Corrective Action Plans

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

2023-004 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. The auditors recommend each report be posted to the University’s website on separate documents by quarter and should not be cumulative. The auditors also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, the auditors recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature and date. Planned corrective actions: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY21, FY22 & FY23 on the University’s website by quarter. Going further it will be the Grant accountant’s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures. Name of Responsible Party: 1. Yolanda Maltos, Grant Accountant 2. Alysia Stevens, Controller 3. VP of Administration/CFO 4. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

Finding: Reporting The Organization is required to prepare and submit annual SF-425 Federal Financial Reports. During the fiscal year, one SF-425 annual report was required to be filed for the September 30, 2021 to September 29, 2022 grant period. We noted that the Cash Receipts and Disbursements on lines 10a and b, and the Federal share of expenditures on line 10e and unobligated balance of Federal funds on line 10h were incorrectly reported and not in agreement with the actual amounts reported in the Organization’s underlying accounting records. We did test Federal draw requests as part of our Uniform Guidance testing and noted that expenditures reported on the Schedule of Expenditures of Federal Awards and cash received and disbursed for this federal award were correct and supported by underlying documentation. No discrepancies in expenditures or cash activity were identified in the Organization’s accounting system but, rather, just the reporting of the figures in SF-425 was incorrect. Views of Responsible Officials and Planned Corrective Actions: Management is in agreement with this finding. We worked with our grants management specialist to correct the error on the SF-425. We have implemented a process for preparing and reviewing the SF-425 to ensure that the cash and expenditures activity for the grant period being reported on agrees with our underlying account systems balances and activity. Responsible Official: Casey Pauly Completion Date: 12/12/2023

Finding Number: 2023-001 Planned Corrective Action: The Dayton Early College Academy will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 07/01/2023 Responsible Contact Person: Steven Hinshaw, Treasurer

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.

Name: Community Services Office of Hot Springs and Garland County Arkansas Contact: Leslie P. Barnes Contact Phone Number: (501) 538-5626 Audit Period Ending: 05/31/2022 Anticipated Completion Date: May 5, 2025 Finding 2022-004: Management concurs with the finding. The Organization has implemented a process where a staff accountant will prepare the necessary reports and the chief financial officer will review such reports. Alternatively, if the chief financial officer must prepare such reports, the review will be performed by the executive director.

Condition and Context: ITCN did not file Form ACF-696T reports, required by the Child Care and Development Block Grant within the required timeframe. ITCN also did not file Form SF-429(A), required by the Head Start program within the required timeframe. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2022, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Recommendation: The auditors recommended that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Contact Name: Deserea Quintana, Executive Director Corrective Action Planned: ITCN has created a federal reporting compliance calendar with automated reminders. Fiscal contractors continue to support timely submission of required reports. MIP/Microix will allow automated report generation and tracking. The training plan includes modules on reporting compliance and deadline monitoring. Anticipated Completion Date: The calendar was implemented in March 2024, with full automation and staff training to be completed by March 2026.

Recommendation: We recommend the College review the reporting requirements and implement procedures to ensure that all required reports are issued/posted in an accurate and timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Collaborative workflow was developed between Grant PI's and IS department personnel to ensure that all reports are posted to the website in a timely manner. Name of the contact person responsible for corrective action: Clarissa Salhus, Finance Manager, Duane VanderGriend, CFO Planned completion date for corrective action plan: Completed as of January 14, 2026

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.