Corrective Action Plans

Action 1: Ensure that cash drawdowns occur within a few days of disbursement as the standard of “minimizing the time elapsing between draw down of funds and disbursement for program purposes.” Action 2: Ensure that the Chief Financial Officer, Director of Accounting & Budgeting, and the HSI Grant Administrator complete the Post-Award Training available from Ed.gov. Action 3: Establish a policy that month end, quarterly, and year end balances in the HSI account are at or near $0.

Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider, which totaled $3,782,381 for the audit period. For all invoices during the audit period, the School Corporation submitted and received reimbursement from the IDOE prior to paying the service provider, and then the School Corporation remitted payment to the service provider. There was significant delay in the time between the School Corporation was reimbursed by IDOE and when the School Corporation paid the service provider. The delay in payment was in the range of 2 – 4 months for the payments made during the audit period. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corporation will pay Special Ed invoice to INDLS within the same week as receiving the reimbursement. Anticipated Completion Date: 05/01/2025

The Authority will disburse all of their funds in a timely manner.

The Authority will pay back the excess interest and monitor the interest earned in the following years and payback any excess amounts.

Corrective Action Plan FY2024 2024-001 Assistance Listing Number, Federal Agency, and Program Name • 10.500 – U. S. Department of Agriculture - Cooperative Extension Services • Research and Development Cluster o 12.000, U.S. Department of Defense, U.S. Department of Defense o 12.431, U.S. Department of Defense, Basic Scientific Research o 47.041, National Science Foundation, Engineering Grants o 47.070, National Science Foundation, Computer and Information Science o and Engineering o 81.049, U.S. Department of Energy, Office of Science Financial Assistance o Program o 93.855, U.S. Department of Health & Human Services, Allergy, Immunology o and Transplantation Research o 93.859, U.S. Department of Health & Human Services, Biomedical o Research and Research Training o 98.001, Agency for International Development, USAID Foreign Assistance o for Programs Overseas Federal Award Identification Number and Year • 10.500 - 2021-48762-35660, 2022-48703-38592, 2021-41590-34813 • 12.000 - 2021-21090200002 • 12.431 - W52P1J-22-9-3009, W52P1J-20-9-3009-10 • 47.041 - 2129782-CMMI, 1647722-EEC, 2132142-EFMA • 47.070 - 2333009-CCF • 81.049 - DE-SC0019215 • 93.855 - 5R01AI146160-05 • 93.859 - 5R01GM143370-02 • 98.001 - AID-7200AA18CA00009 Finding Type - Significant deficiency Repeat Finding – Yes 2023-001 Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - The University did not have adequate controls in place to ensure invoices to subrecipients were paid timely within the 30-calendar-day requirement. Questioned Costs - There were no questioned costs identified. Context - Out of 60 payments to subrecipients that were tested related to the major programs tested, 21 were made after the 30-calendar-day requirement. In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 31-119 days between the invoice being received by the University and payment being made to the subrecipient. The University did implement new preventative controls in place effective December 31, 2023 in response to prior year finding (2023- 001). Of the 21 payments made after the 30-calendar-day requirement, 14 occurred prior to December 31, 2023, and the remaining 7 occurred after. Cause and Effect - While the University had effective controls that were successful in achieving the 30-calendar-day requirement for 39 samples, the University failed to provide supplemental support and preventive controls during a period when it was addressing an issue that prevented timely payment for certain subrecipients. Recommendation - The University should ensure appropriate training of employees is taking place and a preventive control is implemented to ensure that payments are made within the required timeline. Views of Responsible Officials and Corrective Action Plan Purdue University will address the recommendations and implement the following preventative controls to ensure that payments are made within the required timeline. 1) The Office of Research will increase the priority around the 30-day processing deadline mandated by the Uniform Guidance 2 CFR 200.305 (b)(3). This will be accomplished through communications, training and expectation setting with the following audiences: a) Principal Investigators of active grants with sub-awards i) Blanket communication ii) Add the expected turnaround time on each sub-recipient communication when seeking principal investigator review and approval iii) Modify the workflow email to heighten the awareness and timeliness expectations of processing b) Sub-award Team in Sponsored Program Services i) Blanket communications to SPS, Research Account Specialists, Business Offices, Tax, Accounts Payable/Business Operations ii) Utilize a report developed for internal reporting and tracking of pending sub-invoices to improve follow-up on payments approaching the 30-day deadline iii) Increase the frequency of follow-up on outstanding invoices iv) Add the expected turnaround time to the expectations document for each Sub-Award Team Member v) Add sub-recipient payment deadlines to the mandatory training for the Sub-Award Team vi) Update payment terms to “Payable immediately Due net; Based on Doc Date” for all subrecipient invoices vii) Modify procedures for foreign sub payments to streamline the processing between tax and export control offices related to required screenings 2) Conduct semi-annual training/refresher with sub-award staff. The first training will be held January 2025. 3) Work with subaward team staff to ensure that adequate documentation is created and maintained related to the follow-up that occurs when issues are being investigated and resolved that causes a delay in processing. These include visual compliance screenings for foreign wire transfers and other situations where delays occur for justified reasons (performance issues, delay in progress reports, questionable charges, missing or incomplete information, line-item concerns, etc.). Maintain documentation in the grant or posting document file 4) Evaluate and continually monitor staffing levels on the sub-award team and seek supplemental staffing when warranted.

Federal Agency Name: Department of Justice Assistance Listing Number: 16.812 Program Name: Second Chance Act Reentry Initiative Finding Summary: There were two months out of twelve where the draw request amount for the Second Chance Act Reentry program was switched with a draw request for another federal program. The draw request amount exceeded the actual expenditures incurred for these two months. Corrective Action Plan: SHIP’s Finance Director drew down funds for two months of expenditures on the same day for both the Department of Labor‐funded BOOST GO program and the Department of Justice‐funded BOOST Re‐Entry program. This resulted in mistakenly swapping the drawdowns for the programs, therefore drawing down GO’s funds for Re‐Entry and Re‐Entry’s funds for GO. The payments were recorded correctly by Accounting staff. The mistake was caught while the Finance Director was preparing for the annual audit. Once the mistake was discovered, the Executive Director and the Finance Director immediately contacted the Federal Project Officers of both grants to report the error and request information on how to proceed with correcting it. The Federal Project officers were supportive of being informed of the errors, and in providing feedback on how to correct the mistakes, which SHIP did immediately. Next, the Finance Director reported the error to the auditors, and the errors were also reported to the SHIP Executive Committee of the Board of Directors. Moving forward in the short term, the Finance Director has started to double check the account number on the report and the account number on the draw down platform to ensure that it is the correct grant. The reports are prepared monthly and the accountant that will prepare the monthly report will also add the account identifier to the front of the packet. This will be double checked by the Finance Director. Deposits will have to be verified as well to ensure we record the payor correctly. The Finance Director will also reconcile that the payments recorded on the grant platform and SHIP’s financial system to ensure they both agree. Long term, SHIP will be more intentional about the naming and branding of programs. Currently, SHIP is applying for a new grant from the Department of Labor to continue the BOOST Re‐Entry program. If awarded, this program will be dropping the “BOOST” acronym from the name to avoid confusion with the established BOOST GO program. Having two separate programs sharing a name was intended to build on the branding and community awareness of the BOOST program but has had the unintentional consequence of creating confusion for the public, partner agencies, and participants. As the above finding also demonstrates, it can cause unfortunate errors administratively as well. See also 2024‐006 Finding for each program Responsible Individual: Mindy Baylor, Director of Finance Anticipated Completion Date: November 2024

1 We have decided not to withdraw funds from the payment management service until the available funds are used, and moving forward, we will be keen on withdrawing funds using the cost-reimbursement method. 2 We have developed federal funds withdrawal and spending monitoring spreadsheets. We will use this tool to control the balance of funds to make sure that optimum amount of money is maintained.

Management agrees with the finding and recommendation. A process will be put in place to ensure the cash drawn down will be expended within the 30 day timeframe. The Controller will prepare the analysis and the CFO will approve as a part of the month end closing process.

Research and Development Cluster – Assistance Listing Numbers 47.070, 47.076, 47.084, and 93.846 Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Midway through the fiscal year, we introduced a new process involving multiple layers of approval before a drawdown is executed. The drawdown calculation is done either by the Senior Accountant or Grant Manager and sent to either the Grant Manager (if prepared by the Senior Accountant), or Controller (if prepared by the Grant Manager) for review and approval. If additional information is needed, the approver sends the request back for updating and recalculation. Name(s) of the contact person(s) responsible for corrective action: Mutale Sokoni, Associate Vice President for Finance, 703-284-1496 Planned completion date for corrective action plan: Action taken during April 2024

Audit Finding Number: 2024-002 – Cash Management Agency: Public Housing Capital Fund Responsible Person, Title: Stephanie Schmutzer, Accountant Completion date: 7/1/2024 Agency Response: Concur Corrective Action Plan: Management concurs with the recommendation to implement timely LOCCS fundings that coincide with our normal accounting cycle and when directed by HUD to circumvent the rules to get that in writing not just verbal.

Identifying Number: 2024-001 Condition: Controls in place did not minimize the time elapsing between the transfer receipt of billing from the subrecipient and disbursement of federal dollars to the subrecipient in accordance with the guidance above. Corrective Actions Taken or Planned: Federation typically receives vouchers from 14 subrecipient organizations approximately ten days after the end of each month. The number of vouchers per agency depends on the number of programs they provide. Staff reviews the vouchers for allowability and accuracy and submits them to the Illinois Department of Human Services (IDHS) within 24 days of month end. During fiscal year 2024, the IDHS remitted payment to Federation anywhere from 48 to 124 days after the month end. Upon receipt of the cash, Federation pays subrecipient organizations within thirty days. In the instances identified by the auditors, the IDHS remitted payment over 30 days after Federation submitted the vouchers for reimbursement. Federation’s longstanding policy has always been to reimburse each subrecipient agency after it has received payment from the IDHS. Prior to fiscal year 2024, the IDHS usually provided payment within 15 days of receipt of our voucher and therefore Federation was able to comply with the 30-day requirement. However, reimbursement delays from IDHS occurred during fiscal year 2024 resulting in the findings describe herein. To ensure compliance with the 30-day reimbursement requirement, Federation will formally request an advance from the IDHS. Kyu Kim, Director of Finance and Contract Compliance, Refugee Services will be responsible for the oversight of the reimbursement payments and will ensure the Federation adheres to the 30 day requirement going forward. Responsible Person: Kyu Kim Anticipated Completion Date: July 2025

Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Questioned Costs: N/A Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2023 audit report in May 2024. The 2023 audit was completed after substantially all of Fiscal Year 2024 had elapsed, so there was not adequate time for the University to fully implement corrective action. The University is strengthening its accounts payable processes and sign-off approvals to help ensure reimbursements to subrecipients are paid timely. Principal investigators and designated administrative personnel within academic departments will be reminded of the need to initiate payments to subrecipients timely. Name(s) of the contact person(s) responsible for the corrective action: Mr. Robert Dixon, Director, Grants and Contracts Fiscal Administration at Oklahoma State University and Mr. Chris Kuwitzky, Vice President for Fiscal and Administrative Affairs. Planned completion date for corrective action plan: March 2025

Contact Person: Pam Utt, Business Manager. Corrective Action Plan: Management recognizes the deficiency and plans to review the control process for how the District performs the drawdown. Management attributes the occurrence of the deficiency to unfamiliarity with the reporting mechanisms of the grant, which was new to the District during the period under audit, and feels confident such instances can be prevented in the future. Planned Completion Date for CAP: June 30, 2025.

Information on the Federal Program: U.S. Department of Education, Trio Cluster Criteria: 2 CFR 200.305 establishes the procedures for receiving federal payments. Non-federal entities must design and implement internal controls to ensure compliance with cash management requirements. Condition: We selected a sample of 24 reimbursement draw downs made during the year through the G5 payment system. Procedures were in place to accumulate expenses based on approved invoices and draw the reimbursement amount down through G5, however, documentation of review and approval of amounts to be drawn was not available. Management’s Response: The College has always had controls on draw downs associated with separation of duties and the review of grants. The College will ensure a signature page is included to document these efforts of the review and approval of all Federal draw downs. Anticipated Completion Date: January 31, 2025

Management's Response: Management concurs with the above finding and implementation of proper approval and documentation was completed in July 2024. All required documentation will be attached to each drawdown receipt.

Finding Number: 2024-004 Condition: The College does not have a written cash management policy related to federal awards. Planned Corrective Action: In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards in order to implement the requirements of 200.305. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: As soon as possible moving forward starting December 18, 2024.

December 27, 2024 Finding Number: 2024-004 Material Weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) (Workforce Innovation and Opportunity Act- WIOA) Finding 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 was not obtained. Planned Corrective Action: 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 that they are supported by transactions recorded in the general ledger. Cash draws continue to be “necessary and reasonable”. We strive to improve the timing of our cash draws, our grant reconciliations and to continually monitor our cash management to ultimately eliminate this issue. Responsible Contact Person: Shamar Herron (Executive Director) Sherron@mwse.org Anticipated Completion Date: March 2025 Respectfully, Shamar Herron

December 27, 2024 Finding Number: 2024-003 Material Weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) (Wagner Peyser) Finding 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 was not obtained. Planned Corrective Action: 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 that they are supported by transactions recorded in the general ledger. Cash draws continue to be “necessary and reasonable”. We strive to improve the timing of our cash draws, our grant reconciliations and to continually monitor our cash management to ultimately eliminate this issue. Responsible Contact Person: Shamar Herron (Executive Director) Sherron@mwse.org Anticipated Completion Date: March 2025 Respectfully, Shamar Herron

Finding: 2024-008 Name of contact person: Dr. Justin Hoggard, Board President and CFO Corrective Action: Management will reconcile student fees to actual activity each year. Proposed Completion Date: April 30, 2025 Anticipated Completion: April 30, 2025

Cash Management Management agrees with the finding and the auditor's recommendation. There was confusion at the time of this agreement as the nature of the work was in line with providing institutional services rather than a federal grant agreement. This led to a misunderstanding of cash management requirements due to the nature of the award. Mass General Brigham (MGB) has removed the $215K of questioned costs from the Schedule of Expenditures of Federal Awards (SEFA). The funding will be returned to Advanced Regenerative Manufacturing Institute, Inc. in January 2025. Additionally, management will review the limited instances where departments have been previously approved to request federal cash. This review is to confirm that an exception to the standard practice of managing this through the central Research Finance team is appropriate. Based on results of this review, to be completed by March 2025, management will determine criteria and prior approval requirements for departments to request federal cash if MGB concludes this practice will continue on a limited exception basis. The review will be conducted with oversight by the MGB Vice President of Research Management and Research Finance and the MGB Research Controller.

Recommendation: We recommend the Council updates in payment process to ensure that all providers are paid timely after receipt of grant funds. Action Taken: We have established a streamlined process to ensure timely disbursement of funds to providers upon receiving grant funds. Additionally, we have implemented a monitoring system to track payment timeliness and promptly address any delays. Responsible Party: Jeremy Ashbaugh, Director of Finance. Anticipated Completion Date: The issue has been corrected.

We were made aware of this issue by a desk review from the National Science Foundation and we have developed and implemented the following policies and internal controls to ensure grant funds are drawn down only after qualifying expenditures on a monthly basis.: If a grant is awarded on a cost-reimbursement basis, Future Earth draws down funds approximately once a month, unless the funder requires another way of accessing their funds. Funds are not drawn down until they have been spent. Before each drawdown, the third-party accounting firm will confirm the grant's cash balance. If there is a positive cash balance, the third-party accounting firm and COO will investigate the cause and correct it immediately. Grants with negative cash balance will be checked by third-party accounting firm to confirm that the grant was active when the expenses were incurred. The third-party account firm will provide a report of the associated transactions of the negative cash balance. The PI will confirm the report transactions and approve the drawdown request. Once approved, the third-party accounting firm will create an invoice and journal entry in the Quickbooks accounting system and the COO will request the drawdown from the funder.

Action taken in response to finding: LCHC management has implemented a robust task-management software to assist with internal controls, especially when related to grant management. Furthermore, a cloud-hosted warehouse for internal procedures was implemented to properly manage the assignment and transfer of accounting roles/responsibilities like the review and approval of grant drawdown request. Name(s) of the contact person(s) responsible for corrective action: Jeff Nelson, Accounting and Financial Analysis Director Planned completion date for corrective action plan: 9/30/2024

Corrective Action Plan: The District has developed and implemented a Federal Funds Manual. Anticipated Corrective Action Plan Completion Date: November 18, 2024 Contact Information: For additional information regarding this finding please contact Blaise Paul, Chief Business & Finance Officer, at 414-768-6140.

Recommendation We recommend a verification process be established to ensure accuracy in manual journal entries and to prevent the occurrence of duplicate recordings. Regular reconciliations should be enhanced and additional review steps should be incorporated during the financial close process to identify and correct errors promptly. Furthermore, future Federal Financial Report should take this error into account to accurately reflect cumulative expenditures. Management Response Corrective Action: Four Corners REC has added additional verification processes to ensure the accuracy of manual journal entries to prevent duplicate entries. Reconciliations will be done timely and accurately with added steps. Additional reviews will be done during financial closing and future federal expenditure reporting has been corrected. Due Date of Completion: Completed as of September 9, 2024 Responsible Party(ies): Finance Director