Corrective Action Plans

Finding 2024-004 – Material Weakness, Material Noncompliance – Allowable Costs/Activities (Repeat) Name of Contact Person: George Czerwionka, Director of Finance Corrective Action: Management will improve policies and procedures to record the purchase of gift cards as a prepaid transactions and expense the gift cards when all allowable cost criteria are met. We will also get input from our funders when necessary. Proposed Completion Date: May 31, 2025

Georgia Tech management agrees that internal audit reports demonstrated departmental deficiencies in knowledge of policies and procedures that needed to be addressed. Upon disclosure of Internal Audit’s recommendations, the departments and central offices immediately responded with additional training, proactive compliance reviews, and re-enforcement of existing policies and procedures via Institute wide communications and enhanced reviews of support. New system controls regarding spend authorizations were put in place, with Georgia Tech’s Internal Audit department continuing to test these controls through the month of February. Central and departmental units within Georgia Tech will continue to work together to further enhance guidance and training to faculty and staff and to identify and test controls in our systems that will mitigate these issues.

1. Implement pre-approval controls; require date validation for all expenses against the award' s period of performance. Program Director or Executive Director or Accounting Director to review and approve. 2. Conduct training; educating staff on 2 CFR requirements and period-of-performance limitations. 3. Perform periodic reviews; monitor compliance quarterly to detect outliers.

1. Implement pre-submission controls; require Date validation for all expenses against the award's period of performance. Program Director or Executive Director or Accounting Director to review and approve. 2. Conduct training; educating staff on 2 CFR requirements and period-of-performance limitations. 3. Perform periodic reviews; monitor compliance quarterly to detect outliers.

Management agrees with the finding related to Key Personnel Change Approval at our member, Cheshire Medical Center. The post-award management of this grant is currently handled outside of the Dartmouth Health Research Finance and Post-Award department. Management aims to centralize this function by December 31, 2025. In the interim, Dartmouth Health Management will provide training to award operational staff to implement policies that align with the centrally managed awards by June 30, 2025. Specifically, the Member will conduct a monthly review of key personnel efforts to identify any potential changes that require notification to the New Hampshire Department of Health and Human Services or any award sponsor in which the Key Personnel Change compliance requirement is required. Leadership Responsible: John Muhlen, System Vice President of Corporate Finance Anticipated Completion Date: June 30, 2025

2024-007 Research and Development Cluster – Federal Assistance Listing Nos. 84.017 and 47.081 – Period of Performance Recommendation: We recommend that the University review and revise their current procedures in place and provide training to employees within the grant and finance functions related to the grant reconciliation and recording process to ensure expenses are reflected prior to the grant ending and recorded in the correct period on the SEFA. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: Restricted Funds Accounting (RFA) team has restructured with new leadership and added all new staff. RFA will train new staff, develop and update policies and procedures, and automate processes within ERP systems, as appropriate. RFA is creating current and updated SOPS for each task and making sure the current staff is learning processes the correct way; this includes reconciliation and recording in the correct period. Name(s) of the contact person(s) responsible for corrective action: Director of Accounting, Tonya Cardwell. Planned completion date for corrective action plan: December 2026

Dear Mr. Waguespack, Please find below the University's management response to the audit finding titled "Control Weakness and Noncompliance with Personnel Expenses Charged to Federal Awards." Management Response: The University partially concurs with the finding. The audit finding states that UL Lafayette did not perform time and effort certifications for the period January 1, 2024, through June 30, 2024. However, we clarify that these certifications were not intentionally omitted. As outlined in our prior response, the University has been transitioning from a manual to an electronic effort certification system. In the transition, we had opted shifting from a fiscal year-based reporting framework to a calendar-year-based framework. The effort certifications for the period in question are scheduled for completion by April 15, 2025, at which point they will fully support that salaries and wages charged to federal awards are based on records accurately reflecting work performed. Corrective Actions: • The University has developed a structured plan to complete the January 1, 2024 — June 30, 2024 effort certifications, ensuring compliance with 2 CFR §200.430(i), which requires after-the-fact confirmation of personnel costs. • The Standard Operating Procedure (SOP) will be updated to require biannual effort reporting, enhancing monitoring of personnel effort. • The University will retain the full calendar-year effort reports (January 1, 2024 — December 31, 2024), including the January 1, 2024 — June 30, 2024 period, electronically on file for audit and compliance purposes. Planned Actions: • Completion of Effort Certifications: The University will finalize and retain the calendar-year effort reports for January 1, 2024 — December 31, 2024, by April 15, 2025, ensuring compliance with federal regulations and addressing audit concerns. • Transition to Biannual Effort Reporting: Effective FY 2025, UL Lafayette will implement biannual effort reporting to enhance compliance and personnel effort monitoring. The updated SOP will reflect this change. • The University will make every effort to secure effort certification for Key personnel leaving the university prior to their departure. The University remains committed to making continuous improvements and appreciates your understanding and support as we address these challenges.

Dear Mr. Waguespack, Please find below the University's management response to the audit finding titled “Noncompliance with Period of Performance Requirements." Management Response: The University concurs with the audit finding. Expense Posting Delay ($28,833): This salary charge reflects work performed within the approved award period. The delay occurred because the Personnel Action Form was received after the June payroll run, resulting in disbursements in July and August. Although the work was completed on time, the payroll posting did not align with the period of performance requirements. We are reviewing our processes to ensure all required documentation is received and processed promptly. Liquidation of Obligations ($34,957): The University failed to liquidate obligations totaling $34,957 within 120 days following the period of performance. This shortfall is due to staffing challenges in the Sponsored Programs Finance Administration and Compliance (SPFAC) Department. The University is actively exploring strategies to attract and retain qualified grant accountants to improve timely fund closeouts. Additional Mitigation Measures 1. Engaging External Consultants: o The University will engage an outside consultant to assess the university's research and administration structure, identifying opportunities to enhance processes and ensure compliance. o The University is retaining interim professional staffing to assist with invoicing and pre-audit review and to provide functional and technical expertise. 2. Deployment of an Electronic Research Administration System (eRA) o The University has begun identifying and implementing an electronic research administration system to transform grant management by offering a centralized platform that automates the entire lifecycle from proposal to closeout, minimizing manual errors while ensuring policy compliance and providing clear portfolio visibility through comprehensive reporting capabilities. The SPFAC Director will oversee the implementation of these corrective actions.

Dear Mr. Waguespack, Thank you for the opportunity to respond to your office’s findings related to the Special Tests and Provisions Requirements. LSU Health Sciences Center Shreveport (LSUHSC-S) has reviewed the issues identified by your staff. We concur with your recommendations for addressing the finding and provide the following response and corrective action plan. Recommendation: Management should monitor changes in effort for key personnel and verify that prior written approval is obtained from the federal grantor for changes that exceed the thresholds set in federal regulations. Management should revise the Time & Effort Certification policy or implement alternative controls designed to ensure compliance with Special Tests & Provisions requirements. Response and Corrective Action Plan: LSUHSC-S is continuing to strengthen the management, internal controls, and efficiency of the sponsored programs management. In the Fall of 2024 LSUHSC-S began a re-organization of Research Administration, including sponsored programs management. The historical organizational structure supported an office of grants administration (pre-award) that functioned separately from the grants accounting (post-award) functions. This structure created a disconnect between the two functions, caused gaps in the services provided to faculty, and left some responsibilities unattended. The recent re-organization combined Pre-Award Administration and Post-Award Administration into one office, The Office of Sponsored Programs. This team is supervised by the Executive Director for Sponsored Programs and operates under the direction of the Chief Financial Officer and Vice Chancellor for Research Administration. As part of the overall re-organization and improvement of services, several processes are under revision. Time and Effort Reporting: Time and Effort Certification (T&E Certification) transitioned to an electronic process in January 2025. The electronic process is designed to ensure a more efficient certification process and one that is easily documented. T&E Certification is performed on a bi-annual basis. In addition to the certification process, comprehensive training will be provided for Business Managers, Principal Investigators, and other designated departmental staff on an annual and PRN basis. A Post-Award Monitoring process is currently being established for all sponsored programs. Quarterly meetings will be held with Principal Investigators (PIs), Business Managers, and other designated department staff to review documentation of monthly grant account reconciliations, assist and review payroll cost transfers, changes in key personnel, etc. These regular meetings will serve as a checkpoint to review all personnel, payroll and effort supported by grant accounts. PIs and/or departmental staff are expected to perform monthly reconciliation of grant accounts, and the Post-Award Monitoring Meetings will serve as the platform for reviewing the documentation. Post-Award Monitoring Meetings: All agenda items reviewed and discussed in the Post-Award Monitoring Meetings will be documented and follow-up on a quarterly basis or more frequently as needed. Changes in Key Personnel: All changes in key personnel that require federal agency approval must have documented approval from the federal agency prior to the change in personnel occurring. Federal agency approval for key personnel changes must be received prior to the submission of a PER for any employee changes. Changes in key personnel will be reviewed during the Post-Award Monitoring meetings. Training: LSUHSC-S continues to improve training materials covering federal, state, and institutional requirements. Additional training will be provided covering the responsibilities of sponsored programs management and who owns each responsibility. The annual training required for all employees involved in research activities will include Time & Effort, cost allocations, changes in key personnel and other related topics. Continuing education will be provided for Principal Investigators, Business Managers, and designated departmental employees. One-on-One departmental training will also be provided on an as needed basis. The Post-Award Monitoring meetings with department staff will serve as an additional opportunity for training. Name of Contacts Responsible for Action Plan: Ramey Benfield, Chief Financial Officer & Vice Chancellor for Research Administration Ashley Krukowski, Executive Director for Sponsored Programs Valarie White, Director for Pre-Award Administration in Sponsored Programs Tracy Calvert, Director for Post-Award Administration in Sponsored Programs Anticipated Completion Date: June 30, 2025 If you have questions or require additional information, please contact me at 318-675-6327 or via email at ramey.benfield@lsuhs.edu

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure the Special Education Co-op will have controls in place to make sure payments are made within the period of performance. Anticipated Completion Date: September 30, 2025

Boston Public Schools will take a multi-step approach to ensure accuracy of spending to the grant award period. Anticipated Completion Date: January 31, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name(s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

Research and Development Cluster- Assistance Listing Nos. 93.323, 93.847 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name{s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure the Special Education Co-op will have controls in place to make sure payments are made within the period of performance. Anticipated Completion Date: September 30, 2025

Condition: Of the 40 samples included in our sample selected for testing in the Research and Development Cluster (R&D), the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Planned Corrective Action: The university has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period. Contact person responsible for corrective action: Associate Controller, Brenda Lindberg Anticipated Completion Date: The new grants module, which includes grant billing and award calendar schedule became operational at July 1, 2024.

2024-001 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Contacts: Regina Frazier Title: Payroll Manager Anticipated Completion Date: September 2025 Corrective Action: The Center is dedicated to maintaining compliance with federal regulations concerning allowable and unallowable activities and costs. In response to the recent audit finding, the Center’s payroll department will proactively engage with key stakeholders in high-risk areas prior to the start of the fiscal year. This engagement will involve reviewing payroll submission templates and ensuring that the rates align with the most current employment agreements. Status as of March 2025: All affected employees have been reimbursed, and key stakeholders in high-risk areas have been informed of the corrective action plan.

Reference Number: 2024-010 Prior Year Finding: 2023-008; 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: Admin 24A55UI000063 (10/1/2023-12/31/2026), DUA 23A60UD000013 (7/14/2023 - 7/14/2026) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that prior to charging costs to the program, they are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Department will review its procedures and internal controls and update as necessary to ensure that expenditures are incurred within the allowable period of performance for respective awards. It should be noted that during the period of performance for which this audit was conducted there were a large number of personnel changes and shifts. The position that was responsible for the majority of these duties retired in January 2024. We proactively hired for her replacement a year before she retired. Over the course of the year our replacement took over more and more duties. In the process of this replacement, we have completed a tremendous amount of evaluation of our assigned duties, processes, workflow, training, and documentation. Not only in this role, but we are also undergoing a division and business unit wide analysis of our internal controls and workflow. It should also be noted that the UI admin funds are considered ‘formula funds’ from the US DOL. We are expected to run this program year-round with no gaps in service or performance. The funding that we receive from US DOL is based on an antiquated formula that breaks down the amount that is budgeted by Congress between 52 state and territories. We generally do not receive enough funding for the entire year. Also, with the recent trend of Congress to utilize the tool of the Continuing Resolution our funding is often ambiguous until most of the program year is over. We have at times seen our funding cut once a budget had been passed by Congress even though there was only about 3 months left in the program year. We are still expected to run this program and ‘find other sources of funding’. This does make the adherence to the period of performance challenging. However, as we evaluate our internal controls and procedures over the coming months, we will make note of every opportunity to strengthen this function to ensure that all charges applied to program funds are relevant, within the period of performance of the award, and are correctly reviewed and signed. Scheduled Completion Date of Corrective Action Plan: April 1, 2025 Contacts for Corrective Action Plan: Chad Wawrzyniak, Financial Director II chad.wawrzyniak@vermont.gov

Reference Number: 2024-007 Prior Year Finding: No Federal Agency: U.S. Department of Defense State Agency: Vermont State Military Department Federal Program: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing Number: 12.401 Award Number and Period: W912LN2421001 (10/1/2023 – 9/20/2024) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Department agrees with this finding and will implement the following: • Update Accounts Payable Standard Operating Procedures to include instructions for determining the appropriate Federal Fiscal year for coding and paying vendor invoices. • Distribute updated procedures and train staff to ensure understanding of Period of Performance reporting requirements. • Update Vision query to include the Invoice Date field. Current reports used for preparing the SF-270 only include the Vision transaction date, therefore the preparer and reviewer are not able to determine the performance dates of individual transactions based on this report alone and rely on proper coding of the Class field during voucher entry. Adding the Invoice Date to the report will improve the department’s ability to QC the SF-270 for period of performance discrepancies prior to submission for reimbursement. • The Financial Director will perform quarterly audits of this Vision report to identify any improper reporting. Any errors identified will be corrected with a journal voucher and subsequently corrected on the next SF-270. Scheduled Completion Date of Corrective Action Plan: April 15, 2025 Contacts for Corrective Action Plan: Kim Fedele, Financial Director kimberly.fedele@vermont.gov

Corrective action plan: Social Services Block Grant (SSBG) Actions Taken: HHSC Fund Management worked with Chief Financial Officer (CFO) Operations Support to develop a query to identify journal transactions that post in the CAPPS Financials General Ledger module prior to the start date of the project. This query has been run monthly since May 2024, and it was fully implemented as of August 31, 2024. Planned: Additional training on the review process for Accounting and Budget staff, and revisions to the process to emphasize meeting deadlines while new federal grants and old federal grant close out transactions occur. An expenditure transfer voucher (ETV) to correct reconciliation issue will be completed by CFO Budget staff. Block Grants for Community Mental Health Services (MHBG) Actions Taken: HHSC Fund Management will run the monthly query and take corrective action on any resulting journals prior to the close of the fiscal year. In addition, HHSC Fund Management/Cash Management does not draw federal funds past the liquidation date. These dates are denoted in their draw ledgers. Cash Management also sends a semi_x0002_monthly email during the fiscal year and a weekly email from mid-June through the end of July to HHSC Budget identifying transactions by fund source that should be cleared from the draw down report prior to the close of the fiscal year. HHSC Cash Management will continue to send the draw down clean up report and start the weekly emails the first week of June. HHSC Budget will complete any ETVs resulting from the draw down clean up report to HHSC Fund Management General Ledger for processing by July 15 to ensure the draw down accurately reflects federal expenditures for the SEFA population. Planned: Budget Management will revise the coordination process with Behavioral Health Services program financial staff administering MHBG to prioritize addressing encumbered balances on expiring block grant years at the beginning of the liquidation period and set deadlines for Program input on required financial adjustments to ensure sufficient time for processing. ETV to correct reconciliation issue will be completed. Implementation dates: February 28, 2025 Responsible persons: SSBG: Heather Nevill, Fund Management Director, Fund Accounting Raymond Jasik, Budget Director, CFO Budget Heather Anderson, Budget Manager, CFO Budget MHBG: Marcie Ochoa-Gamez, Budget Manager, Budget Management

We concur with the condition. 1. Name of the contact person responsible for corrective action: Grants Manager 2. Corrective action planned: Grants Manager will be tasked with the following: ● Researching and understanding what items are allowable within each federal grant ● Ensuring each budgeted item is not already written into another grant ● Presenting a list of budgeted items and their corresponding fund codes at a grants meeting prior to submitting the budget ● Notifying the Business Manager when the budgets have been approved and that those budgeted items can now be allocated to the corresponding grant under their specific fund code ● Checking the expenditure report to make sure it accurately reflects what was written in the grant before submitting information to the state ● Reporting any errors in coding to the Business Manager to ensure an accurate representation of expenditures is reported before submitting to the state 3. Anticipated completion date: Implementation of the corrective action plan began March 15, 2025.

We concur with the condition. 1. Name of the contact person responsible for corrective action: Grants Manager 2. Corrective action planned: Grants Manager will be tasked with the following: ● Researching and understanding what items are allowable within each federal grant ● Ensuring each budgeted item is not already written into another grant ● Presenting a list of budgeted items and their corresponding fund codes at a grants meeting prior to submitting the budget ● Notifying the Business Manager when the budgets have been approved and that those budgeted items can now be allocated to the corresponding grant under their specific fund code ● Checking the expenditure report to make sure it accurately reflects what was written in the grant before submitting information to the state ● Reporting any errors in coding to the Business Manager to ensure an accurate representation of expenditures is reported before submitting to the state 3. Anticipated completion date: Implementation of the corrective action plan began March 15, 2025.

Finding: Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Instance of Noncompliance and Deficiency Corrective Action: The University has a process in place for personnel charged to grants to complete personal activity reports to monitor their level of effort on the grants. We were not requiring key personnel that are providing in-kind services on grants to complete the personal activity reports, although the project directors are monitoring the involvement of all personnel working on grants to ensure we are providing an appropriate level of effort in the grant activities. The individual identified in this finding was providing in-kind services and was not paid from federal funds. The University will update its processes to ensure that that project activity reports are documented and reviewed for all key personnel assigned to grants, including in-kind personnel. Status: In-progress Person Responsible for Implementing: Edith Cogdell, Chief Financial Officer Implementation Date: 05/31/2025

OSU OKC and OSU Tulsa: The key personnel listed on the GAN will be responsible for completing the post-award training. Key personnel will also reconcile their federal grant budget on a monthly basis and a copy will be submitted to the Office of Institutional Grants and Compliance. The Director of Grants and Compliance will verify the purchases using the approved grant budget. Signed time and effort reports will also be submitted to the grants office at this time. OSU IT: A new PI will be appointed to the grant and ensure accurate reporting of time and effort. OSU IT will also implement a comprehensive training program for PI and grant-related staff, establish a monitoring system to ensure ongoing compliance, and designate a compliance officer to oversee this process. Will also implement a digital tracking system to streamline the reporting process and reduce the risk of errors.

Management's Response: Management concurs with the above finding and will ensure that human resources, fiscal services and Title Ill all have proper approvals, budgets and written authorization of anything that deviates from the approved budget. The corrective action will be implemented immediately and completed by June 2025.

Views of Responsible Officials: Management has implemented mandatory on-boarding training and annual training of all staff on overall grant management, with a focus on compliant entry of time and effort. New budgeting and forecasting tools and processes have been implemented to allow more effective and timely monitoring of expenditures. In addition, CIPE has reviewed and revised relevant policies to ensure they align with best practices. CIPE worked closely with stakeholders on all these remedial efforts.