Corrective Action Plans

Item 2023‐002 Written policies, procedures, and standards of conduct Recommendation: Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non‐Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: § 200.302 Financial management  § 200.305 Payment  § 200.319 Competition  § 200.320 Methods of procurement to be followed  § 200.430 Compensation—personal services  § 200.431 Compensation—fringe benefits We recommend that the City implement the required written policies and procedures. Action Taken: Management, namely Jan Boutwell, City Clerk, agrees with the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2024.

Federal Aid Policies Finding 2023-002 Auditor Description of Condition and Effect: The Authority’s management has completely turned over and been restructured. However, the Authority’s policies for federal aid approved in 2021 have not been revised to update for the current management structure. The policies have also not been updated for changes in the 2 CFR 200 that have occurred. As a result, the Authority is noncompliant with 2 CFR 200. Auditor Recommendation: We direct the Authority review and update all federal aid policies and implement procedures to ensure that they are being reviewed at least once a year for changes in the Authority’s management structure or changes that occur in the 2 CFR 200. Corrective Action Plan: The Authority will update their federal policies to comply with 2 CFR 200 and will review all policies on an annual basis going forward. Responsible Official: Contact person is Rufus Adams, Executive Director,275 East Wall Street, P.O. Box 837, Benton Harbor, Michigan 49023. Telephone (269) 927-2268. Due Date: September 30, 2024

Views of Responsible Officials and Planned Corrective Actions – We have since developed an organization policy for cash management for federally sponsored grant programs. SEH has provided and will continue to provide staff education on this policy in the future.

Medical Teams has identified the process gap that led to the delay of ths payment. A combination of system improvements and capacity building at the program and AP staff level will be implemented to ensure that review, approval, and payment processes are compliant and timely. Correction action plan will be led by the Controller, Matt Kinsella, and the Director of Global Finance, Florence Ruona. The corrective action plan has started in May and is anticipated to be completed by September 30, 2024.

Medical Teams International already has the personnel and resources needed to Calculate the interest earned in relation to Federal awards and included in the month close cycle process for tracking purposes. Medical Teams will set a process in place to ensure funds in excess of the stipulated $500, are identified during the year and remitted. This action plan will be led my the Director of Global Finance, Florence Ruona, with an estimated completion date of September 30, 2024

Finding 2023-001: Cash Management – Disbursement U.S. Department of Education – Education Stabilization Fund ALN 84.425F COVID-19 Institutional Portion Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Condition: Management implemented a financial management system that meets the specified standards for fund control and accountability, but the system failed to ensure disbursement of funds within the required timeframe. Questioned Costs: None noted. Repeat Finding: This is a repeat finding. Management was only made aware of this finding after it was repeated. Cause: Management did not accurately identify the required timeframe of disbursement for funds received under the Institutional Portion subprogram. A mitigating factor is the uniqueness of the Institutional Portion subprogram. Effect: Institutional Portion funds used to defray expenses associated with coronavirus were not disbursed within the required 3 calendar days of the drawdown from ED’s G5 grants system. Planned Corrective Action Management concurs with the finding. Since the program is not applicable to the organization after the issuance date of the financial statements, no corrective action is necessary. Responsible person: Sholom Goldstein, Executive Director Completed date: June 11, 2024

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

Name of Responsible Individual: Tyler Hosey, Senior Accountant Corrective Action: The University acknowledges that the internal controls surrounding the cash management of the Federal Research and Development Programs was not in compliance for federal standards. The University is in the process of enhancing the internal controls and cash management procedures to prevent this from happening in the future. Going forward all federal grant funds that are allocated for the Challenger Learning Center will go directly into the appropriate bank account and will be drawn down and spent in the correct time frame. When operating expenses are incurred for the Challenger Learning Center the payment will be processed from the University’s general checking and the federal grant funds will reimburse the University that day. The same is also true for the payroll expenses incurred by the Challenger Learning Center. Wages will be paid out of the university’s general checking account and then reimbursed to the university from the bank account that hold the federal grant funds. Anticipated Completion Date: June 2024

Finding 2023-004: 2023-004 - Significant Deficiency in Internal Control over Compliance and Noncompliance – Cash Management Contact: Michael Bailey, Chief Financial Officer Corrective Action Plan: The Accounting department at Alaska Behavioral Health has stabilized staffing in accounting personnel, including the replacement of the Chief Financial Officer. The CFO will develop and maintain a Master Grants tracking system that identifies cumulative allowable expenditures, determining the maximum cash drawdown of Federal Funds for the appropriate reporting time period and assuring that drawdowns are made in a timely manner. Proposed Completion Date: 09/30/2024

Contact Person – Krista Martin, Director of Finance and Administration, and Ryan Riesinger, Executive Director Corrective Action Plan – Review and update procedures to ensure accurate reporting. Completion Date –December 31, 2024

UWGC requires the practice of responsible, and reasonable procedures related to minimizing the time betweenreceipt funds from grant funders and disbursement for programmatic expenses as outlined below in the“PROCEDURE: Cash Management” below. The goal of this process is to ensure that federal funds received inadvance of the expenditure are segregated and expended in a manner to minimize the time between date ofreceipt and date of disbursement.

The YWCA will implement the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.

The YWCA will implement the following changes in its accounting procedures. Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.

March 27, 2024 2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Condition: 1) The Condition requested funds in advance of when the related distributions were made, 2) the basis for the advance (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Corrective Action: We agree with the finding. The Consortium has carefully reviewed our policies and procedures and have made the necessary changes to ensure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. We believe the updated procedures will result in the reduction over time and ultimately the complete elimination of this issue. Contact Person: Shamar Herron: Sherron@mwse.org Anticipated Completion Date: December 2024 Respectfully, Shamar Herron

Finding No. 2023-001 Cash Management – Drawdowns of funds Condition Found In two (2) of five (5) drawdowns selected for testing, we found that the disbursements were not transferred to the recipient in a timely manner. Views of Responsible Officials and Corrective Action Plan PRIFA is implementing a new procedure to make sure that funds are paid to DENR within 3 days. Name (s) of the Contact Person (s) Responsible for Corrective Action Nelson Perez, Secretary of the Treasury Department, Eduardo Rivera Cruz, Executive Director Puerto Rico Infrastructure Financing Authority and Anais Rodriguez Vega, Secretary Puerto Rico Department of Natural and Environmental Resources Anticipated Completion Date Immediately

2023-05: Timeliness of Deposits Name of contact person: Caroline Aultman, Executive Director Corrective Action: All receipts will be deposited in a timely manner once received by the Organization. Proposed completion date: The Board will implement the above procedure immediately.

Manuals with respect to Cash Management procedures will be updated to reflect proper disbursement procedures in order to comply with regulations. No longer will drawdowns be made for the totality of the services contracted or items purchased unless the related invoice is fully due for payment. In all other cases drawdowns will be made as payments are due

The Department concurs with paragraph A that some of the cash draws were not performed in a timely manner. The finding was due to a shortage of trained personnel. The Department is in the process of hiring and training additional personnel and reviewing its policy and procedures on cash draws. The Department concurs with paragraph B. The Department can show that the subrecipients disburse payments for program advances within a few weeks from original receipt starting with the first check runs to fuel vendors shortly after receiving the advance. However, the Department will work on reviewing its policies and procedures to ensure the Department monitors the subrecipients’ written procedures to minimize the time elapsing between the transfer of funds and disbursement by the subrecipient. The Department is also creating a tracking method to show the time elapsed when an advance is originally paid to the subrecipient and when it is fully disbursed.

2023-008 COVID-19, Education Stabilization Fund: Higher Education Emergency Relief Fund - Student Aid Portion and Institutional Portion – Federal Assistance Listing Nos. 84.425E and 84.425F – Cash Management Recommendation: We recommend the University formally document, establish controls and monitor advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is minimized and any interest required to be remitted is calculated and returned on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will formally document, establish controls and monitor advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is minimized and any interest required to be remitted is calculated and returned on a timely basis. Name(s) of the contact person(s) responsible for corrective action: Assistant Controller, Clifton Smith, II Planned completion date for corrective action plan: June 2024

Finding Reference Number: SA2023-003 Cash Management - Draw Down of Community Development Block Grant Funds in Advance of Disbursement Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-22-MC-06-0010 COVID-19 - B-20-MW-06-0010 • Fiscal Year of Initial Finding: 2023 • Name(s) of the contact person: Traci Cho, Accountant • Corrective Action Plan: The City will review the retentions payable when preparing the IDIS drawdown to ensure that retentions are not included in the drawdown amount. • Anticipated Completion Date: 06/30/24

Management Response: The BOCES will assure internal control procedures are in place to verify that all grant funding requests meet Cash Management requirements. Reimbursements will be requested subsequent to the expenditure of grant funds. The BOCES will establish internal controls whereby the grant manager determines the amount to be requested and this will be subsequently verified by finance staff to ensure that total requests do not exceed incurred or obligated expenditures. A review of the internal control procedures with all grant management and finance staff will assure that this is not a reoccurring issue.

This error occurred during a time of transition from one outsourced accounting firm and accounting system to another. The new outsourced accounting systems were not fully in place or automated at the time of the reporting error and there was no internal review process. The outsourced accounting firm is now fully transitioned, all systems are fully integrated with the accounting software, and the accounting team provides the program managers and organization managers with the reports needed to prepare drawdown requests. Cure HHT has developed and fully implemented a corrective action plan. The organization has communicated with the cognizant agency and all expenses eligible for submission for payment through grant funding will be submitted to and paid from the overdrawn funds. Once these funds are depleted, the organization will resume monthly draw submissions for all eligible expenses. The organization will reconcile all eligible expenses prior to requesting grant funds to avoid future duplicate and/or incorrect requests for grant funds. In addition, pending proper internal approvals of all submitted expenses, grant funds received will be dispersed within 3-7 business days from the date received.

Federal Agency Name: Department of Education Pass-through Entity: State of Iowa Department of Education Federal Financial Assistance Listing #84.287 Program Name: Twenty-First Century Community Learning Centers Program Cash Management Material Weakness in Internal Control over Compliance Finding Summary: No support could be provided for the third quarter draw requests to substantiate a secondary level of review was completed prior to submission of the draws. Documentation to support the review of draw requests prior to submission was not retained during the transition period in the Finance Director role. Corrective Action Plan: SHIP had a one-month period of transition in 2023 in which there was no one in the Finance Director role. The Executive Director took over those duties and also contracted for higher level review and approval from a third-party accounting firm during the transitional period. All draws were reviewed, approved and even supported by the Executive Director and the contractors. SHIP did provide current auditors with the time tracking from the contracted accounting firm that they did review the 3rd quarter report, the report was just not officially signed off on. Staff requesting the draw forgot to get one approval signature for quarter three, all others were signed. Moving forward, SHIP will re-train staff to ensure all draws are signed off on. Responsible Individuals: Mindy Baylor - SHIP Finance Director Anticipated Completion Date: September 2023

Reporting – Cash Management During the testing of the Department’s cash management procedures, it was determined that two out of sixty payments tested were not distributed within 21 days of the draw down of funds. For the items tested, the time elapsed between draw down and payment ranged to 28 to 57 days. Corrective Action Plan The Accountant draws cash from ASAP. After drawing federal funds, the Accountant sends the TDR to Budget and Finance (B&F) Treasury Management Section. B&F verifies the deposit and validates the TDR. Accountant will check Datamart daily to ensure funds are correctly posted in DataMart one day after B&F validates the TDR. The Accountant will also check DataMart daily to ensure adequate funds are available when invoice payment checks are processed. For payroll and indirect expenses, and DHO invoice expenditures and Pcard transactions the Accountant draws an estimated amount two days before the payroll cycle ends to be sure funds are available in Datamart. The Accountant checks the balance in DataMart daily. Implementation Date: April 1, 2024 Responding Official: Paul Uchima, WIC Administrative Officer

DSHA will establish robust internal controls to monitor and manage the funds held by our organization. We will include regular reconciliations and review to identify any interest accrued and ensure timely remittance to the Department of Health and Human Services. The HAF Program Manager and Financial & Reporting Section Manager will coordinate with the Director of Housing Finance and the Director of Financial Management to oversee this process and address any discrepancies in a timely manner. This corrective action plan will be implemented immediately to prevent any future delays. Responsible Official: Brian Rossello, Director of Housing Finance Completion Date: March 2024