Corrective Action Plans

Federal Agency Name: U.S. Department of Transportation; Pass-through Number: Federal Aviation Administration; Assistance Listing Number: 20.106; Program Name: Airport Improvement Grant; Significant Deficiency in Internal Control Over Compliance – Compliance Requirement – Reporting Finding Summary: The required SF-425 annual reports due December 31, 2022, were submitted late. Corrective Action Planned: The City concurs with the auditors’ findings. The City has corrected this reporting issue. The annual reports due December 31, 2023, were submitted on time. Responsible Individual(s): Mark Hagedorn, Finance Manager/Treasurer; Brooks Slyter, Assistant Finance Manager; Ian Turner, Airport Director; Bruce Young, Assistant Airport Director – Finance & Administration Anticipated Completion Date: December 2023

Finding: 2023-056 – One of four randomly selected (25 percent) and two of three judgmentally selected (67 percent) 5100-126 reports tested did not tie to support, resulting in an overstatement of expenditures. One of three judgmentally selected 5100-127 reports tested (33 percent) had multiple lines in error, resulting in overstatements of revenue and net assets. Questioned Costs: None Assistance Listing Number: 20.106 Assistance Listing Title: Airport Improvement Program Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): Agree Corrective Action (corrective action planned): The Finance Officer will ensure the procedures for the preparation, review, and approval of the 5100-126 and 5100-127 reports are updated to ask for support documentation for Ketchikan and Sitka airports and a complete review and approval is done before submission of the reports. The AIA Controller will develop and implement procedures to ensure proper preparation of the 5100-126 and 5100-127 reports with supervisory review and approval prior to report submission. Completion Date (list anticipated completion date): June 30, 2024 Agency Contact (name of person responsible for corrective action): Elizabeth Dunayski, Financial Services Manager

Condition: As of the June 30, 2023 reporting date, the City’s Project and Expenditure Reports understated expenditures by $629,040. Also, obligations were overstated by approximately $15,000,000. Corrective Action Planned: The City has implemented reconciliation procedures with the City Auditor and the City ARPA Director to reconcile the general ledger with the US Treasury portal prior to submission on a quarterly basis. The ARPA Director reached out to the US Treasury and communicated concerns that obligations cannot be edited on the portal and received guidance on remedies to edit obligations. Anticipated Completion Date: April 30, 2024 Contact: Bridget Almon, Director of Financial Services Kara Humm, ARPA Director Sedryk Sousa, City Auditor

Reference Number: Prior Year Finding: Federal Agency: Federal Program: Assistance Listing Number: Award Number and Year: Compliance Requirement: Type of Finding: Criteria or specific requirement: 2023-002 No U.S. Department of Treasury COVID-19 - Coronavirus State and Local Fiscal Recovery Funds 21.027 ARPl 7SL1 (5/23/2021 - 12/31/2026) Earmarking and Reporting Material Weakness in Internal Control Over Compliance, Material Noncompliance Compliance: Earmarking - Under Treasury's Final Rule that became effective on April 1, 2022, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the Final Rule to determine the amount of State and Local Fiscal Recove1y Funds (SLFRF) that can be used for the "provision of government services." To calculate revenue loss at each of these dates, recipients must follow a four-step process which includes: a. Calculate revenues collected in the most recent full fiscal year prior to the public health emergency (i.e., last full fiscal year before January 27, 2020), called the base year revenue. b. Estimate counterfactual revenue, which is equal to the following formula, where n is the number of months elapsed since the end of the base year to the calculation date: base year revenue x (1 + growth adjustment) n/ 12. The growth adjustment is the greater of either a standard growth rate- 5 .2 percent- or the recipient's average annual revenue growth in the last full three fiscal years prior to the COVID-19 public health emergency. c. Identify actual revenue, which equals revenues collected over the twelve months immediately preceding the calculation date. d. Revenue loss for the calculation date is equal to counterfactual revenue minus actual revenue (adjusted for tax changes) for the twelve-month period. Further, the Final Rule defines the term general revenue to include revenues collected by a recipient and generated from its underlying economy and would capture a range of different types of tax revenues, as well as other types of revenue that are available to supp01t government services. In calculating revenue, recipients should sum across all revenue streams covered as general revenue. Reporting - Per 2 CFR 200.328 and 31 CFR section 35.4(c), States, territories, metropolitan cities, counties, and Tribal governments were required to submit one interim rep01t and quarterly Project and Expenditure repo1ts thereafter. A Key Line Item containing critical info1mation, as defined by Treasury, in these reports is the Revenue Replacement section. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Prince George's County (the County) did not calculate their revenue loss in accordance with the Final Rule. As a result, amounts reported under the Revenue Replacement section of the Project and Expenditure reports were inaccurate for all quarters within the fiscal year ended June 30, 2023. Context: The County used inconect base year revenues in their revenue loss calculation. Only general fund revenue was used in the calculation instead of summing across all revenue streams as defined by the Final Rule. Fmther, the County used an incorrect growth rate of 4.0% instead of 5.2% as required by the Final Rule. The Revenue Replacement section of the Project and Expenditure rep01ts were inaccurate due to these errors. Cause: The County's policies and procedures were not sufficient to ensure that their revenue loss calculation was in accordance with the Final Rule and that accurate information was reported in their Project and Expenditure reports under the Revenue Replacement section. Effect: The County was not in compliance with federal requirements, and failure to comply with those requirements could jeopardize future funding. Questioned costs: Undetermined. Recommendation: We recommend that the County revise the revenue loss calculation to be in accordance with the U.S. Treasury's guidance as outlined by the Final Rule and submit a revised Project and Expenditure report to the U.S. Treasury 's SLFRF p011al. Action taken in response to finding: The Office of Management and Budget (0MB) revised the revenue loss calculation. A revised Project and Expenditure report will be submitted by 0MB through the U.S. Treasury's SLFRF portal in April 2024. Name(s) of the contact person(s) responsible for corrective action: David Juppe Revenue and Legislation Manager. Planned completion date for corrective action plan: April 30, 2024. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Views of responsible officials: At the time that the Office of Management and Budget (0MB) calculated the revenue loss it was unclear whether it applied to only general funds or all funds. Guidance from the U.S. Treasury Department was updated frequently following enactment of the American Rescue Plan Act of 2021. Based on the finding of the audit that the revenue loss calculation is not in accord with the Final Rule, 0MB staff re-calculated the data using all funds . Any questions concerning the findings or corrective action plan can be directed to Stanley A. Earley, Director, 0MB at 301 -952-3300.

The migration to a new general ledger financial reporting system is an isolated incident and given the improved reporting capabilities the change in product provided a positive impact. UWGC experienced turnover for the program manager position that created a learning curve that was addressed but resulted in audit completion delay. UWGC has an experienced manager currently overseeing the program who will follow policies and procedures as prescribed and on a timely basis to allow for prompt reporting submission.

UWGC experienced a staffing turnover during the 2024 fiscal year of the manager responsible for the reporting on the SEFA. The manager tracked financial reports on a cash basis causing a timing difference with not recognizing accounts payable. The finance team accounted for expenses in the appropriate period, therefore the Finance team will crosscheck reports for timing difference prior to submission to governing agency.

2023-003 – Reporting – Significant Deficiency in Internal Controls over Compliance Federal Agency Name: Department of Education Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion Finding Summary: A sample of 4 special reports from the population of 4 special reports was selected. For the three quarterly reports selected, the College could not provide support that the reports were published timely. In addition, the College could not provide consistent institutional records for the data included in the three quarterly reports or annual reports. Three of the four quarterly reports were corrected based on the audit procedures performed, the College did not properly identify these as “corrected” upon posting to the College website. Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer 105 Courtney Judah, Executive Director of Institutional Effectiveness Corrective Action Plan: The college will continue to apply a detailed reporting process for timely collection and reporting of grants. Reporting to include the following:  Accurate and regular collection of data needed to report outcomes and service populations.  Cross verify data with Institutional Effectiveness and Institutional Research.  Post in accordance with grant requirements including documentation to record posting and submission dates. Anticipated Completion Date: Completed April 30, 2024

The YWCA will ensure that all federal award reports are filed in a timely manner. The YWCA is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.

Finding 2023-001 The City concurs with the finding and will strengthen the policies and procedures in relation to grant reporting from award of grant to final report. It will be the policy of the City to assign an employee within the department receiving the grant to track, monitor, and file all required reports in a timely manner. This employee will also be required to forward copies of any grant awards, requirements, communications, and reports to the Finance Department in a timely manner. This will be implemented in April of 2024.

Finding 2023-002 – SF-425 Financial Reporting Condition: The City's internal controls over required reporting requirements were not accurately monitored and reviewed to prevent, or detect and correct the current year's actual federal spending. In conjunction with our fiscal year 2023 audit, please see the City’s corrective action plan below: To address the audit finding, the City agrees with the recommendation. Although inaccuracy is mostly due to changes in personnel, management will make a greater effort to submit complete and accurate reports. The City agrees with the recommendation. Although inaccuracies are mostly due to change in personnel, management will make a greater effort to submit complete and accurate reports. Expected completion date: 9/30/2024. Party Responsible: Larry Mitchell, City Manager Contact Information: citymanager@cityofholdenville.net

Centro Margarita, Inc. acknowledges the finding identified during the single audit regarding reporting requirements. Therefore, CMI will identify additional personnel including finance and accounting staff members and program coordinator that should be involved in financial reporting processes. Also, Centro Margarita, Inc. will conduct a comprehensive assessment of the technical training needs of the identified personnel. Evaluate their current knowledge and skill levels related to reporting requirements, accounting principles, and compliance regulations. Finally, Centro Margarita, Inc. will determine the most effective delivery method for the training program, taking into account the learning preferences and availability of personnel. Options may include: • In-person workshops or seminars led by subject matter experts. • Online courses or virtual training sessions accessible remotely. • Self-paced learning modules supplemented with instructional materials and resources. Implementing this corrective action plan focused on technical training for personnel responsible for reporting requirements, Centro Margarita, Inc. can enhance reporting accuracy, compliance, and overall effectiveness.

Centro Margarita, Inc. acknowledges the finding identified during the single audit regarding reporting requirements stemming from a lack of personnel. However, Centro Margarita, Inc. has already contracted capable personnel in order to assist in the finance department to comply with financial reports.

Finding No. 2023-006: Reporting (Material Weakness - Internal Control Over Compliance) Federal Award: 21.023 - COVID‐19 – Emergency Rental Assistance Program (ERA) Audit Recommendation: We recommend the City be more diligent in following its policies and procedures for submitting quarterly information to the Department of Treasury. We also recommend the City implement retention procedures to track the reports and supporting information submitted to the Department of Treasury. Administration’s Comments: The City will follow policies and procedures for submitting quarterly information to the Department of Treasury and also implement retention procedures to track the reports and supporting information submitted to the Department of Treasury. Office of Economic Revitalization (OER) will provide Fiscal with a copy of the reports. Anticipated Completion Date: May 1, 2024 Contact Person(s): Denise Obrero, Mayor’s Office, Planner VII Rowena Santamaria, Department of Budget and Fiscal Services, Fiscal Officer II

Dear Mr. Waguespack, The Louisiana Department of Health (LDH) acknowledges receipt of correspondence from the Louisiana Legislative Auditor dated January 4, 2024, regarding a reportable audit finding related to controls over reporting and other Federal compliance requirements for the Medicaid and CHIP programs at the LDH. The LDH appreciates the opportunity to provide this response to your office's findings. Finding: Inadequate Controls over Reporting and Other Federal Compliance Requirements for the Medicaid and Children's Health Insurance Programs Recommendation: LDH management should strengthen controls over preparation and review of the quarterly federal expenditure reports to ensure Federal expenditures are accurately reported and should ensure all quarterly checklist reviews are completed. LDH Response: LDH partially concurs with the finding and recommendation. LDH disagrees that the quarterly checklist is intended to demonstrate compliance with the federal reporting requirements. The quarterly checklist is used to document and track the receipt of source documents from other departments so the fiscal staff can develop work papers for the federal expenditure reports. The checklists do not track the accuracy of the work papers. Additionally, the quarterly reconciliations purpose is to reconcile expenditures in the state's accounting system (LaGov) to the Medicaid and Children's Health Insurance Program Budget and Expenditure System (MBES/CBES). During this audit period, LDH was in the process of reviewing the reconciliation procedures to transition from previous methods of reconciliation utilizing the old accounting system (ISIS) to LaGov. Although the duplication was identified through this Single State audit, LDH maintains it would have identified the duplicative entries during the annual grant award reconciliation process which would have been within the federal reporting timelines Corrective Action Plan: LDH will continue to build on the improvements already implemented to prevent Medicaid expenditure misstatements from recurring. As discussed with the Single State auditors, measures to increase operational accuracy were being worked on during the audit or are in the process of being developed. LDH management has already taken steps to implement a corrective action plan to strengthen the internal controls that will enhance the State Agency's preparation and review of the quarterly federal expenditure reports which includes a more thorough review of procedures to collect and review data from program offices and incorporate more cross training amongst the fiscal staff responsible for federal reporting. The anticipated completion date of this corrective action plan is April 30, 2024. You may contact Helen Harris, LDH Fiscal Director, by telephone at 225-342-9568 or by e-mail at helen.harris@la.gov with any questions about this matter.

FINDING 2023-005 Finding Subject: COVID‐19 Education Stabilization Fund ‐ Reporting Summary of Finding: Reports were not supported by underlying accounting records. Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: (812)254-5536 calford@wcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Washington Community Schools like all other school corps across the state, got the requests for these reports with very little to no instruction of how to complete them. We weren’t told they would be part of the audit and therefore didn’t retain reports used to complete some of the reports. Going forward we will ensure reports proving numbers reported are available to SBOA. Anticipated Completion Date: 06/30/2024

The university endeavors to follow all applicable reporting regulations and guidance mandated for federally funded grant and contract programs. The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of September 30th, 2022 for the Institutional Portion. Should similar programs become available in the future, management will develop, in advance of expending funds, documented policies and procedures to administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure. Specifically for the HEERF program that has ended, the university will amend relevant Quarterly report(s) and submit an Annual Report for 2022, as required and in consultation with the Department of Education on reporting timelines and processes for amended reports. Reviews will be completed and documentation retained as described below. For future programs, the Office of Sponsored Projects will monitor available published information from the funding agency(ies) to ensure the university offices responsible for any element of the reporting process are aware of applicable deadlines and requirements. The Office of Sponsored Projects and the Office of Financial Aid will prepare required reports for institutional and student grant-related activity, respectively. These reports will be reviewed by the Office of Financial Aid (for any student portion) and the Office of Institutional Research and the Business Office (for all portions, including any institutional funds). These offices will collaborate to implement a review procedure to ensure the reports are accurate, complete, submitted timely, and if required, posted publicly to the university’s website. Additionally, files will be maintained in a shared location so that documentation is available in the event of turnover, so that support availability (including detail support) withstands any changes in the employment of the employees responsible for preparing, reviewing, and/or posting the reports. Persons Responsible: Assistant VP for the Office of Sponsored Projects; Director of Financial Aid; Controller and Associate Vice President. Targeted Correction Date: September 30th, 2024. Fiscal Year in which Finding Initially Occurred: 2021 (Finding Number 2021-003).

Planned Corrective Action : The County has restructured the duties of the Finance office to ensure the staff with the most appropriate knowledge base is performing the duties that are new or unusual while providing the training necessary to ensure that the source work is done in a way that supports the appropriate reporting outcomes. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Sandy Novak, Finance Director

Reporting requirements are flagged in the University’s financial systems and manually tracked for completion where sponsor systems do not provide systematic alerts of pending and delinquent reports. The Early Head Start program reporting requirements are tracked via the U.S. Department of Health and Human Services Payment Management System (PMS). The Grants Management Specialist (GMS) for the applicable awards has informed the University that technical issues within PMS are preventing reports from automatically being made available for preparation and subsequent certification. The GMS requested the University institute a procedure to request report access when identified as unavailable. The appropriate staff in Sponsored Projects Accounting have been informed of the PMS technical issue resulting in reports not being released for preparation and instructed to contact the GMS immediately to release the reports, if they are not readily available. Anticipated completion date: March 2024 Names of contact person(s) responsible for corrective action: Dave Laffey, Director of Sponsored Projects Accounting

Finding 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and one ESSER III report, for a total of five reports. A single employee prepared and submitted each annual data report without a review or oversight process in place to prevent, or detect and correct, errors. All five reports were selected for testing, two of which were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Another individual will start to review the information entered into the required ESSER reports prior to submission and supporting documentation will be retained. Anticipated Completion Date: April 1, 2024

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: During the audit period the School Corporation submitted three final expenditure reports. The final expenditure reports were completed and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the final expenditure report for the Title I School Improvement for program year 2021, due December 30, 2021, was submitted March 7, 2024. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 39 Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Another individual will start reviewing the final expenditure reports prior to submission to IDOE. Anticipated Completion Date: April 1, 2024

We agree that in previous years, there were deficiencies in compliance with reporting requirements related to the receipt and disbursement of federal funds. There has been turnover in Business Office staff, but now that staffing has stabilized, the following procedures will be implemented regarding the management of federal funds:  The Senior Accountant will be responsible for the receipt and disbursement of federal funds, and for monitoring reporting requirements  The Associate Vice President for Finance and Controller will oversee the process and ensure that spending guidelines are followed and that all deadlines for reporting are met

FINDING 2023-002 Finding Subject: COVID 19 – Education Stabilization Fund - Reporting Summary of Finding: Material Weakness, Other Matters. Contact Person Responsible for Corrective Action: Steve Nauman, Treasurer Contact Phone Number and Email Address: Phone: 812-522-3340 Email: naumans@scsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The SCSC management team will design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place prior to filing required reports. Anticipated Completion Date: The projected date of completion is February 29, 2024.

FINDING 2023-008 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by one employee without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the six reports submitted during the audit period contained errors. The errors were as follows:  The ESSER I, Year 2 and ESSER II, Year 1 reports did not contain expenditures for the reporting period, however according to the School Corporation's records there were expenditures for ESSER I and ESSER II during this period.  The ESSER I, Year 3, ESSER II, Year 2, ESSER III, Year 1, and ESSER III, Year 2 reports were not supported by the School Corporation's records, was not accurate and complete, and was not mathematically accurate. Recommendation: We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Fund program funds. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 / garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: During the audit period, internal control opportunities were in place but not followed. Lewis Cass Schools has an internal control process that is in place but was not followed by the treasurer who in the position during the audit period. The treasurer who did not follow the internal control process is no longer employed by Lewis Cass Schools. To address and ensure Education Stabilization Funds are properly reported by the treasurer the treasurer will print out the form that was completed by the treasurer and must be signed by the superintendent or department head for review before submittal and filed for record keeping. Anticipated Completion Date: 3/11/2024

Description of Corrective Action Plan: The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying detail. The Director of Grants will make sure this is done in a timely manner to comply with the reporting deadlines for each fiscal year. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Superintendent, Dr. Angela Piazza and the Director of Grants, Eric Knebel. The corrective action will be implemented starting immediately.

For the first three quarters of the fiscal year, the reports were timely completed and published online, per the grant requirements with a direct link to the documents. The fourth quarter has now been completed and published there, as well. There was a change in the Business Office, where the person responsible for management of this series of awards resigned from the College. We are actively searching to fill the position, Director of Finance, whose responsibilities will include grant management, overall. Though the awards are fully spent and ended at, June 30, 2023, still responsibilities to the grant for record-keeping and final annual reporting, exist. We acknowledge this and have incorporated these items into the calendar of reporting events for these awards.