Corrective Action Plans

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024

Finding 2022-004: Matching Every Program Director is trained on how The Light House invoices grants to enhance knowledge and decrease mistakes. The Light House finance department has taken over the billing process for all grants for The Light House and Light House Bistro. The streamlined approach provides strict oversight and quality control over what and who is billed to every grant. The Light House finance office is carefully watching the SNAP E&T federal Grant to make sure that the required 50% match is being covered by non-federal funds and not charged back to any federal funds no matter the funding source. Responsible Party: Terry W. Brukiewa, Completion date: 8/1/2022

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is in the process of implementing a new procedure to ensure it is reviewed by accounting and grant managers to ensure accurate reporting. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: March 2024

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is in the process of implementing a new procedure to ensure it is reviewed by accounting and grant managers to ensure accurate reporting. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: March 2024

Finding No. 2022-007 -Activities Allowed or Unallowed, Eligible Uses - FEMA Condition During the closeout procedures, the Cenh·al Office of Recovery, Reconstruction and Resiliency (COR3) office performed a 100% validation on Rental Equipment, supporting documents including conh"act smmnary record, invoices, and proofs of payment. As a result of the validation, the total validated amount is $979,259 from an original amount of $1,260,775 submitted by the Corporation for reimbursement. Corporation response The Corporation agrees with the finding. Corrective Action Plan Upon receiving the audit findings, we initiated an immediate review of our FEMA-funded projects and expenditures. We are implementing immediate corrective actions to address the identified deficiencies and ensure strict compliance with FEMA guidelines regarding eligible uses. • Policies and Procedures Review - Simultaneously, the Corporation is reviewing our existing policies and procedures related to FEMA funds, with a specific focus on eligible activities. Any necessary revisions will be made to strengthen our policies and ensure rigorous adherence to FEMA guidelines and regulations. • Enhance Internal Controls - We are enhancing our internal controls related to FEMA fund utilization. This includes implementing additional checks and balances to improve the accuracy and reliability of our project management processes, ensuring they align with FEMA guidelines. ■ Communication Protocols Enhancements - We understand the importance of transparent communication regarding the use of FEMA funds. To address this, we are enhancing our communication protocols to ensure that all relevant stakeholders are informed of FEMA guidelines, project eligibility requirements, and any changes to procedures. • Return of Funds - Initiate the communication process with the Central Office of Recovery, Reconstruction, and Resiliency to obtain instructions for returning the funds to FEMA. Follow FEMA's specific guidelines on the return of funds, including the appropriate documentation, timelines, and c01mnunication procedures. ■ Finance Team - The Corporation has made changes to its management staff structure in the finance and budget department, with the mission of improving the monitoring process and compliance with federal and local regulations and the support of independent consultants. A new Finance and Budget Director and the Associate Director of Finance and Budget have been appointed. Names of the contact persons responsible for corrective action plan Jesus A. Rodrfguez Aviles - Financial Planning and Analysis Associate Director Cecilia Robles Kakiuchi - Financial Planning and Analysis Director Anticipated Completion Date Fiscal Year 2024

Grantee Response and Corrective Action Plan: We concur with this finding and have implemented measures to mitigate the repetition of additional occurrences. In July 2023, the Accounting Manager, Grants Manager, and Grants Supervisor attended the 2023 Southern Grants Forum in Nashville, TN. This investment in training assisted these key employees in understanding and implementing procedures to effectively match Federal Grant awards. We have updated our Policy and Procedures Manual to reflect a new policy of matching Federal Grant awards with non-federal funding. The Grants Supervisor reviews all invoices submitted by the Grants Manager to ensure compliance with this new policy.

PAX will implement a dedicated cost center in the books and records specifically for tracking these expenses. This will allow for better transparency and accountability in reporting. Additionally, PAX will reconcile against this cost center to ensure that the expenses reported to the grantor and budgetary allocations align with the actual expenditures. Dije Kucana, Comptroller, effective immediately

Name of the Contact Person Responsible for the Corrective Action Plan: Gia Scruggs, City Manager Corrective Action Plan: The private contractor engaged in 2017 to provide government management and operations services staffed the engagement with less than 40 staff including 5 consultants. The City, since the termination of the services contract effective December 31, 2021, has 79 staff involved in City management and operations roles including 5 elected officials. The additional staff, including an additional 5 in accounting/finance, affords the City the capacity to effectively account for and report on restricted funds received in connection with state and federal grant programs. The City Manager staff has grown by an additional 3 staff persons from the contractor level that was assigned in 2021 to monitor grants providing sufficient City staff for current grant programs to be monitored and grant conditions complied with. As the City continues to be eligible for additional state and federal grants, a Grants Administrator position has been added to staff organization and the plan is to organize a grants management team devoted to reporting and compliance assurance as well as seeking to apply for state and federal grant and program funds. Anticipated Completion Date: City Finance Department staff, together with the City Manager, are presently monitoring compliance and reporting relating to state and federal grants and program support. Third-party contractors will no longer be used for these tasks, and as more restricted funds are received by the City, the grants management team will be organized. Presently, the City has only one federal grant program and one state program. The corrective actions have been implemented and are presently operative and in place

Corrective action has been immediately implemented in response to the auditors' recommendation. As financial reporting is still in process of getting to current, the City anticipates findings to be reduced in future fiscal years.

PAX will implement a dedicated cost center in the books and records specifically for tracking these expenses. This will allow for better transparency and accountability in reporting. Additionally, PAX will reconcile against this cost center to ensure that the expenses reported to the grantor and budgetary allocations align with the actual expenditures. Dije Kucana, Comptroller, effective immediately

PAX will implement a dedicated cost center in the books and records specifically for tracking these expenses. This will allow for better transparency and accountability in reporting. Additionally, PAX will reconcile against this cost center to ensure that the expenses reported to the grantor and budgetary allocations align with the actual expenditures. Dije Kucana, Comptroller, effective immediately

Finding No.: 2019-006 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (SED) Award Number: 6U79SM062447-04M001 and 6U79SM062447-04M004 Area: Matching, Level of Effort, Earmarking Questioned Costs: $-0- Contact Persons: Perlie Santos, Chief Financial Officer; Reyna Saures, CGC Director; Vincent Camacho, Grants Administrator. Corrective Action: CHCC does not concur with these findings. CHCC affirms that the Match used to support activities of H71040 and H81040 were from verifiable records, and not from other federal funds. Costs were reasonable and necessary to accomplish the program’s objectives and were provided to and approved by the awarding agency. Finding No.: 2019-006 Continued Furthermore, CHCC sought clarification with SAMHSA and received notice that a match waiver for the Territories of up to $200,000 is applicable to all SAMHSA grants received based on the following federal statute: “Pub. L. 96-205, title VI, Sec. 601, Mar. 12, 1980, 94 Stat. 90, as amended Pub. L. 98-213, Sec. 6, Dec. 8, 1983, 97 Stat. 1460; Pub. L. 98-454, title VI, Sec. 601(b), Oct. 5, 1984, 98 Stat. 1736, subsection (d): ``Notwithstanding any other provision of law, in the case of American Samoa, Guam, the Virgin Islands, and the Northern Mariana Islands any department or agency shall waive any requirement for local matching funds under $200,000 (including in-kind contributions) required by law to be provided by American Samoa, Guam, the Virgin Islands, or the Northern Mariana Islands. Therefore, whatever match amount required per year should be reduced by $200,000 for the Northern Mariana Islands. Summarized below are the required and reported match amounts derived from the Final FFR for Grant SM062447, which included activities for H71040 and H81040 for fiscal year 2019. SOC_CHH61040_Matching_Revised013019.docx SOC_CHH71040 Matching.docx SOC_CHH81040_FY19 Matching.docx SOC_CHH81040_NCE Matching.docx Proposed Completion Date: Not applicable as CHCC does not concur with the findings.