Corrective Action Plans

Finding 2023-006 Cash Management – Timeliness of Subrecipient Payments Plan: The University of Illinois Chicago will send reminders to research administrators communicating the importance of timely payments to subrecipients. This University of Illinois Urbana-Champaign’s administering unit established an email alert to notify individuals when the central sponsored program office sends a subrecipient invoice. Also, an automated process creates a checklist for processing. Additionally, the Sponsored Programs Office will implement internal measures, including the development and implementation of a subaward invoice automation platform, to address inefficiencies related to the current multi-department review, approval, and payment process. Expected Implementation Date: UIC – March 2024 UIUC – June 2025Contact: Katrina Lopez, Assistant Director University of Illinois Chicago – Office of Sponsored Programs (OSP) klopez3@uic.edu 312-996-3782 Justine Story, Director Budget and Resource Planning, Sponsored Research Administration Carl R. Woese Institute for Genomic Biology University of Illinois Urbana-Champaign jrussian@illinois.edu 217-244-0131 Karen Thomas, Director Post-award Sponsored Programs Administration University of Illinois Urbana-Champaign Kthomas2@illinois.edu 217-265-4096

Department: Health and Human Services Title: Internal control over subrecipient cash management needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Department believes that we are in compliance with the requirement for minimizing the time between payments to our subrecipients and the disbursement is as close as administratively feasible. The Department's procedures related to cash management include: reconciling payments to expenditures quarterly and monitoring subrecipient's audits. The Department's subrecipients not only are required to have Single Audits but also are required to have audited financial statements and audited Schedule of Expenditures of Department Awards at a lower threshold than that of the Single Audit through the Department's rule, Maine Uniform Accounting and Auditing Practices for Community Agencies (MAAP). This rule also defines a major program at a much lower threshold than the Uniform Guidance, so far more programs get tested annually than just Single Audits alone. Completion Date: N/A Agency Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

There are 10 audit findings total in calendar year 2022 and are all connected to a former staff person in the accounting function and also in the Trio Upward Bound program. In January 2023, we hired a new Manager of Account Services who immediately implemented new procedures and prepared the appropriate level of detail backup information for the TRIO reimbursements. Each reimbursement was also reviewed and signed by the Controller, who verified the information and transactions before any funds were transferred. This process currently complies with cash management requirements. A new Trio Upbound Bound Director was also hired in fall 2023. Contact person(s) responsible for corrective action: Cassandra Turner, Manager of Account Services, and Sheila M. Brooks, Controller/Director of Business Services (new January 2024) Anticipated Completion Date: Immediate

Finding 2023-005 Cash Management – Timeliness of Subrecipient Payments Condition: Northern Illinois University (the University) did not make certain subrecipient payments timely under the Research and Development Cluster and the Professional and Cultural Exchange Program. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) The University will review and update its current processes, policies and procedures to minimize the time between the transfer of federal funds to the subrecipient. Individual(s) Responsible for Corrective Action: Sponsored Programs Staff Anticipated Completion Date: June 30, 2024

Finding Number: 2023-001 Condition: Out of 20 payments to subrecipients that were tested, 3 were made after the 30 calendar day requirement. Planned Corrective Action: The University has established subrecipient monitoring procedures. Included in those procedures is the control to monitor the 30 day payment requirement. 2 of the payments were during the major service disruption of the entire university network. We have now implemented weekly backups to the network folders that contain our subrecipient monitoring files. 1 of the payments was due to the department not sending us the invoice timely. We plan to do follow up trainings to educate departments and PIs on the requirement for providing payment within 30 days of receipt of invoice to assure payment is made within the 30 day requirement. Contact person responsible for corrective action: Betty McKain, Sr Director Research Administration Anticipated Completion Date: 06/30/2024

Condition - The District's expenditure report filed for June 30, 2023 included expenditures in the amount of $171,918 that were not disbursed as of June 30, 2023. These amounts were not reported as committed or obligated on the June 30, 2023 expenditure report. Plan - Management will monitor expenditure reports to ensure that amounts claimed have been disbursed prior to submitting the report or include them as obligated and file liquidation reports as needed. Anticipated Date of Completion - June 30, 2024. Name of of Contact Person - Tim Farquer, Superintendent. Management Response - There is no disagreement with this finding and management will monitor all future federal reimbursement requests. Committed or obligated expenditures will be reported appropriately. Additionally, the grant expenditures in question were liquidated within 90 days of the fiscal year end.

Condition - The District does not have internal controls in place to prevent expenditure reports being submitted that include expenditures that have not been spent or committed or obligated. Plan - Management will implement internal controls to ensure proper expenditure reports are being submitted. Anticipated Date of Completion - June 30, 2024. Name of Contact Person - Tim Farquer, Superintendent. Management Response - There is no disagreement. The District will implement internal controls to ensure expenditure reports are being submitted accurately.

Condition - The District's expenditure report filed for June 30, 2023 included expenditures that were not disbursed as of June 30, 2023. These amounts were not reported as committed or obligated and were not liquidated within 90 days of the end of the fiscal year. Plan - Management will monitor expenditure reports to ensure that amounts claimed have been disbursed prior to submitting the report or included them as obligated. Anticipated Date of Completion - June 30, 2024. Management Response - There is no disagreement with this finding and management will monitor all future federal reimbursement requests. Committed or obligated expenditures will be reported appropriately, and will be liquidated within 90 days of the end of the fiscal year.

Condition - The District does not have internal controls in place to prevent expenditure reports being submitted that include expenditures that have not been spent, committed, or obligated. Plan - Management will implement internal controls to ensure proper expenditure reports are being submitted. Anticipated date of Completion - June 30, 2024. Name of Contact Person - Jerry Becker, Superintendent. Management Response - There is no disagreement. The District will implement internal controls to ensure expenditure reports are being submitted accurately.

2023-002: Cash Management-Subrecipient Federal Program Title: Research and Development Cluster Assistance Listing Number: Various Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: ISU should evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant accounting staff will follow payment requests through the system to make sure payments are made in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Kirsten Broughton, Director Grant Accounting Planned completion date for corrective action plan: Implemented in FY24

FINDING 2023-009 Finding Subject: COVID -19 - Education Stabilization Fund – Cash Management Summary of Finding: The School Corporation had not properly designed or implemented a system of internal control, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting noncompliance related to the Cash Management compliance requirement. Reimbursement requests for the programs were prepared by an employee and reviewed by another employee. While the School Corporation did have a process in place to review and approve reimbursement requests, not all reimbursement requests were traceable to the fund ledger and no audit evidence was provided to indicate the reviewer verified disbursements to the School Corporation records. Three of five reimbursement requests filed during the audit period were not traceable to the Schools Corporation’s fund ledger. Due to the lack of supporting documentation it was not possible to determine if grant payments were reimbursements of expenditures or advance payment of grant funds. The lack of internal controls and noncompliance were systemic issues throughout the audit period. The noncompliance was isolated to three of the five reimbursement requests filed during the audit period. Contact Person Responsible for Corrective Action: Todd Balmer, Assistant Superintendent/CFO and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 tbalmer@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The same process will be in place to review and approve grant reimbursements. The Deputy Treasurer will verify with the person preparing the reimbursement that the proper accounting information is on the receipt and that it is then receipted into the correct account in the FMS System and sign off. The Corporation Treasurer will review all receipts and be the second signature. Each month the accounts will be checked for accuracy by the grants person and the Corporation Treasurer will again be the second check for accuracy. The grant person will verify that the reimbursements of expenditures or advance payments are clearly marked and accounted for in the FMS System and sign off. The Corporation Treasurer will be the second signature. When reimbursements are prepared, these entries will also be reviewed. Anticipated Completion Date: March 2024

Management Response and Corrective Action Plan CRRUA has not previously required a single audit under Uniform Guidance, CRRUA will work with DAC Grant and Accounting team, who assist in oversight per contract agreement, to develop written procedures and policies per Uniform Guidance requirements. In addition, CRRUA will enlist external assistance for additional review and recommendations regarding the drafted policies and procedures. Finding resolved timeline: Implemented by June 30, 2024. In the next 3 months CRRUA will implement policies and procedures required to conform with Uniform Guidance. Designation of employee position responsible for meeting this deadline: Juan Carlos Crosby, (Interim) Executive Director and Mary DeAvila, Office Manager

As noted in the last fiscal year audit, we incurred the same finding. Immediately after the auditors helped bring the finding to our knowledge, we began procedures to fix and prevent from re-occurring. We began to draw down the actual expenses instead of our budgeted expenses. Our TSL Technical Assistance vendor reconciled all of our incorrect drawdowns and created one final lump sum drawdown to appropriately balance the G5 account. We have since worked closely each month with our RSS payroll department to ensure monthly expenses are correct. If they are incorrect, we make sure they are fixed and accounted for all within the same month.

Condition - The District's expenditure report filed for June 30, 2023 included expenditures in the amount of $27,366 paid in September 2023. These amounts were not reported as committed or obligated. Plan - Grant expenditure reports will be prepared on the cash basis and obligations reported. The liquidation of the obligations will be reported on subsequent liquidation reports. Anticipated Date of Completion - June 2024. Name of Contact Person - Dr. Eric Heath, Superintendent. Managment Response - There is no disagreement with this finding and management will monitor all future federal reimbursement requests.

FA 2023-001 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Cash Management Program Income Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425U210012 Questioned Costs: $309,623 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School emergency Relief Fund Program. Corrective Action Plans: No after-school program expenditures have been or will be included int eh ESSER expenditures for FY2024. Estimated Completion Date: July 1, 2024 Contact Person: Chris Griner, Chief Financial Officer Telephone: 706-546-7721 Email: grinerc@clarke.k12.ga.us

For the Year Ended June 30, 2023 Finding 2023-002 Condition #2: The University withdrew the current year budget amount for one grant for $176,615 before incurring allowable expenses and did not disburse the funds within three days. The University kept the funds in an insured account and used the funds on eligible expenses by June 30, 2023. The internal controls over cash management were not operating effectively. Corrective Action Planned: A desk review of ALN 47.076 National Science foundation (NSF) occurred in August 2023 and identified 17.76%, the current year annual budgeted amount, had been drawn down in advance of expenditures incurred and not fully utilized as indicated in 2 CFR 200.305 Federal Payments. MMU has discontinued the practice of drawing down funds in advance based on the budgeted amount for each year of the project (as prior grants allowed). Instead, MMU will draw down funds based on immediate cash requirements each month of the project after expenditures are incurred, reflected in the general ledger system and reviewed by the Principal Investigator (PI)/Co Principal Investigator (Co-PI) and Senior Accountant. The Business Office has implemented a cash management control as follows: Review financial requirements upon grant submission and again when awarded, adjust accounting controls according to grantor requirements, actively participate in monthly review of financial reporting to grantor and document all financial activities as required Name(s) of Contact Person(s) Responsible for Corrective Action: Cheryl Bailey (PI), and Kathleen Glancey (Co-PI) and Nicole Biddle, Senior Director of Finance. Anticipated Completion Date: Grants Manager, Kathleen Glancey, has experience with grant reporting and management systems. Cheryl Bailey (PI) and Kathy Glancey met during the month of September 2023 to create an updated grants management manual that contains policies and procedures to encompass all federal sponsored programs. MMU shared the grants manual with NSF by September 30th, 2023. Immediately upon completion of manual and submission to NSF, monthly meetings commenced to implement financial review of incurred expenses prior to cash draws. The complete action plan was implemented upon the desk review which was 4 months prior to the Single Audit.

FINDING 2023-003 Information on the federal program: Subject: Education Stabilization Fund – Advance Draws Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Qualified Opinion Condition: The School Corporation requested reimbursement prior to incurring expenditures under federal grant awards. An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Context: During testing disbursements charged to ESF grants, we noted advance payments were received during the audit period prior to allowable costs being incurred by the School Corporation impacting the following Education Stabilization Fund grant awards: ● The School Corporation submitted a claim for reimbursement for $43,864 from the ESSER I grant award (84.425D) which was receipted on August 24, 2021. As of August 24, 2021, the School Corporation had incurred $41,674 of grant expenditures. The remaining $2,190 was disbursed on April 12, 2022. ● The School Corporation submitted a claim for reimbursement for $148,822 from the ESSER II grant award (84.425D) which was receipted on July 28, 2021. There were no expenditures incurred as of the date of the reimbursement request. The School Corporation began incurring expenditures after the advance payment, however, as of June 30, 2022, the School Corporation had an unspent cash balance of $24,613 in the ESSER II fund because of the advance payment. The School Corporation did not request any reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an unspent cash balance of $16,145. FINDING 2023-003 (Continued) ● The School Corporation submitted two claims for reimbursements from the ESSER III grant award (84.425U) during fiscal year 2022. The first claim reimbursement was receipted on November 24, 2021, in the amount of $52,210. The second claim reimbursement request was receipted on June 22, 2022, in the amount of $144,649. The School Corporation had incurred expenditures as of the date of each claim reimbursement requests, however, the amount claimed for reimbursement exceeded expenditures incurred resulting in advance payments being received. As of June 30, 2022, the School Corporation had an unspent cash balance of $88,348 in the ESSER III fund as a result of the advance payment. The School Corporation did not request any claims for reimbursements for the period of July 1, 2022 through June 30, 2023 and continued to incur expenditures. As of June 30, 2023, the School Corporation had an unspent cash balance of $21,842 in the ESSER III fund because of the advance payments. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Going forward the reimbursement will be prepared by the Assistant Superintendent once the funds have been spent and the Corporation Treasurer will review the reimbursement before it is submitted. Responsible Party and Timeline for Completion: The Assistant Superintendent, David Hobaugh, and the Corporation Treasurer, Kristina James, will oversee the corrective action plan and will be implemented immediately.

Corrective Action Plan: The University will remit annually any interest earned in excess of $500 to the Department of Health and Human Services. Implementation Date: 2/2024 Responsible Person: Andrea Wright, Executive Director of Accounting Services

FINDING 2023-003 Information on the federal program: Subject: Education Stabilization Fund – Advance Draws Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs- Cost Principles Audit Finding: Material Weakness, Other Matters Condition: The School Corporation requested reimbursement prior to incurring expenditures under federal grant awards. An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs- Cost Principles compliance requirements. Context: During testing disbursements charged to ESF grants, we noted the ESSER I grant award, tracked in Fund 7940, and the ESSER III grant award, tracked in Fund 7932, had a positive cash balance of $2,718 and $35,661, respectively, at June 30, 2023 as a result of advance payments received during fiscal year 2023. The School Corporation submitted a request for reimbursement on November 15, 2022 for $21,745 from the ESSER I grant award and $565,876 from the ESSER III grant award, respectively. These requests for reimbursements were partially supported by disbursements incurred as of the date of the request, however, partially include requests for advance payments that were still not fully expended as of June 30, 2023. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. If there are any posting corrections after a reimbursement has been made and received, the Corporation Treasurer will contact IDOE (Indiana Department of Education) asking whether they would like the difference between the reimbursement and the new disbursement amount paid back to DOE or spent down within a specific time period. Responsible Party and Timeline for Completion: The Corporation Treasurer, Emma Conwell, will oversee the corrective action plan which will be implemented by June 30, 2024.

Finding 2023-001 & 2023-002 Internal Control over Compliance and Compliance with Cash Management Responsible Official’s Response and Corrective Action Plan Pursuant to s. 216.181(16)(b), F.S., 2 CFR § 200.305(8) and (9), Federal payment, and DEL Program Guidance 240.01 – Cash Management Procedures, the Early Learning Coalition of Southwest Florida will invest the funds it receives under the Florida Department of Education’s Division of Early Learning (DEL) Grant Agreement in secure, interest-bearing accounts, unless DEL otherwise authorizes. The ELC shall return to DEL all interest income earned on VPK funds and interest earned on CCDF funds in excess of $500 for the program year. The ELC shall notify DEL if there are no interest payments due to be returned. The target date for completion is on or before September 1, 2024. The immediate goal is to comply prior to the new contract year beginning July 1, 2024. However, if meeting compliance requirements precipitates a change in banking institutions, this change would require implementing a procurement process in compliance with s. 287.057, F.S., and 2 CFR Parts 200.318-320. Anticipated Completion Date: September 1, 2024 Responsible Party: Melanie Stefanowicz, Chief Executive Officer

DEP will ensure appropriate language as per 31 CFR Section 205.33 (a) of the Treasury-State Cash Management Improvement Act (CMIA) to be included in all Delegation Memorandum of Understandings (DMOU) and Letter of Commitments (LOC) for all future Capital Budget Projects to ensure the expenditure of federal monies is consistent with the progress of the project. Anticipated Completion Date: Completed Contact Names: Patrick Webb, Director, Bur. of Abandoned Mine Reclamation; Tim Golding, Exec. Assist., Office of Admin. and Management

Program: AL 12.401 – National Guard Military Operations and Maintenance (O&M) Projects – Cash Management & Reporting Corrective Action Plan: The Agency will increase continued trend analysis efforts and shift functional responsibilities back to the State Services Support Division for more detailed oversight moving forward now that vacancies have been filled. The Agency will explore the feasibility of increased frequency of funding requests to decrease the amount of time between the Federal draw and the disbursement of funds by the State. Contact: Lauren Hargreaves Anticipated Completion Date: Ongoing

FINDING NO. 2023-002 - TRANSFER OF FUNDS BEYOND THE REQUIRED TIME LIMITS CONDITION During our field work in the cash management area, we noted funds that were requested to G-5 but not disbursed by UPM to minimize the time elapsing between the transfer of funds and disbursement as follows: Descriotion Dates Amount Funds received from G-5 on June 8, 2022 6/8/2022 $610,710.35 Funds disbursed during 2022-2023 Fiscal vear 2022-23 (525,362.27) Available balance from funds received in 6/8/2022 6/30/2023 $75,348.08 Funds received from G-5 on June 22, 2023 6/22/2023 $319,251.71 Funds disbursed at the end of fiscal year 2022- 2023 6/30/2023 (45,000) Available balance from funds received in 6/22/2023 6/30/2023 $274,251.71 RECOMMENDATION The University should reinforce the procedures the draw down of funds to comply with the regulation applicable for the transfer of funds through the G-5 system. Corrective Action Plan: "Corrective Action Plan: UPM acknowledges that recommendation 2023-002 by Mr. Santiago is correct; however, the Dean of Administration and Finance, who assumed this position on February 21, 2023, wishes to explain the reasons behind this occurrence. UPM managed the HEERF funds without prior experience and knowledge of their administration. The officials at that time were unclear about the rules and procedures for managing these funds because the contract details were not received by UPM, preventing them from establishing spending and disbursement policies. Additionally, UPM was without a president for 6 months, and after appointing a president, it operated for approximately a year without a permanent Dean of Administration and Finance. The employees in the Dean's office were not authorized for this level of decision-making, while time continued to pass. Furthermore, there were several changes in the members of our Higher Education Council. As soon as the Dean of Administration and Finance was appointed, consultations with the president were held to make decisions regarding the disbursement and expenses of these funds, which were implemented in June 2023. As a corrective action plan for the future, we will review all certifications related to federal funds management, prepare a comprehensive folder, and administer these funds while adhering to each of these measures. We will proactively identify our needs and align them with the award, clearly defining each process and protocol with the intention of compliance." During the last fiscal year. the Council of Theological Education approved new regulations for: 1. Regulation for the Acquisition of Equipment, Materials, and Non-Personal Services at UPM. 2. Regulation for the Administration of Movable Property (Equipment) at the UPM. hese new regulations complement the existing rules to ensure the integrity, preservation, accessibility, legibility, and legality of our financial actions. We will continue to work together to standardize our processes and address any non-compliance on our part.

Corrective Action Plan FY2023 2023-001 Federal Agency - Multiple Federal Programs - Research and Development Cluster Finding Type - Significant deficiency Repeat Finding - No Criteria As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition The University did not have adequate controls in place to ensure invoices to subrecipients were paid timely within the 30-calendar-day requirement. Questioned Costs There were no questioned costs identified. Identification of How Questioned Costs Were Computed There were no questioned costs identified. Context Out of 60 payments to subrecipients that were tested related to the R&D Cluster, 8 were made after the 30-calendar-day requirement. In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 31-49 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect While the University had effective controls that were successful in achieving the 30-calendar-day requirement for 52 samples, the University failed to provide supplemental support and preventative controls during a period when they were addressing an issue that prevented timely payment for certain subrecipients. Recommendation The University should ensure appropriate training of employees is taking place and a preventative control is implemented to ensure that payments are made within the required timeline.   Views of Responsible Officials and Corrective Action Plan - Purdue University will address the recommendations and implement the following preventative controls to ensure that payments are made within the required timeline. 1. The Office of Research will increase the priority around the 30-day processing deadline mandated by the Uniform Guidance 2 FR 200.305 (b)(3). This will be accomplished through communications, training and expectation setting with the following audiences: a. Principal Investigators of active grants with sub-awards i. Blanket communication ii. Add the expected turnaround time on each sub-recipient communication when seeking principal investigator review and approval b. Sub-award Team in Sponsored Program i. Blanket communication ii. Add the expected turnaround time to the expectations document for each Sub-Award Team Member iii. Add sub-recipient payment deadlines to the mandatory training for the Sub-Award Team iv. Update payment terms to “Payable immediately Due net; Based on Doc Date” for all subrecipient invoices 2. We will begin using the date the invoice is received at Purdue in our financial system instead of the date on the invoice for tracking purposes. 3. Create a report for internal reporting and tracking of pending sub-invoices to improve awareness of payments approaching the 30-day deadline.

Management agrees with this finding and will write policies and procedures for Federal awards.