audit, the proper procedures to correct the CDFI ERP project account were miscommunicated, and the Schedule of Expenditures for Federal Awards (SEFA) were not reduced to reflect the proper adjustments. The corrective action being taken by HCL leadership is to ensure all loans disbursed and charged to restricted grants are reviewed thoroughly by the Finance Director. The Finance Director will review all eligibility requirements that are met, to include the eligible mapping area, as required and provided by the funder. This thorough review of eligibility will ensure that all loans charged to restricted funding will be properly allocated and charged correctly. In addition to the thorough review mentioned above, HCL will develop procedures to review the SEFA, in detail, which is prepared by a third-party accounting vendor. The procedures will include an extensive review of expenditures by the Finance Director and subsequent review and approval by the Executive Director to ensure all expenses are eligible and allocated properly to our federal grants. Once the SEFA has been fully reviewed and approved by the Finance Director and Executive Director, it will be forwarded to the auditors. Additional staff may be involved in the review and eligibility confirmation process to ensure accuracy. Internal audits of expenditures will also be completed on a quarterly basis. The anticipated completion date of this corrective action plan is June 30, 2025. Mahalo, Jeff Gilbreath Executive Director Hawaiʻi Community Lending

Finding 2024-030 Rehabilitation Services Vocational Rehabilitation Grants to States, ALN 84.126 - Accuracy of Financial Reports Management Views LEO agrees with the finding. Planned Corrective Action The LEO Finance Division will implement the following: 1. Improvements to documented procedures for the Vocational Rehabilitation Financial Report (RSA-17) preparation to ensure consistency and accuracy of financial report submissions. 2. Specific RSA-17 training for applicable staff and management in order to enhance knowledge of reporting requirements. 3. An additional layer of management review on RSA-17 financial reports prior to submission. Anticipated Completion Date September 30, 2025 Responsible Individual(s) Heidi Parker, LEO Chris Johnson, LEO

All grant-related information is being thoroughly tracked by the employees currently responsible for submitting reimbursement claims. At this time, Janna Wright and Stacy Swindle are the only staff members filing claims. Their process includes running a Flexible Period Report from Munis, generating a Statement of Revenues and Expenditures from the legacy system for payroll, printing copies of checks, invoices, timesheets, and any other transaction listed on the reports. They also maintain detailed tracking spreadsheets to monitor both expenses and claims, and they collaborate with Directors to ensure accuracy. Once grant funds are received, the payments will be entered into Munis in a timely manner to maintain accurate financial records.

Condition: During compliance testing of the District's accounting records to the expenditure report filed with the Illinois State Board of Education, we noted the District overclaimed $18,940 of expenditures at 6/30/24. Upon review of the general ledger and quarterly expenditure report, it was determined that the District erroneously overstated their claim amount on two function object codes by a cumulative amount of $18,940. Under 2300-200 (23-4300-00), total expenditures were $3,147 but District claimed $12,999, resulting in an overclaim of $9,852. Under 1000-200 (24-4300-00), total expenditures were $31,255 but District claimed $40,343, resulting in an overclaim of $9,088. Plan: Management will periodically review the itemized budget and ensure claimed expenditures fall within or file amendments as necessary for any changes. Anticipated Date of Completion: 6/30/2025. Name of Contact Person: Justin Whitten, Business Manager. Management Response: Management will work together with staff to ensure that grant budgets and claimed expenditures are periodically reviewed and amended as necessary.

Condition: During compliance testing of the District's accounting records to the expenditure report filed with the Illinois State Board of Education, we noted the District overclaimed $727 of expenditures at 6/30/24. Upon review of the general ledger and quarterly expenditure report, it was determined that the District erroneously overstated their claim amount on two function object codes by a cumulative amount of $727. Under 2560-100, total expenditures were $256,193 but District claimed $256,699, resulting in an overclaim of $506. Under 2560-200, total expenditures were $81,610 but District claimed $81,831, resulting in an overclaim of $221. Plan: Management will periodically review the itemized budget and ensure claimed expenditures fall within or file amendments as necessary for any changes. Anticipated Date of Completion: 6/30/2025. Name of Contact Person: Justin Whitten, Business Manager. Management Response: Management will work together with staff to ensure that grant budgets and claimed expenditures are periodically reviewed and amended as necessary.

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the review and approval of expenditures and maintenance of supporting documentation surrounding federal awards. Action Plan:  See the “Conduct Training Sessions for Expenditures Personnel” and “Audit of all FY25 YTD Expenditures” sections of management’s action plan for finding 2024-001  Review and update the Allowable Funds document o Locate the latest Allowable Funds Guide created by KIPP Delta. o Review and update the guide as necessary. o Store the updated guide in a central cloud location for responsible personnel to access easily. o Process completed as of April 17, 2025.  Develop a Federal Funds Workflow in Avid for POs and invoices: o A designated finance team member must review all federally funded purchases to improve the federal funds purchasing process. Steps include:  Create a separate workflow in Avid for POs and invoices to track federal purchases.  Ensure a purchase order is created before an invoice is submitted and paid.  Attach all required documentation to the PO, as with all other expenditures.  Verify that the expenditure complies with the Allowable Funds guide o Anticipated completion date of May 30, 2025.

Finding 2024-002: Review of Compliance Matrices and Narratives The single audit report included the following recommendation: We recommend that Amtrak establishes a more defined timeline for the events that would trigger the update and review of the compliance matrices and compliance narrative, which could include execution of any new federal awards or amendments to existing federal awards. Additionally, Amtrak should establish a process where the modifications to the provisions are assessed for materiality/applicability and include documentation of the respective conclusions as part of the review process. Management Response/Status of Action Plans: Amtrak acknowledges the need to augment process documentation around the controls over the preparation and updates to the compliance matrices. The company is in the process of updating these controls now and will incorporate the identified findings in developing more robust controls. The company specifically notes the need to add more documentation on considerations for what provisions are updated in the compliance matrices and the evidence of review. The review procedures and controls are being enhanced to include a checklist to improve the review. This checklist will be completed by both the compliance matrix creator (upon creation) and the compliance matrix reviewer/approver (upon review and final approval). The contact for this item is Lucia Butts, AVP Funding and Grants and Meghan Histand, Director of Discretionary Grants. Amtrak anticipates fully remediating this finding by September 2025.

Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) The single audit report included the following recommendation: We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner Management Response/Status of Action Plans: Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The contact for this item is Lucia Butts, AVP Funding and Grants. Amtrak anticipates fully remediating this finding by September 2025.

Views of responsible officials and planned corrective actions: The Clinic will be seeking professional consultation and guidance on a process to support and enforce monthly reconciliations of the amounts submitted for the grant with the amounts booked within the system, using appropriate grant-tracking schedules. Relevant staff will be retrained, and a monthly review will be completed by an appropriate professional and submitted to the Chief Executive Officer (CEO). Personnel responsible for implementation: Deborah Lerner, CEO and Board of Directors Date of implementation: July 1, 2025

Finding 2024-027 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-023 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. D. Established a Contract and Compliance Unit responsible for overseeing the filing of the FFATA report. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025