Corrective Action Plans

FINDING 2023-003 Finding Subject: COVID-19-Education Stabilization Fund - Reporting Summary of Finding: The School Corporation was required to submit an annual data report 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 submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were prepared by the Treasurer. Due to the lack of effective internal controls one of the six annual data reports was not supported by the School Corporation’s records. For the ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, total expenses per the report were $688,778. However, the School Corporation’s ledger had total expenses for the award, for that time period, of $784,638. The lack of controls and noncompliance were isolated to the ESSER III, Year 2 report. Contact Person Responsible for Corrective Action: Leslie Rittenhouse Contact Phone Number and Email Address: 765-395-3341 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As the finding and error occurred in one entry of one report the district will continue the practice of having a second party review financial system data against report entries. The error in this instance was a misunderstanding of the entry. A secondary review of reporting guidelines and entries will take place prior to submission of any ESSER Data Reporting. Anticipated Completion Date: Upon the next submission of ESSER Data reporting.

Finding Number: 2023-005 Finding Name: Failure to Accurately Prepare Financial Reports for the COVID-19 – Homeowner Assistance Fund Program Finding Condition(s): The Illinois Department of Human Services (IDHS) did not prepare accurate federal financial reports (Paperwork Reduction Act (PRA) 1505-0269) for the COVID-19 – Homeowner Assistance Fund (HAF) program. Additionally, the auditors noted that the IDHS’ supervisory review procedures of the PRA 1505-0269 reports have not been designed to operate at an appropriate level of precision to ensure the financial reports are accurately prepared. Name of Contact Person(s): Joseph Wellbaum, Chief Financial Officer – Illinois Department of Human Services Corrective Action(s): The IDHS will issue the updated quarterly Treasury data templates to the Illinois Housing Development Authority to collect all necessary data fields in order to accurately report and reconcile HAF expenditure information. (Completed 12/31/23) The IDHS and the Illinois Housing Development Authority will meet with the U.S. Treasury to clarify quarterly and annual reporting needs for the HAF program. (Completed 12/15/22) Proposed Completion Date: December 31, 2023 – Completed

Finding Number: 2023-003 Finding Name: Failure to Accurately Prepare Performance Reports for the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Program Finding Condition(s): The Illinois Governor’s Office of Management and Budget (GOMB) did not prepare accurate federal project and expenditure reports (Paperwork Reduction Act (PRA) 1505-0271) for the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program. Name of Contact Person(s): Lesley Winbush, Accountant – Illinois Governor’s Office of Management and Budget Corrective Action(s): GOMB will improve the reporting process by implementing checks to ensure that all expenditures are reported by State agencies. The checks will include comparing reported data against agency financial reports to ensure that the data is complete. Proposed Completion Date: June 30, 2026

Responsible official: Edwin Garcia, Finance Director. Condition/Cause: Incomplete/late submission of required program reports for ALN 21.027 (SYEP). Corrective actions: (1) Created a Uniform Guidance compliance calendar for all reporting deadlines; (2) Implemented a pre‑submission peer review checklist (accuracy, completeness, tie‑out to ledger/SEFA); (3) Standardized reporting templates mapped to the GL; (4) Automated reminders 10 and 3 days before due dates; (5) Training provided to staff on 2 CFR 200 reporting requirements and City of Chicago contract terms. Timeline: Implemented May–June 2025; sustained monitoring through December 31, 2025. Monitoring: Monthly compliance meetings with program and finance; late submissions escalated to Executive Director.

The village is currently reviewing the Federal Requirement for reporting and how the village will be able to track and handle this reporting in the future. In regard to monthly reporting the village has a population of approximately 1500 residents and received approximately $50,000 SLFRF funds. Well below the quarterly requirements and were only required to file yearly per the guidelines listed by the U.S. Department of Treasury’s own reporting guidelines. See below chart. Please take note that the Village has reported each year since 2022 as required. A copy of the yearly reports are available if needed.

Finding Number: 2023-004 Planned Corrective Action: The extension was granted and the housing authority kept in contact by email to HUD in regard to the lengthy audit process due to former executive director. Our plan is to be timelier once these issues are rectified. Anticipated Completion Date: May 31, 2025 Responsible Contact Person: Sherrie Boudinot, Zackary Dye

Management has instructed the department managers involved with grants to work with the Finance Director and Senior Accountant for all future grant accounting and reporting to ensure that grant expenditures are properly recorded and reported in the correct period. The Senior Accountant will complete GFOA’s Generally Accepted Accounting Principles for Grants in August 2026. As of the date of this letter, Management is working to identify other grants-related training appropriate for the Senior Accountant, the Utility Manager, and the Director of Development Services and Capital Projects, all of whom are involved in grant proposals, management, expenditures, accounting and required reporting. Meetings with all three department managers will be scheduled to coordinate administration and deadlines for the City’s new and existing grants as grant reporting deadlines occur. Responsible Personnel Name and Position: Jill Taura, Interim Finance Director Expected Implementation Date of Corrective Action Plan: Fiscal year 2026

Finding 2023-002: Information on the Federal Program: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – 21.027 Compliance Requirements: Reporting – Timely Submission Type of Finding: Significant deficiency. Criteria: In accordance with 2 CFR 200.328 and the U.S. Department of the Treasury’s SLFRF Compliance and Reporting Guidance, recipients must submit accurate and timely Project and Expenditure Reports by the due dates established by Treasury. Additionally, under 2 CFR 200.303, recipients must establish and maintain effective internal controls over compliance with federal award requirements. Condition: The County did not submit two quarterly Project & Expenditure Reports to the U.S. Department of the Treasury within the required deadlines during 2023 for the SLFRF program. Questioned Costs: $0 Effect: Noncompliance with federal reporting requirements. However, the reports were ultimately submitted and accepted. Cause: Internal control process failure. Repeat Finding: No Recommendation: Management should implement procedures to ensure timely submission of all required SLFRF reports. Action taken in response to finding: Management will implement procedures to ensure timely submission of all required SLFRF reports.

2023‐011 Reporting - COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Person responsible for corrective action – Devlyn Brooks, Executive Director Corrective action planned – Management will refine job duties and responsibilities related to federal, state, and grant reporting required by granting agencies. A review process will be established where an employee independent of the report preparation will review the reports to be submitted along with all supporting documentation. A shared drive will be established where copies of all reporting and supporting documentation will be kept for review and any future requests from granting agencies. Planned implementation date of corrective action – Calendar year 2025.

VIEWS OF RESPONSIBLE OFFICIALS It is recommended, among other things, to establish internal controls that provide certainty, effective monitoring, data validation, and accountability for those employees who execute the reporting processes. To this end, the personnel responsible will be convened and written processes will be issued to expedite the information requests and ensure their rapid submission. This will be in accordance with both state and federal regulations. Once the agreements are finalized, they will be submitted to the auditing firm. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

VIEWS OF RESPONSIBLE OFFICIALS Review the accounting system to ensure consistency with SF– 425 reporting. Establish a protocol for the review and approval of financial reports. Designate a financial compliance officer to validate reports prior to submission. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Families and Children (ADFAN, by the Spanish Acronym)

VIEWS OF RESPONSIBLE OFFICIALS It is recommended, among other things, to establish internal controls that provide certainty, effective monitoring, data validation, and accountability for those employees who execute the reporting processes. To this end, the personnel responsible will be convened and written processes will be issued to expedite the information requests and ensure their rapid submission. This will be in accordance with both state and federal regulations. Once the agreements are finalized, they will be submitted to the auditing firm. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

VIEWS OF RESPONSIBLE OFFICIALS We wish to clarify that the Puerto Rico Department of the Family does not maintain a standalone accounting system but rather records all financial transactions directly in the Puerto Rico Integrated Financial Accounting System (PRIFAS), the centralized accounting platform hosted by the Puerto Rico Treasury Department. Consequently, it is not necessary for PRDF to “update its accounting practices” or “implement” a new financial management system, since PRIFAS already provides a comprehensive and reporting framework that meets state and local agreement requirements. However, it is important to mention that the Certified Fiscal Plan for 2024, certified by the Financial Oversight and Management Board (FOMB), in Section 3.1.7.5, explicitly prioritizes the implementation of an enterprise resource planning (ERP) system to further centralize and streamline financial management across Commonwealth agencies. Once deployed, this ERP will enhance financial transparency, unify budgeting and procurement processes, support real-time transaction recording, and deliver centralized reporting consistent with public sector accounting standards, thereby addressing the core objectives of this finding. IMPLEMENTATION DATE Awaiting system implementation. RESPONSIBLE PERSON Office of the Secretariat and Administrations

VIEWS OF RESPONSIBLE OFFICIALS It is recommended, among other things, to establish internal controls that provide certainty, effective monitoring, data validation, and accountability for those employees who execute the reporting processes. To this end, the personnel responsible will be convened and written processes will be issued to expedite the information requests and ensure their rapid submission. This will be in accordance with both state and federal regulations. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

VIEWS OF RESPONSIBLE OFFICIALS It is recommended, among other things, to establish internal controls that provide certainty, effective monitoring, data validation, and accountability for those employees who execute the reporting processes. To this end, the personnel responsible will be convened and written processes will be issued to expedite the information requests and ensure their rapid submission. This will be in accordance with both state and federal regulations. Once the agreements are finalized, they will be submitted to the auditing firm. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

VIEWS OF RESPONSIBLE OFFICIALS It is recommended, among other things, to establish internal controls that provide certainty, effective monitoring, data validation, and accountability for those employees who execute the reporting processes. To this end, the personnel responsible will be convened and written processes will be issued to expedite the information requests and ensure their rapid submission. This will be in accordance with both state and federal regulations. Once the agreements are finalized, they will be submitted to the auditing firm. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

Condition: The Organization did not maintain proper documentation in support of reporting requirements. Corrective Action Planned: The Organization has hire a new Chief Financial Officer as well as additional supporting staff within the finance department. The accounting staff was restructured in November 2024 with the addition of a Finance Manager and Senior Accountant to strengthen internal control and facilitate segregation of duties best practices for day-to-day activities. In addition to review of month-end journal entries, reporting requirements with additional review was also implemented in 2025. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer. Anticipated Completion Date: Implemented.

Finding Number: 2023-002 Planned Corrective Action: City Auditor has confirmed the ARPA 3/31/24 and 3/31/25 Project and Expenditure Reports submitted agree to City Accounting records. Anticipated Completion Date: July 3, 2025 Responsible Contact Person: City Auditor Sherri Hess

Description of Finding: The monthly narrative reports and beneficiary reports required to be submitted under the CDBG program were unable to be located, and therefore it cannot be determined if the reports were at all submitted as required. Planned Corrective Action: The organization has ceased offering the services related to this grant. That being said, the organization will ensure timely and accurate report filing for all the grant programs that they participate in going forward. The YWCA New Hampshire will implement the following: 1. Report Tracking System: Develop a centralized report tracking system by July 15, 2025, to log all required reports, submission dates, and confirmation of receipt. 2. Standard Operating Procedures (SOPs): Create SOPs for report preparation and submission, specifying responsible staff, deadlines, and documentation requirements. 3. Training: Train program staff on the SOPs and tracking system by July 31, 2025. 4. Backup Documentation: Store all reports and submission confirmations in a secure digital repository, accessible for audits. 5. Monthly Compliance Checks: The Program Manager will review the tracking system monthly to ensure all reports are submitted on time, with findings reported to the Executive Director. Responsible Party: Program Manager, overseen by Caroline Catlender, Executive Director Anticipated Completion Date: August 15, 2025

Fiscal Year 2023 Single Audit Corrective Action Plan Finding Number: 2023-005 Reporting Condition: The CMHSP did not reconcile financial expenditures shown in the Federal Financial Report to the total disbursement and charges in PMS. Planned Corrective Action: The CFO or Finance Manager will ensure that the financial expenditures shown in the Federal Financial Report reconciles to the total disbursement and charges in PMS. Contact Person: Kevin Hartley, CFO 231.633.2171 Kevin.hartley@nlcmh.org Anticipated Completion Date: 10-1-24

FINDING 2023-011 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports, and two ESSER III reports, for a total of six reports. The annual data reports were compiled, prepared, and submitted by the Director of Curriculum without oversight by another individual. All six of the submitted reports were selected for testing. One of the reports, ESSER II, Year 2; was not supported by the School Corporation's records. The School Corporation had expenditures of $583,415 from the ESSER II grant which was not included in this report. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager and Director of Curriculum will review the annual data reports together before submittal. Anticipated Completion Date: September 30, 2024􀀃

Plan of Action: To correct deficiencies in the preparation and submission of the SF-425 Federal Financial Report, the organization has established SOP F1.03: Submission and Recordkeeping of Federal Financial Reports (SF-425). This procedure outlines the steps for accurately completing the SF-425 using verified financial data, submitting it through the appropriate federal systems by required deadlines, and maintaining supporting documentation in compliance with federal recordkeeping standards. It applies to all staff involved in financial reporting on federally funded grants.

Finding Number: 2023-002 Planned Corrective Action: The Chief Financial Administrator will ensure all ARPA expenditures are included on the Project and Expenditure Reports. Anticipated Completion Date: March 31, 2025 Responsible Contact Person: Ben Cowdery, Chief Financial Administrator

2023‐009 Reporting Annual Project and Expenditures Report (Material Weakness): The City did complete the Project and Expenditures Report but just not timely as a result of staff turnover during the actual fiscal year. Since taking office in fiscal year 2024, the current Finance Director has prioritized compliance with federal reporting requirements. As of fiscal year 2025, all required project and expenditures reporting has been completed and submitted in accordance with U.S. Department of Treasury guidelines. To prevent future occurrences, the Finance Department has implemented internal controls ensuring multiple staff members are responsible for federal reporting. Specifically, both the Finance Director and the Financial Analyst now share the responsibility and authority to complete and submit these annual reports. This new process ensures continuity in reporting, even in the event of staff turnover, and strengthens the City’s commitment to compliance with federal funding requirements. In addition, The City’s Procurement officer now maintains responsibility for grants from award to reversion date. A tracking file is maintained for all active grants at the point it is awarded, expended, and reimbursement received to ensure this process is properly managed. Additionally, the Finance Director oversees this responsibility so there are now multiple controls to ensure timely completion.

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.