Corrective Action Plans

Management’s Response/Corrective Action Plan (Unaudited): Management agrees to address the finding in its capital asset tracking schedule. The Organization and its outsourced accountant have discussed the finding and will implement procedures on tracking capital assets funded with federal grants. This tracking will be incorporated to the current capital asset tracking schedule. Planned Completion Date: June 2025 Contact Person Responsible for Correction Action: Adam Courtney

Property and Equipment Management Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Recommendation: We recommend management implement procedures for physical inventory to be taken within a two‐year time frame as well as maintain evidence of assets possession such as photos of the property and equipment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Led by the Director of Capital Planning and Facilities Management, KSU has hired an inventory specialist to improve physical inventory documentation and maintenance. In addition, The Controller is in the process of reevaluating and designing internal controls surrounding capital and non‐capital inventory in conjunction with the President. Name(s) of the contact person(s) responsible for corrective action: Melissa Hicks – Controller in coordination with Jennifer Linton, Director of Capital Planning and Facilities Management. Planned completion date for corrective action plan: June 30, 2026

Finding No 2023-003 “ALN #20.106 Equipment and Real Property Management” Name of Contact Person(s): Sheryl Sizemore, Comptroller Ida S. De Brum, Accounting Manager Zack A. Diaz, Internal Auditor Alex Tudela, Procurement Officer Corrective Action: CPA agrees with this finding. CPA has implemented Equipment Management Standard Operating Procedures (SOPs) in June 2022 and trained staff involved in Equipment Management in August 2022. Because trainings on the newly developed SOPs were first conducted in August 2022, CPA noted and FAA acknowledged that repeat findings may be found in this audit report. CPA emphasizes that SOP trainings are continuing and mandatory for all of CPA Management, and CPA expects that the SOPs and related training will resolve this issue moving forward. Equipment SOP trainings occur twice per year and will continue indefinitely. In July 2023, CPA issued the inventory and property records to all CPA Department Heads to review, verify and confirm details of each fixed asset and provide additional identifying information for entry. These updates will be submitted to the Procurement Division in August 2023 for verification and entry into the Equipment Management System. Condition 1: CPA will ensure that count sheets are dated to reflect timing of the approval of fixed asset inventory performed. Condition 2: The fixed asset schedule provided to the auditors included a column that listed all contributed fixed assets as funded by the Federal Aviation Administration (FAA). The FAA column was mistakenly entered into the schedule. CPA Accounting verified that the details of all assets that were identified as non-FAA assets indicate funding through other federal or local programs. The fixed asset schedule will go through verification by the Accounting Manager and Comptroller to ensure that only the program assets requested are listed. Condition 3a: CPA will write off the asset from its fixed asset system. Condition 3b: CPA will write off assets 000015, 000040, 000047 as they have been already replaced with an existing asset. For assets 000091, 000589, and 000791: we will create maintenance logs for these assets as well as all assets that require maintenance in the fixed asset system. Condition 3c: CPA will write off the asset from its fixed asset system. Condition 3d: CPA will write off the asset from its fixed asset system and adjust and reclassify for any remaining depreciation still left on the books. CPA has developed the following corrective action plan for this finding: 1. Establish Standard Operating Procedures (SOP) for Equipment Management CPA has established Equipment Management SOPs that were implemented and effective on June 30, 2022. The SOPs detail the equipment management requirements, details, and responsibilities. In addition, the SOPs include an annual mandatory schedule for inventory, disposals, and reconciliation. The Department Heads are reviewing their equipment listings to verify the accuracy of equipment details, provide additional identifying information and confirm existence of all assets listed. The Department Heads will be providing monthly updates to the Procurement Department for entry into the Equipment Management System. 2. Implement Standard Equipment Management Forms Standard procurement forms have been developed to establish additional controls and reviews for all equipment. These standard forms include requirements such as identifying details for all fixed assets. 3. Develop a Training Plan for Equipment Management Procedures CPA developed an Equipment Management training plan that was implemented on June 17, 2022. The training plan includes annual requirements for training on equipment management and compliance requirements. The training is based on the established SOPs and best practices and is mandatory for all staff involved in equipment management. 4. Internal Auditor Position An internal auditor position was created on May 16, 2022 and hired on August 29, 2022. Part of the internal auditor’s responsibilities include reviewing inventory records and equipment management files for compliance. The internal auditor reports directly to the CPA Board of Director and provides monthly reports. The internal auditor monthly reports are used as a tool to identify areas of equipment management non-compliance for immediate correction. Proposed Completion Date: June 30, 2025

Management Response/Corrective Action Plan: A formal procedure will be drafted between the city and school to ensure the city is made aware of any assets that are federally funded so they can be designated as such in Munis. The school department will continue to provide the annual asset list to the city and will now include funding source notations for each asset.

Management Response and Corrective Action Plan Finding 2023-001 Federal Agency: United States Department of Health and Human Services Program Name: Research and Development (R&D) Assistance Listing Number: Various Responsible Individual: Jarod Kohr, Director, Research Finance Contact Information: jkohr@bidmc.harvard.edu; 617-667-4136 A review of the Beth Israel Deaconess Medical Center’s (BIDMC) property records maintenance revealed incomplete biennial physical inventory and incomplete tagging of new equipment purchased on federal awards. Management agrees with the recommendation and will update the asset tagging system to support completing the biennial inventory and resume tagging new equipment according to established policy. Corrective Action Plan: Tagging System • Director of Operations and Director of Research Computing will complete work with vendor to update scanning devices and software (complete) • Director of Operations will develop plan to complete inventory and new tagging (complete) Tagging New Equipment • Complete update to equipment list including identifying new (untagged) equipment (complete) • Tag all new items received (complete) • Maintain list of new pending equipment to be tagged Physical Inventory • Establish inventory schedule with clear notification to Research community • Identify all equipment on current inventory • Identify any equipment in lab spaces not on current inventory and tag if appropriate • Reconcile all inventory including any disposition discrepancies Expected Completion Date: June 30, 2024 Status of Completion: In Process

FINDING 2023 - 003 Finding Subject: Water and Waste Disposal System for Rural Communities - Equipment Summary of Finding: Material Weakness, Other Maatters Contact Person Responsible for Corrective Action: Pamela Whitener Contact Phone Number and Email Address: 765-981-4591 clerk@lafontaine.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We have purchased the Silversmith Program to track Capital Assets. All equipment purchased with federal money will be listed in the program and reviewed yearly. Anticipated Completion Date: January 2025

Corrective Action Planned: Capital Assets will be entered into BusinessPlus in a timely manner which is within 30 days of physical receipt of the asset. BusinessPlus was adjusted to accept the source of funding information and account code used. This will be updated in the policies and procedures. Name(s) of Contact Person(s) Responsible for Corrective Action: Chief Financial Officer, Facilities and Maintenance Director and General Accounting Manager Anticipated Completion Date: April 2025

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to perform a physical inventory of property at least once every two years. See 2023-004 for management’s detailed action plan, timeline, and the responsible parties for all Education Stabilization Fund findings.

View of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate property records. See 2023-004 for management’s detailed action plan, timeline, and the responsible parties for all Education Stabilization Fund findings.

CONDITION: The Regional Office of Education No. 39 manually maintains and stores its inventory of property and equipment. Asset details in the property records include only the description of the property, acquisition date, and cost of the property. The other minimum requirements specified by the Code are not included in the property records. Moreover, the Regional Office of Education No. 39 was unable to properly account for the results of its physical inventory count and only performed partial reconciliation. PLAN: The ROE will combine the current inventory documents to provide a complete detailed accounting of all property and equipment which will provide both the required information for federal funds as well as a reconciliation to the capital outlay disclosures within the financial statements. Physical inventory will be taken each year with additions and deletions recorded and signed off on by management. These documents will be recorded and stored each year for review. ANTICIPATED DATE OF COMPLETION: The anticipated date of completion is January 2025. CONTACT PERSON: Jill Reedy, Regional Superintendent

Elementary and Secondary Education School Emergency Relief and Governors Emergency Education Relief Fund– Assistance Listing No. 84.425D & 84.425C Recommendation: We recommend the District design and implement capital asset record procedures and controls that ensure all necessary information is tracked in capital asset records for assets purchased with federal awards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Business office staff will receive training on current district policies regarding the tracking of capital assets for federal purposes. A separate inventory of captial assets purchased with federal funds will be created and maintained. Name(s) of the contact person(s) responsible for corrective action: Brian Dasher, Director of Business Services Planned completion date for corrective action plan: 12/1/2024

Contact Person: Business Manager Planned Corrective Action: The District will perform a physical inventory of all equipment purchased with federal dollars. Planned Completion Date: June 30, 2025

Corrective Action: The district will ensure fixed asset personnel will review all purchases that are assets during the PO process. Also, quarterly and during year-end-close, all assets purchased will be reconciled to the general ledger and fixed asset module. Responsible Parties: Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: October 31, 2024

Finding No. 2023-002: Inaccurate Property Management Records AL Numbers: Various Program Name: Research and Development Cluster Corrective Action: As noted in the finding, in January 2024, the University conducted a full federal equipment inventory to update property records to ensure accuracy of federally funded equipment. Process Improvements: - The University will update its Equipment Disposal Form to align with the University’s Property Management System Manual. - The Central Accounting team will create and publish equipment tagging, disposal guidance and standards to coincide with the updated Equipment Disposal Form. - Annual federal equipment inventory process will be updated to include escalation procedures. This will require outstanding reports are escalated to the appropriate divisional designee. Expected Implementation: June 30, 2024 Training: - All departments of the University will be sent a memo outlining the updated Equipment Disposal Form and process guide, and inventory escalation procedure. - The Central Accounting team will schedule virtual training with all equipment coordinators. Expected Implementation: October 31, 2024 System Improvement: - The University is researching equipment tagging software alternatives that will enhance tracking capabilities and enable asset tagging at a more granular level. Expected Implementation: March 31, 2025 Contact: Kathy Conrad and Craig Elmore

Name of Auditee: Town of Jasper, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2023 CAP Prepared by: Stephen Dennis, Town Supervisor Phone: (607) 792-3686 (2) Audit Finding 2023-002 - The Town did not have accurate capital asset records. (a) Implementation Plan of Actions - The Town is looking into capital asset software and is having a physical inventory performed. (b) Implementation Date - This will be implemented for the year ended December 31, 2024. (c) Persons Responsible for Implementation - The Town Board and Supervisor of the Town of Jasper.

FA 2023-002 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) Questioned Costs: None Identified Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Education Stabilization Fund. Corrective Action Plans: The Finance Department will implement a revision process to work with the technology departments Media Specialist who conduct inventory on an annual basis. We will implement a quarterly meeting to identify any changes in equipment and real property. When funds are identified as equipment and real property for federal grant funds. We adhere to provisions included in the Uniform Guidance, Section 200.313(d)(1). The listing must include the following information. A description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate deposal data for each piece of equipment. Estimated Completion Date: April 30, 2025 Contact Person: Dr. Jute Wilson Telephone: 770-358-5891 Email: Jute.Wilson@lamar.k12.ga.us

FINDING 2023-006 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: The School Corporation hired a consultant to compile and provide to them a fixed asset report that was to contain all inventory and assets purchased that exceeded the School Corporation's capitalization threshold through June 30, 2023. The consultant prepared the report; however, the School Corporation did not have any policies or procedures in place to ensure the listing was complete, nor was there any documentation that differences between the compiled asset report and the School Corporation's equipment records were reviewed and resolved. During the audit period, the School Corporation completed an improvement project totaling $1,738,356 with ESSER funds. This improvement project was not included on the asset listing or physical inventory prepared by the consultant. Contact Person Responsible for Corrective Action: Tracey Haas, Deputy Treasurer Contact Phone Number and Email Address: thaas@mcas.k12.in.us (219)873-2000 ext. 8346 Views of Responsible Officials: We concur with this finding. We are implementing a proper system of internal controls and developing policies and procedures to ensure asset records include all the necessary information, new assets are properly added, and any discrepancies are reconciled. Description of Corrective Action Plan: Moving forward we will ensure that are capital assets list is updated as required. We will also ensure that the capital assets list includes the specifics requirements required in regards to federal grants and attach proper documentation. Anticipated Completion Date: The anticipated completion date for this corrective action will be January 1, 2025.

FINDING 2023-007 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Summary of Finding: The School Corporation maintained a detailed listing of capital assets; however, the asset records provided for audit did not include three of the six assets paid for with federal funds. The School Corporation utilized COVID-19 - Education Stabilization Fund awards, totaling $153,484, to purchase an air handler unit, a generator, planter equipment, auto pilot software, a carpet cleaner, and a floor cleaner. The software, carpet cleaner, and floor cleaner were not included in the capital asset records. Additionally, the capital asset listing provided did not identify which assets were purchased with federal dollars, a serial number or other identification number, who holds title, the location of the asset, nor the use and condition of the property. Contact Person Responsible for Corrective Action: Kelly McPike Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: An effective internal control will be developed to include a description of the property, a serial number or other identifying number, the source of the funding for the property, the award identification number, who holds the title, the acquisition cost, and the cost of the property. This will ensure all asset reports include all of the necessary information and new assets are added properly. Anticipated Completion Date: April 2024

Views of Responsible Officials The Organization agrees with this finding. Corrective Action Plan The Organization will update its property records to include all required information. Additionally, the Organization plans to complete a physical inventory count and related reconciliation on an annual basis. Name(s) of Responsible Individuals Lacy Kimes, Board President Anticipated Completion Date October 31, 2024

Views of Responsible Officials and Planned Corrective Action - The County did complete an annual inventory in November 2023 and is scheduling another inventory for November 2024. Responsible Official -Andrea Montoya, Deputy County Manager, and Robert Placencio, Finance Director Timeline and Estimated Completion Date - December 31, 2024.

Management response: Warren Easton experienced key personnel changes and lingering effects of COVID-19 which had a direct effect on the financial statement year end closing procedures. Easton plans to re-emphasize policies and procedures to enforce a timely financial close. Responsible Party: Lindsay Carter, Chief Financial Officer Estimated Completion Date: December 30, 2023

2023-003 Property and Equipment Management Responsible Person: Ronald McNair, Executive Director The Inventory tracking sheet did not contain all required asset information and was not properly reconciled to property records. Corrective Action Plan: Executive Director, Ronald McNair has requested help in this manner from T&TA. Executive Director, Ronald McNair has hired a Facilities Manager to work with Fiscal staff to ensure any purchase, construction or renovation activities that occur throughout the fiscal year are recorded and added to the inventory schedule and supporting documentation for each transaction is submitted and filed in the Finance Department. This schedule will include a listing of all real property and details for each site, including acquisition cost, renovation and/or new construction, as well as the dates and source of funds expended. Once updated, the schedule will be reviewed and approved by the Executive Director. Monthly audits by Facilities Manager and Fiscal Officer will be conducted to ensure compliance. The Fiscal Officer and Board Directors will conduct quarterly and year end audits to ensure that requirements are met. The Corrective Action will commence Effective September 10, 2024; and shall be completed by May 31, 2025.

We understand how crucial it is to have strong policies and procedures in place. Here’s how we plan to move forward: 1. Review of Existing Policies and Procedures: We’re currently taking a close look at our existing policies and procedures to ensure they align with the Uniform Guidance. This will help us identify any gaps and make necessary updates so that we’re fully compliant. 2. Development of New Policies: Alongside this review, we will create clear and comprehensive written policies in key areas, such as: • Cash Management: Setting up procedures that comply with 2 CFR 200.305 to ensure timely payments. eCFR :: 2 CFR 200.305 -- Federal payment. • Allowability of Costs: Crafting guidelines that follow Subpart E—Cost Principles, so we can confidently determine which expenses are allowable. https://www.ecfr.gov/current/title-48/chapter-7/subchapter-E/part-731/subpart-731.7/section-731.770. • Conflict of Interest: Establishing standards of conduct that address potential conflicts and promote transparency. • Equipment and Real Property Management: Developing policies for managing equipment acquired under federal awards in line with 2 CFR 200.313(b). eCFR :: 2 CFR 200.313 -- Equipment. • Procurement Procedures: Creating clear procurement guidelines that align with 2 CFR 200.318 through 200.326 to ensure fairness and oversight. eCFR :: 2 CFR 200.318 -- General procurement standards. 3. Training and Communication: The Finance Department will be responsible for training all staff involved in managing federal awards. Training sessions will ensure that everyone understands the requirements and their roles in maintaining compliance. This training will be completed by December 31, 2024. Personnel responsible: Eduardo Cedeno, Director of Finance Anticipated completion date: December 31, 2024

Person responsible for corrective action plan: Anthony Madera, CFO Lummi Indian Business Council 2665 Kwina Road Bellingham, WA 98226 (360) 384-7181 Condition: Management completed a physical inventory in 2022-2023, but was not able to provide support showing management review and approval. Solution: With the guidance and authority outlined in the Department’s internal policies and in accordance with 2 CFR, Part 200, Subpart D, Property Standards, The non-Federal entity must submit annually an inventory listing of federally-owned property in its custody to the Federal awarding agency as defined within existing governing statues, regulations, or terms and conditions of the award. Procedures for the delegated staff administering these regulatory activities will follow the minimum requirements of maintaining property records. Final review of inventory will have final reviewed by Department’s CFO of approval and will be documented annually. Corrective action plan will be in accordance with c CFR, Part 200, Subpart F, §200.511 Audit findings follow-up. The Department entered into a professional agreement with Financial Service Advisors, LLC to assess current policies to update standards of management by identifying credentials and experience of senior finance staff who will oversee these activities. Revisions to the policies will provide the Department’s government an extensive manual that will be developed into a fiscal management training. Training will include but not be limited to reviewing procurement methods, fiscal review of ledger activity, and audit responsibility on a quarterly basis and reporting to tribal council. Responsible: Anthony Madera, Chief Financial Officer, Lummi Indian Business Council Anticipated completion date: 06/30/2025

Type of Finding: Significant Deficiency in Compliance and Internal Control over Compliance Federal Agency: U.S. Department of Defense Federal Program Name: Conservation and Rehabilitation of Natural Resources on Military Installations Assistance Listing Number: 12.005 Federal Award Identification Number and Year: H79TI083313 - 2020 Award Period: September 28, 2020, through September 27, 2025 Criteria or specific requirement: 2 CFR 200.313(d)(2) states that a physical inventory of property must be taken and the results reconciled with the property record at least once every two years. Condition: During testing, it was noted that a physical inventory and reconciliation with the property records had not been performed. Questioned costs: None. Context: A sample of 4 was made from a population of 4 pieces of equipment purchased with funds from the major program (entire population). Of the 4 sampled, all belonged to a population of assets that had not been part of a formal physical inventory and property reconciliation. Cause: The Organization does not currently have procedures in place to perform a formal inventory count and reconciliation with the property records at least once every two years. Effect: Without periodic equipment counts, the Organization is in noncompliance with federal regulations around Equipment and Real Property Management. In addition, there is an increased risk of errors and inaccuracies in the inventory records and an increased risk of fraud or theft going undetected. Repeat Finding: No. Recommendation: CLA recommends that the Organization adopt policies and procedures that include performing a formal inventory count and reconciliation back to the property records at least once every two years, in compliance with 2 CFR 200.313(d)(2). The inventory count should be documented and signed by the individual performing the count as a form of attestation to the amounts recorded. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The organization has strengthened their property record policy to include a formal inventory count and reconciliation on an annual basis in compliance with 2 CFR 200.313(d)(2). This inventory also includes description of the condition of the property and documented signature by the individual performing the inventory. Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 10/1/2024