Corrective Action Plans

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Assigned staff will document all advance payments in the Notes section of the Award in Workday. Federal funds reimbursed in advance will be separated into an interest-bearing account. Additionally, staff will compare subrecipient expenses with advance payments on a monthly basis and follow up with the subrecipient as needed to ensure timely use of the funds. • How compliance and performance will be measured and documented for future audit, management and performance review: Staff will document advance payments in Workday's Notes section. The use of an interest-bearing account for advance funds will also be tracked. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Cash Management Subrecipient Federal Program Title: Research & Development Cluster Assistance Listing No. 93.859 & 47.074 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant accounting staff will follow payment requests through the system to make sure payments are made in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Kirsten Broughton , Director of Grant Accounting. Planned completion date for corrective action plan: Implemented for FY25

2024-008 Cash Management Corrective action planned: Federal draws will be made with approval of the Director of Financial Operations or their designee for expenditures that have been incurred and recorded in the general ledger. Electronic documentation will be organized by draw to ensure proper documentation is maintained. Anticipated completion date: 11-30-2024 Contact person responsible for corrective action: Cathy Liles, Director of Fiscal Operations

We agree. The reimbursement has been processed in the Voucher for the month of August 2024. Procedures have been established improving the reviewing and monitoring process in order to detect and help to identify errors before vouchers processed.

Finding 2023-007 – Payroll and Cash Management Deficiencies Responsible official: Executive Director and Accountants Corrective action planned: Management acknowledges that the same payroll and cash management deficiencies identified in the 2023 audit also occurred during 2024 and part of 2025. Specifically, when federal cash balances were insufficient, payroll was paid temporarily from private funds, followed by the issuance of federal checks to employees for reimbursement purposes. During the 2025 audit, management recognized this as a recurring and systemic deficiency. A formal Cash Management and Interfund Transfer Policy is now being drafted and will be approved by the Board by February 2026. This policy will require: 1. Payroll to be processed directly from the federal account when possible. 2. Temporary transfers from private funds to be documented as interfund advances, with full repayment recorded upon reimbursement. 3. Prohibition of issuing duplicate payroll checks to employees. 4. Reconciliation of all interfund transfers within ten (10) business days after reimbursement. The organization will also implement a dual-authorization process for interfund transactions and establish a monthly reconciliation checklist to be completed by accounting staff and reviewed by the Executive Director. Monitoring: Monthly payroll and cash reconciliations will be reviewed by the Executive Director, and External Accountant. Evidence of reconciliations and approvals will be retained for audit purposes. Target completion date: March 31, 2026 Status: New finding – corrective actions in process.

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: Certain 2023 draws were processed as advances outside grant guidelines, although these draws were properly recorded as advances payable in the accounting records. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers this finding resolved. A written drawdown procedure is now in place, requiring two-tier preparation and review, and, for working-capital advances, written approval from the prime funder. When the non-compliance was identified, CUAHSI suspended all NSF draws (late March 2023) until new controls were implemented. On 15 June 2023, CUAHSI completed its first draw under the revised policy. Name of Contact Person: • Jordan S Read, Chief Executive Officer • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete

Management believes that in order to ensure that the amount being drawn down are timely and more accurate to the amounts being drawn upon, management is in the process of developing a more formal policy whereby the general ledger will be formally closed on a monthly basis and all amount will be reconciled to the ledger. Once all amounts are proven, then the drawdown amounts will be initiated with the proper documentation attached.

Benjie Read CFO and Felecia Read Staff Accountant, will develop a policy and establish procedures to maintain federal grant funds in an interest-bearing account. This will be done within 90 days of audit completion.

Benjie Read CFO and Felecia Read Staff Accountant, will update written policies and procedures to implement the requirements of 2 CFR 200.305 to include a review and documentation of the cash draw requests prior to submission. This will be completed within 90 days of audit completion. In addition, we no longer operate the only Federal program where cash draws were allowed.

Finding 2023-006 Lack of Internal Control over Cash Management Type of Finding: Material Weaknesses Name of Contact: Adela Lane, Executive Director Corrective Action Plan: 1. Strengthen the payment review process: • Action: Enforce and document a stricter segregation of duties in the payment process. This will ensure the individual requesting a payment is not the same person who authorizes the payment. • Details: All payment requests must be cross-referenced with a corresponding invoice or receipt and reviewed and approved by an authorized department head. This Department Head must not be the one who submitted the initial request. 2. Implement a two-tiered review for cash receipts: • Action: Establish a formal two-tiered cash receipts process to enhance accountability and accuracy. • Details: o Tier 1: The individual receiving and logging cash receipts will immediately perform a preliminary count and documentation. o Tier 2: A separate, authorized staff member will perform a second, independent review of the cash receipt records and verify the funds against the deposit slip before the funds are deposited. 3. Standardize training and onboarding for all staff: • Action: Develop a standardized training curriculum on financial management policies and procedures, including a dedicated section on cash management best practices. • Details: o All new permanent and staff members will undergo mandatory training on the updated policies. o Training will cover the importance of internal controls, specifically emphasizing segregation of duties in cash handling. o The Executive Director will meet with all new finance and administrative staff within their first two weeks to review proper protocols and emphasize the organization's commitment to financial controls. 4. Introduce periodic, surprise cash audits: • Action: Conduct unannounced cash counts and reconciliations to ensure compliance with procedures. • Details: An authorized, independent party will perform these surprise audits quarterly to check cash on hand and compare records against financial systems. 5. Enhance oversight and reporting: • Action: The Executive Director will provide regular updates on the implementation of these corrective actions to the Native Village of Point Hope Tribal Council. • Details: A formal report will be presented quarterly, outlining the progress of the corrective actions and any findings from the new oversight procedures. This provides a clear accountability mechanism. Proposed Completion Date: Ongoing, starting in early 2026.

Clean Water State Revolving Fund – ALN: 66.458 Finding: Material Weakness in Cash Management Controls Recommendation: We recommend that the City develop and implement formal, documented procedures and internal controls to ensure that federal funds are drawn only when needed and disbursed in a timely manner in accordance with federal cash management requirements. This should include documented monitoring of the timing of drawdowns and corresponding disbursements. Action Taken: The City of Hartwell acknowledges the importance of establishing formal internal controls over federal cash management activities. In response to this finding, the City will develop and implement written policies and procedures specifically addressing the timing of federal drawdowns and subsequent disbursements. These actions are expected to mitigate the risk of future noncompliance and address the material weakness identified. SIGNIFICANT DEFICIENCY None Reported

2023-005 – Inadequate Policies and Procedures (Significant Deficiency in Internal Controls over Compliance) Recommendation: We recommend the College establish the required written procedures for federal monies and have them available to all personnel who work with federal programs. Action Taken: The 2022-2023 fiscal year was entirely encompassed by the separation Memorandum of Understanding (MOU) of March 2022 and then the final release settlement in December 2023. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Unfortunately, due to the untimely receipt of the completed audit report, the College did not have the opportunity to review and begin addressing several of the findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. Corrective Action Taken / Planned: • Policy Development o The institution will develop comprehensive written policies and procedures to address compliance requirements related to 2 CFR 200, Subparts D and E of the Uniform Guidance and approved by institutional leadership by July 31, 2025. • Policy Review and Approval o Draft policies will be reviewed by VP of Business and Finance and approved by institutional leadership by August 31, 2025. • Training o Relevant personnel will be trained on the new policies and procedures to ensure consistent understanding and compliance. • Implementation o The institution will fully implement the new procedures by August 31, 2025, and will ensure all departments involved with federal awards are following them. • Ongoing Review: o Policies and procedures will be reviewed annually, and updates will be made as necessary to ensure continued compliance with federal regulations. Due Date of Completion: August 31, 2025 Responsible Official: Carolyn Kasdorf, Vice President for Business and Finance (or appropriate official), Karla Volpi, Dean of Business and Finance, Rebecca Silva, Director of Finance, Lisa Ryan, Restricted Funds Manager

Corrective Action Plan: The Program will work with the finance department to better match advanced drawdowns to the actual disbursement for the period. This will be done by comparing the funds on hand (bank balance) to program costs. If sufficient funds are on hand a drawdown request will not be made. Person(s) Responsible: Deanne Bear Catches, LIHEAP Director Estimated Completion Date: Effectively immediately

Corrective Actions Taken:

1.       SCMRC revised its federal drawdown procedures in 2024 to require documented review and approval of all expenditures before submitting any drawdown request.

2.       A Draw Down Request Workbook is now prepared by the Controller and reviewed against supporting documentation, including invoices, timecards, and purchase records.

3.       The CEO reviews and signs off on each Draw Down Request prior to submission.

4.       Completed Draw Down Request Workbooks are submitted to HRSA for prior approval and retained for audit purposes.

5.       Internal drawdown audits are conducted monthly to confirm alignment with federal cash management standards.

Corrective Action Plan:

1.       Updated drawdown procedures have been incorporated into SCMRC’s financial policies and will be re-reviewed annually.

2.       Refresher training on 2 CFR § 200.305 and internal drawdown requirements will be conducted by Q4 2025.

3.       Results of monthly drawdown audits will be included in the Finance Committee compliance dashboard starting in September 2025.

4.       SCMRC will continue to require documented CEO approval on all federal drawdown submissions to ensure sustained internal control.

Criteria: Recipients of federal awards must minimize the time elapsing between the receipt of funds from the U.S. Treasury and disbursement by the Organization set out at 2 CFR section 200.305(b). Audit Recommendation: We recommend that the Organization 1) maintains timely and accurate recording of disbursements in its job‐costing system and 2) regularly request grant funds based on amounts expended as report in the Organization’s job‐costing system. Auditee Response: UICSL has limited access to its accounting system and removed access by outsourced financial management personnel. In addition to better invoicing structure, UICSL also revised its job-costing system to better comply with these requirements. Together, these systems will be used to request only the amount of attributable ot the programs for reimbursement-based grant funding. Corrective Action Plan: All transactions are logged into the accounting system with appropriate respective grant codes and departments. Invoices and transactions will not be processed without approval and proper coding. UICSL has also implemented a new credit card tracking system along with a purchase order system that is active and maintained by Finance and Accounting. Monthly and quarterly invoices will be prepared for grants in compliance with 2 CFR section 200.305(b). Person Responsible: Matt Poss, Executive Director and Mary Louise Santacaterina, Grants Manager Timeline: Already removed accounting system access by prior outsourced financial managemnet personnel. Monthly check-ins and expenditure reports have been implemented with department leads in 2024. Grants Manager tasked along with Director of Finance of reviewing monthly invoices and ensuring each meets grant and expenditure requirements. All invoices reviewed with grant/project leads and logged appropriately. Staff acountant hired in 2024 to help provide oversight.