Corrective Action Plans

Federal Award Findings Finding 2023-001 Lack of Internal Controls Over Cash Management Name of Contact Person: Galen Gilbert, First Chief Corrective Action Plan: AVC staff were unable to complete a drawdown for the HUD grants due to a change in staff. AVC is working with HUD to resolve the matter. AVC staff is currently drawing down all other funds in a timely matter. AVC has limited unrestricted cash. AVC is currently looking for opportunities to increase unrestricted cash, such as increasing prices for gas and electric. Proposed Completion Date: July 31, 2024

Condition: The Organization did not have appropriate segregation of duties surrounding the preparation and review of the monthly NIST schedules which accumulate the information necessary to calculate allowable costs and matching for drawdown requests. Further, while the Organization had written procedures over cash management, they were outdated and did not reflect the current staffing model. Planned Corrective Action: Subsequent to year end, the reorganized finance team put new controls and procedures in place. Moving forward the Accounting Supervisor will calculate the NIST MEP monthly program income which is used to determine the monthly award drawdown of cash from the available grant award funds. This is reviewed by the Controller and this report is used to create SF-425. Contact person responsible for corrective action: Alan Kowalewski, Controller Anticipated Completion Date: 07/01/24

A grant manager and grant-financial coordinator have been hired to work with the finance team to communicate the whole gamut of applicable elements of ASC 606. Also, we are purchasing a grant management system—not a manual Excel sheet- that can scan grants and identify conditions and restrictions.

Finding: 2023-005 • Condition: There are no written policies and procedures for allowable costs/cost principles, cash management, procurement and suspension and debarment requirements. • Planned Corrective Action: Financial policies and procedures will be created and implemented. Contact Person: Katherine Jaeger Anticipated Date of Completion: 6/30/2025

FA 2023-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: SO10A210010-21A (Year: 2022) SO10A220010 (Year: 2023) Questioned Costs: None Identified Repeat of Prior Year Finding: FA 2022-003, FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and School Emergency Relief Fund programs. Corrective Action Plans: District office has put procedures in action to make sure that all drawdowns are in line with expenditures. All draw down packets will be viewed and singed off by federal programs director. This packet will include detail expenditure sheet for the month, year to date expenditure report and a cover sheet. Estimated Completion Date: December 31, 2024 Contact Person: Torrence H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

FA 2023-003 Improve Controls over Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Prior Year Finding: None Description: The School District made cash drawdowns in excess of immediate cash needs for the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: The district will implement procedures to ensure all drawdowns align with expenditures. The program director or coordinator will view and sign all draw- down packets. The packets will include detailed expenditure reports for the month and year-to-date of the expenditures that are a part of the requested drawdown. Estimated Completion Date: June 30, 2024 Contact Person: Daisy M. Prather, Finance Director Telephone: (478) 836-3131 extension 106 Email: daisy.prather@crawfordschools.org

Views of Responsible Officials: Federal grant requests and reporting is the function of three teams: Programs, Development and Finance. Prior to the hiring of the VP-Finance, the Associate Director, Grants Management and Compliance met with the Associate Director, Partnerships on a quarterly basis to discuss required program spend reimbursements and projected program cash needs prior to submitting the formal requests. With the onboarding of the new VP-Finance, internal review processes were changed to incorporate more robust segregation of duties, alignment with the internal cash management policies and procedures and formal review of drawdown requests prior to submission. The VP-Finance became a permanent employee in October 2024 so the anticipated completion date of this corrective action is the end of the respective calendar quarter (December 31, 2024).

Management acknowledges that improvements were necessary in assuring that drawdowns of grant funds are in compliance with regulations. Accordingly, drawdowns of grant funds will be more aligned with bi-weekly and/or monthly expenditures as supported by an analysis of payroll and accounts payable system activity by the Chief Financial Officer prior to authorizing any drawdowns. This process revision will be implemented no later than March 31, 2025.

Auditor’s Recommendation: The Organization document internal control over compliance procedures and document written procedures to ensure compliance with 2 CFR 200.305. Corrective Action: Implement Policy A10 – “Grant Management Protocols.” Utilize Donor Database for managing subawards. Responsible for Corrective Action: Finance Team (Outsourced accounting firm, Operations Manager, Executive Director) Anticipated Completion Date: December 31 2024

CDFI ERP Program (COVID-19) – Assistance Listing No. 21.033 Recommendation: Management should develop a procedure to track its federal award advances to ensure those funds are placed in interest-bearing accounts, when applicable, and any interest earnings on those funds are separately tracked, reported, and remitted in accordance with the program requirements. A documented review of this activity should be performed by a knowledge individual who is aware of the program requirements prior to reporting or remitting payment back to the federal agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will ensure funds that are not being used from federal awards be placed in interest-bearing accounts and any interest earnings on those funds will be tracked. Name(s) of the contact person(s) responsible for corrective action: Arlo Washington Planned completion date for corrective action plan: January 1, 2025

Contact Person LeAnn Littlewolf, Executive Director Corrective Action Plan We are in the process of updating the Organization’s written policies and procedures to include the requirements of the Uniform Guidance. Completion Date Fiscal year end 2024

CORRECTIVE ACTION PLAN (Concerning Finding 2023-006) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Town Manager and Select Board will take the following actions to address finding 2023-006 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 has drafted, had approved and has implemented the new Internal Controls Policy that addresses this deficiency. This policy will includes 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. Anticipated Completion Date: This was completed February 20, 2024.

Condition: As a precondition to receive federal awards, prospective recipients must have effective internal controls over the federal award. As described in 2 CFR, Part 200.303, nonfederal entities must have certain written policies and procedures surrounding the management of their federal awards. Such policies should include procedures for collecting payments of federal funds per 2 CRF 200.305, cash management (i.e., minimizing the time between draws and actual disbursing of federal awards) per 2 CFR 200.302(b)(6), allowable cost per 2 CFR 200.403, and conflict of interest per 2 CFR 200.318. Per 2 CFR 200.319(d), the non-Federal entity must have written procedures for procurement transactions. Recommendation: The Authority should adopt written policies and procedures over cash management and allowable costs required under the Uniform Guidance. Planned Corrective Action: The Authority implemented these policies during the FY 2024 (BA054 Cash Management Policy and BA059 Authorization of Purchases). Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024

The County does not have a complete set of written cash management policies and procedures as required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Grantee Response: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.

FINDING 2023-004 Finding Subject: Twenty-First Century Community Learning Centers – Cash Management, Program Income and Reporting. Summary of Finding: The School Corporation had not established an effective system of internal controls related to the grant agreement and the Cash Management, Program Income and Reporting compliance requirements. Cash Management The school submitted reimbursement requests without taking into considering the program income or reducing the request by the program income earned due to the lack of adequate program income. Program Income Controls had not been designed or implemented adequately to ensure that the proper fees were assessed and that the cash collections remitted were accurate. Additionally, the school-maintained program income in a separate fund and comingled with other non-grant funded program revenues. The unit did not deduct program income from allowable costs prior to claiming reimbursement. Reporting The total requested reimbursements for the audit period were understated by $32,605 when compared to the ledger. Of the two End of Year reports selected for testing neither properly included program income that was received during the year due to inadequate tracking of program income. Contact Person Responsible for Corrective Action: Tracey Haas, Deputy Treasurer Contact Phone Number and Email Address: thaas@mcas.k12.in.us (219)873-2000 ext. 8346 Views of Responsible Officials: We concur with this finding. We are implementing a system of internal controls to strengthen our policies and procedures and ensure the proper tracking of Program Income is reported and submitted accurately for Twenty First Century Learning center grant funds. Description of Corrective Action Plan: We have reached out to our liaison at the Department of Education to determine if program income should be reported monthly or annually. Management will be working with the Safe Harbor Director to implement a system to ensure separation of the Twenty first Century grants and other funds that are under the Safe Harbor program. Anticipated Completion Date: The anticipated date of correction for this is January 1, 2025.

By the end of 2023, the organization adjusted processes surrounding cash management. Since December of 2023, the organization has requested funds after the end of the month based on the actual expenditures of that month to minimize the time elapsing between the transfer of funds from the grant program and disbursement by the organization. However, the audit firm is recommending that the process be in the form of written policies and procedures. We have complied and are following written policies, however the policies were not created before the end of 2023. The change in processing occured immediately upon notification, effective December 6, 2023.

The City will not draw down any grant funds prior to incurring the expenditure.

The County has written Policy and Procedures to be reviewed by the commission in November 2024 for approval. Responsible Official - Andrea Montoya, Deputy County Manager and Robert Placencio, Finance Director Timeline and Estimated Completion Date - November 2024.

Audit Finding Reference: 2023-003 Department’s Response: We concur. Views of Responsible Officials and Corrective Action: Not all reimbursement submissions were reviewed by someone other than the preparer prior to submission. Subsequent to June 30, 2023, CCEOK established an internal control that requires all requests submitted for reimbursement be reviewed by someone other than the preparer prior to submission. Name of Contact Person: Lisa Wheeler, CPA Director of Finance Lwheeler@CCEOK.org 918-508-7118 2340 N Harvard Ave, Tulsa, OK 74158 Projected Implementation: July 1, 2024

Action taken in response to finding: 1. Develop documentation procedures: In Progress a. Establish a standardized procedure for documenting the preparation and review of drawdown requests. 2. Select appropriate party for independent review: Complete 3. Store and maintain documentation in a shared location for future audit and review: Complete Name of the contact person responsible for corrective action: Keith Flores, CFO Planned completion date for corrective action plan: End of 2024

To address these issues - UPCEE has hired a new Contract Manager (that comes highly recommended and has worked successfully with other TRIO programs) who will continue to do the following: • Oversee office management processes, budgets, and enhance our current way of working with federal timelines. • Ensure billings are kept timely and entered in the financial system for QuickBooks Online and now updates data entry after each completed month. These changes allow for the immediate completion and availability of data to be used for 990 completion and audit processing. • Work in tandem with the UPCEE Executive Director to ensure these tasks are done. With the implementation of these new processes, UPCEE feels very confident that this will prevent any further need for risk management.

1. Cleveland UMADAOP will obtain written prior approval for any expenditure deviations from the originally approved budget. This topic will be covered when training occurs during the quarterly review of grant guidelines. 2. As part of its updated financial policies and procedures, Cleveland UMADAOP will seek to document all financial activity to ensure compliance with grant and federal guidelines. 3. As part of the updated financial policies and procedures, Cleveland UMADAOP will seek written confirmation from funders whenever there is a deviation from the terms outlined in the original award documentation. 4. As part of the updated financial policies Cleveland UMADAOP will be using the services of a virtual accounting firm that specializes in: a) standardized monthly financial reporting packages that will be reconciled to the approved budgets; b) standardized monthly close processes that lock transactions at the end of each month; and c) electronic document retention for A/P and A/R among other services.

As part of the on-boarding process with the virtual accountant, Cleveland UMADAOP will document its financial procedures to ensure consistent execution of financial activities.

Low-Income Home Energy Assistance Program (LIHEAP) – Assistance Listing No. 93.568 Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the reimbursement request and documentation be retained. Reconciliations should be reviewed and approved by an individual other than the preparer at the time of the request and this documentation should be retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: County department personnel changes have been implemented which address this deficiency. New department personnel have been properly trained by County Auditor staff as well as State grantor personnel to ensure proper compliance with all program requirements. Community Resources staff have been trained on keeping proper detailed records of all cash draws. Name(s) of the contact person(s) responsible for corrective action: Dave MacDonna, Director of Community Resources. Planned completion date for corrective action plan: July 1, 2024

Individuals Responsible for Corrective Action Plan: Kristine Steinmann, Alliance Director Shelby Mahoney, State Alliances Accounting Manager Corrective Action: The Alliance will enhance its procedures and internal controls around cash management to ensure that time between receipt of federal funds and payment to its local clubs is minimized. The Alliance will also request notification of funding from the agency. Anticipated Completion Date: December 31, 2024