Corrective Action Plans

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.

Recommendation We recommend that management: ▪ Establish a formal reporting calendar outlining all required financial and performance reports, including due dates ▪ Implement procedures to ensure reports are prepared accurately, reviewed, and submitted timely ▪ Maintain documentation of submitted reports, including confirmation of submission and supporting schedules ▪ Assign clear responsibility for reporting compliance and implement supervisory review controls ▪ Provide training to relevant personnel on federal reporting requirements Strengthening reporting processes will improve compliance, enhance transparency, and ensure that the organization meets its obligations under federal awards.

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.

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