Corrective Action Plans

2022-006 a. Name of Contact Person Responsible for Corrective Action: Jeff Burks, General Manager, and Cynthia Fowler, Office Manager & Comptroller Phone Number: (256) 356-8622 b. Corrective Action Planned: The Water Works and Gas Board of the City of Red Bay will ensure payments under reimbursable grants are made prior to reimbursement requests. c. Anticipated Completion Date: Immediately

U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: 5 H49MC00119-21-00 / 6 H49MC00119-20-01 2022-007: Cash Management – Material Weakness Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all draw down requests are reviewed and approved to ensure costs were accurately reported and paid before requesting reimbursement. Grantee Response and Corrective Action Plan 2022-007: We concur with this finding and have implemented measures to mitigate the repetition or additional occurrences. Previously draw down documentation was uploaded to a shared folder, in which the CEO and Fiscal Manager had access. In 2023, we implemented additional procedures to document review of drawdowns and supporting documentation. Additionally, documentation includes attaining the CEO signature on draw down documentation before the draw down is made. Responsible Parties: Jemea Dorsey, CEO Date Corrected: April 30, 2024

Significant Deficiency in Internal Control over Compliance and Compliance Recommendation: CLA recommends that The Organization move away from using a cumulative profit and loss report and instead run monthly general ledger details by program as support for their monthly reimbursement requests. This will enhance clarity of costs attributable to each monthly period and reduces the chance that costs will be missed when requesting for reimbursement. Any reconciling transactions can be clearly tracked an Excel file of the general ledger detail by program. In addition, CLA recommends that The Organization emphasize to program management staff the importance of filing reimbursement requests each month and in a timely manner to reduce administrative and financial burden. There is no disagreement with the audit finding. Action taken in response to finding: The organization has modified our approach to making monthly reimbursement requests by including monthly general ledger details by program to ensure we have appropriate support and to increase clarity of costs attributable by month. Since fall/winter 2023, we have increased training to financial and program management staff around the importance of filing reimbursement request in a timely manner and we intend to increase the size of the financial support staff to further help minimize timely delays in reimbursement requests. Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 4/1/2024

Finding: 2022-006: Significant Deficiency in Internal Controls over Compliance – Cash Management Name of Contact Person: Shema Jones CFO Catholic Community Service 1803 Glacier Highway Juneau, AK 99801 Corrective Action: Controller reviews and corrects billings received which includes backup by AR, then CFO reviews prior to submission to payment management system. Proposed Completion Date: 6/30/23

March 27, 2024 2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance not obtained. Corrective Action: We agree with the finding. The Consortium has carefully reviewed our policies and procedures and have made the necessary changes to ensure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. We believe the updated procedures will result in the reduction over time and ultimately the complete elimination of this issue. Contact Person: Shamar Herron: Sherron@mwse.org Anticipated Completion Date: December 2024 Respectfully, Shamar Herron

The County does not have a complete set of written cash management policies and procedures as required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Grantee Response: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.

Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to establish procedures that incorporate controls to review expenditures for payment prior to submitting request for reimbursement, and that the outstanding checks (and other reconciling items) be resolved in a reasonable period of time. Such evidence of control activities including review will be documented and maintained.

Finding 2022-006 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 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

2022-005 - Year Ended December 31, 2022 Department of Health and Human Services CFDA #93.829 Section 223 Demonstration Programs to Improve Community Health Services (CCBHC) Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Finding Summa,y: - Rimrock Foundation does not have formally documented written internal control procedures over compliance with federal award programs to meet the requirements regarding compliance with federal regulations for procurement, suspension and debarment. Responsible Individuals Jeffrey Keller, CEO and Shirley Ehlang, Lead Financial Accountant Corrective Action Plan: Rimrock Foundation will adopt written internal control procedures over compliance with federal award programs regarding compliance with federal regulations for procurement, suspension and debarment. Anticipated Completion Date: Ongoing

Finding 2022-007: Costs Incurred & Paid Prior to Reimbursements (Significant Deficiency over Internal Control and Instance of Noncompliance – Cash Management; Period of Performance) Response and Corrective Action Plan: Management agrees with finding. The Health System will review and modify policies and procedures over the program to ensure management implements policies, procedures, and processes to make sure that funds are disbursed for incurred expenditures prior to reimbursement requests. Anticipated Completion Date: by March 31, 2024 Responsible Person: : Ann Metzger, Vice President Finance

The Treasurer, Town Manager and Select Board has taken the following actions to address finding 2022-007: The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted a new Procurement Policy that addresses this deficiency. This policy was approved and implemented by the Select Board on January 23, 2024.

Recommendation:We recommend management and the board of directors should review reporting frequently to make sure that they are complying with the requirements. Management Response: We agree with the recommendation and the record retention policy that was adopted on November 14, 2022 should prevent this from happening in the future.

2022-005 Significant Deficiency in Controls over Compliance: Administrative Requirements of Uniform Guidance-Administrative Policies The schools have documented their administrative policies effective 3/1/2023.

2022-003 Cash Management Management?s Response and Planned Corrective Action: Management will monitor reimbursement requests to insure that payments have been made to vendors prior to submitting the reimbursement request. Name and Title of Contact Person: Timothy Matte, Executive Director

Finding 2022-003: Noncompliance with Cash Management Condition: Cash draws from WIOA Cluster and Coronavirus Relief Fund grants exceeded the amount needed to cover allowable costs. Recommendation: Management needs to work with the State of Indiana Department of Workforce Development to refund the overdrawn funds or apply the funds to allowable costs in the upcoming fiscal year. Management?s Corrective Actions: Staffing changes have occurred, and the fiscal management duties have been outsourced to a third party which has experience with Workforce Boards and related grants. These issues are being addressed with IN DWD.

Federal Program Name: ? Block Grants for Community Mental Health Services ? ALN 93.243 ? Substance Abuse and Mental Health Services Projects of Regional and National Significance ? ALN 93.829 ? Section 223 Demonstration Programs to Improve Community Mental Health Services ? ALN 93.958 Recommendation: Our auditors recommended the Organization revise their Financial and Control Policy to encompass the requirements defined within ? 2 CFR 200.305. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management concurs with the audit finding. While the policy has been updated previously, it was not updated such that it complied with the requirements of 2 CFR 200.305. The Controller and CFO have updated the policy so that it fully complies with all of the requirements defined within 2 CFR 200.305. Name(s) of the contact person(s) responsible for corrective action: CFO and Controller. Planned completion date for corrective action plan: Will implement in fiscal year 2023.

FINDING 2022-014 Contact Person Responsible for Corrective Action: Casey Brewster Contact Phone Number: 812-752-8935 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The approved grant budgets for all federal grants will be input into the financial management system and with all expenditures reported monthly from the Treasurer to the Director overseeing the federal grant for review and final approval. The monthly reports will then be used by the Director to generate a reimbursement request for actual expenditures. The reimbursement request must then be reviewed and signed by the Treasurer or the CFO prior to submission to the State by the Director. Anticipated Completion Date: April 2023

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

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

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

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

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

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

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