Corrective Action Plans

Recommendation: The Auditor noted the Organization should consider implementing policies, procedures, and internal controls specific to federal awards which are in writing and are approved by the appropriate level of management or those charged with governance. Planned Corrective Action: Management agrees with the recommendation and has implemented the following steps. A procurement policy, compliant with the Procurement Standards codified in 2 C.F.R. ? 200.317 through ? 200.327 has been approved by the Board of Directors. This policy states the procedures required for documentation for procurement of goods and services related to all Federal awards. Specific additional procedures have been implemented providing an additional level of review for all Federal expenditures, including a quarterly reconciliation of reporting submitted to the granter.

Material Weaknesses identified was from 2022-01 - Housing Quality Standards Inspections During audit procedures, it was identified that the Unit's Inspections were completed but if there was a failure, re-inspections were not completed as required within the 30-day period. The cause was identified that we did not have the necessary internal controls over compliance in place. That we are not re-inspecting units timely. The failure rate of 40 units examined during audit resulted in 14 failures for re-inspection. The recommendation was that we implement internal control processes and procedures to ensure that re-inspections are completed on a timely basis. Management Response: We became aware of a concern and performance issues with our HCV manager in the summer of 2021. She provided her notice of intent to resign effective December 31, 2021. We began a search for a manager in the fall of 2021 through many processes, including posting the position, inquiring of other housing authorities of our open position and networking. Additionally, we brought in a consultant to complete requirements of our contract effective January 1, 2022. This is a specialized position and one that requires experience for the position. We hired an experienced manager in May 2022 to organize the HCV program. During this audit period HUD had in place a moratorium on inspections due to COVID outbreak. We did not at this.time need to inspect units. However we did inspect units, of the 40 that had inspections we recognize as a result of the audit that we failed 14. We requested a listing of the 14 failed inspected units as a result of the audit. Senior Management was not informed during the audit process, rather during the reporting phase of the audit. Once we received the 14 names we reviewed them. Upon first inspection two of the names immediately were known. One of the persons was living in a situation where she would not have been able to pass inspection, she was a Choice for Independent living recipient approved for services by Medicaid. She was assigned to a case manager and should have been receiving services in her existing housing, however area agencies were unable to provide services per her eligibility requirements and therefore we placed her on our waitlist and worked towards housing her. She was transferred to our housing and is receiving services effective January 2022. During her first months with us she received inspections regularly to ensure that she would not fail and be in jeopardy of eviction. She is now receiving services, doing well and passing inspections. The second person was one of our Choice for Independent living residents in one of our units, his unit failed inspection on Sept. 20, 2021 and a work order for repairs was completed on October 14, 2021, which was within the 30 day re-inspection process. However this was not reported in our housing software, rather was in our work order software. We identified that three of the additional tenants that failed inspection had been re- inspected in May of 2021 and had passed within a few days of their inspection which was under 30 days, however once again was not reflected in our software. During our review process it became known to us that there is a flaw in our software package that we have been addressing with PHA Web for some time. We are working towards accurate notifications within our software. Additionally, during the period of time reviewed we had staff shortages due to COVID positive employees and a needed to change work schedules to maintain our properties effectively. We had created a practice of quarantining due to exposure and or symptoms which affected our HCV inspection staff members, both having tested positive with symptoms. Corrective Actions: We recognize and appreciate the information to work towards improvement of our HCV program. In May 2022 we hired a new Manager for our HCV program. The new Manager is working on preparing a new administration plan to be implemented for our HCV program. The new Manager is working on hiring a team and organizing existing staff to ensure that necessary details including inspections and follow up inspections are kept on track as required and documented properly. There is a process in place for HQS inspections to be followed and reports will be utilized. We have worked on training additional staff members and certifying them in HQS inspection process to ensure inspections are done timely. All our current voucher holders will be receiving a scheduled inspection to create a baseline and to move forward effectively. We anticipate completion of inspections according to our plan to be within six months of this report.

Finding 2022-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2022-002. A Sams.gov account has been activated in order to verify that entities that are being utilized for County business are not excluded from or are ineligible for participation in Federal programs or activities. Also, the County is currently drafting a Procurement Policy for Washakie County to utilize for the use of Federal funding as well as in an everyday manor of purchasing and maintenance of county facilities in order to satisfy above finding.

Cook County BOE FA 2022-001 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) S425U2120012 (Year: 2021) Questioner Costs: $195,559 Description: The School District made cash drawdowns in excess of the immediate cash needs of the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: In order to prevent drawdowns from being mixed up between two federal grants, an additional financial staff member will sign off on the drawdowns. Estimated Completion Date: August 1, 2023 Contact Person: Jackie Sparks, Finance Director Telephone: (229)-896-2294 Email: jsparks@cook.k12.ga.us

Finding Number: 2022-002 Condition: The College drew down HEERF related expenses for the institutional expenditures at a rate that differed from the final, reported expenditures. This was based on the identification of expenditures that were later not included in the final annual reporting, placing the timing of drawdown for reported expenditures to be outside of the cash management regulations. By extension, the institutional quarterly reporting was also incorrect as it is based on the initial expenditure classifications. Planned Corrective Action: The College drew down funds based on expenditures that management deemed to be qualified however, at year-end, concluded to charge other expenditures to the grant causing the mismatch in the timing of drawdowns and final expenditures charged to the grant. Although HEERF and other COVID 19 Pandemic funding has ended, in the future, such expenditures will be discussed and documented prior to the drawing of funds. Contact person responsible for corrective action: Amanda Ewers, Director of Finance and Gary Black, Chief Financial Officer Anticipated Completion Date: Corrected reporting was submitted on March 22, 2023

Individual Responsible for Corrective Action Plan: Romero Brown, Virginia Alliance Director Corrective Action: Weekly Monitoring: Management will proactively check the Virginia Portal each week to determine if any payments have been made. This will allow us to stay updated on incoming funds. Cross Training: Management will initiate cross-training sessions for additional staff members to ensure that Club payments can be processed even in the absence of the current staff. This step will enhance our operational resilience. Calendar Prompts: Management will implement calendar reminders to ensure that payments are promptly presented for processing within five days of receiving the deposit notification. This measure will help us adhere to the required disbursement timeframe. By implementing these actions, we aim to mitigate delays in the disbursement process and establish a more efficient workflow. Anticipated Completion Date: June 30, 2023

Corrective Action Plan: To ensure accurate reporting and remittance of interest, the Agency shall implement the following steps: 1. Responsible staff will review; Uniform Guidance training resources on the U.S. Treasury website; ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO); and training resources on the State of Vermont, Agency of Administration website. Status; completed. 2. Responsible staff will communicate with Vermont Treasury to ensure the interest accrued by HAF program funds are attributed to the HAF program and will be reflected on all reports sent to financial and program staff. Financial staff will set an automatic reminder in Vision to ensure interest is remitted per 2 CFR section 200.303(a). Status; completed. 3. Responsible staff will communicate with U.S. Treasury and U.S. Department of Health and Human Services regarding the unremitted interest and will remit the interest accrued above $500 for 2021 and 2022. Status: communication with U.S. Treasury and U.S. Department of Health and Human Services is initiated, estimated completion date March 31, 2023. 4. Responsible staff will review quarterly reports and ensure interest is being accrued and attributed to the HAF program. If interest is not accruing or any abnormalities are noted, program staff will communicate with financial staff and Vermont Treasury to address the issue. Status: completed and ongoing. 5. Upon receipt of the yearly report from financial staff, Responsible staff will request the annually accrued interest in excess of $500 be remitted to the U.S. Department of Health and Human Services per 2 CFR section 200.303(a) and any instructions issued by U.S. Treasury. Status: completed and ongoing. 6. Responsible staff will verify with financial staff that interest has been remitted. If any errors have occurred, program staff will communicate with the Supervisor and financial staff to address said errors and properly account for and remit the interest. Status: completed and ongoing. Scheduled Completion Date of Corrective Action Plan: Mach 31, 2023 Contacts for Corrective Action Plan: Maxwell Krieger, DHCD General Counsel maxwell.krieger@vermont.gov Naomi Cunningham, Housing Program Administrator naomi.cunningham@vermont.gov Chris Banning, ACCD Administrative Services Director IV christopher.baning@vermont.gov Tracy Badeau, ACCD Financial Director I tracy.badeu@vermont.gov

Contact Person Kirk Geadelmann, Finance Corrective Action Plan We are in the process of updating the Center?s written policies and procedures to include the requirements of the Uniform Guidance. Completion Date Fiscal year end 2023

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