Corrective Action Plans

In response to the Auditor’s recommendations and as corrective action, the responsible staff or department will locate, and document all required reports that were filed in accordance with the grant agreement requirements, including reconciliations with the Municipality’s official accounting subsidiary ledgers. Furthermore, the Municipality will design, document, establish, and provide the necessary training, along with written 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 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 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.

The Municipality will designate the appropriate personnel to systematically identify, compile, and securely retain all required reports as stipulated in the grant agreement, ensuring reconciliation with the official accounting records and subsidiary ledgers. Furthermore, the Municipality will develop and implement a comprehensive training program, accompanied by detailed written guidelines and procedures, to equip all staff involved in managing federal funds with the necessary knowledge and tools to maintain compliance and enhance accountability.

FINDING 2024-004 Finding Subject: Water and Wast Disposal System for Rural Communities - Reporting Contact Person Responsible for Corrective Action: Beth Jones Contact Phone Number and Email Address: 812 723-2739, clerk@paoli.in.gov Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: The town is contracted with Baker Tilly Financial Advisors and the Clerk Treasurer will provide all pertinent information to Baker Tilly in order for them to prepare the Statement of Budget, Income, and Equity- Form 442-2; and the Balance Sheet - Form 442-3) that is required by the USDA for the Sewer Bonds. Once the reports are completed by Baker Tilly, the Clerk Treasurer will review the reports and then submit them to the USDA. This will be done annually. Anticipated Completion Date: Effective immediately

Condition: The District claimed expenditures that did not agree with their underlying accounting records. Plan: The District will hire a full-time employee to execute the completion of all State and Federal grants. Addidtional training and reources will be provided to ensure the District remains in compliance. Anticipated Date of Completion: 'June 30, 2025. Name of Contact Person: Dr. Kevin J. Nohelty, Superintendent. Management Response: The District will review the itemized budget and ensure claimed expenditures fall within the grant. If necessary, amendments will be filed accordingly.

Condition: The District claimed expenditures that did not agree with their underlying accounting records. Plan: The District will maintain records that accuaratetly support reported expenditures on the expenditure claims effective immediately. Anticipated Date of Completion: 'June 30, 2025. Name of Contact Person: Dr. Kevin J. Nohelty, Superintendent. Management Response: The District will periodically review the itemized budget and ensure claimed expenditures fall within planned grant expenditures or file amendments as necessary.

Finding 2024-001 Internal Controls Over Compliance for Cash Management, Allowable Costs, Procurement, and Conflicts of Interest 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Subsequent to year-end, the City addressed this matter by formally adopting written policies meeting the referenced requirements of the Code of Federal Regulations. 3. Official Responsible The City Administrator is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2025. 5. Plan to Monitor Completion The City Council will be monitoring this Corrective Plan.

Finding 2024-004 Internal Controls Over Compliance for Cash Management, Allowable Costs, Procurement, and Conflicts of Interest 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding The City will adopt the referenced policies in order to comply with Uniform Guidance. 3. Official Responsible Nicole Coler, City Clerk/Treasurer, is the official responsible for ensuring corrective action. 4. Planned Completion Date December 31, 2025. 5. Plan to Monitor Completion The City Council will be monitoring this Corrective Plan.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. The Group will prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Group staff are trained on the requirements related to federal award reconciliations and SEFA preparation which mitigates the risk of noncompliance in the future.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. The Group will prepare and maintain an accurate Schedule of Expenditures of Federal Awards (SEFA) in accordance with 2 CFR Part 200.510 to ensure proper documentation and compliance with federal reporting requirements. Group staff are trained on the requirements related to federal award reconciliations and SEFA preparation which mitigates the risk of noncompliance in the future.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will work with management to design and implement internal controls related to federal program grant management, including assignment of responsibility for grant oversight to specific individuals or departments.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will work with management to implement internal controls over tracking of expenditures related to federal award grants, especially personnel costs, and the related reimbursed cost to ensure compliance with federal requirements.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will implement internal control procedures to establish separate accounts, classification, use of cost centers and project codes to clearly distinguish expenditures by funding source, especially federal and state funds, as well as revenues received.

Supportive Services for Veteran Families Assistance Listing No. 64.033 Recommendation: We recommend that the Corporation strengthen its internal controls over cash disbursements. This should include retention of payments supported by valid invoices and proof of payment documentation as well as periodic internal audits to ensure compliance with the documentation requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All purchase-related supporting documentation will be transitioned to paper files to eliminate confusion created by the electronic record-keeping system, and to ensure that all staff requiring access to such documentation can immediately and easily retrieve them. Records will be maintained in the Finance Department office for seven years. Name of the contact person responsible for corrective action: Karen Harshman Planned completion date for corrective action plan: 06/12/2025

DEPARTMENT OF HOMELAND SECURITY Disaster Grant Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Recommendation: We recommend that the organization implement a review and approval process for all quarterly progress submissions. This should include: Training staff on the importance of the review and approval process. Ensuring adequate staffing levels to handle the review process. Developing clear guidelins and procedures for the review and approval process. Regularly monitoring and auditing the review process to ensure compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The City will implement a review and approval process for all quarterly progress report submissions within it ERP (Enterprise Resource Planning) software system. The City will train its staff on the importance of the review and approval process. The City will ensure adequate staffing levels to handle the review process. The City will develop clear guidelines and procedures for the review and approval process. The City will regularly monitor and audit the reivew process to ensure compliance. Name(s) of the contact person(s) for corrective action: Guillermo Polanco. Planned completion date for corrective action plan: 09/30/2025

Department of Homeland Security Federal Emergency Management Agency Disaster Grant Public Assistance – FEMA – Assistance Listing No. 97.036 Recommendation: Provide clear, updated guidance and periodic training sessions on earmarking rules and how to apply them. Conduct reviews of earmarking compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: New procedures will be implemented that strengthen internal controls to ensure that all grant revenues are recorded properly. Name(s) of the contact person(s) responsible for corrective action: Lindsey Barwick, Accounting Manager Hardee County Clerk of Courts & Lorie Ayers, General Services Director Hardee County Board of County Commissioners Planned completion date for corrective action plan: September 30, 2025

Condition: A weakness existed in the overall reconciliation/tie-in procedures performed over the Tribe’s financial statement accounts for the fiscal year ended September 30, 2024. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included: A)   Beginning Balances B)    Account Receivables C)    Grant Receivables/Unearned Revenues D)   Accounts Payable E)    Payroll and Other Current Liabilities Recommendation: The Tribe should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. Action Taken: We agree with the auditor’s recommendation. We expect this to be complete within 120 days past the issuance of this report

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.