Corrective Action Plans

FA 2024-001 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 235GA32N1199 Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None identified Prior Year Finding: FA 2022-001, FA 2021-001, FA 2020-001, FA 2019-003, FA 2018-002, FA 2017-004 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Child Nutrition Cluster and Elementary and Secondary School Emergency Relief Fund programs. Corrective Action Plans: Management has strengthened controls over equipment to ensure that the records are complete, accurate and r reflect all required information. We are in the process of developing a physical inventory list of equipment. The inventory listing will have all identifying information such as an item description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location of the equipment, the use and condition of the equipment, and any ultimate disposal data for each piece of equipment. A complete physical inventory will be performed each year and reconciled with the equipment listing. Estimated Completion Date: 12/31/2025 Contact Person: Christopher Stephens, Chief Financial Officer Telephone: 229-268-4761 Email: christopher.stephens@dooly.k12.ga.us

Finding 2023-003 Information on the federal program: Subject: Water and Waste Disposal Systems for Rural Communities – Equipment and Real Property Management Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.760 Federal Award Number: N/A Pass-Through Entity: N/A Compliance Requirements: Equipment and Real Property Management Audit Finding: Material Weakness, Noncompliance Condition: An effective internal control system was not in place at the District to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. Context: The District did not maintain an updated asset listing that reflects the construction in process balance related to the project funded with federal funds. There was approximately $10.9 million of disbursements from federal funds related to the project as of December 31, 2023. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The third-party accounting firm will compile a capital asset listing that lists out the District’s capital assets and notes the required information, which will include the federal funding source (if applicable). The capital asset listing will be updated on an annual basis. The Board of Directors will review the capital asset listing. Responsible Party and Timeline for Completion: The third-party accounting firm and the Board of Directors will implement the corrective action plan, which will go into effect immediately.

Management believes that in order to ensure that the amount being drawn down are timely and more accurate to the amounts being drawn upon, management is in the process of developing a more formal policy whereby the general ledger will be formally closed on a monthly basis and all amount will be reconciled to the ledger. Once all amounts are proven, then the drawdown amounts will be initiated with the proper documentation attached.

We will work to establish written procedures and policies related to the management of Federal awards, including reporting requirements.

Finding 2023-001 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment (Material Weakness) Condition: An effective internal control system was not in place at the District in order to ensure compliance with requirements related to the grant agreement and the simplified acquisitions procurement method of the Procurement and Suspension and Debarment compliance requirement. Context: There were two contracts subject to procurement and suspension and debarment during the year. For both procurements, the District could only provide final signed contracts and did not have evidence of the full bid process. For the first selection, the District provided the request for proposal but did not provide all bids that were received or a scoring rubric to support why the District selected the vendor. For the second selection, the request for proposal, bids received, and scoring rubric were not provided. Additionally, evidence of a suspension and debarment check for both selections was not available. The District did not have a formal procurement policy documented. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will ensure that a procurement policy is adopted and followed and documents to support the process and vendor selections are maintained. Responsible Party and Timeline for Completion: The Treasurer is the responsible party. The completion will go into effect immediately.

Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting - Material Weakness in Internal Control over Compliance Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.498 Program Name: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Finding Summary: There was no documentation of review and approval of the expenditure listing, lost revenue calculation, or the Department of Health and Human Services Period 4 report prior to submission of the HHS Period 4 report. Responsible Individuals: Dawn Ballard Corrective Action Plan: Management agrees with the finding. Due to the small accounting staff, there was little internal review of the calculations resulting in unallowed expenditures based on underlying supporting schedules that was not recognized until single audit. The Authority has adopted policies where every spreadsheet and schedule will be reviewed and checked by a second member of the Administration team as well as final review by the Contracted CPA. Anticipated Completion Date: September 29, 2023

Reporting - Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.498 Program Name: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Finding Summary: The Authority selected Option 1, as defined by HRSA, to calculate lost revenue. This option consists of reporting actual revenues from relevant quarters in the period of availability with the system calculating lost revenues because of declines. The fiscal year 2021 single audit identified unallowable expenses totaling $263,861. The Authority utilized excess lost revenues at the time to cover this difference. To capture the use of these lost revenues from Period 1, the Authority should have used Option 3, as defined by HRSA, to calculate and report lost revenues. Within that calculation, lost revenues could then be reduced by the $263,861. Responsible Individuals: Dawn Ballard Corrective Action Plan: Due to the timing of completion of the 2021 single audit, which included the identification of questioned costs, and the deadline for the Period 4 Provider Relief Fund report to the HHS portal, the Period 4 report was submitted utilizing Option 1. The Authority does not expect to complete any additional HHS reports related to this program. Management will implement a process and procedures to ensure all required reports are completed accurately, in the event similar funding is received in the future. Anticipated Completion Date: January 16, 2025

Benjie Read CFO and Felecia Read Staff Accountant, will update the policies and procedures for all program reports and the review of each before submission. We will also negotiate with the grantors for appropriate time frams as some of these time frames are impossible for us to meet in an accurate manner. These policies will be done within 90 days of audit completion.

Benjie Read CFO and Felecia Read Staff Accountant, will update the policies and procedures for purchasing, documentation, and suspension and debarment to align with Uniform Guidance or other requirements. This will be done within 90 days of audit completion.

Benjie Read CFO and Felecia Read Staff Accountant, will develop a policy and establish procedures for calculating the MTDC in accordance with Uniform Guidance for federal contracts and reviwing the indirect cost allocations. We will also educate ourselves and all financial staff on these requirements. These efforts will be complete within 90 days of audit completion.

Twin Oaks has updated their payroll provider to Paylocity as of 4/1/2024. This change has given us better oversight and documentation of hours worked at all our programs. Benjie Read CFO and Felecia Read Staff Accountant, will educate the payroll staff on federal and state requirements for payroll allocations within 90 days of audit completion.

For every program that Twin Oaks operates, there is an approved budget by the grantor agency that includes incentives for modifications and awards for youth behavior. Twin Oaks will strictly go by these approved budgets and better document the purpose. In addition, Benjie Read CFO and Felecia Read Staff Accountant, will educate financial staff on using proper allocation schedules and proper supporting documentation. Expense allocation schedules will be updated periodically whenever program additions or deletions occur with a minimum of twice per year. Twin Oaks has already replaced expense reproting software that was inadequately providing backup documentation with a new system which has greatly improved our accuracy and documentation. Also, our systems have greatly improved since we started with quarterly reporting to our CBCs, especially NWF Health Network, who have greatly assisted in our correct allocation of expenses. This education process will be completed within 90 days of completion of audit.

Benjie Read CFO and Felecia Read Staff Accountant, will update procedures for documented review of the program reports prior to submission to the grantors. Also see 2023-013 for timely submission. These updates will be completed within 90 days of audit submission.

Benjie Read CFO and Felecia Read Staff Accountant, will update written policies and procedures to implement the requirements of 2 CFR 200.305 to include a review and documentation of the cash draw requests prior to submission. This will be completed within 90 days of audit completion. In addition, we no longer operate the only Federal program where cash draws were allowed.

For every program that Twin Oaks operates, there is an approved budget by the grantor agency that includes incentives for modifications and awards for youth behavior. Twin Oaks will strictly go by these approved budgets and better document the purpose. In addition, Benjie Read CFO and Felecia Read Staff Accountant, will educate financial staff on using proper allocation schedules and proper supporting documentation. Expense allocation schedules will be updated periodically whenever program additions or deletions occur with a minimum of twice per year. Twin Oaks has already replaced expense reproting software that was inadequately providing backup documentation with a new system which has greatly improved our accuracy and documentation. Also, our systems have greatly improved since we started with quarterly reporting to our CBCs, especially NWF Health Network, who have greatly assisted in our correct allocation of expenses. This education process will be completed within 90 days of completion of audit.

Finding 2023-003 - Activities Allowed or Unallowed/ Allowable Costs/ Cost Principles Responsible Individual: Arlene Dickens, Chief School Financial Officer Corrective Action: A review process has been established requiring Superintendent approval before expenditures are charged to the grant. Supporting documentation will be maintained to verify prior approval for all allowable costs and activities. Anticipated Completion Date: October 1, 2025

Finding 2023-002 - Equipment and Real Property Management Responsible Individual: Arlene Dickens, Chief School Financial Officer Corrective Action: All capital expenditures will require documented prior approval from the grantor agency before encumbrance. Property records will be updated and maintained in accordance with 2 CFR 200.313 and 200.439. A physical inventory will be conducted and reconciled at least once every two years. Anticipated Completion Date: October 1, 2025

Finding 2023-001 - Special Tests and Provisions: Wage Rate Requirements Responsible Individual: Arlene Dickens, Chief School Financial Officer Corrective Action: Wage rate clauses will be included in all federally funded construction contracts. Contractors and subcontractors will be notified in writing of prevailing wage requirements, and certified payrolls will be required and reviewed for all weeks for which construction work is performed. Anticipated Completion Date: October 1, 2025

2023-009- Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: American Rescue Plan Act / Coronavirus State Fiscal Recovery Fund (ARPA) Assistance Listing Number: 23.027 Federal Award Identification Number and Year: Various Pass-Through Agency: Pennsylvania Department of Health and Human Services Pass-Through Number(s): Not Available Award Period: 1/1/2023 – 12/31/23 Type of Finding: Significant Deficiency in Internal Control Over Compliance Condition: Policies and controls in place regarding the completeness of the SEFA were not properly functioning. Within the supporting listing of expenses relating to ARPA expenditures, multiple transactions were identified as 2022 fiscal year expenditures that were included in the 2023 expenditure total. The County revised the 2023 SEFA to exclude the 2022 expenditures. Recommendation: We recommend management should review the process of recording federal expenditures to determine expenditures are being included in the appropriate fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned and taken in response to finding: The reason for the finding’s recurrence is in part a result of the timing of when the finding was issued. For example, the 2022 Single Audit was issued in August 2024. At this point, the 2023 fiscal year was already complete. Additionally, the implementation of corrective actions are in progress, including providing training, oversight and guidance to departments administering the grants, but these efforts take time to complete and/or are ongoing. A Deputy Controller of Grant Accounting was hired in February 2023, and a Manager-Grant Accounting was hired in July 2024, after working in this capacity as a temporary staff member since mid-2023. The County approved an additional full-time grant accounting position in May 2025 and will begin recruiting for this position in June 2025. These positions are responsible for establishing accounting policies based on best practices for grant-related activities, developing and providing training and resources to grant- funded departments, reviewing grant-related accounting in the Infor system, preparation of the annual SEFA, and assisting in the facilitation and preparation of documents needed for the Single Audit. The work performed by these positions had been vacant since the departure of Internal Audit Staff who helped General Accounting prior to the 2021 audit as well as the SEFA. Several changes have been made since the grant accounting team was created including the following: The grant accounting team is developing streamlined and standardized SEFA templates for each department for SEFA preparation. The expenditures reported on each SEFA are being compared to the financial information in the GL where possible to ensure all appropriate expenditures are included. Additionally, we are incorporating tracking of lifetime grant expenditures into the SEFA process to ensure no expenditures are missed due to cut off or timing issues. In 2023, the grant accounting team created a Montgomery County Grant Repository. This repository is used to store all grant agreements awarded to the County. Departments submit grant information to the repository upon notification of grant award. The grant accounting team reviews the Grant Repository when preparing the SEFA to ensure no grant programs are inadvertently left off of the SEFA. Additionally, the availability of the Grant Repository enables members of the accounting, finance and grant departments to quickly access grant award information when needed for audits, reporting, or other requirements. The grant accounting team is continuing to review and update the County’s Grant Accounting policies and is working closely with departments to understand their utilization of Infor to account for grant- related activities. As these policies are formalized, we will continue to provide training and resources; in late 2023, the County hired an outside trainer to provide an in-depth training on the accrual method of accounting, grant accruals, and the treatment of grant revenue. The Grant Accountant provided training in April 2024 to explain and outline the SEFA and Single Audit processes. Grant-funded departments received a two-day training on utilization of the Grant Management components of Infor in February 2024. We are also providing guidance and education to departments on the differences in timing of various grant fiscal years and how these impact the financial audit, SEFA and Single Audit. For example, departments must understand how to report expenditures and receipts in the correct period regardless of the fiscal year associated to the contract (State: July-June; Federal: October-September; County: January-December) and understand how these amounts reconcile to the amounts reported to the funding agencies. The accounting department continues to work with departments to emphasize the importance of submitting financial documentation timely and reviewing what is in the General Ledger promptly at the end of each month. The Finance department is performing quarterly reviews with departments to go over financial status, including grant financials. Departments are continuing to utilize Project Codes and other components of Infor’s Grant Management System to ensure the proper accounting of grant-related expenses, receipts, and revenues in the GL. Name(s) of the contact person(s) responsible for corrective action: Thomas Landauer and Fonta Reilly Planned completion date for corrective action plan: September 2025

2023-008 – Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Emergency Rental Assistance Program (ERAP) Assistance Listing Number: 23.023 Federal Award Identification Number and Year: Various Pass-Through Agency: Pennsylvania Department of Health and Human Services Pass-Through Number(s): Not Available Award Period: 1/1/2023 – 12/31/23 Type of Finding: Significant Deficiency in Internal Control Over Compliance Condition: Policies and controls in place regarding the completeness of the SEFA were not properly functioning. Within the supporting listing of expenses relating to ERAP expenditures, six transactions were identified as prior fiscal-year expenditures that were included in the unadjusted 2023 expenditure total. The County revised the 2023 SEFA to exclude the 2022 expenditures. Recommendation: We recommend management should review the process of recording federal expenditures to determine expenditures are being included in the appropriate fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned and taken in response to finding: The reason for the finding’s recurrence is in part a result of the timing of when the finding was issued. For example, the 2022 Single Audit was issued in August 2024. At this point, the 2023 fiscal year was already complete. Additionally, the implementation of corrective actions are in progress, including providing training, oversight and guidance to departments administering the grants, but these efforts take time to complete and/or are ongoing. A Deputy Controller of Grant Accounting was hired in February 2023, and a Manager-Grant Accounting was hired in July 2024, after working in this capacity as a temporary staff member since mid-2023. The County approved an additional full-time grant accounting position in May 2025 and will begin recruiting for this position in June 2025. These positions are responsible for establishing accounting policies based on best practices for grant-related activities, developing and providing training and resources to grant- funded departments, reviewing grant-related accounting in the Infor system, preparation of the annual SEFA, and assisting in the facilitation and preparation of documents needed for the Single Audit. The work performed by these positions had been vacant since the departure of Internal Audit Staff who helped General Accounting prior to the 2021 audit as well as the SEFA. Several changes have been made since the grant accounting team was created including the following: The grant accounting team is developing streamlined and standardized SEFA templates for each department for SEFA preparation. The expenditures reported on each SEFA are being compared to the financial information in the GL where possible to ensure all appropriate expenditures are included. Additionally, we are incorporating tracking of lifetime grant expenditures into the SEFA process to ensure no expenditures are missed due to cut off or timing issues. In 2023, the grant accounting team created a Montgomery County Grant Repository. This repository is used to store all grant agreements awarded to the County. Departments submit grant information to the repository upon notification of grant award. The grant accounting team reviews the Grant Repository when preparing the SEFA to ensure no grant programs are inadvertently left off of the SEFA. Additionally, the availability of the Grant Repository enables members of the accounting, finance and grant departments to quickly access grant award information when needed for audits, reporting, or other requirements. The grant accounting team is continuing to review and update the County’s Grant Accounting policies and is working closely with departments to understand their utilization of Infor to account for grant- related activities. As these policies are formalized, we will continue to provide training and resources; in late 2023, the County hired an outside trainer to provide an in-depth training on the accrual method of accounting, grant accruals, and the treatment of grant revenue. The Grant Accountant provided training in April 2024 to explain and outline the SEFA and Single Audit processes. Grant-funded departments received a two-day training on utilization of the Grant Management components of Infor in February 2024. We are also providing guidance and education to departments on the differences in timing of various grant fiscal years and how these impact the financial audit, SEFA and Single Audit. For example, departments must understand how to report expenditures and receipts in the correct period regardless of the fiscal year associated to the contract (State: July-June; Federal: October-September; County: January-December) and understand how these amounts reconcile to the amounts reported to the funding agencies. The accounting department continues to work with departments to emphasize the importance of submitting financial documentation timely and reviewing what is in the General Ledger promptly at the end of each month. The Finance department is performing quarterly reviews with departments to go over financial status, including grant financials. Departments are continuing to utilize Project Codes and other components of Infor’s Grant Management System to ensure the proper accounting of grant-related expenses, receipts, and revenues in the GL. Name(s) of the contact person(s) responsible for corrective action: Thomas Landauer and Fonta Reilly Planned completion date for corrective action plan: September 2025

To: FY2023 Uniform Guidance Reporting Package From: David Noble, Director, Grant Administration RE: 2023 Uniform Guidance Audit Corrective Action Plan Date: September 25, 2025 Finding 2023-003 Federal Agency: U.S. Department of Treasury U.S. Department of Homeland Security ALN: 21.027 / 97.036 Grady Memorial Hospital Corporation’s CFO and VP of Fiscal Services/Controller have reviewed the reporting from KPMG relating to the Uniform Guidance. We understand the recommendation set forth by KPMG and will update our controls and processes to include additional review of expenses incurred during the relevant audit period. Grady’s corrective action plan: We have restated 2023 SEFA totals based on updates to the project funded within ALN 21.027 and for the project funded within 97.036. Going forward the SEFA will be reviewed to ensure that all related expenses for the audit period are incorporated. Contact person/s responsible for the corrective action: David Noble, Director, Grant Administration Anticipated Completion Date: Consistent with 2024 Financial Audit Reporting

FINDING 2023-005 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Disbarment: Summary of Finding: Material Weakness, Modified Opinion An effective internal control system, which would include segregation of duties, was not in place at the County in order to ensure compliance with requirements related to the grant agreement and the procurement and suspension and debarment compliance. Prior to entering into subawards and covered transactions with Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), SLFRF funds, recipients are required to verify that contractors and subrecipients are not suspended, debarred, or otherwise excluded. Upon inquiring of the County to determine its policies and procedures related to suspension and debarment requirements for the CSLFRF, SLFRF funds, the County stated procedures were not in place to ensure vendors were not suspended or debarred prior to entering into covered transactions. The County had not performed procedures to ensure the vendors were not suspended or debarred or otherwise excluded or disqualified from participation in federal assistance programs or activities during the audit period on all of the 13 vendors determined to have covered transactions totaling $4,440,497, that were paid with SLFRF funds. The lack of internal controls and compliance under the previous Auditor Timothy J. Stabosz were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Michael Rosenbaum Contact Phone Number and Email Address: 219-326-6808 Ext. 2226; mrosenbaum@laporteco.in.gov INDIANA STATE BOARD OF ACCOUNTS 44 Views of Responsible Official: We concur with the finding under the prior Auditor Timothy J. Stabosz. Description of Corrective Action Plan: Policies and procedures will be put in place to search on sam.gov to determine if a vendor has been suspended or disbarred. Anticipated Completion Date: August 2025

FINDING 2023-004 Finding Subject: Drinking Water State Revolving Fund (DWSRF) Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will develop and implement a formal process for verifying that vendors are not suspended, debarred, or otherwise excluded from receiving federal funds before entering into contracts or transactions that meet or exceed the $25,000 threshold. The City will develop a purchasing policy that reflects the applicable state laws and regulations related to procurement. The City will also maintain proper documentation to support the appropriate procurement method. Anticipated Completion Date: December 31, 2025

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: As a measure of corrective action, I will be implementing a check sheet that will be attached to every claim sheet. This new procedure requires that you go through the check sheet and initial each item to ensure that all procedures have been followed correctly before submission. Additionally, I will also maintain a check sheet in my office since I am the last person to review each claim. This will help to ensure thoroughness and accuracy in our claims processing. Furthermore, moving forward, any grant funds will be placed into their own individual funds and distributed through an individual account. This approach will allow us to track payments for any expenses associated with these funds more effectively. Additionally, the BOT expenditure is done and in the future we will do a better job. Anticipated Completion Date: October 31,2025

Views of Responsible Officials: The cause is related to the digital nature of the drawdown process and staff turnover. ICFJ will institute a procedure to capture drawdown information and/or create a documentation at the time of drawdown. Storage of the documentation will be incorporated into ICFJ’s digital records storage.