Corrective Action Plans

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

Finding 2024-003 – Fiscal Management (Material Weakness) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(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 200.328 and 200.329. Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District, and potential refunding of reimbursements received. Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation for each report was not possible because original data was not relied upon by management, to complete the reports and reimbursement requests. Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned. Questioned Cost: No Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities in the form of refunds due to ODOT.  Repeat of a Prior-Year Finding: Yes Recommendation: The District should design and implement internal control policies and procedures for cash management, including fiscal management and financial reporting. Monitoring, information and communication control activities should also be designed and implemented as part of the effort the reduce the risk of continued matters of noncompliance related to cash management. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving these deficiencies has been offered by ODOT and accepted by the Board. Planned Implementation Date: October 31, 2024 Responsible Persons: District Board, Umpqua Public Transit District

FINDING 2024-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When the criteria for the reporting is changed forcing us to change our answers, we will keep better notes of what we changed, and why we changed it. Our final numbers were correct, and we spent the money out of the correct categories. Jennifer Mossburger, Title I coordinator, and I worked together on this reporting. We will continue to work together on the reporting for the federal grants. However, we will do a better job of documenting our work. Anticipated Completion Date: 3/3/2025

FINDING 2024-005 Finding Subject:. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation was required to submit five annual data reports as outlined below. Fund Applicable Reporting Period ESSER I July 1, 2021 – June 30, 2022 ESSER II July 1, 2021 – June 30, 2022 ESSER III July 1, 2021 – June 30, 2022 ESSER II July 1, 2022 – June 30, 2023 ESSER III July 1, 2022 – June 30, 2023 All five annual data reports were selected for testing. Two of the five annual data reports did not include the correct expenditure information. Specifically the ESSER II and ESSER III annual data reports with an applicable reporting period of July 1, 2022, to June 30, 2023, did not include expenditure data for this period. Instead, the annual reports incorrectly reported expenditures from the previous period of July 1, 2021 to June 30, 2022. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: Since the conclusion of the 2020-2022 SBOA audit, the CFO and Corporation Treasurer have archived numerous email threads and other evidence of communication which documents the process for pulling ESSER financial data from the Skyward Finance system and submitting the required reports. This documentation shows the CFO and Treasurer regularly communicating, checking and rechecking the data, and verifying the timely submission of that data. The school received periodic requests from the Indiana Department of Education, Office of Federal Grants asking it to submit financial data for all ESSER funds. Originally, the data requests were submitted through JotForms which do not have the capability of notifying any individuals other than the recipient. The school was required to create its own documents for proof of submission and did so. In subsequent requests, IDOE provided Excel spreadsheets to be completed and returned electronically. Those emails and spreadsheets have been curated by the school. The school has documented unclear instructions provided by IDOE, the pass through agency. The school accepts responsibility to report grant activity for the federally required reporting periods regardless. The school will ask for explicit instructions from IDOE and reconfirm the reporting data required and time period(s) in question. This additional layer of internal controls will be added to the process currently utilized by the CFO and Corporation Treasurer. The school has not expended any dollars from any ESSER fund since 2023. Anticipated Completion Date: TBD based on when the next reporting submission is requested by IDOE (all ESSER grants activities have ceased and the funds have been closed out locally.)

FINDING 2024-006 Finding Subject: Education Stabilization Fund--Reporting Contact Person Responsible for Corrective Action: Andrew McDaniel, Chief Financial and Operations Officer Contact Phone Number and Email Address: 260.894.3191 and mcdaniela@westnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Chief Financial Operations Officer will prepare the reports and have the Curriculum Director review for accuracy. Anticipated Completion Date: July 1, 2026

Reporting, Significant Deficiency, Other Matters Federal Agency: U.S. Department of Education Federal Program Name: Fund for the Improvement of Postsecondary Education Assistance Listing Number: 84.116 During testing it was noted that the College did not submit the required annual report. Recommendation: We recommend the College should establish a policy that provides the guidance required to comply and address regulatory reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has since communicated key personnel changes to the US DOE and is working to finalize and submit the Annual Performance Report that is currently due to regain good standing with the financial reporting compliance requirement. Name(s) of the contact person(s) responsible for corrective action: Sarah Simard, Controller Planned completion date for corrective action plan: April 2025