Corrective Action Plans

Title: Incomplete Support for Capital Fund Program (CFP) Drawdown Sample Program Name: Capital Fund Program ALN: 14.872 Description: As part of the testing of the Capital Fund Program (CFP) major program, a sample of six drawdown vouchers were selected for review. The Authority was unable to provide adequate supporting documentation for one voucher in the sample. The missing documentation prevented verification of the eligibility, timing, and allowability of the associated expenditures. Planned Corrective Action: Fiscal Vear 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to ensure that every drawdown request is accompanied by the required supporting documentation. In addition, the supporting documentation will be reviewed to ensure that it meets eligibility, timing, and allowability of the associated expenditures.

Title: Unsupported MTW Capital Fund Program (CFP) Drawdowns Program Name: Moving to Work Demonstration Program - Capital Fund Program ALN: 14.881 Description: During testing of the Moving to Work Demonstration Program - Capital Fund Program, we selected a sample of eight eLOCCS drawdown vouchers for review. Of these, the Authority was unable to provide sufficient supporting documentation to substantiate the eligibility, timing, or purpose of the drawdowns for two vouchers. In addition, for one voucher, the Authority did not provide evidence of immediate obligations or expenditures to support the drawdown, indicating a potential violation of the federal "just-in-time" funding requirement. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to ensure that every drawdown request is accompanied by the required supporting documentation. In addition, the supporting documentation will be reviewed to ensure that it meets eligibility and "just-in-time" requirements prior to the Executive Director signing the request.

The Department of Behavioral Health (DBH) concurs with the finding. All grant expenditures and cash drawdowns will comply with the guidelines established for DIFS including the requirement that drawdowns are only submitted for paid expenditures. The receivable invoice will be generated in the Project and Grant module reflecting the total paid expenditure. DIFS will automatically send notification to the Accounting Officer for invoice approval. Upon approval, the Accountant must submit the draw request through the relevant Federal Treasury system based on the approved invoiced amount. The funds will not be drawn until the approval of the invoice. Contact: Barbara S. Roberson, Accounting Officer, Human Support Services Cluster Estimated Completion Date: October 2025 See Corrective Action Plan for chart/table

Condition: The Organization did not have a formal cash management policy in place for the period under audit. Planned Corrective Action: The Organization implemented a Federal Awards Administration Policy which includes a formal cash management policy in February 2025. Contact person responsible for corrective action: Valeria Watson Anticipated Completion Date: February 2025

Title: Housing Choice Voucher Program Name: Section 8 Housing Choice Vouchers ALN: 14.871 Description: During the audit of the Authority, it was noted that federal funds were inappropriately loaned to affiliated entities without proper authorization or adherence to federal cash management requirements. Specifically, the entity disbursed $43,533 in federal funds to the Housing Authority of Florence under the guise of a temporary loan, which was not supported by a formal agreement, lacked board approval, and was not repaid within the fiscal year. Planned Corrective Action: Today’s Marlboro County Housing Authority management concurs with the auditor’s finding that federal funds were disbursed to an affiliated entity without proper authorization, documentation, or compliance with federal cash management requirements. The Authority acknowledges that this disbursement represented a lapse in internal controls and was not consistent with the requirements outlined in 2 CFR §200.305(b). During the fiscal year ended September 30, 2024, the Authority also had a payable to the same affiliate in its Public Housing Program totaling $37,658. During the current 2024-2025 fiscal year, the Authority reimbursed its HCV program the amount loaned from its HCV program by the funds owed to the affiliate in its Public Housing Program. Today’s Marlboro County Housing Authority currently has an amount of $2,015 due to its affiliate as of May 31, 2025.

Town will no longer be holding invoices until ARPA funding is received but will follow the reimbursement guidelines per the grant agreement. April 30th 2025 anticipated completion date. James A. Sullivan Mayor

Planned Corrective Action: Housing Compliance team will immediately train staff on the requirement to ensure that retainages are paid prior to draws from the HOME Treasury account. Retainage reimbursements will require additional verification in AMS to ensure payments are processed. Responsible Party: Cynthia Rogers-Ellickson, Director – Housing & Community Development Planned Implementation Date: June 13, 2025

Finding 2024-001 Lack of Internal Controls Over Cash Management Name of Contact Person: Galen Gilbert, First Chief Corrective Action Plan: In the prior fiscal year, Arctic Village Council (AVC) experienced delays in drawing down HUD funds due to staff transitions and turnover. While reimbursement was ultimately received, the funds were not deposited until after fiscal year-end, contributing to the reported cash management issue. To strengthen internal controls and avoid future delays, AVC will continue to follow its monthly reconciliation process to ensure that all grant expenditures are accurately aligned with drawdown activity and supported by eligible costs. In addition, AVC will explore establishing a line of credit (LOC) in FY2025 to help bridge timing gaps between expenditures and reimbursement cycles. This LOC would provide short-term liquidity support and help reduce reliance on general fund balances while awaiting federal reimbursements. Proposed Completion Date: September 30, 2025

Finding Number 2024-001 Contact Person(s): Dionne Gordon dgordon@pnri.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Although the findings consisted primarily of a small number of late payments that were either 1 day late or late as a result of a poorly timed holiday, we fully acknowledge the accuracy of the finding and have added an additional control to account for the impact of weekends and holidays on our AP payment runs. Corrective action planned: Internal control established in AP department to keep track of sub recipients’ request reimbursement to ensure payments are disbursed within 30 calendar days after receipt of request. Anticipated completion date: March 31st 2025

2024-002 Twenty-First Century Community Learning Centers - Assistance Listing No. 84.287 Significant Deficiency in Internal Control Over Compliance and Noncompliance - Appropriate Review of Expenditures Claimed B. Allowable Costs/Cost Principles Recommendation: The Auditors recommend that management strengthen its review procedures over expense cutoff to ensure that expenditures are recognized on the SEFA in alignment with GMP. Additionally, training should be provided to accounting personnel on Uniform Guidance compliance and GMP requirements related to expense recognition. Planned Corrective Action: We agree with the recommendation and plan to have the corrective action implemented by August 2025.

To address the identified non-compliance with timely subrecipient payments, the Cook County State’s Attorney Office has implemented an internal invoice submission form designed to streamline and formalize the invoice processing workflow. This form is now utilized by all business managers and program managers, who have been trained and granted functional access to ensure consistent and accurate usage. Additionally, a dedicated SharePoint site has been established to manage and monitor the invoice submission process. This platform allows for real-time tracking of invoice numbers, amounts, vendor names, and payment statuses, thereby enhancing transparency and accountability. These measures collectively aim to strengthen internal controls, improve communication among parties involved, and ensure compliance with federal cash management requirements moving forward. Party(ies) responsible for overseeing the corrective action plan for the grant programs: - Nader Abusumayah, Chief Accountant, nader.abusumayah2@cookcountysao.org, 312.603.1840 The department plans on completing the above corrective action on 6/1/2025.

The cash draw findings were focused on tracking staff time and effort. The Museum implemented corrective action regarding the use of time sheets for federal award tracking immediately after the DOE grant performance period and exists for each time period in FY25. The Human Resources department has incorporated the timesheets into employee training, onboarding, and the updated staff handbook. Already Completed. Kevin Cantfil, VP of Finance and Administration.

Drawdown requests that include reimbursement for time and attendance will include documented approval by one additional staff member. If programmatic staff prepare the drawdown, the VP of Finance and Administration will complete the final approval. If the VP of Finance and Administration prepares the drawdown, a member of the Advancement department will complete the final approval. June 30, 2025. Kevin Cantfil, VP of Finance and Administration.

Item: 2024-001 Assistance Listing Number: 93.243 Program: Substance Abuse and Mental Health Services, Expanded Access to Homeless Services Federal Agency: U.S. Department of Health and Human Services Pass-Through Agencies: n/a Contract Number: 5H79TI082775-02 Award Year: 9/30/2023 – 9/29/2024 Compliance Requirement: Cash Management, Reporting Criteria: Per 2 CFR 200.305, under the reimbursement method, expenditures must be incurred prior to the date of the reimbursement request. The Organization is also responsible for submitting an annual Federal Financial Report (“FFR” or SF-425) to the U.S. Department of Health and Human Services, Substance Abuse and Mental Health Services Administration. Condition: The Organization erroneously included a duplicate request for reimbursement in a monthly reimbursement request report submitted to the granting agency and was overpaid by the amount of this duplicate request for reimbursement totaling $41,042. Additionally, the total expenditures reported in the FFR/SF-425 were misstated by $23,058. Name of Contact Person: Ramon Dominguez, CFO Phone Number: (480) 831-7566 x4909 Anticipated Completion Date: September 30, 2025 Views of Responsible Officials and Corrective Actions: The Organization will implement additional controls to ensure monthly requests for reimbursement and reviewed and approved prior to submission. Additionally, the annual FFR/SF-425 will be reviewed and reconciled to the monthly draws.

Corrective Actions Taken Commons has taken the following actions to protect against such fraudulent incidents in the future: • Engaged a firm to assist with managing the incident; • Opened a new bank account; • Added account verification services with our banking partner, which will be utilized to verify account updates; • Limited the amount of per vendor/subrecipient daily payments to our insurance limits, with verifications prior to releasing additional funds when the total payment exceeds the insurance limits; • Subrecipient payment receipt is verified by both the subrecipient and the Commons grants team; • Updated our policy and procedures to direct our subrecipients to request banking changes through our procurement system and not through email; and • Expanded implementation of our Kissflow procurement system across the organization, which includes new vendor process as well as a change of vendor information module. Vendor changes would be approved first by the program/department that works with the vendor prior to Finance approval. Completion Date With the exception of implementing the change of vendor information module in Kissflow, the above actions have all been completed by the date of this report. The projected completion date for Kissflow change of vendor information module is April 30, 2025. Responsible Party Dana Thomas, Chief Financial Officer Angela Allen, Vice President of Finance

Finding 2024-001: Cash Management Federal Grant – ALN 93.788 and ALN 93.959 Condition – During testing, it was noted that cash was requested prior to disbursement of funds by a month or more. Corrective Action –HealthWest finance management will conduct a mandatory staff training session for all relevant staff on cash management requirements, including timing of cash requests, documentation of expenditures, and consequences of non-compliance. Refresher grant compliance and cash management policy review and training will be incorporated into annual training for all grant management personnel. HealthWest will update grant pre-draw process to require a documented review and approval of all cash draw requests by finance leadership or designee ensuring drawdowns are supported by general ledger expenditure activity reports. Contract Person – Brandy Carlson, Chief Financial Officer Anticipated Completion Date – June 30, 2025

The reconciliation process implemented in Finding 2024-001 includes a formal method of matching drawdowns to allowable expenditures. Each grant will continue to be tracked in a separate cost center and La Casa will document the reconciled expenditures in the general ledger to amounts drawn from each grant. The monthly reconciliation will be reviewed by the CFO to ensure that revenue is recognized in accordance with ASC 958-605 and that federal expenditures reported on the SEFA and financial statements comply with 2 CFR §§200.302, 200.303, and 200.305. The CFO will utilize the reconciliations to prepare the SF-425 filings and confirm that cumulative drawdowns reconcile to allowable costs and recorded revenues. All supporting documentation will be retained electronically and included in monthly close procedures.

Views of Responsible Officials: Federal grant requests and reporting is the function of three teams: Programs, Development and Finance. Prior to the hiring of the VP-Finance, the Associate Director, Grants Management and Compliance met with the Associate Director, Partnerships on a quarterly basis to discuss required program spend reimbursements and projected program cash needs prior to submitting the formal requests. With the onboarding of the new VP-Finance, internal review processes were changed to incorporate more robust segregation of duties, alignment with the internal cash management policies and procedures and formal review of drawdown requests prior to submission. The VP-Finance became a permanent employee in October 2024 and since then all submissions have obtained the appropriate approval prior to submission.

Transfers and Disbursement process will be reviewed to minimize the time between drawdown and disbursement and comply with Federal regulations. Funds are regularly monitored to ensure that only needed funds for immediate use are drawdown. Drawdowns are initiated when accounting department send the Grant monthly reconciliation to Federal and State Funds Administration Office, Compliance officer reviews the reconciliation and Director of Federal Funds Administration determine needed funds to be requested. A new Enterprise Resource Planning (ERP) software it’s under implementation and will address this issue as part of the implementation process.

Contact Person – Krista Martin, Director of Finance and Administration, and Ryan Riesinger, Executive Director Corrective Action Plan – Review and update procedures to ensure accurate reporting. Completion Date –December 31, 2025

Recommendation: We recommend the Agency revise federal award cash draw procedures to ensure compliance with cash management requirements. Such draws should be made solely for immediate cash needs. Action taken: Management agrees with this finding and has implemented corrective actions. Current and future draws are made for immediate cash needs for expenses already incurred.

The City is in agreement with the finding and noted and will consider formally documenting policies and procedures. Heather Shippey, City Clerk will be responsible for the corrective action and anticipated completion of corrective action is undetermined.

The Utilites Board of the City of Oneonta will not request advance receipt of payment. The Organization will be following Procedure CFR section 200.305 (b)(1). Payments will be processed and issued within 10 business days of received date from engineer. If payments cannot be made within 30 days, received funds will be required deposited into a designated insured interest-bearing account until payments have been issued. Anticipated Completion Date: 2/4/2025 Responsible Person: Mark Gargus, General Manager

Corrective Action Plan We are in the process of updating the Organization’s written policies and procedures to include the requirements of the Uniform Guidance. Completion Date Fiscal year end 2025

Finding 2024-03: Cash Management Approval Views of Responsible Officials Management agrees with the findings and recommendations. Through the merger with Old Dominion University, additional controls have adopted around the processes and controls around the review and approval of cash drawdown requests. Corrective Action Plan Effective July 1, 2024, EVMS merged with ODU and the ODU Research Foundation became the fiscal and administrative agent for EVMS’s transferring sponsored programs on behalf of ODU. As per ODU’s Memorandum of Understanding (MOU) with the ODU Research Foundation, the ODU Research Foundation has policies and processes in place to manage the review and approval of cash drawdown requests. The ODU Research Foundation uses its own system of internal controls for the review and approval of cash drawdown requests with no reliance on ODU systems for those processes and are audited separately. As a corrective action moving forward, ODU management will notify the ODU Research Foundation management of the audit findings, so they are aware of the internal control deficiencies. ODU will request the Research Foundation to provide a copy of their single audit report to monitor continued compliance with Uniform Guidance. The corrective action plan will be completed by March 31, 2025 and the contact person for this finding is Victoria Dean.