Corrective Action Plans

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

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