Corrective Action Plans

CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 2) accurate, current and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in sections 200.328 and 200.329 of the Uniform Guidance. 74CORRECTIVE ACTION PLAN: The School District concurs with the above noted finding. The School District has employed a new Business Manager whose responsibilities include the oversight of the financial management system and the posting of all transactions into that system. Procedures will be put into place during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for ensuring federal program expenditures are properly coded within the District’s financial management system so as allow for proper reporting related to those expenditures.

Condition: The City did not prepare and file the four required quarterly Project and Expenditure reports for fiscal year 2023. Corrective Action Planned: The City has prepared and filed the Project and Expenditure reports for fiscal years 2023 and 2024. The City has implemented procedures to prepare and file the four required quarterly Project and Expenditure reports by the required deadline. We feel the finding has been resolved going forward. Anticipated Completion Date: June 30, 2024 Contact: Conor MacCorkle, City Chief Financial Officer

Corrective Action Plan for Finding 2023-005 City Management is in receipt of the Finding Required to be Reported by the Uniform Guidance, specifically finding 2023-005 regarding the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds with respect to the Reporting Compliance Requirement. Corrective Actions Already Taken Place: City Management acknowledges this finding. City Management has thoroughly reviewed the existing procedures to determine where improvements could be made. As part of this process, City Management identified improvements to policies and procedures to ensure reports are prepared, reviewed and submitted prior to the deadline. View of Responsible Officials and Timeline for Implementation: Responsible Person’s: Charles Williams, Finance Director, and Brent Batla, City Manager. The planned corrective action will be in effect by May 30, 2024, through completion of the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Program.

County staff have improved the internal control processes to include a secondary review of all submittals related to federal grants. The County Finance Director or delegate will review these submittals quarterly in advance of remitting them.

Finding 2023-003 Reporting – Internal Control and Compliance over Reporting Information on the Federal Program: Assistance Listing Number: 21.027 Federal Program Name: Coronavirus State and Local Fiscal Recovery Fund Federal Agency: Department of Treasury Pass-Through Entity: N/A Federal Award Number and Award Year: N/A - FY22-23 Criteria: Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter II - Office of Management and Budget Guidance. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D - Post Federal Award Requirements. Performance and Financial Monitoring and Reporting. §200.328 – Financial Reporting (2 CFR 200.328): Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. Title 31 – Money and Finance: Treasury. Subtitle A – Office of the Secretary of the Treasury. Part 35 – Pandemic Relief Programs. Subpart A – Coronavirus State and Local Fiscal Recovery Funds. § 35.4 Reservation of authority, reporting. (c) Reporting and requests for other information. During the period of performance, recipients shall provide to the Secretary periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory’s tax revenue sources, and such other information as the Secretary may require for the administration of this section. In addition to regular reporting requirements, the Secretary may request other additional information as may be necessary or appropriate, including as may be necessary to prevent evasions of the requirements of this subpart. False statements or claims made to the Secretary may result in criminal, civil, or administrative sanctions, including fines, imprisonment, civil damages and penalties, debarment from participating in Federal awards or contracts, and/or any other remedy available by law. Condition: For the Coronavirus State and Local Fiscal Recovery Funds (SLFRF), the City did not submit the reports within the required deadline: Report Type Report Type Period Date Due Date Submitted Project and Expenditure Report Performance Report 1/1/23-3/31/23 4/30/2023 5/3/2023 Project and Expenditure Report Performance Report 4/1/23-6/30/23 7/31/2023 8/25/2023 Four (4) performance reports were tested and two (2) of the reports tested were not submitted by the required deadline. In addition, expenditure information reported on the Project and Expenditure Reports were not supported by the City’s accounting records and did not match expenditures reported on the SEFA. This was due to the City not reporting the Revenue Replacement project expenditures of $4,821,936. The City’s Corrective Action Plan: The City concurs with the auditors’ finding. The City will take steps to improve identification and monitoring of required grantor reporting deadlines. Contact person responsible for corrective action: Betsy Howze, Interim Finance Director Anticipated completion date: June 30, 2024

Condition - The School District incorrectly reported expenditures on its reimbursement requests and final expenditures reports to the State. This resulted in the School District not providing accurate information to the State that is used to determine if grant money was expended in accordance with the original or amended grant application. Recommendation - That the School District should review their internal controls and establish procedures to ensure that reports comply with 2 CFR section 200.328 and ensure proper reporting by ESSER Subgrant fund, expenditure category, and object code. Method of Implementation - Accounts Payable will review all purchase orders (P.O.s) on a monthly basis for accuracy, using a checklist provided by the Business Administrator. Person Responsible for Implementation - AP Specialist / ABA / SBA Implementation Date - April 1, 2024

January 8, 2024 To whom it may concern: Southeast Conference (SEC) respectfully submits the following corrective action plan for the fiscal year ending 6/30/23. Our independent single federal audit was performed by Mertz, CPA & Advisor, 3140 Nowell Ave. Juneau, AK 99801. The following finding was discovered, and a corrective plan has been implemented: Finding number: ALN Title: ALN Number: Federal Award Year: Type of Finding: 23-0001 reporting Economic Adjustment Assistance (EDA BBB) 11.307 October 1, 2022, through September 30,2023 Deficiency in Internal Control and Noncompliance Condition and Context: This was the first year that SEC needed to implement the reporting requirement to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System {FSRS) for its subawards as required by FFATA guidance. SEC did not make timely, accurate reports as required. While this did not in any way compromise federal dollars, SEC has committed to the following corrective action plan and will continue its rigorous oversight of its 13 subaward recipients. Corrective Action: SEC will review and assess all federal grant award agreements, the reporting requirements, and guidelines to follow for each. SEC has hired additional staff and delegated to them the role of reporting requirements for SEC upon completion of the assessment. Those reporting requirements include the following: • Send monthly reminders to all project managers for all new / updated contracts or sub award agreements signed to be sent out 5 days prior to the end of each month. • Compile all data received from project managers and record in tracking spreadsheets for each specific grant by the 5th of the following month. ARDOR • Send cover sheet and all contracts or sub awards signed in the previous month to SEC's Chief Financial Officer (CFO) for FFATA reporting by the 7th of every month. • Train finance staff for FFATA reporting and compliance guidelines, completed by 1/31/24. • Engage in semiannual compliance reviews with an experienced federal audit consultant. In addition to the FFATA reporting, the executive assistant will also review with the CFO all reporting requirements for all grants and contracts whether they are monthly, quarterly, semiannually, or annually. Once this review and assessment is completed, the executive assistant will develop an internal reporting calendar and execute the following: • Regular reminders based on reporting requirements to all project managers and the finance staff for all related progress and financial reporting. • Follow up with project managers and finance staff 10 days prior to the deadline to ensure all reporting has been completed. Anticipated Completion Dates: • Grant award review 1/15/24 • Development of compliance corrective action 1/20/24 • Implementation of compliance reporting 1/20/24 • Finance staff training FFATA 1/31/24 • Additional BBB finance technician training 2/05/24 Responsible individual: Robert Venables, Executive Director. SEC and their contracted CFO have discussed the corrective action plan and are working cooperatively to ensure that all deadlines are met for compliance and training. Thank you, Robert Venables Executive Director

RE: Special Tests and Provisions (Reporting) Highway Planning and Construction, CFDA # 20.205 County Department – Department of Transportation and Highways Finding 2023 – 003 The Cook County Department of Transportation and Highways (DOTH) would like to respond to the FY2023 audit. As indicated in finding 2023-003, DOTH submitted BoBS 2832 reports later than 30 calendar days following the period covered, and thus, did not comply with the reporting requirements outlined in the following grant agreement(s): • County Line Road from I-294 to North Ave (16-W7331-00-RP) - C-91-200-17 • County Line Rd from Grand Ave to Lake St (18-W7331-00-RP) - C-91-381-19 To ensure the timely submittal of BoBS 2832 reports, the following corrective action plan will be implemented by DOTH. By the close of the fiscal year on November 30, 2024, DOTH must: 1. Ensure proper training of staff and/or consultants responsible for grant reporting for projects with active grant agreements. Training will include how to gather data for the BoBS 2832 report, how to complete the BoBS 2832 report, and the cadence of reporting. A representative from the Cook County Comptroller will be invited to participate. Training materials will be distributed to participants following the session. 2. Place recurring dates on all project lead’s calendars, and on the calendars of any support staff or consultants responsible for grant reporting for the project, with a reminder when the BoBS 2832 report must be submitted. Each reminder date must be sufficiently in advance to allow for the preparation, review, and final signature in order for each BoBS 2832 report to be submitted no later than 30 calendar days following the period covered by the report. The project lead will have the ultimate responsibility of ensuring that staff assigned to the project submit BoBS 2832 reports two weeks prior to due date for proper review, sign-off, and submission to Illinois Department of Transportation (IDOT) prior to the due date. Parties responsible for overseeing the corrective action plan for the grant programs included in the 2023-003 findings: • Nathan Roseberry, Assistant Superintendent and Interim Chief Engineer of Construction • Aaron Lebowitz, Deputy Bureau Chief of Construction

CORRECTIVE ACTION PLAN: We will take the necessary steps to get clear deadlines from the awarding agency on the reporting dates for Head Start and update our formal reporting schedule with those dates. The Head Start Fund Accountant will work with the Administrative Assistant/Facilities Manager in gathering the necessary information earlier in the year for the yearly property reporting (SF-429). The Head Start Fund Accountant will email copies of these reports to the Director of Head Start to ensure compliance.

Corrective Action: As part of DRW’s internal control revision, we will enhance policies and practices associated with reporting including the semi-annual SF-425. Steps: 1. DRW will review current systems and tools in use for reporting and complying with Federal award reporting requirements and modify or implement systems or tools that are more reliably accurate than current systems and tools. 2. DRW will implement internal controls that require the preparation and review of federal reporting requirements by two distinct people at DRW. 3. DRW will implement a reporting calendar and review regularly to ensure activities including preparation and review are being performed regularly and consistently. Anticipated completion September 30, 2024.

Item 2023‐003 Performance Reporting – Annual Project and Expenditure Report Recommendation: We recommend the strengthening of controls to ensure annual reporting required under the compliance supplement is performed in a timely manner. Action Taken: Management, namely Jan Boutwell, City Clerk, agrees with the finding and will implement the necessary internal controls to ensure annual reporting is submitted timely. Management anticipates completion by September 30, 2024.

The Airport has created additional internal notifications to prevent late submittals of annual Federal Aviation Administration SF 425 and SF 271 Reporting Forms.

2023‐005 (Pages 33‐34) – During the review of the reporting compliance requirement related to major program, it was determined that FFATA reports were not filed by the Organization within the required period. Furthermore, the Organization did not file an FFR report within the required deadline for a grant it is a prime recipient. For grants on with the Organization is a subrecipient, it was determined the reimbursement requests and progress reports were not submitted within the required deadline. • Audit Recommendation – We recommend that management attend training related to federal grant requirements. We also recommend that management establish procedures to ensure that it meets FFATA requirements on a timely basis. The Organization should review its internal controls surrounding financial and progress reporting for each federal award and develop an effective reporting tracking system to allow the Organization to monitor and ensure reports are prepared and submitted within deadlines. • Management Response – We want it noted as the Prime Recipient for the aforementioned FFR report, that the system was down when the report was due, thus causing the report to be filed late. Attempts were made to reach out to get technical assistance in order to submit the report on time unfortunately it was submitted late. The staff did attend a training on FFATA procedures to ensure accurate and timely reporting as required. Finally, FFATA login has been established for collecting, and entering the required data into the FFATA portalsystem. • Contact Person: Charles Denny, Jr. – Director of Finance & Operations • Contact Person: Charysse Beard – Director of Regional Programs • Contact Phone Number: (540) 345‐1184 Ext. 128 and Ext. 134 • Proposed Completion Date: September 30, 2024

2023-005 - Internal Control Over Compliance and Compliance – Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Contact: Jordan Kramer Title: Chief Financial Officer Phone Number: 202-624-7787 Anticipated Completion Date: December 2024 Management’s Corrective Action Plan NGA has begun to produce quarterly versions of the Statement of Federal Awards (SEFA). This routine process has enabled staff to proactively identify new awards and lapsed agreements to keep the SEFA current. Given the importance of this schedule to NGA’s continued management of federal funds, we have emphasized and trained staff to follow all applicable federal requirements when managing funds on this schedule. We expect our action plan to continue until December 2024 as we have encountered several issues this fiscal year that required reconciliation of prior years.

The Finance department will document the reconciliation of the City's GL ARPA expenditures and obligations to the Department of Treasury ARPA reporting portal report both quarterly and annually. All reconciling adjustments and GL report documentation will be properly retained.

All Final Expenditure Reports will include the appropriate expenditure amounts associated with the grant year.

Finding #2023-001: Type of Finding: Questioned Cost and Other Noncompliance Responsible Person Hector P. Luevano – Controller Richard Davidson – Chief Operating Officer Implementation Date January 1, 2024 Views of responsible officials and planned corrective actions Management agrees and will more closely monitor obligated and incurred expenditures near the end of reporting periods to ensure they are completed within 120 days after the close of the grant year. Future planned expenditures are to be tracked separately and not reported as expenditures until an expense is obligated or incurred by the program. Family Service will be elevating the responsibility of monitoring the execution of projects with their scheduled expenses to the Chief Operations Officer and Controller, to avoid future gaps between obligated and/or future planned expenditures, project completion and payments.

Corrective Action Plan: The San Diego County Air Pollution Control District (District) agrees that a report for the Homeland Security Bio Watch Program was submitted more than 30 days after the reporting period ended as required by OMB. As corrective action to ensure reports related to Federal awards are submitted timely the District has added additional resources to the grants team to ensure timely report submission. Additionally, the District is currently establishing a written procedure for the grant reporting process and once finalized, will communicate to the appropriate staff of required federal reporting standards and deadlines. Anticipated Implementation Date: June 2025

Finding 2023-001 Condition: As of the March 31, 2023, reporting date, the Town understated its expenditures by approximately $1,132,000 and did not report any obligations for contracted amounts not spent. Corrective Action Planned: Update the expenditures to reflect the inclusion of prior reported expenditures for an accurate cumulative spending. Existing obligations will also be updated accordingly. A review of all obligations will be completed to ensure all necessary contracts are in place prior to 12/31/2024. Anticipated Completion Date: Expenditure and obligation reporting corrected with submission due by 4/30/2024. Contracted obligations to be in place prior to October 31, 2024. Contact: Kristine Russell, Town Accountant

The Council disputes this finding and did have a system in place to document program participant enrollment and received services participant's file records and sign-in sheets. Due to the number of various kinds of services an individual received in a month, services and activities sign-in sheets had to be used to prevent duplication of counting for program reports Regarding reports, the organization does use its email system involving multiple employees to prepare, review, approve, and submit reports which involves the Executive Director or Grants Manager submitting final reports. A new form was created to include a final sign-off by the Executive Director to indicate approval of reports. However, this was not accepted as sufficient by the auditor. Per new grant reporting regulations, at the recommendation of the auditor, staff will establish a shared Adobe document system to allow for the collection of staff signatures and approvals at all levels before each report is submitted. These signatures and approval document will be attached to submitted reports for review. Expected completion date: July 2024

The County’s management will seek out assistance from the US Department of Treasury about correcting their access to the SLFRF quarterly reports. Management anticipates the completion of this item by November 30, 2024.

Department of Transportation Airport Improvement Program, CFDA #20.106 AIP3-46-0050-60, AIP3-46-0050-62 Finding Summary: The SF-425 annual report dated September 30, 2023, for award AIP3-46-0050-54 underreported the federal share of expenditures by $80,133, while the FAA Form 5100-127 annual report dated December 31, 2022, for all awards underreported the externally restricted assets by $397,646 Responsible Individuals: Dan Letellier, Executive Director Corrective Action Plan: Management will ensure correct support documentation is provided to 3rd party account for correct submission of FAA Forms 5100-127. Director will also verify that annual report form SF-425 reconciles to underlying supporting records. Anticipated Completion Date: Ongoing

Recommendation: Internal controls over reporting should be designed, implemented, and documented to ensure compliance with 2 CFR section 200.302(b)(2), including who is responsible, what they are reviewing for, when reviews are to take place, and how documentation of the controls will be maintained. The general ledger should be set up to properly capture and track expenses as well as budgets prepared and approved with the actual costs expected to be incurred. Reports should be reconciled to the general ledger. Budgets should be complete and include all line items and not just include all expenses under supplies. Ac􀆟on Taken: This is a project Finance team is currently working on. The new Compliance Director will manage the grant writing process. During the grant and award process, Compliance, the Program with award, and Finance will establish an appropriate budget which, in turn, will be reflected in general ledger and monitored by the team. The contact persons responsible for this corrective action plan are Alan Branch, Sr VP of Compliance and Workforce Development, the new Compliance Director, Wendi Speed, CFO, and the entire Finance Team. The anticipated completion date is June 30, 2025.

The City will review the current procedures for maintaining documentation for when quarterly project and expenditures reports are completed, reviewed and submitted. Contact Person: Rosie Cavazos, CFO Proposed Implementation date: September 30, 2024

Finding: The Office of Financial Management did not have adequate internal controls over and did not comply with reporting requirements for the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Office has continued to strengthen internal controls for the Coronavirus State and Local Fiscal Recovery Fund (SLFRF) reporting to ensure compliance with the federal requirements. The Office will continue to: • Monitor updates to the U.S Treasury’s Project and Expenditure Report User Guide. • Improve the quarterly reporting template and assist state agencies during the reporting process. • Communicate with agencies to remind them of the requirement to maintain adequate supporting documentation for all reports, including quarterly reported obligations. • Ensure reported amounts, including corrections or adjustments made during the reporting period, are properly tracked and documented for the subsequent reporting cycles. • Perform reconciliations of reported expenditures to ensure agency expenditures are accurately reported, allowing for adjustments/ corrections required due to issues with the reporting system. • Ensure reported expenditures and supporting accounting records are adequately reviewed by management before the information is uploaded to the federal reporting system. • Document correspondences with the U.S. Treasury when system errors are identified and resolutions recommended by the grantor, if received. The conditions noted in this finding were previously reported in finding 2022-020. Completion Date: January 2024 Agency Contact: Sara Rupe Deputy Statewide Accounting Director PO Box 43127 Olympia, WA 98504-3127 (360) 974-9252 sara.rupe@ofm.wa.gov