Corrective Action Plans

Finding No.: 2022-003 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 should be prepared on the cash basis and obligations reported. The liquidation of the obligations should be reported on subsequent liquidation reports. Anticipated Date of Completion: August 31, 2022 Name of Contact Person: Chuck Milem, 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.

Federal Award Findings Finding 2022-001 Lack of Internal Control Over Cash Management Name of Contact Person: Galen Gilbert, First Chief Corrective Action Plan: AVC staff were unable to complete a drawdown for the DOJ grants due to a technical matter that suspended drawdowns in the ASAP system. The technical matter has been resolved. AVC staff is currently drawing down funds in a timely matter. AVC has limited unrestricted cash. AVC is currently looking for opportunities to increase unrestricted cash, such as increasing prices for gas and electric. Proposed Completion Date: Already Completed.

Finding Summary: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Responsible Individual: Kathryn Lynch, Town Administrator Corrective Action Plan: The Town will be updating the Town?s procedures and policies to incorporate the requirements of Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Anticipated Completion Date: June 30, 2023

Finding Number: 2022-002 Planned Corrective Action: The District has initiated an internal audit reconciliation system to confirm each month that all reimbursable breakfast and lunch reports agree. Anticipated Completion Date: 07/01/2022 Responsible Contact Person: Neil Laughbaum, Director of Operations

Finding Reference Number: SA2022-005 - Cash Management ? Draw Down of Community Development Block Grant Funds in Advance of Expenditures Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0042 COVID-19 ? B-20-MW-06-0042 CDBG Daly City Pass Through #Not Available Name of Pass-through Entity: City of Daly City ? Name(s) of the contact person: Karen Chang, Finance Director ? Corrective Action Plan: The CDBG grant seldom involves a contract that has included a retention payable. Going forward, staff will double check contracts that have retention clauses and ensure the reimbursement submission does not include an unpaid retention. Staff will also check with the grantor to see if the City needs to reimburse the interest earned on the grant funds advanced. ? Anticipated Completion Date: December 31, 2023

Management agrees with the recommendation and has incorporated policy updates within the September 2023 updated policies and procedures to ensure compliance with required regulations. AALV will continue to update its policies to meet regulatory requirements.

THE UNIVERSITY OF ALABAMA AT BIRMINGHAM RESPONSE TO THE UNIFORM GUIDANCE AUDIT The following is the University of Alabama at Birmingham?s Response to the audit of Federal programs in accordance with the Uniform Guidance for the year ending September 30, 2022. Finding 2022-001- Return of Interest Earned on Advance Payments Program: Research and Development Cluster Awards: Beta Blockers for the Prevention of Acute Exacerbations of COPD ? 12.420 Management understands the requirement to remit interest earned on advance payments in excess of $500 annually to the Department of Health and Human Services (HHS). Advance payment on awards are uncommon at our institution with only two such awards active during the period under audit. Management acknowledges and agrees with the finding as presented. The Grants and Contracts Department (Department) tracked the monthly interest earned on the advance payment received from the DOD. The department requested clarification from the DOD as to what constitutes ?annually?. There was no clarification provided at the time from DOD, as such the department used the fiscal year-end. During the fiscal year 2022, the award went through a request for an extension which coincided with the award end period. The department elected to hold off on remitting the earned interest until a final resolution on the award extension period was received. The award closeout process would include the remittance interest earned. The award was extended for an additional 12 months, but the interest earned was not remitted timely. The department also experienced turnover of a manager and an accountant during fiscal year 2022, both were actively involved in the maintenance of the award in question. The interest earned has since been remitted to HHS. Management notes that award will end September 29, 2023 with no option to extend. Interest earned will be tracked by the department and remitted with closeout documents. The University of Alabama at Birmingham expects to have this item completed by October 2023. For follow-up questions and information, contact Bernard Mays, University Controller at bmaysjr@uab.edu.

Our response: UPCEE has hired a Contract Manager. This person recently retired as the Director of Contracts from a four-year emerging research institution. They come highly skilled in working with federal granting agencies. ? They will oversee office management processes, budgets, and enhance our current way of working with federal timelines. ? They will ensure billings are kept timely and entered into our financial system of QuickBooks to better serve annual audit engagement and reporting requirements. Additionally, ? UPCEE drawdowns will be scheduled and done bi-monthly effective June 2023. UPCEE reserve the right to deviate for special events and give notice to program manager beforehand. ? The Contract Manager will generate payable documents that now will have the certifying official approve before requesting funds in G-5. With the implementation of these new processes, UPCEE feels very confident that this will prevent any further need for risk management.

The District concurs with finding and recommendation. Marlboro County School District's Board of Trustees approved the Cash Management Policy that addresses the timing and frequency of requests for grant cash reimbursements; however, the policy will include additional information regarding obligating, liquidating, and reimbursing federal funds awarded by the US Department of Education in the G5 portal.

FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-002 U.S. Department of Environment Protection ? Assistance Listing # 66.468 Capitalization Grants for Drinking Water State Revolving Fund (Drinking Water State Revolving Fund Cluster) Lack of Required Written Policies & Procedures ? Compliance Condition & Criteria: The Authority does not currently have all the written policies and procedures in place as required by the Uniform Guidance as it relates to financial management and determining allowability of costs for the federal program (Title 2 U.S. Code of Federal Regulations (CFR) 200.302 & 200.305). In addition CFR sections 200.318, 200.319, and 200.320 require there to be written policies and procedures regarding procurement and conflicts of interest. Planned Corrective Action: This is the Authority?s first time subject to the requirements of the Uniform Guidance as we have not had any significant grant funding since 2004. The Authority does have a set of informal policies and procedures that are followed as it relates to financial management, allowability of costs, procurement, and conflicts of interest, and have been very careful to carry out all federal program activities in accordance with established regulations; however, the Authority was simply not aware of the requirement that these polices and procedures be documented in writing. The Authority will begin immediately to get these policies and procedures as they relate to federal programs documented in writing. The Authority is currently working with their consultants to have the written polices established and plan to have this completed within the next fiscal year. If the U.S. Department of Environmental Protection has questions regarding this plan, please contact: Mr. Kenneth Bost, Authority Chairman Alexandria Borough Water Authority PO Box 336 Alexandria, PA 16611 Phone: 814-669-4441

AUDIT FINDING 2022-002 Cash Management Condition: During our audit, we noted draw downs from the Sustainable Fisheries Fund XII award were on hand in excess of thirty days during the periods April through July 2022 and October through December 2022. Funds from the Sustainable Fisheries Fund XIII award were on hand in excess of thirty days from September through December 2022. The excess funds on hand for these awards ranged from approximately $4,000 to $16,000. CORRECTIVE ACTION Regarding the SFF XII award, per GMD requirements related to the annual closure of the asap.gov site a draw down for estimated expenses was made in September 2022. No additional drawdowns were made. Regarding SFF XIII award, a drawdown for expenses was made in August 2022. A journal entry was made to balance the 2021 trial balance in quickbooks. This was done to match the end of year auditor?s trial balance in September 2022. No additional drawdowns were made. Cash on hand and existing expenses will be reviewed by the Fiscal Officer prior to the 15th and end of month payables. Draw down of funds will be made based on existing cash on hand and expenses entered for the applicable period. Funds will be expensed in a timely manner.

Oversight Agency: U.S. Department of Housing and Urban Development Northwest Compass, Inc. respectfully submits the following corrective action plans for the year ended June 30, 2022. Auditor: Dugan & Lopatka, CPA?s 4320 Winfield Road Suite 450 Warrenville, IL 60555 Audit Period: For the year ended June 30, 2022 The findings from the schedule of finding and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings ? Federal Award Programs Audit DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-001 (repeat finding of 2021-002) Youth Homelessness Demonstration Program, CFDA #14.276 Auditor?s Recommendation: We recommend that each reimbursement request agrees to what is allocated through the accounting system by grant or program for actual expenses. This will help support the request and, if needed, a method to provide the actual invoice for the expense being requested. This is Northwest Compass Policy. Each Grant program has its own identifiable "cost center" that both revenue and expenses are posted in NWC accounting system. If the funding agency has questions regarding this plan, please call me at (847) 392-2344.

Finding 2022-008 Timing of Subrecipient Payments Plan: UIUC- The University of Illinois Urbana-Champaign 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. UIC - The University of Illinois Chicago will communicate reminders and provide training, as necessary, to parties involved in the subrecipient payment process. The University will continue to monitor and refine procedures. Expected Implementation Date: April 2023

Finding Number: 2022-001 Planned Corrective Action: The correction of this issue has already been in place even prior to this audit. As I have research more on federal funding and the criteria for drawing funds and the time line of disbursing them. Vantage has not drawn funds in advance of spending them to date and will continue to follow that method. Anticipated Completion Date: Already in place Responsible Contact Person: Laura Peters, Treasurer/CFO

Planned Corrective Action 1. Mr. Samuel Fischer has implemented a system to minimize the time elapsing between the transfer of funds from ED?s G5 grants system and disbursement by the organization for both institutional aid and student financial aid purposes. 2. Mr. Fischer has designated Mr. Getzel Falkowitz to monitor the system and to review the terms, conditions, and requirements governing any future grants to ensure the system?s compatibility.

December 12, 2022 Finding: 2022-001 Procurement, Suspension and Debarment US Department of Agriculture ? ALN # 10.555/10.559/10.582 ? Child Nutrition Cluster Green Mountain Unified School District Single Audit ? Material Weaknesses Responsible Official - Cheryl Hammond ? Business Manager Anticipated completion date: December 12, 2022 The school district agrees with this finding and will implement the following: ? Review the procurement policy and procedure ? Distribute the policy and procedure to the food service and business staff ? Train staff on what needs procurement documentation ? Beginning this process immediately

Planned Corrective Actions: The Organization will incorporate policies and procedures to ensure requests for reimbursement are in line with 2 CFR 200.305(b)(3). Anticipated Completion Date: The Organization expects these actions to be completed by June 30, 2023. Responsible Contact Person: Richard Bennoch, Finance Director

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 reviews budgeted expenses to determine their timing and nature (one time, recurring, allowability); reviews quarterly expense reports and alters payments to meet immediate cash needs, and finally, monitors subrecipient single audits to ensure there are no cash management findings. The Department's approach is administratively reasonable and does minimize the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes given administrative and operational needs. We believe we have procedures in place that can be corroborated by the fact that our subrecipients do not receive single audit findings related to cash management. Completion Date: N/A Agency Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

Finding 2022-006 Beginning June 1, 2022, grans accounting staff were trained to utilize a draw report that calculated cleared (paid) expense to ensure expenses were invoiced in accordance with federal and program regulations. During fiscal year 2022, a new director and staff were hired in the grants accounting office. In addition, with completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations. Responsible Official: Associate Vice Chancellor for Finance & Treasurer Implementation Date: February 2023

Finding 2022-001 Beginning June 1, 2022, grants accounting staff were trained to utilize a draw report that calculated cleared (paid) expense to ensure expenses were invoiced in accordance with federal and program regulations. During fiscal year 2022, a new director and staff were hired in the grants accounting office. In addition, with completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations. Responsible Official: Associate Vice Chancellor for Finance & Treasurer Implementation Date: February 2023

Finding Number: 2022-002 Planned Corrective Action: If the district is required to return to tally sheets for the calculation of site claim forms, more stringent reviews will be put into place between the tally sheets and the entering of the site claim form data. The 2021 ? 2022 school year had special procedures in place due to the ongoing pandemic. Anticipated Completion Date: March 16, 2023 Responsible Contact Person: Mandy Hildebrand, Treasurer

Item 2022-001 Written policies, procedures, and standards of conduct Recommendation: Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non-Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: ? ? 200.302 Financial management ? ? 200.305 Payment ? ? 200.319 Competition ? ? 200.320 Methods of procurement to be followed ? ? 200.430 Compensation?personal services ? ? 200.431 Compensation?fringe benefits We recommend that the Board implement the required written policies and procedures. Action Taken: The Board?s management, namely Stacey Parker, CFO and General Manager, acknowledges the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2023. Audit finding 2022-001 relates to prior year 2021-001 finding. Updated reference number to current audit year 2022.

Views of responsible officials and planned corrective actions: Management agrees with this finding and will write policies and procedures for Federal awards.

Compliance requirement ? Cash Management Institutional Comments on Findings and Recommendations: 1. The institution does concur with the auditor finding. The institution is revising the accounts' payable structure to ensure future payments falls within the allowed elapsed time. Actions Taken or Planned: The institution is revising the accounts' payable structure to ensure future payments falls within the allowed elapsed time.

1. The institution does not agree, nor concurs, with the auditors on this finding because the institution used the reimbursement payment method. This method was the preferred one when the non-federal entity, as our institution, cannot meet the requirements in 2 CFR, section 200.305(b)(1) for advance payment and the federal awarding agency sets a specific condition for use of the reimbursement. Title 2 of the CFR Part 200.305(b)(1), establish among others: "The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part". Furthermore, 2 CFR Part 200.305(b)(3) states: "Reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. " Since our institution was not able to meet 2 CFR, section 200.305(b)(1), and the HEERF guidelines has specific condition on how to use the funds; we choose the reimbursement method in the execution of the funds. Our institution adopted all HEERF instructions and guidelines as their policies to comply with the HEERF requirements, in addition to the CFR's regulations. Below some of the guidelines, instructions ad FAQs we adopted followed" a. Higher Education Emergency Relief Fund III, Frequently Asked Questions, American Rescue Plan Act of 2021, Published May 11, 2021, Questions 7 and 11 updated May 24, 2021, Question 36 updated September 30, 2021 b. US Department of Education, Notice of Proposed Institutional Eligibility Criteria, February 25, 2021 c. Federal Register Notice of Interpretation (NOI), regarding Period of Allowable Expenses for Funds Administered under HEERF Program, March 22, 2021 d. HEERF Notice of Interpretation for Period of Allowable HEERF Expenses (March 22, 2021) e. HEERF Lost Revenue FAQs (March 19, 2021) f. HEERF Period of Allowable Expenses Grant Records Notice (March 19, 2021) g. HEERF Grant Program Auditing Requirements (March 8, 2021) h. CRRSAA HEERF II Section 314(a)(1) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) i. CRRSAA HEERF II Section 314(a)(2) Frequently Asked Questions (January 14, 2021) j. CRRSAA HEERF II Section 314(a)(4) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) k. HEERF I and HEERF II Comparison Fact Sheet (Published January 14, 2021 and Updated: March 19, 2021) 1. HEERF Lost Revenue FAQ's, Published March 19, 2021 m. HEERF II, Public and Private Nonprofit Institution (a)(2) Programs (CFDAs 84.425K), FAQ's, Published January 14, 2021 n. HEERF II, Proprietary Institution Grant Funds for Students (CFDA 84.425Q) ((a)(4) Program), FAQ's Published January 14, 2021, Updated March 19, 2021. o. HEERF II, Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F), FAQ's Published January 14, 2021, Updated March 19, 2021. p. CAREST Act HEERF Rollup FAQs (issued October 14, 2020 and revised November 20, 2020) q. CARES Act HEERF Round 3 FAQs (Issued October 14, 2020 and revised November 20, 2020) r. CARES Act HEERF Supplemental FAQs (Issued June 30, 2020 and revised September 08, 2020) s. CARES Act HEERF Student FAQ's (Issued May 15, 2020) t. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) u. CARES Act HEERF Emergency Financial Aid Grants to Students under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) v. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, Issued April 9, 2020 w. COVID-19 FAQ's for Title III, IV, V and VII Grantees, June 16, 2020 x. COVID-19 Letter to HEP Grantees on Flexibilities Available Under CARES Act Section 3518, July 1, 2020 2. The institution does not agree, nor concurs, with the auditors on this finding because, as we mention in number 1 above, the institution adopted and followed the federal award and HEERF guidelines in the execution of the funds. The HEER funds were provided during the special national emergency caused by COVID-19. The DOE and HEERF officials issued many written guidelines, instructions, and FAQ's (Frequently Asked Questions) documents, due to the nature and novel of the national emergency situation. The institution adopted, followed, and relied on the many referenced guidelines and exercise extreme judgment to ensure compliance with the federal requirements and use of the funds. The institution belief this referenced guidelines and instruction were very specific and sufficient to execute the use of the funds. All direct charges to federal awards were for allowable costs under the guidelines and instructions from the Department of Education. Some of the allowable costs were verified and validated by an officer of the Department of Education and reviewed by an independent consultant. 3. The institution concurs with the auditor finding. Actions Taken or Planned: The institution begins in addition to the adopted HEERF guidelines, instructions, and CFRs; to develop additional procurement policies and are in the process of completing those policies. The institution expects to have those completed by May 31, 2023.