Corrective Action Plans

2024-007 Material Weakness and Noncompliance, Equipment and Real Property Management Audit Finding: Non-federal entities other than states must follow 2 CFR sections 200.313 (c) through (e) which require that 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, who holds the tile, the acquisition date, cost of property and other info. The Town could not provide property records including all required information as indicated in the 2 CFR section 200.313 (d)(1). The Town did not perform a physical inventory of the property. Corrective Action Taken: The Town maintains a list of physical inventory by capital project. While it is not cost-efficient to take a full physical inventory, the Town will develop a process to track equipment purchased with federal funding and will maintain support that physical inventories were performed as required. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425U Recommendation: CLA recommends that the District establish and implement procedures to ensure that a physical inventory of equipment is conducted at least once every two years. This should include assigning responsibility for the inventory process, setting a schedule for inventory counts, and ensuring that the results are reconciled with the equipment records. CLA also recommends the District review its capital asset tracking processes and implement internal controls to help ensure that all required documentation is entered into the capital asset software when federal funding is involved and there is adequate segregation of duties in regards to capital asset reporting. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The District will either do a self-inventory or hire a firm to do the inventory for us. Name(s) of the contact person(s) responsible for corrective action: Dawn Rausch, Brooke Rosemeyer Planned completion date for corrective action plan: June 30, 2026

Yankton Transit will become familiar with the requirements of CFR, §200.313(a) and will establish internal control policies and procedures and will train staff on those policies and procedures. Currently, we have changed the debit cards to credit cards for proper approval and complete support for the transactions that occur monthly.

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 very two years. See 2024-007 for management's detailed action plan surrounding the property findings.

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate property records. Action Plan:  Develop a workbook to document all property records in compliance with CFR requirements. o Create a spreadsheet with the required fields (i.e., item description, acquisition date, cost, funding source, location, condition, disposal status). o Align data fields with CFR property requirements. o The anticipated completion date is May 30, 2025, with an updated monthly review.Extract fixed asset purchase records from eFinance and compare them to the latest audit fixed asset listing. o Pull all of the fixed asset account codes since the last completed audit (FY22). o Priority- focus on items purchased with federal funds. o The anticipated completion date is May 30, 2025, with an updated monthly review.  Conduct a physical inventory to verify the present of all listed assets. o Use the workbook developed above as the inventory list to begin physical inventory. o Designate staff to conduct physical verification. o Check each item’s presence, condition, and tag number against records o Use asset tags or serial numbers for tracking. o Note missing, unrecorded, or damaged assets for follow-up. o Adjust the property workbook as needed. o Submit a summary of discrepancies and corrective actions to the Executive Director. o The anticipated completion date is June 30, 2025, with an updated monthly review.  Update the workbook with required details for assets still in possession. o Record all property purchased with federal funds, ensuring accuracy and completeness. o Regularly review, update, and reconcile records with physical inventory. o Save in a shared, secure cloud location for easy access and audit readiness. o Anticipated completion date of July 15, 2025, with an updated monthly review.  Write off any assets listed by not physically accounted for. o Follow the proper steps to write off assets in eFinance. For assistance, refer to the eFinance instructions and APSCN help desk. o Anticipated completion date of July 15, 2025, with an updated monthly review.  Establish procedures for conducting this process and maintaining records annually. o Set up a recurring annual timeline for physical asset verification. o Develop consistent forms and tracking sheets for inventory records. o Designate personnel to conduct, review, and reconcile inventory. o Conduct physical audits regularly. o Update and maintain records. o Annually assess and refine procedures for efficiency and compliance. o Anticipated completion date of July 31, 2025, with an updated monthly review.

Condition: The District did not maintain adequate property records to comply with 2 CFR section 200.313(d)(1). Plan: The District engaged a third party fixed asset vendor to ensure annual updating of property records, including the tagging and marking of items of Federal origin. Date of Completion: June 30, 2025 Name of Contact Person: Dennis Forst, Assistant Superintendent of Business & Operations Management Response: Management concurs with the finding and has developed applicable procedures.

The district will develop written fixed/capital asset procedures that will require that all equipment over the capitalization threshold must include serial numbers in property records and be affixed with a unique asset identification tag. We will conduct a full physical inventory of equipment. As part of this process we will record serial numbers for all applicable items, affix asset tags to all untagged equipment, and record proper disposal of assets. We will provide staff training for all relevant staff on asset management procedures and responsibilities.

The district will develop written fixed/capital asset procedures that will require that all equipment over the capitalization threshold must include serial numbers in property records and be affixed with a unique asset identification tag. We will conduct a full physical inventory of equipment. As part of this process we will record serial numbers for all applicable items, affix asset tags to all untagged equipment, and record proper disposal of assets. We will provide staff training for all relevant staff on asset management procedures and responsibilities.

Corrective Action Plan: The identified conditions relate to the proper maintenance of detailed records of equipment and other assets acquired for research purposes from federal award funding. As a result of personnel turnover in the Union College finance department, the required bi-annual inventory count and reporting was not conducted for fiscal year 2024. The corrective action plan is to conduct this audit at the conclusion of the current fiscal year (2025). Timeline for Implementation of Corrective Action Plan: These corrective action will be completed concurrently with the fiscal year 2025 year end closing and audit procedures. The College will then get back on cycle with a research equipment inventory audit for fiscal year 2026, and then each bi-annual cycle thereafter.

As a corrective measure, BGCPR will take the following actions and will anticipate completing on June 30, 2025: a. Implement and maintain an automated accounting and financial records system to enable real-time oversight of the asset capitalization policy. b. Establish a robust internal control framework including pre-approvals for equipment purchases and cross-validations of financial data. c. Periodic internal monitoring’s to ensure compliance and documentation.d. Update BGCPR’s fiscal management guidance to include a formal provision requiring the capitalization policy to be reviewed every three (3) years in compliance with the ensure compliance with federal regulation 2 CFR §200 regarding asset capitalization criteria. e. Conduct a training program for accounting and financial personnel.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – COVID-19 – EDUCATION STABILIZATION FUND (ALN 84.425) 2024-006 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 priio year 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. The Academy was responsible for submitting a corrective action plan to the Minnesota Departement of Education to rectify this finding, but none was submitted. 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, 2025. 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.

Finding Number: 2024‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Arlene Laughter, Business Coordinator Anticipated Completion Date: September 30, 2025 Planned Corrective Action: The District will develop and implement stronger internal control procedures to ensure accountings and financial statements are free from misstatements and are in accordance with District policies and Federal and State requirements. Inventories of capital assets purchased with federal funds will be conducted every two years, as required.

Finding 2024-005 Personnel Responsible for Corrective Action: Kim Johnson, SLPS Chief Financial Officer/Treasurer and Kelly Genge, Controller Anticipated Completion Date: June 30, 2025 Corrective Action Plan: The finance department engaged an asset services firm to perform a physical inventory of the District’s capital assets during fiscal year 2025.

The district will implement a dual review process prior to each fiscal year end, involving both the Treasurer and Assistant Treasurer, to ensure that all assets acquired during the fiscal year are properly identified and established within the districts’ inventory system. All assets acquired will be coded in a manner that allows for an identification of the federal grant utilized to acquire. The current inventory system will be reviewed by the Treasurer and Assistant Treasurer, to ensure that existing assets purchased with federal funds are coded in a consistent manner. A physical inspection of assets acquired under ESSER and ARP ESSER will be conducted immediately, and will be placed on the departmental activity list to be performed at a minimum every two years, prior to June 30th of that year.

Finding 2024-003: Physical Inventory Observation Synopsis of Finding CAPSC has not performed a physical inventory in the last two years. Management’s Response We have implemented an annual schedule of Physical Inventory being taken every July, while classrooms are closed for the summer. This will be conducted by our Facility and Operations team members with support from Head Start leadership. Contact Person Responsible for Corrective Action: Kate Devine, Director of Operations and Change Management Anticipated Completion Date: 7/15/25

CORRECTIVE ACTION PLAN (CONTINUED) FINDINGS—FEDERAL AWARDS 2024-005 EQUIPMENT/REAL PROPERTY MANAGEMENT Program: Education Stabilization Fund CFDA Number: 84.425D, 84.425U Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESSII-111389-01A, 21FESIII-111389-01A Questioned Costs: $-0- Type of Finding: Noncompliance, significant deficiency Compliance Requirement: F. Equipment/Real Property Management Condition/Context: The District did not properly update its capital assets listing to include equipment purchased using Education Stabilization Fund monies. Additionally, the District has not performed a full physical inventory of its assets purchased using federal monies in the two year period ended June 30, 2024. Action planned in response to finding: The District will implement procedures to ensure that all assets, including those assets purchased with federal funds, are properly added to the asset listing, tagged, and inventoried at least every two years. Planned completion date for the corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Judy James, Business Manager Please do not hesitate to contact us for further information. Sincerely,

Finding No: 2024-003 Condition: The District does not currently maintain a detailed accounting/list of its capital assets, including Federal assets. The District does not have a recent replacement cost valuation for insurance purposes. We consider this finding to be a material weakness in internal control over major programs. Plan: The district has allocated internal business office resources to perfrom a deterailed inventory and accounting of capital assets and Federal assets. Anticipated Date of Completion: December 31, 2024 Name of Contact Person: Christopher Blomquist, CSBO Management Response: See plan above

Views of Responsible Officials and Planned Corrective Action The County will enhance the control activities and procedures to ensure physical inventories are taken at least every two years and will track and maintain equipment purchased with federal funds. Finding resolution timeline: There is currently a documented process and a physical inventory was completed in February 2025. A spreadsheet has been developed for assistance of tracking federal assets. Designation of employee position responsible for meeting this deadline: Andrea Montoya, Deputy County Manager

U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 Education Stabilization Fund – AL #84.425C, 84.425D & 84.425U 2024-002 Equipment and Real Property Management (Repeat Finding 2023-002) Significant Deficiency Recommendation: The Auditor recommended the Organization develop a system of internal controls aligned with the applicable compliance requirements to properly track equipment acquisitions in the accounting records and to ensure a physical inventory is appropriately documented when completed. Planned Corrective Action: The Organization has implemented a location software for student devices that tracks the majority of the required information for devices that are live on the network. An internal reconciliation of these records will be performed to align with the Organization’s accounting records. The Organization concurs that additional internal controls are necessary to ensure all compliance requirements are met. These controls will include exports from the location software for a periodic inventory as well as additional procedures for tracking defective devices. Similar controls will be implemented to ensure proper tracking and inventory of all assets purchased with federal funds. Michelle Krauter, VP, Chief Financial Officer, will oversee the ongoing implementation of this process to ensure adherence to all compliance requirements.

Amend the property records invenotry procedures to follow 2 CFR Section 200.313 (3 through (2); see the criteria of the finding for the detailed list of requirements.

Significant Deficiency 2024-001. Equipment and Real Property Management United States Department of Education, Passed Through New York State, Department of Education: Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief ALN: 84.425U Condition: The District did not include COVID grants-funded capital improvements in its capital assets inventory records. Planned Corrective Action: The District’s Assistant Superintendent for Business will put procedures in place to ensure that capital spending of federal funds are included in the District’s capital assets inventory reports. The federally-funded capital improvements cited in this report will also be added to the capital assets inventory records for financial reporting purposes. Responsible Contact Person: Mr. Idowu K. Ogundipe, CPA Assistant Superintendent for Business Freeport Union Free School District 235 North Ocean Avenue Freeport, New York 11520 Tel: (516) 867-5212 Email: iogundipe@freeportschools.org Anticipated Completion Date: September 1, 2025.

Finding 2024-007 U.S. Department of Homeland Security Pass-through North Lake Tahoe Fire Protection District Assistance to Firefighters Grant, 97.044 Finding Summary: SCBA packs received as a sub-recipient of North Lake Tahoe Fire Protection Districts AFG grant did not have necessary information documented on inventory schedule. Responsible Individuals: Scott Lindgren, Fire Chief, Tahoe Douglas Fire Protection District Kevin Lawson, Asst. Fire Chief, Tahoe Douglas Fire Protection District Bryce Cranch, Asst. Fire Chief, Tahoe Douglas Fire Protection District Carrie Nolting, Finance Manager, Tahoe Douglas Fire Protection District Corrective Action Plan: The inventory schedule for these items will be updated with all required fields of information. Inventory for the district will be assigned to a Chief officer who will be responsible for making sure property received from federal funding will be tracked appropriately in compliance with CFR 200. Anticipated Completion Date: April 30, 2025

Corrective Action Plan The University acknowledges the findings of the audit report and is committed to immediate corrective measures to enhance compliance and assurance. To address these issues, the University will: 1. Establish an Internal Audit Function: Request a position number from the State of South Carolina Human Resources Office to create an internal auditing role and develop a dedicated budget line item to support this function. 2. Realign the Physical Inventory Team: Reorganize the physical inventory team to strengthen procedures and improve the documentation process, ensuring adherence to federal requirements. 3. Implement Advanced Inventory Management Software: Adopt a technology-based platform to enhance the efficiency and accuracy of equipment and real property management systems. The newly established internal audit team will oversee and manage the corrective action plans until full compliance is achieved. The University is dedicated to enhancing its procedures and internal controls to meet federal equipment and real property management standards. By implementing these measures, the University aims to rectify the identified deficiencies and ensure ongoing compliance with federal regulations. Anticipated Completion Date: September 1, 2025

Corrective Action Plan: Temple concurs with the finding and has contacted the specified sponsors to obtain specific required documentation on transferred equipment and request retroactive disposition instructions. To improve compliance, Temple will update its equipment management policy to include procedures for equipment transfers between institutions. Equipment transfers will also be added to the internal PI transfer checklist. Additionally, we will enhance the training program for equipment managers to cover equipment transfer procedures. Action Date: March 24, 2025 Final Implementation Date: May 31, 2025 Name And Phone Number of Person Responsible for Implementation: Josh Gladden, (215) 204-370- 8138 See " Corrective Plan" on pages 127-128

Finding No. 2024-006 Department(s): New York City Police Department Program(s): Assistance Listing Number 97.075, Rail and Transit Security Grant Program Corrective Action(s): While the one (1) piece of equipment that was identified as “active equipment” was in fact disposed of prior to the most recent inventory count, the equipment was not listed as disposed of because the command’s current member in charge of equipment inventory is still new to the job. A list of equipment that needed to be entered into GTS as “DISPOSED” was left by the previous command member who has since retired. It was an error of happenstance that will not be repeated. Along with all other command inventory managers, NYPD Grants Unit has already provided one-on-one virtual training to this new GTS user, providing him a step-by-step approach on inputting and updating assets in GTS. The new user is able to successfully complete transactions in GTS maintaining accurate and up to date inventory records from the first (new) entry to the final entry (disposal). The user is also in process of working on a complete inventory check of their command’s items purchased with grant funding. The user will ensure all equipment purchased with grant funding with a value of $5,000 or over has been recorded in GTS. In addition, the user will ensure all equipment records in GTS are physically identified as on-hand and active. Furthermore, the Grants Unit will continue with its one-on-one sessions on an as needed basis to update the users on any improvements or required information they should have to ensure they continue to use GTS accurately. Anticipated Completion Date: May 2025 and ongoing Person(s) Responsible for Implementation: Andy Shiwnarain, Assistant Commissioner, Grants & Capital Section Andy.Shiwnarain@nypd.org