Corrective Action Plans

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

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.