Corrective Action Plans

Finding 2022-002 Condition: As of the March 31, 2022, reporting date, the Town underreported federal expenditures by $211,064. Corrective Action Plan: The Emergency Management Director will confirm with the Finance Director the ARPA expenditures being submitted to Treasury on the annual Project and Expenditure Report, and reconcile with expenses listed in all applicable MUNIS accounts. Anticipated Completion Date: 4/30/2023 Contact Information: Chief Michael Cassidy, Emergency Management Director cassidym@holliston.k12.ma.us Chris Heymanns, Finance Director ? Treasurer/Collector heymannsc@holliston.k12.ma.us

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation’s existing controls over federal award reporting did not identify and correct that reports submitted to the grantor were submitted with inaccurate information and that the supporting documentation used to prepare the reports were utilizing budgeted expensed amounts rather than actual. Furthermore, the budgeted expensed amounts from the supporting documentation that were the basis for the amounts to report, did not agree with the ultimate amount reported. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will leverage our general ledger to retain documentation for approval and review of expenditures. We will utilize actual amounts for expenditures and in circumstances where budgeted amounts are needed, we will perform a true-up on a quarterly basis. Management will perform quarterly reviews over financial reporting. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: July 2023

Views of Responsible Officials and Planned Corrective Actions: We agree with this finding and have implemented the following internal control policies and procedures concerning the timeliness of financial activities: Rainbow Health Minnesota is reimplementing monthly board meetings that will include a financial review of income and expense reports and balance sheets. The lateness for the 2022 audit was partially due to staff turnover of the CFO and the subsequent review by the new Finance Director. Responsibility for administering this process resides with the Finance Director

The College has implemented procedures in which the Manager, Business Operations will work with the Director of Financial Aid to ensure that all HEERF quarterly reports depict accurate data. The Dean, Student Affairs and Enrollment will verify the accuracy of these reports prior to submission.

Finding 2022-004: Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Finding: The SEFA as prepared by management did not originally include one federal grant with federal expenditures during the year and one grant for which the Assistance Listing Number (ALN) did not match the grant documents. Corrective Action: Compare all contract or award letters for accurate information reported on the SEFA prior to submission. Contact: Carmen Stevens, Finance Director Expected Completion Date: 11/30/2023 If you have any questions, please contact Carmen Stevens at 713-472-0753 or by email at cstevens@tbotw.org.

The input error was corrected prior to end of the audit. The credit union's CDFI analyst was contacted by the Chief Strategic Officer and the analyst opened the data field for editing in the AMIS system. The Chief Strategic Officer made the correction in the AMIS system and submitted the corrected information. The Chief Strategic Officer has assigned CDFI reporting responsibiities to the Director of Strategy. Future submissions will be performed by the Director of Strategy and reviewed by the Chief Strategic Officer prior to submission. Executive Responsible - Brady Popp, Chief Strategy Officer Projected Completion Date - Completed prior to the close of the audit

The Grants Administrator and the Finance Department will work closely to compare all expenditures incurred by quarter to the expenditures as reported to the grantor in the quarterly reports. The Grants Administrator will contact the grantor to determine if any corrections are requested for any reports previously submitted to address the timing and presentation issues of expenditures as incurred versus as reported. Going forward, the Grants Administrator will be more involved in communicating with the Finance Department, at a minimum on a monthly basis, as related to the reporting of expenditures that are being funded by federal, state, and local awards.

Condition: As of the June 30, 2022 reporting date, the City’s Project and Expenditure Reports overstated expenditures by $274,713 and overstated obligations by $14,045,059. Corrective Action Planned: ARPA Director reviews all expenditures for the quarter with City Auditor to reconcile cumulative expenditures and obligations for entry into portal. Anticipated Completion Date: October 31, 2023 Contact: Bridget Almon, Director of Financial Services Kara Humm, ARPA Director Sedryk Sousa, City Auditor

Regional Planning Commission (RPC) has hired a new Executive Director effective March, 2023. RPC also hired a new Finance Director effective September, 2023, who is experienced in public finance and general reporting requirements. Both staff members are dedicated to ensuring proper procedures and performance going forward. Both staff members will review and sign off on the timely and accurate filing of all grant reporting documentation and requirements.

The School District Treasurer will review all Final Expenditure Report data to ensure its accuracy prior to submission to the Ohio Department of Education. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Lee Elliott, Treasurer

Corrective Action Plan: PREMA will establish and enforce procedures to ensure that quarterly SF-425 or equivalent COR3 financial reports are prepared, reviewed, reconciled to PRIFAS and SEFA records, and submitted within required deadlines; PREMA will create reconciliation checklists, ensure reports include federal and recipient share, drawdown activity, and unliquidated obligations, designate responsible personnel for review and approval prior to filing with evidence of submission retained, and provide staff training on federal reporting requirements under 2 CFR 200.327–200.329 to strengthen compliance and accuracy in financial reporting. Lead Person: Maritza Torres, Fiscal Area Director, and Contractors (Robles & Assoc.). Anticipated Completion Date: December 2025.

Corrective Action Plan: PREMA will strengthen internal controls over financial management and reporting by improving the maintenance of subsidiary records, enhancing PRIFAS reconciliations, increasing coordination among fiscal, program, and grants personnel, and establishing written procedures to ensure timely, accurate, and complete financial information for the Statement, SEFA, and required federal reports; PREMA will also evaluate staffing needs, provide training on PRIFAS and federal reporting requirements, and conduct periodic reviews to ensure compliance with reporting deadlines and data accuracy. Lead Person: Maritza Torres, Fiscal Area Director, and Contractors (Robles & Assoc.). Anticipated Completion Date: December 2025.

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.

Program: Airport Improvement Program Finding: 2021-001 Contact Person: Mony Chhey Financial Services Officer Long Beach Airport Phone: (562)570-2664 Email: Mony.Chhey@longbeach.gov Corrective Action Plan: The Airport Department will provide more training to staff that are involved with the preparation, review and approval of the reports to reduce the risk of misinterpreting reporting requirements. The Airport Department will also strengthen internal controls by requiring at least two levels of review for Federal Financial Report SF 425, prior to submission. These improvements to the process will ensure that reports are complete and accurate. The expected completion date for implementation of these planned actions is no later than July 31, 2022.

The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.

Finding 2021-007 Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Program Director Jacy Hyde, Executive Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Program Director Corrective Action Plan: • Clark Nuber has reviewed the current closing and reporting policies and procedures. Clark Nuber’s proposed updates and revisions will be reviewed and approved by CFSC Management and thereafter implemented by CFSC staff. • CFSC will be considering an automated AP and approval processes through Bill.com or another similar provider to determine whether a provider of this nature will assist in more timely expenditure recognition workflows. • CFSC will update its fiscal reporting policies and procedures to direct that all reports are reviewed by both the grant manager and finance manager to ensure all known expenses are included and that the Schedule of Expenditures of Federal Awards is properly prepared in accordance with the Uniform Guidance. • CFSC will be doing a full review of policies and procedures to ensure they are compliant with GAAP and Uniform Guidance requirements. • The Board of Directors has approved hiring three additional Financial Staff to improve capacity for reporting. Anticipated Completion Date: CFSC will establish and implement the enhanced policies and procedures by the end of Q2 of 2024. CFSC aims to fully onboard additional Finance Staff in Q2 of 2024.

Finding 2021-006 Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jessica Martinez, Program Director Joel Rusco, Chief Financial and Administrative Officer Jacy Hyde, Executive Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Program Director Corrective Action Plan: • CFSC retained Clark Nuber to review current reporting policy and procedures. Clark Nuber’s recommendations will be reviewed and approved by CFSC management and thereafter implemented by all CFSC staff. • CFSC will implement the updated policy, procedures, and tracking mechanisms to ensure all grant progress reports are submitted to managers prior to the due date for review, approval, and timely submission to the funding agency. • CFSC is conducting a full review of policies and procedures to ensure they are compliant with GAAP and Uniform guidance requirements. Anticipated Completion Date: CFSC will establish and implement the new policies and procedures by the end of Q2 2024.

Lack of Controls Related to Filing Reports Condition: The Organization did not maintain proper documentation to support the review of the report prior to submission to the grantor, other than the review done by the preparer. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its reporting policy and implemented the changes. The corrective action for this finding has been approved and implemented by the Organization. Person Responsible for Corrective Action: Robert Thompson, Chief Executive Officer Anticipated Completion Date: Implemented

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 of March 2022, as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to included only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization. Person Responsible for Corrective Action: Robert Thompson, Chief Executive Officer Anticipated Completion Date: Implement

U.S. Department of Health and Human Services 2021-003 Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: The auditors recommend that the Organization design, implement and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will maintain evidence of timely submission of reports, review of reports and documentation to support amounts reported. Additionally, management will implement a formal documentation retention policy. Name of the contact person responsible for corrective action: Lyn Elliot, CEO Planned completion date for corrective action plan: 3/1/2024

A Financial System Enterprise Resource Planning (ERP) has been selected for implementation which will connect financial processes between the Puerto Rico Treasury Department and ADSEF fo facilitate the compliance with the required time frame. The training started on January 2023, and will continue until implementation in 2024. (ERP SYSTEM) Achieve the centralization of the fiscal and accounting systems of the agencies, instrumentalities, and public corporations to facilitate access to financial information for the Government of Puerto Rico. The ERP will lead the government to prepare and publish audited financial statements in a timely manner, and therefore, ensure that PR has access to financial markets again. During these sessions of work ADSEF has participated in several trainings with new and updated information. Centralize Government financial systems Integrate finance, buy, human capital management and payroll modules into a single platform.

Management Response to Audit Comment # 2021-004 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PERPARATION, PROPER APPROVAL OF DISBURSEMENTS, GRANT CLOSE-OUT PROCEDURES AND REQUIRED REGULATORY REPORTING. POLICIES AND PROCEDURES SHOULD BE IMPROVED LOW INCOME HOME ENERGY ASSISTANCE PROGRAM HEAD START AND EARLY HEAD START PROGRAMS Federal Assistance Listing: 93.568 and 93.600 Responsible Person: G. Keith Williams Anticipated Completion Date: December 31, 2023 / On-Going Corrective Action: The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and fully agrees with the need for improved internal controls over financial statement preparation. Management believes that the proper approval of disbursements was adhered to during the reporting period with minimal deviation and continues to ensure proper policies are followed. Federal reports (SF425’s, LIHEAP) were filed during this period and may not have been properly reviewed during the course of this audit. For example, the LIHEAP reports were reconciled with the assistance of the State Program Specialist to ensure proper return of funds as requested by the funding agency. Management reserves the right to discuss this further as needed for the purpose of this finding. Adequate fiscal personnel staff has continued to be a challenge for the agency as management has done an exhaustive search for additional fiscal personnel and made job offers to qualified individuals only to have them decline the offer at the last moment. We have just offered the position of General Ledger Accountant to an individual and they are expected to start in two weeks. This will assist the CFO in the area of financial controls and reporting. It should also be noted that all bank reconciliations are current and being completed in a timely manner as dictated by our policies and procedures. Management continues to ensure all federal, state, and local and local regulatory reports and completed and submitted in a timely manner. As stated previously, the CFO worked directly with the State LIHEAP Program Staff to ensure proper reporting and reconciliation before returning unused funds.

A specialized federal funds firm was hired that is working with internal control to improve the method of accounting for federal funds that meets accounting and FEMA requirements.

FINDING 2020-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities – Reporting Summary of Finding: The Town did not prepare or file the required reports, submit financial data on other forms, or submit an annual audit in lieu of the forms to the USDA. As such, there was no evidence to substantiate the financial operations or the financial status of the project. Contact Person Responsible for Corrective Action: Bobbi Elston (Clerk-Treasurer) Contact Phone Number and Email Address: (260) 433-4800, 104 Allen St, Monroeville, IN 46773 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Town will implement internal controls over the reporting compliance requirement related to the Water and Waste Disposal Systems federal program based on the State Board of Accounts Uniform Internal Controls Standards for Indiana Political Subdivisions. This will include involving the Town Council to assist in verifying the Town has met reporting requirement. Anticipated Completion Date: January 1, 2025