Corrective Action Plans

Although there was been improvement in the grant reporting from the prior year, specifically in the area of expenditures, there were delinquent reports. The improvement was a result of the following internal control factors: a. Personnel responsible for the grant reporting has been reassigned. b. Personnel responsible for grant reporting was directed to report to the district office to complete the reports. c. More frequent communication updates and action planning regarding the status of the grants and their respective reports. The District will continue to utilize the internal controls listed above to ensure that all eligible grant expenditures are appropriately submitted for reimbursement in a timely manner. Anticipated Completion of Corrective Actions: 12/19/2023 Contact: Dr. Lynette Thrasher, MCUSD#1 Grants Coordinator 400 N. Pine St. Momence, Il. 60954 815-472-3501

Contact: Reginald Gregory Title: Executive Director/Controller Phone Number: 202-772-4300 Estimated completion date: June 30, 2024 Corrective Action: Management will continue to stress the importance of following the detailed procedures for preparation and review of the SEFA. Responsibility for compiling the SEFA was assigned to a Senior Program Accounting Manager who is tasked with assuring the SEFA and all support reconciliation are complete and accurate. Both the Director of Program Accounting and the Executive Director of Finance/Controller will review the SEFA for completeness, accuracy, and compliance with CFR Section §200.510(b).

Type of Finding – Significant Deficiency in Internal Control Over Compliance Condition/Context – Internal Control procedures over reporting requirements did not ensure compliance with federal awards. The reports prepared by the Director of Grant Compliance and Procurement are not reviewed and approved before being submitted. Corrective Action Plan – Management has reviewed and revised procedures to review and approve all reports prepared in connection with federal awards prior to being submitted. Anticipated Completion Date and Person Responsible – As of December 1, 2023, all reports will be reviewed and approved prior to submission and all reports submitted prior to November 30, 2023, have been reviewed to detect if there were any material errors or adjustments needed.

Finding #2023-003 - Major Federal Award Finding - Reporting Significant Deficiency-in Internal Controls over Compliance Corrective Action Plan: Procedure(s) were drafted covering data collection, storage, and reporting of HEERF data, including setting alerts to comply with the reporting due dates, however, the VP of Finance did not adhere to them. The VP of Finance will meet with the Executive Vice President to set up an accountability structure to ensure that quarterly reports are reviewed and filed on or before the due date. A revised annual report for calendar 2022 will be submitted to the Department of Education.

The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of each of the 48 pages) makes review before submission extremely difficult. There were literally hundreds of entries in this report, and there were three errors, each of which reflected information that was reported accurately in the quarterly reports posted on the University’s website. Despite the unfortunate design constraints, the University will endeavor to identify a practical way to conduct a review of the annual report before submission next spring. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin

Finding 2023-003 Reporting – Material Weakness in Internal Control Over Compliance Federal/State Agency Name: Department of Justice and State of South Dakota Department of Public Safety Program Name: Crime Victim Assistance FFAL # 16.575, 2022-COMBO-00022 Finding Summary: The Victims’ Service final financial report was not completed until requested by the auditors. Responsible Persons: Shannon Clark, Chief Financial Officer Lynn Peterson, Controller Michelle Tarrell, Finance Administrator Corrective Action Plan: A Finance Administrator has been designated for each Federal Financial Assistance Program. The Controller and Finance Administrator(s) will monitor and ensure reporting requirements are timely completed. Anticipated Completion Date: June 30, 2024

The Municipality established internal control to maintain schedule of the due date reports in order to avoid this situation.

Planned Corrective Action(s): SIG-NAL will enhance internal controls by implementing formal review and approval processes for payroll, expenses, and financial reporting. The organization will require documented evidence (digital or written) of all reviews and approvals and will maintain these records in a standardized, centralized system. The Finance Team will ensure that all controls are performed and documented in accordance with 2 CFR Part 200 requirements. Updated internal control policies and procedures adopted in 2025 address these requirements and are being fully implemented. Anticipated Completion Date ● March 2026 Responsible Party ● Director of Operations, with support from the Finance Team and Executive Director

Management has contracted with a contract accountant who has already started audit preparation services for future audits. The 2022 has been started and will be completed shortly. The 2023 audit will be started shortly. The Native Village expects to be fully caught up by their fiscal year 2025 audit.

Management will ensure that all required grant reporting, both financial and/or narrative/programmatic will be prepared and submitted timely. The final reporting for the Treasury CARES ACT has been completed and submitted subsequent to year end.

All FFR and PPR reporting requirements for all federal grants and agreements are tracked in a master spreadsheet, with reminders to all program and project managers at least 2 weeks in advance of reporting due dates.

Individual(s) Responsible: Chelsea BadHawk, Chief Financial Officer Action: Management will prepare and implement an internal control system that provides effective oversight of operations, reporting, and compliance. The systems and controls will be designed based on standards set forth in the Government Accountability Office Green Book. Anticipated Completion Date: 12/31/2025.

FINDING 2022-003 Information on federal program: Subject: Water and Waste Disposal Systems for Rural Communities - Reporting Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.760 Federal Award Number: 92-02 92-03 Pass-Through Entity: N/A Compliance Requirements: Reporting Audit Findings: Significant Deficiency Condition: The City did not have proper controls in place to ensure that the annual report was accurately filled out and agreed to underlying detail. Context: Variances to key line items were noted when comparing the Form RD442-2 and Form RD442-3 to supporting documents. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will ensure that reports agree to underlying detail. Responsible Party and Timeline for Completion: The Clerk-Treasurer is the responsible party. The completion will go into effect during 2025.

The Morgan County Economic Development Office acknowledges status reports submitted by the required due date for the CDBG program.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Jessica Martinez, Deputy Director Corrective Action Plan: In response to the FY21 Corrective Action Plan, CFSC implemented an updated Reporting Policy in June 2024 to ensure compliance with timely and accurate reporting to funders. This policy includes defined responsibilities for grant reporting and procedures for tracking report deadlines. To further strengthen compliance and eliminate late submissions, CFSC will implement the following corrective actions: 1.Report Deadline Tracking: CFSC will enhance its report tracking to flag upcoming report due dates and set reminder alerts for responsible staff. 2.Late Submission Justification: Any delays in submission (whether approved by funder or not) must be documented in the grant file. 3.Quarterly Compliance Audits on Reporting: CFSC will conduct quarterly internal audits to review: a.Timeliness of report submissions (ensuring they met funder deadlines) b.Accuracy & completeness of reports filed in the Master Grant File. c.Corrective actions for any delayed or missing reports. Anticipated Completion Date: These corrective actions will be fully implemented by the end of Quarter 2 of FY25.

2021-108 Lack of Documentation Related to Reporting Condition: The Organization did not maintain proper documentation in support of reporting requirements. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. Source documentation for grant reporting is retained and maintained in grant folders on the shared drive for future reference. The corrective action for this finding has been approved and implemented by the Organization. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer Anticipated Completion Date: Implemented

Management acknowledges the need to address and enhance this finding. We are committed to implementing new procedures for recording and tracking program income, including documenting its source, amount, and application. These procedures will be put in place within three months, with oversight provided by senior management to ensure proper compliance and effective implementation.

Management will be more vigilant and will review future filings before they are published.

The Department has ramped up recruiting efforts by advertising positions on external websites such as indeed. The accounting department has recently increased the wages of existing staff and the starting wages of all positions in an effort to attract and retain qualified staff.

We agree with the finding that CAC could not provide evidence in some instances that required demographic information, monthly, quarterly, or cumulative annual reports were submitted or submitted in a timely manner. In order to ensure that CAC maintains evidence of timely submission of all required reports in adherence to the requirements of 2 CFR 200.328, the following corrective action plan will be implemented. Beginning in the FY2025 fiscal year, CAC will add a senior level staff position designated as Director of Compliance. The Director of Compliance will review and update current policies and procedures regarding Compliance Reporting and Eligibility. The Director of Compliance will work with the CPO and CFO to develop and ensure reporting guidelines are established and applied. The Director of Compliance will maintain listings of all reporting requirements and work with the CPO and Program Directors to ensure timely reporting for grant award agreements, in accordance with the terms of each agreement. The projected date for full implementation of the corrective action plan for this finding is June 30, 2025. The contact persons for this corrective action are: Barbara Kelly, Executive Director, Windie Wilson CAC Human Resources Director, Misty Goodwin, CAC Chief Program Officer, CAC Director of Compliance, to be selected.

Finding No. 2022-007 We agree and acknowledge the audit findings related to the reporting discrepancies identified in Finding No. 2022-007, associated with our Federal Awards: H8031624, H8F41048, and H8D36529 under the U.S. Department of Health and Human Services (AL Program 93.224). To address this issue and ensure that future SF-425 reports are accurately aligned with the underlying accounting records, KCHC has implemented the following corrective actions: 1. Enhanced Reporting Procedures: A rigorous review process has been put in place to reconcile the SF-425 reports with the underlying accounting records before submission. The finance team will reconcile program expenditures and income monthly, ensuring that all figures match the accounting system's data. 2. Monthly Reconciliations: To maintain accurate and up-to-date records, we have implemented a monthly reconciliation schedule for all federal grants. This practice allows us to monitor the program's financial data consistently, reducing the possibility of variances between the reported and actual figures. 3. Training and Education: Our finance personnel have undergone additional training on SF-425 reporting requirements and reconciliation processes. This ensures that they are fully aware of federal guidelines and capable of handling reporting tasks accurately. 4. Improved Internal Controls: To further ensure compliance, we have enhanced our internal controls by requiring dual approval of all SF-425 reports. Both the preparer and the Chief Financial Officer (CFO) will review the reports to verify that the data aligns with the accounting records before final submission. We have also incorporated periodic internal audits to detect potential errors early. 5. Use of Integrated Software Systems: To improve accuracy and tracking, KCHC has integrated its accounting and procurement systems (ProcurementExpress) to facilitate real-time data entry and reconciliations for grants. These systems enhance the workflow and reduce the risk of manual errors. Implementation Timeline: Implemented in August 01, 2024 and by the end of Fiscal Year in April 30, 2025, KCHC will be in full compliance with the SF425 reporting requirements. Responsible person: Arlene Deleon Guerrero, CFO

Finding Number: 2022-005 Planned Corrective Action: AMHA and our accounting firm are working diligently to meet deadlines. Completed bank recs and financial documents are finished more timely. Anticipated Completion Date: January 1, 2023 Responsible Contact Person: Sherrie Boudinot

The County Clerk is in the process of perparing the needed documentation to document their internal control structure in conformity with the Uniform Guidance. The County will work diligently to comply with and to fully understand the proper procedures of completing the SEFA. As the state does not provide SEFA training, advice may be sought from Certified Public Accountants with SEFA knowledge and local governments.

FINDING 2022-005Contact Person Responsible for Corrective Action: Lynn Leininger, Business ManagerContact Phone Number: (260) 367-3677Whitko Community Schools concurs with the finding and will implement internal controls for all grantrequirements and reporting compliances of the Education Stabilization Funds. All reporting will be a jointeffort between the Business Manager preparing the reports with the assistance of the business officepersonnel. Supporting paperwork and calculations will be maintained to support all report informationsubmitted. Prior to submission of Education Stabilization Funds, all information will be reviewed andsigned by the Deputy Treasurer to insure reporting compliance.The completion date for this corrective action will be May1, 2023.INDIANA STATE

FINDING 2022-005Contact Person Responsible for Corrective Action: William LutherContact Phone Number: (812) 330-7700Views of Responsible Official: We concur with this finding. This finding has been remediated as of the completion dateshown below.Description of Corrective Action Plan:All Education Stabilization Funds applicable to the reporting in this finding have been expended as of the completion datebelow. We will continue to submit all future Education Stabilization Funds annual reports with evidence to support thesubmission.Completion Date: September 30, 2022