Corrective Action Plans

FINDING 2022-006 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 67 Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

FINDING 2022-011 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Additional training related to grant budgets entered into and monitored within the financial software will occur, as will the new practice of having the program directors initiating monthly reimbursement requests informed by the accurate reports from the software (ledger), with documented review by the Treasurer or CFO. Additional training over the reporting requirements is taking place with the Treasurer, CFO and Directors overseeing federal funds provide accurate reporting. Anticipated Completion Date: June 2023

Findings Required to Be Reported by the Uniform Guidance Department of Education Finding: 2022-001 CFDA #: 84.425 E & F Recommendation: We recommend the College adopt the reimbursement method of cash management for all federal funding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Planned: Subsequent to June 30, 2022, we have disbursed all of the remaining Student Aid Portion and there are no remaining Higher Education Emergency Relief Funds subject to cash management compliance. The College already operates under the reimbursement method for all other federal funds. Name of Contact Responsible for Corrective Action: Mike Trochuck, Vice President for Finance, 708-239-4836. Anticipated Completion Date: Completed as of November 29, 2022.

FINDINGS - FEDERAL AWARD PROGRAMS AUDIT SIGNFICANT DEFICIENCY/COMPLIANCE 2022-01 Procurement Policies and Procedures Recommendation: Quotes should be obtained whenever possible when purchases are expected to be between $10,000 and $250,000. If purchases are to equal or exceed $250,000, the proper bidding procedures should be followed. Bidding procedures, quotes, and efforts to give preference to minority or women-owned businesses should be documented, including documenting if bids or quotes could not be obtained. A procurement policy should be established as soon as possible and an individual should be assigned to monitor the implementation of the policy. Action Taken: The Organization has begun the process of establishing a procurement policy and have it completed by March 16, 2023. The Organization will also go back to purchases starting July 1, 2022, that exceeded the micro purchase threshold of $10,000 and prepare the required documentation as listed in the recommendation. This will be completed by April 30, 2023. Any purchases exceeding the micro purchase threshold of $10,000 going forward will be supported by the required documentation.

Finding 2022-003 ? Special Education Cluster ? Cash Management Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Upon receiving invoices from K12 for programs funded through reimbursement grants, Union will issue payment immediately upon receiving reimbursement. Anticipated Completion Date: 06/30/2023

View of Responsible Officials Related to compliance with the CMIA, the Department of Energy acknowledges there were several instances where draws were not completed on a monthly basis for the prior month?s expenditures following the CMIA agreement in FY22. The Department of Energy has hired another staff person to complete business office grant-related tasks and will be reviewing and adjusting our policies and procedures if and where needed in the future. This staff person is still in training, therefore the completion date is not known at this time. Related to the timing of payments to subrecipients, due to staffing issues in both the Administrative and Fiscal offices, this recommendation is acknowledged and accepted. Support staff in both offices are being recruited and trained. This will ensure that adequate supervision and compliance of sub-recipient cash advances procedures are followed. Anticipated Completion Date: Ongoing Contact Person: Jane Lemire Business Administrator IV (PT) and Eileen Smiglowski, NH LIHEAP Administrator

Program: AL 12.401 ? National Guard Military Operations and Maintenance (O&M) Projects ? Cash Management & Reporting Corrective Action Plan: The USPFO Grants Officer Representative (GOR) will continue to work closely with the Cooperative Agreement Program Mangers (CAPMs) to track projected invoices so they are paid out in a timely fashion (per Federal Cash Management requirements) from the Cooperative Agreement advance funds (as required by the State). Also upon implementation of the recommendation to change the data in the SF270 (contained in the Exit Conference), the SF270 submission will track the availability of advance funds ? thereby preventing excessive advance funds requested ? and fully expending current available advance funds to the federal requirements. Contact: Matt Zeigler, Grants Officer Representative Anticipated Completion Date: Implementation will occur at the start of the new State Fiscal Year 01-Jul-2023.

View of Responsible Officials The State concurs in part with the premise of the findings identified, but it does not concur with the characterization of the Governor?s Office for Emergency Relief and Recovery (GOFERR), the process for authorizing the relevant subaward and relevant amendments, the nature of the subaward and amendments, or the recommended corrective action. Moreover, the full $49,250,000 identified in the finding was not provided to the subrecipient in one lump sum. The State was allocated $50,000,000 from U.S. Treasury for the purposes of designing and facilitating the State?s HAF program. The State received $5,000,000 from U.S. Treasury up front and received the remainder after approval of the State?s planned program. As a result, the State?s subrecipient received an initial subaward for administrative and planning purposes from within the initial $5,000,000 delivered to the State. The subrecipient was advanced only a portion of those initial funds and then was provided the remainder upon request and justification. A subsequent amendment to that subaward provided additional funds to the subrecipient as needed for the same purpose and as part of the U.S. Treasury required process of designing and then attaining approval for the State?s HAF program. The State ultimately received approval from U.S. Treasury for the State?s HAF program plan, which is a complex multi-faceted program that provides various forms of assistance to homeowners, and then received approval from State officials to launch the program. The State?s program is run entirely through a single subrecipient, New Hampshire Housing Finance Authority, which is the only entity of its kind as a statewide housing authority. This subrecipient facilitates a variety of larger-scale, federally funded housing programs. While developing the State?s HAF program and as it neared the launch date, the State began receiving preapplications through its subrecipient. Additionally, during this time, the State was facilitating its Emergency Rental Assistance (ERA) program, which has provided assistance to renters as opposed to homeowners and is facilitated by the same subrecipient of the State. Within the context of having received nearly 200 preapplications for the HAF program and witnessing a heavy and increasing demand in the rental assistance program, the decision was made to advance the remainder of the State?s HAF allocation ($45,000,000) to its subrecipient in order to provide prompt and adequate assistance, believing the program would experience high demand at the outset and funding shortfalls would be problematic for its success. Moreover, the amount of funds provided to the subrecipient was consistent with past advances to the same subrecipient under the ERA program, and as with prior delivery of funds, the subrecipient placed the funds in an appropriate account. However, demand for assistance did not unfold as anticipated due to the features of the program and the areas of need ultimately demonstrated by applicants after review and processing of initial applications. As part of the State?s monitoring protocols, and in part because of a lower initial expenditure rate than expected, the subrecipient began providing biweekly reports on the usage of funds, which the State has used as a measure of cash on hand. Moreover, the State also engages in standing, calendared, weekly calls with the subrecipient to discuss these reports. The State has provided documentation to support the process outlined above as well. Finally, as a result of the State?s remaining HAF allocation having already been provided to the subrecipient, the recommended corrective action is not feasible. However, the State acknowledges the need to more formally memorialize its review of the subrecipient?s cash on hand. As a result, the biweekly reports received and reviewed by the State will now include a specific section providing such information; review and discussion of that data will be incorporated into the weekly calls with the subrecipient, and the process and protocols will be documented in the State?s transaction processing memo for the program. Corrective Action Incorporation of cash on hand related data in biweekly reports received and reviewed by the State, documentation of that review as part of the weekly calls with subrecipient, and memorialization of the process and protocols in the State?s transaction processing memo for its HAF program. Anticipated Completion Date: Cash on hand data into biweekly reports and documentation of review said data as part of weekly calls with the subrecipient is being is actively being incorporated as of this response. The State will ensure that the transaction processing memo is updated with the requisite processes and protocols during the next update before the end of Q1 2023. Contact Persons: Chase Hagman, Lisa Cota-Robles, and Michele Zangri-Crean

The primary recipient of cash advanced under the SCRI program was the USDA Agricultural Research Service (ARS). The USDA-ARS Trust agreement with SHAC allowed for advancement of funds to the Federal agency so they could hire staff under their contracting agreements with the Department of Energy?s ORISE program. Funds are required up front for ORISE hiring contracts. USDA-ARS manages the risk by portioning out payments to ORISE so funds can be suspended upon unsatisfactory performance. Secondarily, cash advances were also made to the Land Grant University Subawardees for similar hiring and supply procurement reasons at the start of the grant. Due to extreme labor shortages caused by post-pandemic issues with available staffing, some positions remained unfilled for longer than expected, creating a discrepancy in expected expenses. This issue has been resolved. All Subawardee contracts were transitioned to a cost-reimbursement basis in the 2023-24 grant period. SHAC will ensure proper reporting of expenditures in a timely manner from its Subawardees through timely pursuit of invoices from University sponsored program offices. Relevant Personnel details: Mike Miyahira, Accountant, mike@shachawaii.org, Ph 808-987-8438 Suzanne Shriner, Executive Director, suzanne@shachawaii.org, Ph 808-365-9041

Recommendation: Management should do a thorough review of all contracts to ensure they are not drawing funds prior to incurring expenditures to ensure they are properly following cash management regulations for Federal contracts. Action Taken: Codman Square Health Center, Inc. (the Health Center) received a two-year $4.053 million HRSA Workforce Development grant from April 1, 2021, through March 31, 2023. The funding was provided to support staffing recruitment and retention efforts as summarized by HRSA ? ?On Thursday, April 1, 2021, HRSA awarded more than $6.1 billion in funding provided by the American Rescue Plan Act (ARPA) to 1,377 HRSA-funded health centers (activity code H8F). The purposes of the ARPA funding are to prevent, mitigate, and respond to Coronavirus disease 2019 (COVID-19) and to enhance health care services and infrastructure. Consistent with these purposes, funding may support a wide range of in-scope activities, which may change as COVID-19 circumstances and related community, patient, and organizational needs evolve over the two-year period of performance?. We began program implementation on September 6, 2021, and management drew down $1 million on November 17, 2021, to cover eligible spent monies for that period. An additional $1 million was drawn down on June 1, 2022, to cover eligible expenditures as of May 2022, in the amount of $1,176,844. It was anticipated that there was a total of $1.9 million in eligible expenses to be spent in the month of September 2022 which included items such as retention bonuses, leadership training, staff recruitment, and placement costs. These expenses were never realized prior to August 2022 draw down. The remaining HRSA ARPA funds were expended by March 31, 2023. The Health Center was consistent with adhering to the proper grant billing procedures for the first two drawdowns. The Health Center will follow HRSA Compliance requirements detailed in Compliance Requirements - Cash Management and will draw down HRSA grants on an incurred cost reimbursement basis. If the Department of Health and Human Services has questions regarding this plan, please call Sandra Cotterell at 617-822-8212.

Finding No. 2022-002 ? Cash Management View of Responsible Officials: The University maintains that it has policies and procedures in place to ensure expenditures are paid in accordance with 2 CFR Part 200.305(b) which requires non-federal entities to ??minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity??. The University states in Note 1 to the Schedule of Expenditures of Federal Awards that it reports expenditures on an accrual basis of accounting unless otherwise directed by the terms and conditions of the underlying awards. These accrued expenditures are paid on a timely basis in accordance with the University?s existing processes, thereby ensuring compliance with the requirements in 2 CFR Part 200.305(b). This finding is based on the results of testing for Audit Objective No. 4 in Part 3, Section C. Cash Management, in the Office of Management and Budget (?OMB?) Compliance Supplement issued April 2022 which states ?For grants and cooperative agreements to non-federal entities that are paid on a reimbursement basis, supporting documentation shows that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request.? However, as noted above, 2 CFR Part 200.305(b) requires only that non-federal entities minimize the time elapsing between the receipt of funds and the ultimate disbursement for the expenditures, and does not otherwise state that expenditures must be paid prior to the date of the reimbursement request. In October 2017, on behalf of its member institutions, the Council on Governmental Relations (?COGR?) issued a letter to the OMB Office of Federal Financial Management requesting that the Compliance Supplement be amended, followed by an update to 2 CFR Part 200.305, to address these inconsistencies. This request has not been addressed to date. The University will continue to monitor the OMB interpretation and responses to COGR?s request, and reevaluate its existing policies and procedures as necessary. Anticipated Completion Date: N/A

CORRECTIVE ACTION PLAN (Concerning Finding 2022-001) Contact Person Responsible for Corrective Action: Melody Ackerman, Executive Director Corrective Action: The Derry Housing and Redevelopment Authority will take the following actions to address finding 2022-001; The Derry Housing and Redevelopment Authority (DHRA) will select an accurate Rent Reasonableness system to use. Once an accurate NH022 Rent Reasonableness system has been selected, the PHA must update HCV Administrative Plan, including receiving Board approval, to document the use of this new system. The PHA must perform Rent Reasonableness determinations utilizing the Board approved methodology on all currently leased vouchers. The DHRA expects to have all corrections in place by December 1, 2023.

Finding No.: 2022-001 Condition: The District's expenditure report filed for June 30, 2022 included expenditures paid in July and August 2022. 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: August 31, 2022 Name of Contact Person: Tony Ingold, Superintendent Management Response: There is no disagreement with this finding and management will monitor all future federal reimbursement requests. Committed and obligated expenditures will be reported appropriately, and will be paid within 90 days after project completion.

Finding 2022-002: Grant Program/ALN #: Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease/ALN # 93.918 Federal Agency/Pass-Through Entity: U.S. Department of Health and Human Services Federal Award ID#: 5H76HA00151-31-00; 6H76HA00151-31-01; 2H76HA00151-32-00; 6H76HA00151-32-01 Name of Contract Person: Lito Landas, Controller Management Response: The Ryan White Part C program project period ended December 31, 2021 and a new project period started January 1, 2022 with the first federal financial report due in April 2023. Starting with the new program year, Valleywise Health management will develop and implement internal controls to ensure that program income is accurately calculated and reported in the federal financial report. Proposed Completion Date: March 31, 2023

Views of Responsible Officials and Planned Corrective Actions - SoutheastHEALTH ("SEH") has developed an organization policy for cash management for federally sponsored grant programs. SEH will generally use the reimbursement method unless there is an immediate cash need to minimize the time elapsing between the drawdown and disbursement of funds. Responsible Party: Krista Berry, Controller

The City is in agreement with the finding noted and will consider formally documenting policies and procedures. Heather Shippey, City Clerk will be responsible for the corrective action and anticipated completion of corrective action will be taken before September 30, 2023.

May 31, 2023 Finding 2022-001: 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 not a repeat finding. 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 was 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: May 31, 2023

Action item - Title 2022-002 - Time Elapsing Between Transfer of Funds and Disbursements Date Identified: March 2023 Status: (Open; In-process) In-process Description Time elapsed between the transfer of funds from the US Department of Education and UPPR disbursement, instances where found in which the time elapsed exceeds a reasonable time. Grantee Required Action: PUPR should identify a time control method to assist the University in reducing the time elapsing between the transfer of funds from the Federal awarding agency and its disbursements. Identified Root Cause: Lack of controls over the cash management requirement to maintain the advance method. Grantee resolution plan: Transfers and Disbursement process will be reviewed to minimize the time between drawdown and disbursement and comply with Federal regulations. Funds are regularly monitored to ensure that only needed funds for immediate use are drawdown. Drawdowns are initiated when accounting department send the Grant monthly reconciliation to Federal and State Funds Administration Office, Compliance officer reviews the reconciliation and Director of Federal Funds Administration determine needed funds to be requested. A new Enterprise Resource Planning (ERP) software it?s under implementation and will address this issue as part of the implementation process. Anticipated completion date: September 2023 Name and Title of contact person responsible for corrective action: Pablo Salom Portela- Director, Federal and State Funds Administration Office Phone: 787-622-8000 ext. 683 Email: psalom@pupr.edu

Finding Number: 2022-001 Condition: The College drew down an estimated amount for student and institutional portion prior to the funds being disbursed to students or used for allowable expenditures. Planned Corrective Action: The College will review its cash management policies and in the future follow U.S. GAAP and the uniform guidance. Contact person responsible for corrective action: Tom Reynolds, Associate Vice President of Business Services and Deputy Treasurer Lakeland Community College Anticipated Completion Date: As soon as possible moving forward starting 12/19/2022

2022-011 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, Sasha N. Lee. Planned completion date for corrective action plan: June 2023

Finding No.: 2022-002 Condition: The District's expenditure report filed for June 30, 2022 included expenditures paid in August 2022. 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 1, 2023 Name of Contact Person: Dale Heidbreder, Superintendent Management Response: There is no disagreement with this finding and management will monitor all future federal reimbursement requests. Committed and obligated expenditures will be reported appropriately, and will be paid within 90 days after project completion.

Finding Number Planned Corrective Action Anticipated Completion Date Responsible Contact Person 2022-001 We will continue to discuss and review the issue with our GAAP converter to make sure adjustments are properly made to the financial statements. May 31, 2023 County Auditor 2022-002 We will implement procedures to ensure all quarterly reports are submitted timely under this grant. December 31, 2023 Director of Morrow County Job and Family Services and Morrow County Area Transit

2022-034 Oregon Housing and Community Services Ensure review of subrecipient requests for funds verifies immediate cash needs are supported Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Families Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program 93.568 Low-Income Home Energy Assistance Program (COVID-19) Federal Award Numbers and Years: 2001ORE5C3, 2020 (COVID-19); 2102ORLIEA, 2021; 2102ORE5C6, 2021 (COVID-19); 2202ORLIEA, 2022 Compliance Requirement: Cash Management Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR ? 200.305(b), (b)(1); 2 CFR ? 200.508 Federal regulations require that auditees maintain documentation as needed for the performance of audit procedures related to the Single Audit. Additionally, regulations require payment advances should be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the subrecipient for carrying out the approved program. We reviewed 60 sample cash draws and were unable to obtain adequate supporting documentation for 4 subrecipient requests for reimbursement/advances demonstrating they were appropriate and for immediate cash needs. We also identified an advance payment for which there was not an adequate explanation indicating why an advance was needed. These 5 exceptions totaled $124,304 in expenditures. Department management cited a breakdown in control process and communicated their intention to train relevant staff to ensure adequate support is obtained. Without adequate verification of cash needs, the department could be sending funds to subrecipients that are not for a reimbursement of expenditures or immediate cash needs. We recommend department management strengthen internal controls to ensure support for subrecipient requests for funds adequately documents they are appropriate and for immediate cash needs. MANAGEMENT RESPONSE: We agree with this recommendation. Strong internal controls exist and costs were eventually substantiated and allowable, however OHCS had significant staff turnover and newer staff processing these advance requests did not gather the level of detail required by OHCS to substantiate draws in a timely manner. Training has been completed for FY23. Anticipated Completion Date: June 30, 2023 Contact: Beth Brown, Accounting Manager

2022-002 HEERF Institutional Aid Portion ? Assistance Listing No. 84.425F, Grant Period May 20, 2020 through May 11, 2022; and Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ? Assistance Listing No. 84.425E, grant period April 25, 2020 through May 11, 2022 Recommendation: Eastern Center for Arts and Technology should more closely monitor the timing of the expenditure of federal funds received. In addition, Eastern Center for Arts and Technology should return unexpended funds once the grant period has ended. Corrective Actions Plan: Moving forward, we will be creating a means of capturing federal grant costs by using funding sources that are provided through our financial software program to track and monitor federal grants. In doing this, it will allow us to account for the funds appropriately. The grant time frame for the expenditure of federal funds was extended to June 30, 2023. Due to this, we will not have to return any federal funding.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Melissa Hinds, Director of Special Education Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to cash management for the Special Education Cluster (IDEA), the District?s Treasurer and Special Education Director will review all cash balances quarterly to verify compliance with the grant agreement. As of July 2022, internal controls were put into place to ensure supporting documentation was attached to all reimbursements. Anticipated Completion Date: March 2023