Corrective Action Plans

Finding Reference Number: 2023-001   Description of Finding:As required by 2 CFR 200.328, the auditee failed to submit the required Federal Financial Report (“SF425”) for two of their awards by the required due date of January 31, 2024.  Corrective Action: The Organization concurs with this finding and recognizes that the required SF425 reports for two awards were not submitted by the due date of January 31, 2024.   SEMI constantly communicates with the program managers for these awards and meets weekly to discuss project progress. The Organization has commonly received extensions for these reporting deadlines; however, this has not been documented in writing.   SEMI will evaluate process improvements to provide accounting information to the SEMI R&D team two weeks after the reporting period end date. This will help ensure sufficient time for the reports to be prepared and submitted 30 days after the reporting end date. If additional time is needed, SEMI will obtain prior written approval for report submission extension.   Name of Responsible Person: Kevin Bauer (Chief Financial and Business Operations Officer)  Melissa Grupen-Shemansk (Vice President, Technology Communities)  Anticipated Completion Date: The Organization anticipates completing the corrective action by Q4 2024.

FINDING 2023-001 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The Kosciusko County Sheriff's Office applied for the Indiana Local Body Camera Grant (ILBC). The sheriff’s office was awarded this grant on January 1, 2023, with a grant cost amount of up to $31,920. This grant is a reimbursable grant through the Indiana Department of Homeland Security. The period of performance was from January 1, 2023, to December 31, 2023. The Kosciusko County Sheriff's Office ordered body-worn cameras and equipment on April 26, 2023. The invoice for the cameras and the camera equipment was paid on July 14, 2023. The Kosciusko County Sheriff's Office then submitted a Reimbursement Claim Form on September 11, 2023. The Reimbursement Claim Form shows the Sheriff's Office incorrectly requested the full $31,920. They received $31,920 from the Indiana Department of Homeland Security on September 27, 2023. However, the county had only spent $9,581 of the grant money towards the body camera purchase. Therefore, there is a remaining balance in the fund of $22,339 as of December 31, 2023. Due to the period of performance, the county should have reimbursed the Indiana Department of Homeland Security $22,339. On May 9, 2023, the Sheriff's Office grant administrator submitted a Program Report for the ILBC grant. This report was filed without an implemented internal control or evidence of a review. The report was completed and submitted by the Sheriff's Office grant administrator. The report incorrectly indicated that all expenditures had been completed. As of the date of the submission, the county had not purchased the bodyworn cameras and all federal funds had not been expended. Contact Person Responsible for Corrective Action: Alyssa Schmucker Contact Phone Number and Email Address: 574-372-2325 aschmucker@kosciusko.in.gov View of Responsible Officials: We concur with the findings identified. Description of Corrective Action Plan: The Kosciusko Sheriff’s Office, grant coordinator will contact IDHS for instruction on how to return the $22,339.00 and prepare a claim to be processed by the Kosciusko County Auditor’s office. The grant balances are submitted each month by departments these are checked and confirmed by the Auditor’s Office this one was overlooked in the review process. The person who applied for the grant no longer works for the county. It is believed the new person handling the grants was not aware that this grant even existed. The Grant Administrator(s) will have someone sign off on the grant report submissions and forward all reports to the Auditor’s Office. Anticipated Completion Date: It is anticipated that this will be completed as soon as the information to return the funds is received from the state and the claim is submitted to the Auditor for payment. This claim will be paid as soon as it is received. On or before 12/31/2024.

Report has been submitted, will issue a list of reporting deadlines to staff.

The City will implement additional control procedures to ensure all reports are filed in a timely manner.

The City will implement additional control procedures to ensure all reports are filed in a timely manner.

Criteria: In accordance with 2 CFR 200.328 and 31 CFR section 35.4(c) Reporting and requests for other information, grantees are required to file quarterly Project and Expenditure Reports listing significant projects, significant payments to subrecipients, subawards, and expenditure awards greater than $50,000. Condition: The Tribe incorrectly listed some project vendors as a subrecipients on the Project and Expenditure reports. Cause: Treasury guidance for reporting subrecipients versus contractors was in transition during the reporting periods for the year. Effect: The Tribe reported subrecipients on the Project and Expenditures Reports, but did not have any subrecipients of Coronavirus State and Local Fiscal Recovery Funds (SLFRF). Recommendation: Update reporting to ensure payments are reported as project vendors rather than subrecipients. Management's Response: Management recognizes that the error exists and has not been able to correct the report due to US Treasury’s portal not accepting prior period revisions. Treasury has changed its guidance on SLFRF multiple times over the past several years which has created an increased risk in filing errors for all reporting for these funds. Person Responsible: Robert Schulte, CFO Anticipated Completion Date: Ongoing evaluation

Material Weakness in Internal Controls over Compliance Condition: As of the March 31, 2023 reporting date, the Town’s Project and Expenditure report had reported cumulative expenditures that were approximately $134,000 more than what was recorded in the grant fund on the general ledger. In addition, obligations were overstated by approximately $85,000. Corrective Action Planned: ARPA funds were tracked on a spreadsheet by the DPW Director. Reporting was done using the spreadsheet. Later, it was found the expenses didn’t match up to GL. We will use the GL for reporting purposes in the future. Anticipated Completion Date: Next submitted reporting Contact: Katie Medina, Town Accountant

Management agrees with the three findings and recommendations for corrective action to ensure that these instances do not occur again. 1. During the year ended December 31, 2023, the final project report was not submitted timely, as directed in the Notice of Award, as the “Not Completed Task” list in the HRSA Electronic Handbook portal indicates the Final Report is due October 29, 2025, which is 90 days after the grant’s budget period. The true due date was October 26, 2023, which was 90 days after Project Completion, which was when the New York State Department of Health approved the renovated space for occupancy following a site visit on July 28, 2023. The final project report due October 26, 2023 was submitted on August 13, 2024. 2. The December semi-annual report due December 14, 2023 was submitted one week late, on December 21, 2023. 3. The FFR submitted on October 24, 2023 was submitted with inaccurate data. The FFR due October 29, 2024 was submitted on August 6, 2024 and included the $749,892 that was omitted from the prior FFR to ensure that all funds were accounted for in the FFR reported to HRSA via the Payment Management System. Flushing will also implement the following controls and procedures to prevent any future untimely report submissions or submissions with inaccurate or omitted financial data: 4. The grants contract manager, along with the director of planning, will review all programmatic grant reporting requirements in all Notice of Awards, amendments and agency portals to ensure completeness of reports due and their respective deadlines. All programmatic reports going forward will be reviewed by the grants contract manager along with the director of planning and will be submitted on a timely basis going forward. The grants contract manager in conjunction with the director of planning will monitor the HRSA website on a monthly basis to ensure no deadlines are missed regarding the required reports for the grant in question. 2. Going forward, the expenses related to cost-reimbursement grants will be accrued/accounted for on an accrual basis prior to the submission of the FFR, even though we may not be able to drawdown the funds at that time. These controls and procedures will be implemented by the end of the 3rd quarter of 2024. Management responsible for corrective action plan: James Farrell, Assistant Director, Development (jfarrel1@jhmc.org) Viola Lingat, Senior Accountant (vlingat@jhmc.org) Ira Freiman, Grants Accountant (ifreiman@jhmc.org) Manzar Sassani, Vice President of Finance (msassani@jhmc.org)

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.