Corrective Action Plans

Identifying Number: SA 2024-001 Description of Finding: MARTA does not have comprehensive written policies and procedures concerning the following key compliance areas which are required by the Uniform Guidance: Equipment and Real Property Management MARTA has an Asset Inventory Policy and Procedures, however, it does not clearly define the policies and procedures that are in place for the use, management and disposition of equipment acquired under a Federal award in accordance with 2 CFR sections 200.313(c) through (e). Cash Management MARTA does not have written procedures to implement the requirements of 2 CFR 200.305 Federal Payment. Procurement, Suspension and Debarment MARTA has a Procurement policy, however, documented procedures are not well- defined regarding the purchase process for different types of procurement, obtaining quotations, bidding, and procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Corrective Actions Taken or Planned: We have an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. We also have Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing resources available. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. We are in the process of updating our Procurement Policy. We will review and update these policies and/or create new policies to make sure we are compliant with the Uniform Guidance. The updated or newly created policies will be brought to our October 2025 Board of Directors meeting for Board review or approval. Personnel responsible for implementation: Sean Gillingham, Finance Manager Anticipated completion date: October 2025

Management agrees with the finding related to Equipment Management. Management conducted a biannual physical inventory count of specific federally purchased research equipment in Fiscal Year 2024. Management did not include all required fields within the clinical engineering database as required by 2 CFR section 200.313 (d) (1) such as the percentage of Federal participation in the project costs for the Federal award under which the property was acquired, asset location and the use and condition of the equipment. Management will update the clinical engineering database to include these fields within the details by June 30, 2025. Management did not verify the completeness of the listing against the entire federal equipment inventory. Management will establish a quarterly control in which Research Finance will reconcile federal equipment inventory within the clinical engineering database against the Corporate Finance federal equipment listing, starting with the quarter ending March 31, 2025. Leadership Responsible: John Muhlen, System Vice President of Corporate Finance Anticipated Completion Date: June 30, 2025

2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease Federal Financial Assistance Listing Number: 93.323 Federal Grantor: U.S. Department of Health and Human Services Award No. and Year: Various Compliance Requirements: Equipment and Real Property Management Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of Noncompliance Criteria: In accordance with 2 CFR section 200.313(d)(1), 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 sale price of the property. Condition: Property records were not maintained in accordance with Uniform Guidance for all property and equipment purchased. As a result, we were unable to (1) test whether there were any differences between the physical inventory and equipment records were resolved and (2) sample equipment from the property records and physically inspect the equipment and determine whether the equipment is appropriately safeguarded and maintained. Cause: The HCA department did not have adequate internal controls to ensure its property records included all the requirements under Uniform Guidance or properly identify all property and equipment purchased with federal funds. Effect: Property records were not adequately maintained. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: No sampling was used. We examined the department’s property records in total. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA department enhance internal controls to ensure its property records include all the requirements under Uniform Guidance and properly identify all property and equipment purchased with federal funds. Management Response and Corrective Action: 1. Person Responsible: Tommy Bui, HCA Property Officer 2. Corrective Action Plan: County of Orange has implemented a new Asset tracking system that has fields which allow departments to identify the funding source. HCA is currently migrating and cleansing data from a legacy asset solution to this new system, OpenGov. 3. Anticipated Implementation date: June 30, 2025

Identifying Number: 2024-001 – Equipment and Real Property Management Finding: The University’s controls were not operating effectively to reasonably ensure the University maintained property records with the above required information and performed the required physical inventory of equipment within the two previous years. As a result, the University did not comply with the compliance requirements for equipment and real property management. The University does not have processes and procedures in place related to equipment management, tracking and required physical inventories. Corrective Actions Taken or Planned: We agree with the auditors’ findings. Currently, the University’s federally funded equipment inventory consists of 6 pieces of equipment located in the laboratory where they are used on a regular, if not daily, basis, facilitating a regular visual inventory. However, the need to accurately track and document each piece of equipment, in accordance with Federal guidelines, is recognized. Going forward, an annual physical inventory will be taken, during which each piece of equipment will be identified based on the unique serial number as provided by the manufacturer. Documentation will be maintained by the department with an annual inventory supplied to the Dean and Grants Management department. Person(s) Responsible for Correction Actions: Christine Seitz McCauslin, Ph.D. Anticipated Completion Date: completed

2024-001. Equipment and Real Property Management United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP Allocations ALN:84.027X Special Education Preschool Grants: IDEA Preschools ALN: 84.173 Special Education Preschool Grants: DEA 619 ARP Allocations ALN: 84.173X 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 COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W Condition: The District did not include all equipment purchased with federal grant awards within its current year additions in the District’s capital assets inventory records. Planned Corrective Action: The District will implement procedures where a formal reconciliation will be performed between the District’s equipment expenditure codes and the additions to the District’s capital assets inventory records. Responsible Contact Person: Dr. Patrick Pizzo Assistant Superintendent for Business and Finance East Meadow Union Free School District 718 The Plain Road Westbury, New York 11590 Anticipated Completion Date: June 30, 2025.

Finding Number: 2024-003 Equipment Property Management Recommendation: The University needs to enhance the precision of the controls over equipment purchases to ensure that a property record is created within the system containing the required information for all federally funded equipment. Management concurs with the auditor’s recommendation. The University has taken immediate steps to comply with 2 CFR 200.313 and is in process of implementing the following actions: Planned Corrective Action (1): The University is incorporating an additional worktag into the procurement approval workflow for asset management, enabling the identification of asset purchase orders and ensuring their proper routing to the Asset Management team for asset record creation. Anticipated Completion Date: May 2025 Responsible Contact Person: Eric Hughey, Fiscal Manager, Asset Accounting & Surplus/Nataliya Samodov, GCA Director Planned Corrective Action (2): The University will be implementing Multi-book functionality in the Workday ERP to improve asset management including creation of multiple asset books to meet different accounting standards as well as tracking of the assets from acquisition to disposal. This implementation will provide active monitoring of assets to ensure compliance. Anticipated Completion Date: Fall 2025 Responsible Contact Person: Eric Hughey, Fiscal Manager, Asset Accounting & Surplus/Nataliya Samodov, GCA Director

We will give instructions to the Head Start program staff to prepare a capital assets subsidiary record which include a full description of the capital assets, the source of the property, who holds title, the acquisition date, cost of the property, percentage of Federal participation in the cost of the property, use and condition of the property, and any ultimate disposition data including the date of disposal, among others.

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: Governor's Emergency Education Relief Fund ALN: 84.425C 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 COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Youth and Children ALN: 84.425W Condition: The District did not include the capital expenditures for the “Unit Ventilators Replacement Project” paid with CRRSA ESSER 2 funds in its current year’s capital assets inventory additions. Planned Corrective Action: The District’s Assistant Superintendent for Business and Operations will review and update existing procedures relating to the recording and tracking of capital assets purchased with federal funds. The cost of the unit ventilators replacement project and pertinent information will be added to the District’s capital assets inventory report. Responsible Contact Person: Brian Phillips Assistant Superintendent for Business and Operations West Hempstead Union Free School District 252 Chestnut Street West Hempstead, NY 11552 Anticipated completion date: September 1, 2025.

Finding No. 2024-001: Inaccurate Property Management Records AL Numbers: Various Program Name: Research and Development Cluster Corrective Action: The Central Accounting team will conduct bi-annual equipment training with all departments of the University, scheduling virtual training with all equipment coordinators. Expected Implementation: June 30, 2025 and December 31, 2025 The University is researching equipment tagging software alternatives that will enhance tracking capabilities and enable asset tagging at a more granular level. The Central Accounting team will work with leadership to outline a timeline for a new tagging system. Expected Implementation: September 30, 2025 Contact: Kathy Conrad and Craig Elmore

2024-003 Equipment and real Property Management Recommendation: The School should ensure proper policies and procedures are in place to monitor the physical inventory requirements and ensure the physical inventory is completed and documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A physical inventory of capital assets will be done in the spring/summer of 2025 and every other year after. Adjustments to financials will be recorded as necessary upon completion of physical inventory. A Capital (Fixed) Asset policy will be created and presented to Board for approval. Name(s) of the contact person(s) responsible for corrective action: Deborah S. Czmiel Planned completion date for corrective action plan: 06/30/2025

Finding 2024-006 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: We will work with the Capital Assets reporting Firm more closely to assure that all listed property is properly marked and that it is still in our possession. Anticipated Completion Date: March 2025

The District immediately took corrective action by adding the items to the equipment subsidiary ledger. The District acknowledges the need to further strengthen the internal control process to prevent similar failures in the future. In addition to strengthening internal controls, the District has sought ancillary services to improve the management of equipment and the recording of items to the equipment subsidiary ledger.

Finding Number: 2024-001 Planned Corrective Action: The Board of Directors has a Fixed Asset and Inventory Policy in place which requires all acquisitions of property purchased with federal funds to be placed in the Board’s inventory and appropriately tagged with identifying information, including the specific grant funds used for the acquisition. In addition, the Policy requires the Education Management Organization (“EMO”) to maintain data records and an accurate inventory of all Board-owned property. The EMO is responsible for performing an annual physical inventory of all property owned by the School and non-Board assets located at the School. The inventory process includes confirming and validating asset records and confirming compliance with legal, auditing/reporting and insurance requirements regarding all Board-owned assets. The EMO is also required to compare the actual inventory on hand to property records and the Board reviews a copy of the comparison report on an annual basis. Skyway has recently purchased an inventory tracking system that will provide information on all tangible inventory in the building with necessary information to include funding source of the item purchased. The inventory hardware is currently getting the software installed. Once this is complete (April 2025) a full inventory process will be taking place for all tangible items in the building. The process of inputting all information and tagging each item will be completed before the beginning of August 2025. The new inventory system will replace any inventory systems or processes used in the past and all previous tags will be removed and replaced. Anticipated Completion Date: August 1, 2025 Responsible Contact Person: Stephanie Ataya, Treasurer and Noreen Brown, Director of Federal Programs

2024-008 Research and Development Cluster & Higher Education Institutional Aid– Federal Assistance Listing Nos. Various and 84.031 – Physical Inventory on Property & Equipment Recommendation: We recommend the University review its policies and procedures related to PPE purchased with federal funds and include the necessary information to be compliant. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: Restricted Fund Accounting (RFA) will work with the Assistant Controller to ensure access to information about the PPE purchased with federal funds are readily available. RFA & Assistant Controller will have quarterly reviews of PPE listing related to federal funds. Name(s) of the contact person(s) responsible for corrective action: Director of Accounting, Tonya A. Cardwell & Assistant Controller, Clifton Smith, II. Planned completion date for corrective action plan: October 2025

Contact Person: Business Manager Planned Corrective Action: The Business Manager currently maintains a file which includes documentation in support of all amounts submitted on federal quarterly SF-425 reports. Planned Completion Date: Throughout the fiscal year ending June 30, 2025 and ongoing 2024 – 007 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

Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management Requirements compliance requirements. Context: The School Corporation was not able to provide a complete capital asset listing with the required information to support that the equipment purchases of $46,727 and $12,408 with COVID-19 – Education Stabilization Fund ESSER II and ESSER III funds had been added to the capital asset listing. Additionally, the School Corporation was not able to provide support that an inventory of capital assets had taken place at least once in the last 2 year. Corrective Action Plan: The School Corporation will implement a system of internal controls to ensure the capital asset listing is updated at least annually to include all equipment and real property acquisitions as well as dispositions that took place. The School Corporation will ensure the capital asset listing includes all required information. Person responsible for implementation and projected implementation date: The Business Manager will be responsible for overseeing the implementation of the corrective action plan, which will go into effect immediately.

2024-004 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior approval will be acquired by District purchasing agents on the ND DPI Capital Expenditure Prior Approval For Use of Federal Funding form before capital purchase is made using federal funding. Anticipated Completion Date: Fiscal Year 2024-2025

Personnel Responsible for Corrective Action: Julie McGovern, Chief Financial Officer Anticipated Completion Date: September 30, 2025 Corrective Action Plan: Due to turnover in the Business Office, the corrective plan identified with the FY23 audit was not completed. The corrective action remains the same. The Business Office will implement a systematic process to properly track fixed assets that will include a description of the property, a serial / identification number, the source of the funding for the property including the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any disposition information should the asset be sold, retired or disposed. A key resource has been obtained that will enable this project to be completed in the timeframe noted.

The University initiated a thorough inventory process, including a requirement to tag and photograph all assets, during the fiscal year ended June 30, 2024. The inventory process was started on schedule in May 2024, and departments were asked to complete their inventory procedures and sign off on the inventory reports by June 2024. Despite the additional complications created by the University’s campus relocation project necessitated by the closure of the Hawai‘i Loa campus and the construction of the science laboratories, 91% of the departments completed their inventories prior to June 30, 2024. The remaining 9% of departments completed their inventories after requesting an extension and/or providing additional details on the requested inventory items in the meantime, and these inventories were completed during the fiscal year ending June 30, 2025. These results demonstrate improvement and progress compared to the prior year’s finding in this area and illustrate the University’s commitment to adhering to tits fixed asset inventory processes and procedures. The University is committed to addressing these issues promptly and effectively to ensure compliance with federal regulations. Accordingly, the University will complete the following tasks to correct this repeat finding: 1) Assess the allocation of resources. Assess the resources required to complete physical inventories and reconciliations timely. Allocate personnel, temporary assistance, and/or reassign staff duties as needed to support compliance with policy and regulation. 2) Review the inventory timeline and monitoring process. Assess, and if necessary, adjust the timeline for conducting and reconciling physical inventories of all department assets within the required two-year cycle. Consider modifying the time of the inventory to enable reconciliation prior to fiscal year-end. Evaluate whether shifting to a staggered inventory process to spread the workload throughout the year would assist with achieving compliance. 3) Leverage technology for inventory management. Identify ways to leverage the University’s existing ERP software alongside reporting technologies and techniques to aid in the inventory management and property reconciliation process. Use these tools to improve the efficiency and accuracy of inventory management. 4) Ensure the proper tagging of equipment. Conduct a review of all equipment items to ensure they are appropriately tagged or assigned unique identifiers in accordance with the Fixed Asset Policy and related regulations. 5) Train and guide staff and faculty who are responsible for asset management. Develop and provide training sessions for responsible staff and faculty on the inventory process, reconciliation procedures, and tagging requirements, to include individuals within the Business Office and located within the departments. Reinforce accountability and ensure consistent application of policies. 6) Monitor and report on the progress of the action plan by providing regular updates to Management. Person(s) Responsible: Controller & Associate Vice President. Targeted Correction Date: December 31, 2025. Fiscal Year in which Finding Initially Occurred: 2023 (Finding Number 2023-003).

Prior to June 30, 2025, the University will conduct a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero on the University’s books as of June 30, 2024. For new purchases of equipment using federal funds, the University will tag these assets on a monthly basis. In addition, a physical inventory of equipment purchased using federal funds will be conducted every two years going forward. The inventory process will be reviewed by management to ensure timely and accurate completion.

Significant Deficiency 2024-001. Equipment and Real Property Management United States Department of Education, Passed Through New York State, Department of Education: Education Stabilization Funds COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief Fund ALN: 84.425U Condition: The District did not include capital expenditures paid with federal awards in its capital assets inventory records. Planned Corrective Action: The Deputy Superintendent will put procedures in place to ensure that equipment and capital spending of federal funds are included in the District’s fixed assets inventory. The federally-funded project noted in this report will also be added to the fixed assets inventory records for financial reporting purposes. Responsible Contact Person: Ms. Diane Castonguay, CPA Deputy Superintendent East Williston Union Free School District 11 Bacon Road Old Westbury, New York 11568 Anticipated Completion Date: August 15, 2025.

FINDING 2024-003 Finding Subject: Education Stabilization Fund- Equipment and Real Property Management Contact Person Responsible for Corrective Action: Todd Slagle Contact Phone Number and Email Address: 812-874-2243 tslagle@northposey.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will develop and implement a formal internal control system to ensure proper segregation of duties and compliance with federal regulations. Missing assets, such as the ironworker purchased with ESSER 3E funds, will be added to the listing immediately. The School Corporation will conduct periodic reviews and reconciliations to verify that all assets, including those purchased with federal funds, are accurately reflected in the capital asset ledger. Anticipated Completion Date: We anticipate completing the Corrective Action by July 1, 2025

Finding 2024-004 – Equipment Management (Significant Deficiency and Noncompliance) Planned Corrective Action: The University is currently conducting an inventory and will ensure that it occurs at least every two years. Anticipated Date of Completion: June 2025 Person Responsible for Corrective Action: Director of Financial Services & Cost Management and AVP/Controller

Contact Person Responsible for Corrective Action: Dalton C. Tunis Contact Phone Number: 574-896-2155 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: For future projects and purchased equipment, NJ-SP will make sure proper documentation will be recorded for any equipment and real property purchased. An internal control system will be put into place that ensures the Business Manager receives proper documentation and records the capital assets into a spreadsheet in order for the equipment can be traced and the School Corporation stays in compliance. Anticipated Completion Date: June 30, 2025

CORRECTIVE ACTION PLAN - Recognizing the need/requirement to maintain property records appropriately, the district is working to schedule/complete a comprehensive physical inventory that should assist in identifying the location of equipment funded by the Education Stabilization Fund (ESF), resulting in questioned costs of $2,186,066 per this finding (in addition to all other equipment carried by the district regardless of funding source). The district plans are to continue to work with NEFEC to enact property records within Skyward to capture accurate information and a base starting point per completion of a physical inventory. All property records will then be maintained in Skyward to capture all information required under Federal funding provisions and a reconciliation to physical inventory counts will be prepared no less than every 2 years. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Walter Copeland, Interim CFO