Corrective Action Plans

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.

Finding 2023-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2023-002. Washakie County is currently working on implementing a more thorough tracking procedure in order to document all of the significant processes for our federal awards. Also, in order to further track funds disbursed, a sams.gov account has been set up and is currently utilized in order to determine if an entity is eligible for disbursement of federal funds. An amendment to implement sams.gov utilization will be produced in order to add it to our current Procurement Policy.

2023-005 – HEERF lack of compliance at one campus - (Significant deficiency) Cluster: Not applicable Sponsoring Agency: Department of Education (ED) Award Names: COVID-19 Education Stabilization Fund Award Numbers: P425E200430 and P425F201596 Assistance Listing Titles: COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and Institutional Aid Portion Assistance Listing Numbers: 84.425E and 84.425F Award Year: 2022-2023 Pass-through entity: Not applicable Cash Management Interest in the amount of $172,641.83 was remitted to DHHS on December 8, 2023. Effective June 2022, a new standard operating procedure (SOP) was implemented requiring a full reconciliation of costs prior to drawdowns to ensure only actual costs are drawn. The reconciliation must also be reviewed and approved by the Project Portfolio Financial Management Supervisor prior to the draw. The SOP applies to all Federal draws and therefore would apply to any “ad hoc” emergency programs moving forward. Eligibility In the event of any future “ad hoc" emergency federal programs with eligibility requirements, our policy has been updated as of 2/13/2024 to require two approvals and to document the approvals. • The reports used to determine student eligibility will be written and implemented by the Assistant Director of Financial Aid Systems. • The Deputy Director will then direct the awarding of direct grant payments which is executed by the Financial Aid Systems team. • Payments awarded to cover balances will be awarded by various members of the Financial Aid team during the processing of special circumstance appeals. Period of Performance As a result of the unallowable cost, the University took the following action in February 2024: • The Vice Chancellor for Student Affairs (VCSA) conducted a comprehensive review of current financial management policies and processes with specific attention to grant expenditure guidelines and timelines and provided training and educational resources to VCSA office staff since they do not ordinarily have responsibility for federal funding. Specifically, VCSA office staff have been trained on federal cost principles and now have responsibility for reviewing expense requests for allowability and allocability. Policies, training documents, and all resources developed as a result of this effort have been saved to a shared location for future reference. • Additionally, the unallowable charge identified in the audit was reversed and HEERF balance instead used for lost revenue previously accrued but not claimed. Reporting The Office of Financial Aid and Scholarships (OFAS) conducted a comprehensive review of the reporting process for HEERF and in October of 2023, established and documented a more systematic approach to reconcile the reports to the underlying data. At this time, updates to the 2022-2023 quarterly HEERF reports were also made. For inquiries regarding this finding, please contact Amanda Preston-Nelson at anelson10@ucmerced.edu who is responsible for the corrective action.

Federal Program Title: Research and Development Cluster ALN: Various Recommendation: We recommend the University 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 planned/taken in response to finding: Boise State University continues to review and enhance its internal subrecipient payment processes to find ways to identify and prevent untimely subrecipient payments, and to reduce the potential for human error. The University will implement additional internal measures to address inefficiencies related to the current multi-department review, approval, and payment process. Name(s) of the contact person(s) responsible for corrective action: Jen Lutke, Assistant Director, Post Award: jenniferlutke@boisestate.edu Planned completion date for corrective action plan: February 2024

Finding Number: 2023-001 Condition: Out of 28 payments to subrecipients that were tested, 12 were made after the 30 calendar day requirement. Planned Corrective Action: Accounts Payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, Accounts Payable will manually change the payment terms to 30 calendar days or less, to ensure compliance. Periodically, Accounts Payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable Offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by Accounts Payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and Principal Investigators (PIs) to highlight the need for prompt review and approval of Federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the university’s Fundamentals of Sponsored Administration training courses. Contact person responsible for corrective action: Accounts Payable: Erik Sager; Purchasing: Tom Guerin; Sponsored Research Services Accounting: John Ungruhe Anticipated Completion Date: Initial corrective action, including review of invoices, reminders and modifications to training, will be completed by 10/31/2023. Additional solutions to eliminate manual updates, if possible, will be completed within 12 months.

SUBRECIPIENT CASH MANAGEMENT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788 The West Virginia Department of Health and Human Resources, Bureau for Behavioral Health (BBH), analyzed this finding and hereby offers more details into the condition and cause of the finding. For the first noted exception, the grant was finalized on March 20, 2023. The BBH received the subrecipient’s first request for payment on April 12, 2023, at which point the reconciliation indicated that the subrecipient had incurred expenses of $118,186.21 to date. Although the reconciliation was not reviewed and approved by the BBH timely, it indicated that the subrecipient had not been reimbursed at all; therefore, the subrecipient had no cash on hand at the time of the request for payment. For the second noted exception, the BBH received the reconciliation on June 2, 2023. Although the reconciliation was not reviewed and signed by the BBH timely, it indicated $41,296.14 of cash on hand, which was under the 10% threshold established by the BBH when monitoring cash management for subrecipients of the Opioid program. For the third noted exception, the BBH received the reconciliation on March 14, 2023. Although the reconciliation was not reviewed and signed by the BBH timely, it indicated expenditures of $63,839.08 and cash on hand of only $18,070.92, which was less than the 10% threshold established by the BBH when monitoring cash management for subrecipients of the Opioid program. For the fourth noted exception, a processing error within the BBH caused the subrecipient to receive a payment that should have been held due to the subrecipient having sufficient cash on hand at the time of the payment. Nonetheless, after the period of performance, the subrecipient did not have excess cash on hand, or any cash on hand for that matter. The subrecipient returned $218,290.74 to the BPH on November 14, 2023 and $2,317.10 on November 29, 2023 in accordance with the closeout procedures referenced in 2 CFR 200.344(d). The total amount of $220,607.84 constituted the balance of unobligated cash that the BPH paid the subrecipient in advance and was not authorized to be retained by the subrecipient for use in other projects. In an effort to enhance internal controls, the BBH’s central level managers continue to work with internal and external parties to improve everyone’s understanding of the federal rules and regulations and the BBH’s existing policies, procedures, and overall expectations concerning subrecipient cash management.

SUBRECIPIENT CASH MANAGEMENT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.323, COVID-19 93.323 The West Virginia Department of Health and Human Resources, Bureau for Public Health (BPH), will analyze the condition that led to this finding in an effort to determine if the subrecipient has any excess cash on hand to date. In an effort to enhance internal controls, the BPH has initiated mandatory retraining for all staff members who are responsible for reviewing subrecipient expenditure reports and processing invoices. The retraining effort has already begun and will be conducted on a monthly basis for existing employees and at the start of employment for new staff members. The BPH has also developed and implemented a Subrecipient Grant Expenditure Checklist and Subrecipient Grant Invoice Checklist. The checklists outline the steps to take when reviewing subrecipient expenditures and invoices; provide a means to verify whether the grantee is under the 10% threshold established by the BPH when monitoring cash management for subrecipients of the Epidemiology program, including a means to compare expenditures between reporting periods; and require the staff member to certify that the reviews were completed.

Due to a turnover in the office of Controller, the Interim Controller drew down SIP grant funds for qualified purchases prior to the funds being disbursed, which is not the normal University procedure. The Interim Controller is no longer with the University, and the current administration has returned to the established University practice of not drawing down grant funds until payments have been made to vendors for grant purchases.

The Home contacted the Office of Refugee Resettlement (ORR) and was instructed to keep the funds and submit a carry-over request for these funds.

Condition: The College drew down an estimated amount of cash prior to the funds being disbursed to students or used for allowable expenditures. Planned Corrective Action: There is not anymore HEERF or federal stimulus funding to be drawn down moving forward. However, if there is in the future, the College will follow the three-day drawdown rules for cash disbursements. Contact person responsible for corrective action: Tom Reynolds College Treasurer Anticipated Completion Date: 12/14/2023 as soon as possible moving forward