Corrective Action Plans

5.       Internal drawdown audits are conducted monthly to confirm alignment with federal cash management standards.

Corrective Action Plan:

1.       Updated drawdown procedures have been incorporated into SCMRC’s financial policies and will be re-reviewed annually.

2.       Refresher training on 2 CFR § 200.305 and internal drawdown requirements will be conducted by Q4 2025.

3.       Results of monthly drawdown audits will be included in the Finance Committee compliance dashboard starting in September 2025.

4.       SCMRC will continue to require documented CEO approval on all federal drawdown submissions to ensure sustained internal control.

Finding Reference Number: MW2022-07 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2022: Certain 2022 draws were processed as advances outside grant guidelines, although these draws were properly recorded as advances payable in the accounting records. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers this finding resolved. A written drawdown procedure is now in place, requiring twotier preparation and review and, for working-capital advances, written approval from the prime funder. When the non-compliance was identified, CUAHSI suspended all NSF draws (late March 2023) until new controls were implemented. On 15 June 2023 CUAHSI completed its first draw under the revised policy; the certified SF-270 and supporting documentation were reviewed and approved by NSF. Name of Contact Person: • Jordan S Read, Executive Director • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete

NMC has formal internal controls and policies and procedures for cash drawn downs. Our drawn downs are not on a reimbursement base, but advance basis. Funds were drawn down to pay the invoice in question. The mobile unit was being repaired, and when we notified it was ready to be picked up the funds were drawn down. Once we were at the vendor to pick up the unit, it was discovered that it had not been properly repaired. The funds were not given to the vendor until the unit was properly repaired. We held the funds until such time.

Views of Responsible Officials and Planned Corrective Action Plans: Management agrees with this finding and has implemented process to prevent excessive draws. In addition, RoboNation has subsequently settled all amounts owed to the Office of Naval Research.

Finding 2022-002 Name of Responsible Individual: Carolina Liriano, Grant Manager; Holly Forester, Controller; Sheri Brady, VP and Chief Program Officer   Corrective Action: CDF hired an Outsourced Grant Manager starting January 2025 who will assume comprehensive oversight of all facets of grant administration and compliance. The grant manager's duties will include ensuring that all reimbursement requests are substantiated by adequate documentation, such as actual invoices, payroll registers, and payment records. Key actions include:  Establishing a systematic process for the collection, organization, and retention of all requisite documents.  Implementing internal review and approval procedures to guarantee that every reimbursement request undergoes thorough vetting and receives approval prior to submission, with explicit documentation of the review process.  Instructing both existing and new personnel on these newly instituted procedures to prevent future inconsistencies. Anticipated Completion Date: December 31, 2025.

The City has identified federal grants subject to the Uniform Guidance and will develop written procedures to implement the requirements of 2 CFR § 200.305 Payment.

FA 2022-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: SO10A200010 (Year: 2021) SO10A210010-21A (Year: 2022) Questioned Costs: None Identified Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund, COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D210012 (Year: 2021) S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Finding: FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and School Emergency Relief Fund programs. Corrective Action Plans: District office has put procedures in action to make sure that all drawdowns are in line with expenditures. All draw down packets will be viewed and singed off by federal programs director. This packet will include detail expenditure sheet for the month, year to date expenditure report and a cover sheet. Estimated Completion Date: December 31, 2024 Contact Person: Terrance H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

No federal funds are drawn until the suppliers’ banking information is provided and an additional employee is now available to handle disbursements.

Views of Responsible Officials The Organization agrees with this finding. Corrective Action Plan The Organization has strengthened its internal controls over non-payroll transactions such that all expenditures can be properly explained with supporting documentation, and all expenditures are reviewed and approved prior to payment. Additionally, the Organization only submits expenditures for reimbursement that have been paid. While the Office of Management and Budget allows the reimbursement of expenditures that have been incurred, the pass-through entity will only reimburse expenditures that have been paid. Name(s) of Responsible Individuals Lacy Kimes, Board President Anticipated Completion Date Already implemented.

Management Response #2022-009: Due to the staff shortages and turnover in FY2020-2022 the company did not have adequate personnel in place to monitor or document grant activity. Formal documentation of policies and procedures were also deficient. Additionally, documents were not stored centrally, which made it extremely difficult to find supporting documentation. Corrective Action Plan: The following action plans have since been implemented: • During the fourth quarter in 2022, finance team delineated and expanded positions whose primary responsibility is to monitor and manage all grant activities. • During the fourth quarter in 2022 a new process was implemented to track grant related activities. Prior to any drawdown, the expenses are pulled from the G/L and reviewed. The expenses are entered into a spreadsheet and totaled based on the applicable federal award which has been assigned a client ID in the accounting system. The finance team is notified of the amount due to be drawn for each federal award. That amount is entered into the accounting system as an accounts receivable entry. This process has been formally documented. • Project Budget Reports have been created for each federal award. These reports include the budget, expenses for each month and the revenue (drawdown) incurred for each month. The reports will be reviewed and reconciled by the grants administration staff and finance monthly to ensure all agree with the allocated costs and costs and are in compliance with grant regulations. Once approved by both teams the reports will be routed for signatures. This process was launched in July 2022. • Supporting documentation for all draws will be maintained on a shared network drive so that an adequate audit trail will be established. This drive will be backed up on a regular basis by the Information Technology team. Responsible Party: Tamara Barnes, CFO

In the response for Finding# 2022-001, the College described the events that led to the excess funds on hand. The institution did not any earn interest on these funds. The College now recognizes that the approach used in Finding# 2022-01 is unallowable and will confine its future drawdowns of federal funds to actual, not speculative, expenditures. The Board will implement the above procedure immediately.

Management Response / Corrective Action: Rowan-Salisbury School hired a new payroll director in May of 2022 who identified the cause for the above noted discrepancy, noting the team was overbudgeting taxes on staff personnel payments due to employees who opt in for the ?pre-tax contributions.? When an employee enrolls in the ?pre-tax contributions,? the budgeted amount for Social Security/Medicaid is adjusted so that the rate no longer meets the 7.65% calculated amounts for all employees. As a result, the team has gone through each month?s drawdown and determined that $7,793.78 was over budgeted and we are correcting that in our February 2023 drawdown by reducing the drawdown by $7,793.78. We have also adjusted our budget calculation so that we are properly accounting for those employees who opted for ?pre-tax contributions? going forward.

The Auditor's office with work with the Community Transportation Connection and provide training on the importance of grant reporting and tracking.We will also explain and show how using the ERP system can aid in the tracking of expenses and help to ensure better accounting for grants.The Auditor's office will implement an additional level of control for this department's grant award, reporting, and reimbursements to be reviewed by our office for accuracy.Use online state and federal agency websites to verify grant awards amounts and disbursements.

Assistance Listings number and program name: 84.374 Teacher and School Leader Incentive GrantsDepartment: Maricopa County School SuperintendentContact Person(s): Matt Morales, Deputy Superintendent of Schools, Maricopa County School Superintendent?s Office.Anticipate completion date: June 30, 2023Concur: The Maricopa County School Superintendent?s Office (Superintendent's Office) acknowledges the human error that was made with the May 2022 drawdown. Once the error was identified, the Assistant Superintendent for Economic Management, along with the grant project leader and the Human Capital Management Administrator, contacted the program officer at the US Department of Education and notified them of this error. The overdraw was resolved as there were additional program costs prior to the grant?s closeout in September 2022, and all program expenditures and reimbursements were reconciled prior to closeout. The Superintendent?s Office has implemented updated procedures including the addition of one more person to the reimbursement request approval process who will ensure that program expenditures are reconciled based on the fund balance report from the financial system for the correct time frame.

Federal Funds Received Were Not Disbursed or Refunded Within Required TimeframeState Agency: Utah State UniversityFederal Program: Student Financial Assistance ClusterUtah State University will change its process for requesting federal funds in advance. The Controller?s Office will down less than the full amount of the estimated financial aid disbursement amounts to be issued to students, as calculated by the University?s Financial Aid Office at the first of each semester.The Controller's Office personnel will then review federal financial aid disbursements within three days of receiving the advance draw in order to return any undisbursed funds to the Department of Education within the required timeframe. Federal financial aid funds will then be drawn down on an on-going basis as additional federal financial aid funds are disbursed to students during the semester.Contact Person: Jennifer Jenkins, Manager of Sponsored Programs Accounting, 435-797-1077Completion date: October 31, 2022

ULMS Corrective Action Plan for FY 21-22 Audit FindingsULMS faced significant challenges with the departure of its longtime CFO two months post fiscal year 2021. In addition, the third-party management company who had been responsible for the Partnership accounting, ceased the relationship abruptly without opportunity to smoothly transition the responsibility in-house to ULMS. Our external auditor does not prepare a Management Letter typically used to communicate with the Board of Directors and Governance issues that may not elevate to a finding. As such, significant findings are reflected in Section III ? Federal Award Findings and Questioned Costs.FY 2021 was the organization?s first single audit reporting requirement. ULMS engaged a third-party CPA to review past audit and current documents needed to commence the FY 2022 audit. However, due to an emergency there was limited independent review of documents prior to being submitted to the auditor due to time constraints. ULMS continues to strengthen its accounting team and has hired a new Controller in July 2023. The new Controller is a licensed CPA with over 30 years accounting experience and over 10 years? experience as an independent auditor for a range of organizations including non-profits. The Controller will collaborate with the CFO to ensure there is accuracy in reporting, especially for major federal programs. Finding #: 2022-003Contact Person: Mansour Camara? During the FY 2021 audit, the auditor recommended that ULMS formalize written federal payment procedures in compliance with required standards. ULMS developed procedures for advance federal payment which was sent to the auditor for feedback. There was no feedback proposing ULMS update its advance federal payment procedure until the issuance of this finding. The finding states a lack of written policy that complies with the federal payment standard per CFR 200.305. However, the recommendation instructs ULMS to formalize written procedures. Such procedures were in place during FY 2022.Actions to be taken: Notwithstanding the inconsistency between the finding and the recommendation provided by the auditor, ULMS prepared written procedures consistent with CFR 200.305 and recorded transactions consistent with that procedure for FY 2022. ULMS will update its accounting policy and procedures manual to create a written policy in addition to the procedures that have already been in place consistent with CFR 200.305.

ULMS Corrective Action Plan for FY 21-22 Audit FindingsULMS faced significant challenges with the departure of its longtime CFO two months post fiscal year 2021. In addition, the third-party management company who had been responsible for the Partnership accounting, ceased the relationship abruptly without opportunity to smoothly transition the responsibility in-house to ULMS. Our external auditor does not prepare a Management Letter typically used to communicate with the Board of Directors and Governance issues that may not elevate to a finding. As such, significant findings are reflected in Section III ? Federal Award Findings and Questioned Costs.FY 2021 was the organization?s first single audit reporting requirement. ULMS engaged a third-party CPA to review past audit and current documents needed to commence the FY 2022 audit. However, due to an emergency there was limited independent review of documents prior to being submitted to the auditor due to time constraints. ULMS continues to strengthen its accounting team and has hired a new Controller in July 2023. The new Controller is a licensed CPA with over 30 years accounting experience and over 10 years? experience as an independent auditor for a range of organizations including non-profits. The Controller will collaborate with the CFO to ensure there is accuracy in reporting, especially for major federal programs. Finding #: 2022-002Contact Person: Mansour Camara? Management has determined that the finding as written is misleading. The Schedule of Expenditures of Federal Awards (SEFA) prepared by ULMS initially contained errors. However, all errors were corrected by the time the draft financial statements were presented. There was no financial impact on the organization and the most significant issue on the SEFA schedule was a result of miscommunication with ULMS? funding source including the lack of clear identification of the funding source within the contract.Actions to be taken: ULMS migrated to a new and more sophisticated accounting system. This new system has more reporting and tracking capabilities which will enhance grant tracking and review of activities. These additional tools will aid management in overseeing future endeavors. In addition, ULMS will proactively contact the CFO or contract signer of the funding entity and confirm the source of funding for all grants over $100,000. ULMS will participate in more nonprofit conferences on a regional and national level.

Federal Agency Name: Department of State ? Bureau of Population, Refugees, and MigrationProgram Name: Oversees Refugee Assistance Programs for AfricaCFDA #19.517Federal Agency Name: Agency for International DevelopmentDepartment of StateProgram Name: USAID Foreign Assistance for Programs OverseasCFDA #98.001Finding Summary: CVT does not have an internal control designed to ensure advance payments are placed in an interest-bearing account.Responsible Individuals: James Behnke, CFO and Mary Kinder, ControllerCorrective Action Plan: Management will complete an extensive review over cash management policies to make sure requirements under the CFR section are met.Anticipated Completion Date: June 2023

Criteria: Recipients of federal awards must minimize the time elapsing between the receipt of funds from the U.S. Treasury and disbursement by the Organization set out at 2 CFR section 200.305(b). Audit Recommendation: We recommend that the Organization 1) maintains timely and accurate recording of disbursements in its job‐costing system and 2) regularly request grant funds based on amounts expended as report in the Organization’s job‐costing system. Auditee Response: The Organization is implementing a grant tracking system in addition to its job costing system to better comply with these requirements. Together, these systems will be used to request only the amount attributable to the program for reimbursement. Corrective Action Plan: (1) Records will be kept in a newly developed spend down report for each grant/contract and reviewed with Division Directors and DFO monthly. All transactions are now being logged in QuickBooks with respective grant codes and departments, will not be processed without. (2) Monthly and quarterly invoicing according to each grant / contract agreement will be enforced by the GDCM and DFO in compliance with 2 CFR section 200.305(b). (3) The Organization has enrolled with the Treasury’s Invoice Processing Platform (IPP) to ensure all future Invoicing and payments can be easily tracked to the program/grant. Person Responsible: Matt Poss, Director of Finance Operations Timeline: All expenses and disbursements being coded to proper Grant/Type in QuickBooks Online – January 2023 Treasury Invoice Processing Platform (IPP) Onboarded – April 18th, 2023 Invoicing Timeline Created per collaboration with GDCM and DFO – May 18th, 2023 Revenue Reconciliation and clearing out of uncollectible or overbooked revenue – June 30th, 2023

During 2022, there was a change in accounting staff which led to difficulty in tracking and preparing the SEFA. Once management became aware of the issues, changes have been made to internal processes to allow for proper SEFA tracking moving forward.