Corrective Action Plans

Findings Related to Federal Awards 2023 002 Equipment and real property management Federal Agency: U.S. Department of Transportation Program Name (ALN): Public Transportation Emergency Relief Program (ALN 20.527) Federal Grant Numbers: NJ-44-X004 Contact Person: Fatima Castellanos, Manager, PATH Financial Services, PATH Financial Services Division, 201-216-6459. Corrective Action: The Port Authority acknowledges an internal control deficiency in performing a physical equipment inventory of equipment as required under CFR 200 for the Public Transportation Emergency Relief Program 2013 49 U.S.C. 5324 (Grant award NJ-44-X004 PATH-H). PATH successfully performed a physical inventory of equipment in 2018, the first year it was required. In 2020, the performance of a physical inventory coincided with the COVID-19 pandemic which facilitated the retirement of key personnel in PATH who were responsible for performing the physical inventory of the equipment that was federally funded. This staff transition led to a loss of PATH system expertise necessary to pick up the process previously developed, resulting in the inadvertent lapse in performing the physical inventory in 2020 and 2022. To mitigate this deficiency PATH has performed a physical inventory in 2024 and updated its procedures as they relate to performing the physical inventory of equipment and to have staffing redundancies in place to account for staff turnover. In addition, PATH updated its equipment inventory log to reflect the correct serial numbers on the four pieces of equipment that KPMG identified. Anticipated Completion Date: The entry of all FTA Funded assets for the Public Transportation Emergency Relief Program 2013 49 U.S.C. 5324 will be loaded into the Port Authority Asset Management System (PAMS) by December 31, 2024. Entry of these assets will contain details pertaining to the categories (Asset Name, Supplier, PO#, Cost, Grant #, FTA Share, Date Received, Property Number/Serial Number, Useful Life, Date of Last Inventory, Observed Location, Condition, Current Use, Holder of Asset, Disposition Date) required under CFR 200 and updated on a biennial basis. It is important to note, however, that due to PATH’s nature as an operating railroad, equipment is moved frequently across the system as required. Therefore, the location of the equipment will only be accurate as of the date the inventory is performed.

REFERENCE # 2023-004 Public Transportation Emergency Relief Program (ALN # 20.527)- Significant Deficiency-Non-Compliance Agency: U.S. Department of Transportation Criteria: Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management: • Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). • A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition/Context: The MTA has Equipment and Real Property management procedures in place. MTA has corporate policies and procedures regarding Equipment and Real Property management. We tested the Public Transportation Emergency Relief Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted of sixty samples selected, eight (8) equipment samples related to New York City Transit Authority were transferred to the City of New York Police Department. The eight piece of equipment related to police radios and were included in MTA Biannual report as out-of service and fully depreciated. Therefore, we were not able to verify existence of these piece of equipment. Recommendation: We recommend that the MTA ensure all equipment in service should be properly accounted and reported in MTA’s Bi-Annual report and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Corrective Action Plan: Capital Asset Planning will remove the assets from the Biennial listing extracted from PSR (Project Status Report). The accounting group will write off the assets from the accounting system. We don’t need to notify FTA since the assets are fully depreciated. Action Date: October 31, 2024 Final Implementation Date: October 31, 2024 Name And Phone Number Of Person Responsible For Implementation: Brian Kershaw (646) 252-4495 Lloyd Jairam (646) 252-7122

REFERENCE # 2023-002 Rail and Transit Security Grant Program (ALN # 97.075)- Significant Deficiency-Non-Compliance Agency: U.S. Department of Homeland Security Criteria: Equipment and Real Property Management - As stated in Uniform Grant Guidance - §200.313 Requirements for Equipment and Real Property Management: • Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). • A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition/Context: The MTA has Equipment and Real Property management procedures in place. MTA has corporate policies and procedures regarding Equipment and Real Property management. We tested the Rail and Transit Security Grant Program’s Equipment and Real Property management compliance. Based on our review of the Equipment and Real Property for this program, we noted that the physical inventory of the program property was not taken in the last two years, as required by 2 CFR section 200.313(d)(2). . Recommendation: We recommend that MTA ensure that the physical inventory of the property must be taken and the results reconciled with the property records at least once every two years as required by 2 CFR section 200.313(d)(2). Corrective Action Plan The MTA Office of Security is implementing an update on our procedures for equipment inventory management. We will be working with the Office of Security’s Director of Quality Assurance along with MTAHQ Audit, to help us review all equipment inventory listings and physical inventory inspection of federally funded purchased equipment. We will be implementing an internal agreement between MTA Office of Security and the MTA Agency awarded federal funds under grant programs managed by HQ Office of Security. This agreement will include all terms and conditions applicable to the specific grant award. Action Date September 30, 2025 Final Implementation Date September 30, 2025 Name And Phone Number Of Person Responsible For Implementation Daemion De Vonish Work Ph# 212-878-4768

FINDING 2023-001 Finding Subject: Airport Improvement Program – Equipment & Real Property Management Summary of Finding: Material Weakness, Other Matters. The airport does not have a detailed listing of capital assets. Contact Person Responsible for Corrective Action: Kelsey Veatch Contact Phone Number and Email Address: 812-877-2542 kveatch@huf.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The airport currently has a capital asset listing, but it does not contain all the information that State Board of Accounts (SBOA) would like to have provided in the listing. SBOA has offered to provide a capital asset template that they recommend units use. Using the provided template the airport will work to update their current capital asset listing. The HR/Business Relations Manager will take the lead on ensuring the capital asset listing is updated to the new format and keeping the listing current and accurate. Anticipated Completion Date: Upon receiving the template from SBOA, the airport will work to have the capital asset listing updated to the new format by Dec 31, 2024.

Title of result and comment:: Frankton FINDING 2023‐004 Contact person Responsible for Corrective Action: First Name: Timothy Last Name: Detrick Contact’s Phone Number:: (765) 754‐7285 Contact’s Email Address:: tdetrickct@gmail.com Views of Responsible Official:: We concur with the finding. Description of Corrective Action Plan:: We are making an Asset Ledger this year. And we will keep it updated every two years and add to it when we purchase a asset that exceeds $5,000. I will also have our Town Administrator double check. Anticipated Completion Date: Year: 2024 Month: 7 Day: 1 If applicable: Document reason issue will NOT be corrected within 6 months:: INDIANA STATE BOARD OF ACCOUNTS 33 Unit Name: Town of Frankton County: Madison Report period beginning date: Year: 2023 Month: 1 Day: 1 Report period ending date: Year: 2023 Month: 12 Day: 31

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 2023-001 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Health and Human Services Pass-Through Entity: Direct Assistance Listing Number and Title: 93.600 - Head Start Federal Award Number: 04CH01123704 (Year: 2023) 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 Head Start program. Corrective Action Plans: An extensive physical inventory has been performed by the Finance Department and the Head Start program manager to identify all equipment and property purchased and maintained by the Head Start program. We are updating the equipment and inventory listings to ensure that records are maintained in accordance with federal regulations. We are reviewing and revising our procedures for performing physical inventories on an annual basis. Estimated Completion Date: 12/31/2024 Contact Person: Mollie Smith, Finance Director Telephone: 478-237-6674 Email: mhsmith@emanuel.k12.ga.us

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE – U.S. DEPARTMENT OF EDUCATION – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, COVID-19 – EDUCATION STABILIZATION FUND, FEDERAL ALN 84.425 2023-002 Internal Control Over Compliance and Material Noncompliance With Equipment and Real Property Management Requirements Finding Summary 2 CFR § 200.313 (c)(1) and (d)(1) requires that Aurora Charter School (the School) obtain approval from the federal funding agency or pass-through agency prior to the purchase of equipment with federal funding. During our audit, we noted the School did not have sufficient controls in place within the COVID-19 – Education Stabilization Fund federal program to assure compliance with federal equipment and real property management requirements, resulting in material noncompliance. Corrective Action Plan Actions Planned – This condition and the resulting material noncompliance was caused by a misunderstanding of the cost threshold at which federal equipment and real property management compliance requirements must be applied, due to the School’s adopted internal capitalization threshold being lower than the federal threshold. The School intends to revise its internal capitalization threshold to align with the federal threshold, and to review its other control procedures relating to equipment and real property management requirements to ensure compliance for future federal awards expenditures. Official Responsible – Matthew Cisewski, Executive Director. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The School agrees with this finding. Plan to Monitor – The School’s Executive Director, Matthew Cisewski, will oversee the implementation of proposed corrective actions and verify that appropriate controls are in place and understood by individuals responsible for federal program oversite at the School to ensure future compliance with federal equipment and real property management requirements.

FINDING 2023-001 Finding Subject: Community Development Block Grants/En􀆟tlement Grants ‐ Equipment and Real Property Management Summary of Finding: Although the City maintained property records, adequate property records for assets purchased with CDBG award funds were not maintained. One asset, totaling $222,333, was purchased with CDBG funds during the audit period The one asset purchased was added to the property records but did not include the source of funding for the property, who holds 􀆟tle, percentage of federal par􀆟cipa􀆟on, and condi􀆟on of the property. Contact Person Responsible for Correc􀆟ve Ac􀆟on: Douglas Whitham, City Controller Lelia Kelley, Director of Community Development Contact Phone Number and Email Address: (765) 648‐6034; dwhitham@cityofanderson.com (765) 648‐6096; Ikelley@cityofanderson.com Views of Responsible Officials: We concur with the finding. Descrip􀆟on of Correc􀆟ve Ac􀆟on Plan: We concur that the Community Development Department should properly maintain a lis􀆟ng of all equipment and real property purchased with Community Development Block Grant (CDBG) funds exceeding the prescribed threshold, presently $5,000, to sa􀆟sfy all related federal award requirements. The City Controller maintains capital asset records with robust internal controls in place. Such records are maintained for the purpose of financial repor􀆟ng with appropriate thresholds in place designed to capture significant asset addi􀆟ons for the stated purpose. Such thresholds do not correspond to those required in the administra􀆟on of federal funds. Addi􀆟onally, capital asset records maintained for financial repor􀆟ng would not require the capture of other informa􀆟on such as who holds 􀆟tle, percentage of federal par􀆟cipa􀆟on, and condi􀆟on of the property. Each department of the City administering federal awards should maintain records designed to achieve federal compliance. The City Controller will work with the Community Development Department to ensure a proper system of internal control is in place and that a list of equipment and real property is sufficiently maintained by Community Development to sa􀆟sfy federal compliance requirements. An􀆟cipated Comple􀆟on Date: The an􀆟cipated correc􀆟ve measures should be in place by December 31, 2024.

2023-005 – Equipment and Real Property Management Corrective Action: CBNHC will implement the following corrective actions: • CBNHC will immediately conduct a physical inventory of all items listed on its capital asset listing. • Once a physical inventory has been taken, CBNHC will create an effective property record which includes the description of the property, a CBNHC serial number, the funding source for the acquisition of the property (including the Assistance Listing Number), and the relevant title information, acquisition date and cost. • CBNHC will thereafter assign department managers responsible for the custodianship of the said equipment/property. • At the end of each fiscal year, CBNHC will conduct a physical inventory and maintain evidence in its accounting files. Person Responsible: The following individuals will be responsible for the above corrective action plan: • Accounting Technician (Charlotte Sandoval) – Is responsible for scheduling and performing the physical inventory inspection. • Accounting Supervisor (Candyce Guerro) – Is responsible for coordinating the custodial assignment of the CBNHC’s property and equipment. • Interim Finance Director/Chief Operations Officer (Volelle Zamora) – Is responsible for ensuring the completion of the physical inventory on an annual basis. Completion Date: CBNHC will perform its physical inventory immediately, with completion by September 30, 2024. Thereafter, the physical inventory count will be performed annually before the last day of the calendar year.

Corrective Action: Monroe County Schools will take the following corrective actions to improve the equipment and real property management – ESSER: • The Board will develop a policy with guidelines detailing proper inventory of real property and equipment. This policy will include maintaining inventory of items purchased with federal funds. • A detailed inventory listing for all real property and equipment, including those acquired under the COVID-19 American Rescue Plan ESSER program will be developed. • The listing will be updated through annual physical inventory. Effective Date: November 30, 2024 Person(s) Responsible: CSBO & Director of Federal Programs, Monroe County Schools

Recommendation: We recommend the Entity enhance the design of its control activities and policies and procedures should be developed to ensure physical inventories are taken at least once every two years. Action Taken: The Organization understands the importance of regular physical inventories and will implement this control activity for the June 30, 2023 fiscal year end. Responsible Person: John Clemons, Chief Financial Officer Timelines for implementation: July 31, 2023

The District will communicate with the team at DESE to determine what is needed to bring all files current.

The District understands fully that all state and federal spending must follow guidelines set forth in the grant or amount allocated.

Accounts payable will not release funds until all guidelines and documents are secured and attached to the Purchase Card of Purchase Order form. The district has appointed a different Federal Program Coordinator and this action has been practiced since January 2, 2024.

The District will conduct a training to inform supervisors what forms and guidelines are required prior to the release of any monies by the end of July 2024.

ALN: 20.509, Corrective Action Plan: Noncompliance with Federal Procurement Requirements - MDT - The Montana Department of Transportation has hired new leadership for the Transit Section, who are actively working with the Federal Transit Administration (FTA) and the subrecipients to formalize procedures, document oversight measures, and correct the deficiencies. Person(s) Responsible for Corrective Measures: Rob Stapley, Administrator, Montana Department of Transportation, Target Date: 06/30/2025

ALN: Various R&D, Corrective Action Plan: Equipment Inventory Controls - MSU - Montana State University - Bozeman will enhance the internal controls surrounding the capital asset inventory and tagging process, including accessing research space to count and tag new assets. The university had a difficult time over the pandemic in retaining employees and hiring replacements. There were also difficulties accessing space on campus due to social distancing requirements. The university has been able to hire employees in Property Management and expects the pandemic-related challenges to be minimal moving forward. Person(s) Responsible for Corrective Measures: Aaron Mitchell, Associate Vice President for Financial Services, Montana State University, Target Date: 12/31/2024

ALN: Various R&D, Corrective Action Plan: Equipment Inventory Controls - UM - The University of Montana - Missoula has strengthened internal controls by hiring an Account Analyst to manage asset tagging and to conduct comprehensive reviews to ensure all assets are tagged and accounted. The Account Analyst will be assisted by an intern to conduct a thorough review to verify and update the status of all assets. Person(s) Responsible for Corrective Measures: Rachel Buswell, Controller, University of Montana - Missoula, Target Date: 09/30/2024

Response to "2023 - 003 Finding: Activities Allowed/Unallowed and Cost Principles (Compliance; Internal Controls Over Compliance)" Yankton Transit will become familiar with the requirements of 2 CFR, §200.313(a) and will establish internal control policies and procedures and will train staff on those policies and procedures.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – COVID-19 – EDUCATION STABILIZATION FUND (FEDERAL ALN 84.425) 2023-003 Internal Control Over Compliance With Equipment and Real Property Management Requirements Finding Summary 2 CFR § 200.313(d)(1) requires the Academy to designate fixed assets purchased under federal programs and to maintain related property records, including a description of the property, a serial number or other unique identification number, the source of funding for the property (including the federal Assistance Listing Number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use, and condition of the property, and any ultimate disposition data, including the date of disposal and sale price of the property. During our audit, we noted that the Academy did not have sufficient controls in place within the COVID-19 – Education Stabilization Fund federal program to specifically identify federally-funded fixed assets and maintain the required records as noted above to assure compliance with federal equipment and real property management requirements. Corrective Action Plan Actions Planned – The Academy plans to review its internal control procedures to ensure future compliance with the federal compliance requirements specific to equipment and real property management for the COVID-19 – Education Stabilization Fund federal program. Official Responsible – The Academy’s Executive Director, Farhiya Einte. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The Academy agrees with this finding. Plan to Monitor – The Academy’s Executive Director, Farhiya Einte, will ensure that federally-funded fixed assets are distinguishable within the Academy’s finance system. The Academy also intends to review its control procedures relating to equipment and real property management requirements to ensure compliance for future federal awards expenditures.

Name of Auditee: Town of Alexander, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2023 CAP Prepared by: David Miller, Supervisor Phone: 585-591-2455 (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 Alexander.

Recommendation: The auditor recommends the City enhance the design of its control activities and create a tool to assist in tracking and maintaining equipment purchased with federal funds. Additionally, the employees responsible for the inventory count should be trained to ensure understanding of the Uniform Guidance requirements relevant to equipment and real property management. Periodic review should also be designed to evaluate compliance with the relevant requirements. Action Taken: The City agrees with this finding. In November 2022 (about 5 months into FY23) the City hired a new Airport Manager with substantial experience managing municipal airports and overseeing federal funding for airports. During FY23 the long‐time Administrative Manager at the Airport separated without notice from the City and other staff were unable to access needed files which included equipment records. In FY24 the Airport Manager hired a heavy equipment mechanic. This position is responsible for tracking, maintaining, and repairing Airport equipment. Logbooks are now being kept for all equipment. In CY24 the Finance Director and the Accounting Officer will work with the Airport staff to improve internal controls over equipment purchased with federal funds. Policies and procedures will be developed to ensure that an accurate physical inventory is conducted timely, and that assets are removed from the asset listing when they are disposed of. Tools will be developed to facilitate tracking and maintaining equipment purchased with federal funds. In CY24 the City will provide Uniform Guidance training to staff which will include capital assets and equipment information. The City is in the process of identifying a vendor to contract with Airport to assist with federal compliance and provide training to Airport staff on relevant Uniform Guidance requirements. The vendor’s scope of work will also include helping with developing and documenting standard opera􀆟ng procedures related to equipment and real property management. Due Date of Completion: December 31, 2024 Responsible Official: Emily Oster - Finance Director, James Harries - Airport Manager, Jerome Sanchez - Airport Heavy Equipment Mechanic, Matthew Bonifer - Accounting Officer, Grants Manager (in recruitment)

Planned Corrective Action: The District confirms the audit finding and will implement policies and procedures, as well as staff training, to ensure compliance with the ES fund. Anticipated Completion Date: October 1, 2024 Responsible Contact Person: Matthew Bryant, Director of Facilities

Research and Development – Assistance Listing No. Various Recommendation: We recommend the University ensure that a physical inventory over equipment is completed at least every two years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Langston will strengthen its equipment inventory practices ensuring that a physical count is completed at least every two years. Name(s) of the contact person(s) responsible for corrective action: Mr. Chris Kuwitzky, Vice President for Fiscal and Administrative Affairs. Planned completion date for corrective action plan: June 2024