Corrective Action Plans

Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process Require training for all staff involved in preparing, reviewing, or certifying federal grant reports, prior to beginning any work. Work with a Financial Program Manager at the Office of Budget and Management (Neal Bucklew was the district’s contact on this particular grant) to ensure that all activity reports are submitted correctly and received on time.

To address the finding, ARC will strengthen internal controls related to federal reporting by taking the following actions: 1. Enhance Reporting Oversight: The Finance Manager and Grants and Compliance Officer will assume primary responsibility for monitoring and verifying all federal reporting deadlines and submission requirements. 2. Document Retention Procedure: Additional double checks of record retention will take place in monthly reporting meetings, ensuring that centralized record keeping is complete. 3. Compliance Calendar Audit: A quarterly internal audit of the compliance calendar and reporting checklist will be conducted to verify deadlines are met.

2024-002 - Late submission of reports Auditor Description of Condition and Effect: The Agency failed to submit the required report for the federal grant within the stipulated deadlines as outlined in the grant agreement and Uniform Guidance. During reporting testing, it was noted that the Final FFR report was not submitted into the Payment Management Services (PMS) prior to the required due date. Late submission of reports results in noncompliance with federal regulations, potentially leading to administrative actions such as withholding of future grant funds, increased monitoring, or other penalties as deemed appropriate by the Federal awarding agency. The Agency did not comply with contractual reporting requirements. Auditor Recommendation: We recommend the Agency implement procedures to ensure timely submission of all required reports. Corrective Action: The Agency will implement a system of reviewing the semi-annual and annual federal financial reporting which would include the reports being prepared by the Financial Grants Manager, reviewed by the Chief Financial Officer and submitted by the Chief Executive Officer, all of whom will be aware of the reporting due dates as to ensure they are filed timely. Responsible Person: Anthony J Samon, CFO Anticipated Completion Date: Immediately, the Agency’s next FFR due date is September 30th.

Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) The single audit report included the following recommendation: We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner Management Response/Status of Action Plans: Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The contact for this item is Lucia Butts, AVP Funding and Grants. Amtrak anticipates fully remediating this finding by September 2025.

Action taken: Effective immediately, management has implemented a new federal grant reporting calendar to track the due dates for SF-425 and other federal reporting requirements. This adjustment ensures proper reporting and alignment with compliance requirements. Person responsible: ShaQuina Davis, Chief Operating Officer Date completed: March 12, 2025

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, 2025.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – TITLE i GRANTS TO LOCAL EDUCATION AGENCIES FUNDS (FEDERAL ALN 84.010) 2024-005 Internal Control Over Compliance With Federal Reimbursement Submission Deadline Requirements Finding Summary 2 CFR § 200.328 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program reporting, including reimbursement submission requirements applicable to Title I grants. During our audit, we noted the Academy did not have sufficient controls within its Title I federal program to ensure compliance with federal reporting requirements. Corrective Action Plan Actions Planned – The Academy is in the process of reviewing and updating its policies and procedures relating to reimbursement submission for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to ensure that academy personnel are following the requirements of the Uniform Guidance related to reimbursement submission requirements. Official Responsible – The Academy's Executive Director, Farhiya Einte. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The Academy agrees with this finding. Plan to Monitor – The School’s Executive Director, Farhiya Einte, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with reimbursement submission requirements.

2024-003: Reporting Compliance Requirement 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, 2025

Name of Auditee: California Community Foundation (CCF) Audit Period: Year Ended June 30, 2024 Finding Reference #: 2024-003 – Reporting Finding Description: The Single Audit report identified a reporting-related finding (2024-003) associated with the Coronavirus State and Local Fiscal Recovery Funds under the U.S. Department of Treasury. The Foundation overstated expenditures by $203,329 and the corresponding indirect costs by $20,363 in the Schedule of Expenditures of Federal Awards (SEFA). Additionally, discrepancies were noted in the June 30, 2024 Quarterly Performance Report to the County, where advances to vendors were overstated by $120,000 and vendor-incurred expenditures were understated by $519,259. This condition reflects a gap in internal controls that could impact accurate financial reporting. Corrective Action Planned: CCF acknowledges the finding and is implementing corrective measures to strengthen the accuracy and integrity of its financial and programmatic reporting. CCF has enhanced its internal review process and implemented a reconciliation protocol to ensure consistency between internal records and external reports. Finance staff have received additional training, and final reports are now subject to dial validation by both the Compliance and Finance teams prior to submission. Anticipated Completion Date: Corrective action will be implemented by May 15, 2025. Responsible Official(s): Jose Najera, Sr. Compliance & Operations Officer (213) 452-6218 – jnajera@calfund.org Management Comments: CCF remains committed to maintaining robust internal controls and ensuring compliance with all applicable federal requirements. We appreciate the audit team’s observations and will continue enhancing our procedures to prevent future discrepancies and to uphold the highest standards of financial integrity and transparency.

CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 2) accurate, current and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in sections 200.328 and 200.329 of the Uniform Guidance.CORRECTIVE ACTION PLAN: The School District concurs with the above noted finding. The School District has employed a new Business Manager whose responsibilities include the oversight of the financial management system and the posting of all transactions into that system. Procedures will be put into place during the remaining months of the 2024-2025 fiscal year, and all subsequent years, for ensuring federal program expenditures are properly coded within the District’s financial management system so as allow for proper reporting related to those expenditures.

Management stated they have established a policy to ensure each quarterly report is submitted by its due date.

Finding 2024-002 Department of Transportation Airport Improvement Program, CFDA #20.106 AIP3 46 0050 59, AIP3 46 0050 62, AIP3 46 0050 63, and AIP3 46 0050 64 Finding Summary: The SF-425 annual report dated September 30, 2024, for award AIP3 46 0050 64 underreported the federal share of expenditures by $23,588, while the FAA Form 5100-127 annual report dated December 31, 2023, for all awards underreported the total capital expenditures and construction in progress by $2,729,962. 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

FINDING 2024-003 Finding Subject: COVID- 19 – Education Stabilization Fund – Reporting Summary of Finding: The School Corporation submitted one ESSER III report where the expenses per the report did not tie to the ledger or the Schedule of Expenditures of Federal Awards by approximately $300,000. Contact Person Responsible for Corrective Action: Matt Miles Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will ensure ESSER reports are saved and tie to the accounting records and will improve record keeping of supporting documentation. If any edits are made to the reports, the Curriculum and Accounting Departments will document the reason for all changes. Management in each department will review all ESSER reports and sign off on all documentation. Anticipated Completion Date: Corrective action steps have been implemented and will be refreshed.

RIDE monitors 193 subrecipients – this process is overseen largely by one individual. This individual also monitored COVID era funds such as ESSER. With those programs having passed, more time can be re-allocated to subrecipient monitoring. RIDE does review risk scores for sub-recipient monitoring and considers risk as a basis for onsite visits/monitoring. RIDE disagrees that a higher risk assessment was not given for non-completion of the annual survey; we don’t disagree that a site visit was not performed, but that’s due to resource constraints. RIDE will work on documenting these reviews more formally than the current process, while also documenting decisions for either performing a site visit, or not performing a site visit. Anticipated Completion Date: Ongoing Contact Persons: Brandon Bohl, Finance Director, Department of Elementary and Secondary Education brandon.bohl@ride.ri.gov Crystal Martin, Senior Finance Director, Department of Elementary and Secondary Education crystal.martin@ride.ri.gov

RIDE has hired a full-time fiscal officer to oversee these programs from a fiscal perspective and maintain compliance with reporting requirements including the SF-425. RIDE is currently hiring for a program person who will assist the fiscal officer with reporting compliance. Anticipated Completion Date: Ongoing Contact Persons: Brandon Bohl, Finance Director, Department of Elementary and Secondary Education brandon.bohl@ride.ri.gov Rosemary Reilly-Chammat, Director – Office of School Health & Wellness, Department of Elementary and Secondary Education rosemary.reilly-chammat@ride.ri.gov

Friday, April 11, 2025 Dear Sir(s): CORRECTIVE ACTION PLAN In prior years the accounting of Pyramid Learning Corp. was executed externally by a contracted accounting company. During the year ended June 30, 2024 we acquired a specialized accounting software. After the acquisition of the new software, we recorded the data from the beginning of the year to the present, which required significant staff effort and made it impossible to maintain accounting and financial reports on a month-to-month basis. At the present, the data is already being recorded, and the accounting is up to dates. This allows us to keep our accounting and interim financial reports such as Balance Sheet, Statement of Activities, Bank Reconciliations, and monthly analysis of accounts, up to date and on a current month-to-month basis to be more transparent, and any errors are corrected on a timely manner.

The Fiscal team lacked sufficient knowledge and understanding to properly execute accurate financial statements. During FY24 there was significant turnover in the Fiscal department, necessitating contractual services from outside fiscal parties. A total of four additional fiscal content contractors were secured to assist the Finance Director. The Finance Director has been replaced by a qualified CPA. There is currently an ongoing rebuilding of the Fiscal Department with the intent of filling positions with qualified permanent staff. Internal controls are to be reviewed, revised as necessary, and followed, by the new team to ensure accurate and timely financial reporting.

The Finance Director was unable to balance competing priorities, resulting in delayed submission of SF-425 reports. The Finance Director has been replaced by a CPA. Support from an external content specialist was secured to train the current CFO on the proper preparation of the SF-425 reports. Reporting has been brought current. Alert emails from HSES are being reviewed by leadership and the HSES website is being monitored for submission deadlines. Priority is given to ensure timely deliverables.

Finding: 2024-002 Federal Agency Name: U.S. Department of Health and Human Services Assistance Listing Number(s): 93.423 Program Name: 1332 State Innovation Waivers Finding Summary: Recipients of federal funds must submit financial reports as required by the Federal award. Reports submitted annually by the recipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period, in accordance with CFR § 200.328(c). The Association’s existing controls over their reporting processes, to ensure reports were submitted timely, were not functioning in such a way that ensured reports were submitted on time. Responsible Individuals: Christopher E Howard, General Counsel and Secretary Corrective Action Plan: Management has established a multi-tier calendar control to notify them when reports are due in order to ensure timely filing of all reports. Anticipated Completion Date: Completed April 9, 2025.

2024-034 Oregon Housing and Community Services Department Quarterly Performance Report should include all expenditures incurred to date Management Response: The agency agrees with this finding. Quarterly performance report requirements will be reviewed with staff and additional oversight will be added to ensure accurate reporting occurs. Corrective reports will be filed to the extent allowed by HUD. Anticipated Completion Date: June 30, 2025 Contact person: Beth Brown, Controller

2024-034 Oregon Housing and Community Services Department Quarterly Performance Report should include all expenditures incurred to date Management Response: The agency agrees with this finding. Quarterly performance report requirements will be reviewed with staff and additional oversight will be added to ensure accurate reporting occurs. Corrective reports will be filed to the extent allowed by HUD. Anticipated Completion Date: June 30, 2025 Contact person: Beth Brown, Controller

The City internally identify improvement opportunities in managing grants. As a part of the City’s grant oversight improvement efforts, the City began implementing various processes and internal controls surrounding grant monitoring, which improves the SEFA drafting process and mitigates risks of future inaccuracies. These efforts began in early 2024 and include the following: • Creation of a grant policy that provides City staff with guidance, information, and expectations surrounding grants. • Creation of a master grants database that lists the general ledger fund, applicable project ledger references, status, grant type, start/end dates, granting agency, pass-through agency, grant name, assistance listing numbers, grant amounts, and the grant manager for each grant. This database is now used to verify the completeness and accuracy of the SEFA (beginning FY24). • Formal quarterly monitoring. Each quarter, the City will formally review the grants database with department contacts and grant managers to verify the completeness and accuracy of the database. The City is formalizing this process and plans to include department signoffs evidencing the review process. If any items are missing, the missing component will be identified and added to the database on a timely basis. The City will also utilize this quarterly process to review the grants policy to ensure grant managers are aware of the requirements related to their grants. • The City is in the process of formalizing the SEFA drafting process utilized during the FY24 SEFA preparation, which includes additional mitigating procedures such as reviewing all next FY federal receipts to ensure none of them relate to the SEFA year federal expenditures. Personnel Responsible for Implementation: Marvin Lopez Position of Responsible Personnel: Deputy Administrative Services Director (Fiscal Services) Expected Date of Implementation: June 30, 2025

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 coordinators 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.

Name of Contact Person: Dickie Motto, Mayor and Jade Hill Treasurer Corrective Action Plan: NWAB established a policy/procedure to ensure that they are successful and compliant with the program’s reporting requirements and the award(s) are used in accordance with federal statutes, regulations, and the terms and conditions of the federal and state awards. Proposed Completion Date: Fiscal Year 2024

Finding 2024-001 Reporting – Internal Control and Compliance over Reporting (Significant Deficiency) Criteria: Code of Federal Regulations, Title 2 – Federal Financial Assistance, Subtitle A – Office of Management and Budget Guidance for Federal Financial Assistance, Chapter II – Office of Management and Budget Guidance, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements: Performance and Financial Monitoring and Reporting Section § 200.328 Financial reporting. (a) The Federal agency must require only OMB-approved government-wide data elements on recipient financial reports. At the time of publication, this consists of the Federal Financial Report (SF-425); however, this also applies to any future OMB-approved government-wide data elements available from the OMB-designated standards lead. (b) The Federal agency or pass-through entity must collect financial reports no less than annually. The Federal agency or pass-through entity may not collect financial reports more frequently than quarterly unless a specific condition has been implemented in accordance with § 200.208. To the extent practicable, the Federal agency or pass-through entity should collect financial reports in coordination with performance reports. (c) The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. (d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient. Section § 200.303 Internal Controls The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context: For the Community Development Block Grants/Entitlement Grants Cluster, the City did not submit the reports within the required deadline: Report Type Award Number Period Date Due Date Submitted SF-425 Financial Program-wide reporting 7/1/2023 - 9/30/2023 10/30/2023 1/16/2024 SF-425 Financial Program-wide reporting 1/1/2024 - 3/31/2024 3/30/2024 7/24/2024 Four (4) quarterly financial reports were tested, and two (2) reports were not submitted by the required deadline. City’s Corrective Action Plan: The City has already taken steps to improve its processes/procedures to insure timely submission of all required SF-425 reports. Contact person responsible for corrective action: Michael Lima, Finance Director Anticipated completion date: June 30, 2025