Corrective Action Plans

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

The University is currently following and believes it is in compliance with the cash management regulations as written in 2 CFR Part 200.305(b) which require the organization to minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. We understand that variations remain in the interpretation of the cash management compliance requirement. For example, on October 20, 2017, the Council On Governmental Relations (COGR) wrote a letter to the Office of Financial Management expressing concern that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management as currently written in 2 CFR Part 200.305(b). COGR?s position is that the Compliance Supplement should be revised to conform with the cash management requirements as written in 2 CFR 200.305(b). The University agrees with COGR?s position and believes the language in the Compliance supplement leads to an unrealistic and unreasonable administrative burden for universities and possibly a reconfiguration of smoothly running electronic process or a complete replacement of electronic processes with an inefficient, manual one in efforts to ensure each vendor has been paid prior to requesting reimbursement from the sponsoring agency. The University will continue to monitor the OMB interpretation of the Cash Management requirements. For FY22, we note that the overall number of exceptions has decreased. Furthermore, the payments identified as exceptions in the FY22 audit were almost all made to vendors within our institutional standard terms of net 45 days, with the exception of 1 which was made 51 days after the request for reimbursement. The Office of Research Services remains committed to ensuring that the federal government is not unfairly disadvantaged by our processes. To that end, during the fall of 2022, the University implemented certain enhancements to further minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. A custom process was implemented in the University?s financial system to update payment terms to `immediate? for vendor invoices on Line of Credit sponsored awards. In addition, the University added a new metric to the reporting dashboard for its Procure-to-Pay system to specifically highlight Purchase Order invoices for sponsored awards which were on hold, to assist the university business and grant managers in prioritizing the resolution of those holds preventing 2 invoices on sponsored awards from being paid immediately. We expect to see the impact of these enhancements in the FY23 audit.

US Department of Health and Human Services HIV CARE Formula Grants Passed-through State of Hawaii Department of Health 1250 Punchbowl Street Honolulu, HI 96813 Hawaii Health & Harm Reduction Center (HHHRC) respectfully submits the following corrective action plan for the year ended June 30, 2022 for the finding identified in the schedule of findings and questioned costs as identified by our auditors, KKDLY LLC, who are located at Topa Financial Center, 745 Fort Street, Suite 2100, Honolulu HI 96813 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Material Weakness Finding 2022-001 Eligibility U.S. Department of Health and Human Services HIV CARE Formula Grants CFDA No. 93.917 Condition During the in-take and re-assessment process for the Ryan White HIV/AIDS Part B (RWB) program, case managers are responsible for (1) ensuring that all required forms and documents are received from clients, (2) reviewing those forms and documents for completeness and accuracy to verify that RWB program eligibility requirements are met; and (3) inputting the client?s information into e2 Hawaii, HHHRC?s system to monitor and track all RWB program clients. Effective April 1, 2022, HHHRC updated their policies and procedures, requiring a manager or knowledgeable employee other than the case manager to sign off on the certification forms to document their review of eligibility determinations for completeness and accuracy. We selected a sample of 60 clients receiving assistance under the RWB program as part of our eligibility testing. Within the 60 files, we examined 61 annual or semi-annual certification forms dated prior to April 1, 2022, and 32 annual or semi-annual certification forms dated April 1, 2022 or later. Of the 61 certification forms dated prior to April 1, 2022, we noted 59 certification forms did not contain evidence of a review performed by a manager or a knowledgeable employee other than the case manager. Of the 32 certification forms dated April 1, 2022 or later, we noted 6 certification forms were not signed off by a manager or knowledgeable employee other than the case manager. Criteria The Uniform Guidance, as prescribed in 2 CFR section 200.305, requires that non-federal entities receiving federal awards establish and maintain internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Internal controls over compliance with RWB eligibility requirements should include formal policies and procedures to ensure that data used to determine eligibility are complete and accurate in compliance with RWB program requirements. Eligibility determination procedures should be performed by case managers and reviewed by a manager or knowledgeable employee. Cause HHHRC implemented a formal policy requiring a manager or knowledgeable employee other than the case manager to sign off on the annual and semi-annual certification forms for each client. This formal policy was implemented on April 1, 2022. As such, the certification forms that were prepared prior to this date were not reviewed in accordance with this policy. Effect Without appropriate internal controls, noncompliance with RWB eligibility requirements may occur. Refer to Finding 2022-002 for instances of noncompliance identified in the current year. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding 2021-001. Recommendation We again recommend that HHHRC adhere to established policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager for completeness and accuracy. Views of Responsible Officials and Planned Corrective Action HHHRC has implemented a formal policy and review process by a manager or higher level within the organization for every certification form within 1 week of completing the form. As noted earlier in the audit, HHHRC has made significant progress on this compliance measure with certifications dated after April 1, 2022 having significantly higher review rates (26/32 had review compared to 2/60 prior to April 1, 2022). Additionally, HHHRC has added an additional policy of the HIV Director or Clinical Deputy Director will review twice annually a random selection of at least 20 certification forms to ensure there was manager review documentation and this internal control will hopefully identify any deficiencies in this practice.

2022-004 Significant Deficiency in Compliance and Internal Control over Compliance - Collateralization Special Tests Same as 2022-002 above. 2022-002 Significant Deficiency in Compliance and Internal Control over Compliance ? Collateralization Special Tests Name and Contact Person: Janelle Friday, Tribal Administrator Corrective Action: Klawock Cooperative Association has switched banks and will collateralize the accounts. Proposed Completion Date: June 30, 2023

SUBRECIPIENT CASH MANAGEMENT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788 The DHHR Bureau for Behavioral Health concurs with the recommendation to mandate additional documentation to support amounts of drawdowns that appear to exceed a subrecipient's immediate cash needs. Upon identification of the condition that led to this finding, the bureau provided additional guidance to all internal grant staff. The guidance was distributed on October 25, 2022 and requires a documented justification for approval of any invoice that appears to exceed 10% of total grant amount for cash on hand. The bureau also intends to seek out and provide technical assistance and/or training for internal staff and subrecipients to ensure they understand the cash management requirements within 2 CFR 200.305.

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 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: Dr. Mike Ruff, 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 No.: 2022- 003 Condition: The District's expenditure report filed for June 30, 2022 included expenditures paid in July 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: July 31, 2022 Name of Contact Person: Jake Flowers, 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.

Twin Oaks will implement a policy so that only the cash needed will be drawn down to cover expenses to ensure that excess cash is not drawn down. This will be reviewed on an annual basis or as needed.

2022-002 ? Noncompliance and material weakness for federal awards. The District agrees with this finding and has taken corrective action to ensure that established procedures are followed timely and appropriately. 1) New Braunfels ISD will be contracting with an outside entity to provide an evaluation of business office practices and procedures in order to identify areas in which improvement is needed. 2) New Braunfels ISD has documented due dates for Federal drawdowns so that there is a level of responsibility for all involved in ensuring that these are completed in a timely manner. The due date is the last Friday of each month. 3) The drawdowns will be completed by the Director of Financial Services and backed up by the Assistant Director of Financial Services. They will then be reviewed by the Chief Financial Officer.

DTC had multiple key leadership changes shortly prior to and during the financial audit. DTC will ensure related policies and procedures are updated, staff trained, and documented evidence is maintained. DTC will comply with 2CFR section 200.305 requirements.

Finding 2022-001 Lack of Internal Controls over Cash Management Name of Contact Person: Karen Linnell, Executive Director Tamara Hamby, Accountant Corrective Action Plan: Account and grant receivables will be tracked and collected within 30 days of the closing of the quarter. We will be aggressive in collecting past due receivables. We will continue to follow the specific grant guidelines on drawing down funds. Proposed Completion Date: December 1, 2022

Cash Management ? 10.557 Special Supplemental Nutrition Program for Woman, Infants, and Children (WIC) Corrective Action Plan: Upon being advised that the State of Hawaii Department of Budget and Finance determined that the "administratively feasible" time period of advance payments was 21 calendar days", the WIC Accounting Section implemented the following changes to its Invoice payment process. 1. The WIC invoice payment workflow tracking system was revised to also track the number of days from the ASAP draw date to the check process date on Data Mart. 2. The Accountant meets with the Account Clerk weekly on the invoice workflow system to review invoices in the workflow from receipt to when payment checks are processed. 3. Within two workdays from the date that the Accountant makes the ASAP draw and transfers federal funds to the State Treasury to pay for approved invoices , the Account Clerk prepares and "pouches" the invoices to ASO Pre-Audit. 4. If a payment check is not processed within 14 calendar days from the date an invoice is pouched to ASO Pre-Audit, the Account Clerk notifies the Accountant, and contacts ASO to verify that the invoice was received. After implementation of the revised changes, WIC saw a significant improvement in the number of days it took DAGS to enter a check process date on Data Mart. Implementation Date: July 1, 2022 Responding Officials: Melanie Murakami, Public Health Program Manager and Paul Uchima, WIC Services Administrative Officer/Family Health Services Division

Management?s View and Corrective Action Plan Finding 2022-001 ? Cash Management Cluster: Research and Development Cluster Grantor: National Cancer Institute and National Science Foundation Assistance Listing #: 93.397, Cancer Centers Support Grants and 47.049, Mathematical and Physical Sciences Title: Case GI SPORE, Case Comprehensive Cancer Support Grant, MRI: Acquisition of an SEM instrumented to conduct in-operando observations of materials performance under external stimuli Award Year and Number: 08/21/21-07/31/22 (CA150964), 04/01/21-03/31/22 (CA043703), 08/01/20-07/31/23 (DMR-2018167) The University believes it is in compliance and currently follows regulations pertinent to cash management in 2 CFR Part 200.305(b) (Uniform Guidance) which requires "payments methods must 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." As such, organizations are to minimize the time difference between vendor payment and requesting reimbursement from the sponsoring agencies. We acknowledge that there are discrepancies in the interpretation of the Office of Management and Budget (0MB) cash management compliance requirements and the Uniform Guidance Part 200.305(b). In October 2017, the Council on Governmental Relations (COGR) sent a letter to the Office of Federal Financial Management (OFFM) expressing concerns that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management included in the Uniform Guidance Part 200.305(b). COGR's stance is for the Compliance Supplement to be updated to correspond with the cash management requirements as written in the Uniform Guidance Part 200.305(b). In August 2021, COGR sent a follow-up letter to OFFM regarding the 2021 Compliance Supplement emphasizing the inconsistency has yet to be addressed or resolved and most recently followed-up again in June 2022. In September 2022, The Office of Research Administration (ORA) sent a letter in support of COGR's June 2022 Comment Letter and followed up in November 2022 as well, with no response. The Office of Research Administration is sincerely devoted to ensuring institutional compliance with Uniform Guidance and the Compliance Supplement. It is important to note that these exceptions pertain to accounts payable transactions only. ORA will be cognizant of OMB's current interpretation of the Cash Management requirements and will continue to monitor for additional guidance regarding discrepancies in the Compliance Supplement. Primary responsibility for implementing this corrective action plan for this finding rests with Diane Domanovics, Assistant Vice President for Sponsored Projects. Sincerely, Joan Schenkel Associate Vice President for Research

Finding 2022-001 ? Non-compliance with Cash Management Requirements of the Capital Fund Program Corrective Action The Authority will expend the unexpended Capital Fund Program grant proceeds held, prior to drawing down additional funding from Capital Fund Program grant allocations which are budgeted for capital improvements. The Authority?s Executive Director, Jeff Sklet has assumed the responsibility of executing this corrective action as of March 31, 2024.

Agency: U.S. Department of Agriculture passed through State Department of Education

Management is implementing an enhanced, more detailed invoice review process where invoices will be reviewed irrespective of materiality by leadership on the RETAIN team. In addition, the invoice process will include periodic meetings to go through expenditures in detail prior to invoice submission. The contacts for this finding are Kori Smith, RETAIN Program Manager, KASmith4@mercy.com and Alice Parisi, Foundation System Director, Alice_Parisi@mercy.com.

The HIDTA Financial Manager, in conjunction with the City's Finance Assistant, will request smaller dollar amounts with new advances in order to liquidate the prescribed HIDTA guideline of 21 days.

Finding 2022-004 Personnel Responsible for Corrective Action: Assistant Comptroller ? Brian Huggins Anticipated Completion Date: July 2022 Corrective Action Plan: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.

Written policy will be adopted to reflect the process being undertaken to minimize the time elapsing between the transfer of funds from the US Treasury. Current process of carrying out detailed analysis of anticipated expenses for the quarter will be reflected in the policy.