Corrective Action Plans

Corrective Action Plan Response to Finding 2024-001 and Finding 2024-002: Management agrees with the recommendations and will implement the following changes: 1. On a monthly basis the Controller will review and approve all financial reporting submitted to programs to allow finance department to capture and record missing information. This will be implemented by January 31, 2025. 2. A member of the finance department will participate in the sub-recipient monitoring to provide the monitoring team with oversight and ensure compliance with accounting best practices. This will be implemented by February 28, 2025. 3. The “Budgeting, Contracts, and Grants Manager” within the OMRS program will be responsible for notifying the Chief Financial Officer of any non-compliance from Sub-recipient grants and agreements within ten business days. This will be implemented by January 31, 2025. 4. The two sub-recipients with late invoicing will be issued corrective actions plans by Office of Maine Refugee Services for timely submittal of financial reports and invoicing. This will be completed by January 31, 2025. Estimated completion date for all items above: February 28, 2025 Responsible party: Reed L. Westgate, Chief Financial Officer

UWGC does not have specific policies and procedures in place as to how monthly personnel costs across federal programs will be aggregated and charged and reported to federal programs. Management’s Corrective Action Plan: UWGC has developed a procedure as outlined below in “Payroll Allocation Grants” to ensure that prior to submission of invoices to federal awarding agencies, management prepares a monthly analysis based on 211 call logs to support the actual amounts allocated across all programs and invoiced to the awarding agencies that are reconciled to payroll reports, which then will allow UWGC to present evidence that all hours submitted for reimbursement are supported with the appropriate allocation. The process will include management staff from both 211 and finance departments thus maintaining internal controls. Additionally, this procedure will be reviewed at least annually by both departments as it relates to the allocation methodology to ensure that its appropriate given changes in the program and workforce.

We agree with the recommendation and as of October 2024 have implemented an additional layer of review, effective for the first round of reports filed for FY2025.

Finding Number: 2024-003 Condition: Controls in place were not adequate to ensure the Township reported expenditures on the report in the proper categories. Planned Corrective Action: Management will ensure procedures are put into place to ensure expenditures are reported under the correct categories. Contact person responsible for corrective action: Finance Director Anticipated Completion Date: 3/31/2025

Reference Number: 2023-010 Finding: Improve Controls and Compliance with Reporting Name of Contact Person: Lorina Esposito Corrective Active Plan: In the past year, the City has fully staffed the division of housing and community development which has led to the successful submission of the 2024 CAPER. The staff worked diligently to find all required data for the report and participated in training courses to prepare for future CAPERs. Proposed Completion Date: 3/31/26

Reference Number: 2023-008 Finding: Improve Controls and Compliance with Reporting Name of Contact Person: Christine Chamberland Corrective Active Plan: The City will develop and implement formal written procedures for preparing, submitting, and retaining all required quarterly performance and evaluation reports in compliance with program requirements. Designated staff will be responsible for tracking reporting deadlines, ensuring timely submissions, and maintaining thorough documentation of all reports. Management will conduct regular reviews to monitor compliance and address any deficiencies promptly. Proposed Completion Date: 6/30/26

Finding Number: 2023-003 Planned Corrective Action: City Auditor will stay in contact with Municipal Court Administrator and the Police Captain to ensure they submit Quarterly Reports on a timely basis. Anticipated Completion Date: July 3, 2025 Responsible Contact Person: City Auditor Sherri Hess

Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence. County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on federal funds. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners. County Treasurer: The County was under the understanding that once we established we were reporting as revenue loss, we would not have to submit the report annually. The final reporting was submitted prior to deadline.

Corrective Action Planned: We will ensure the submission of the reports remian timely and general ledgers from the subject fiscal years are used in preparing the reports. The County will ensure that informaiton garnered from the general ledgers coincide and accurately match future reports before submission. Anticipated Completions Date: April 1, 2024. Name of person responsible for corrective action: Ricky Ferguson, Chancery Clerk.

The City will work to ensure all reports for grant funding are completed.

The City will work to ensure all reports for grant funding are completed.

Thomas Swabb, Tribal Chairman Marjianne Yonge, Tribal Treasurer PO Box 747 Lone Pine, CA 93545 (760) 876-1034 Condition: The Tribe was unable to provide copies of the required quarterly progress/performance reports, and as a result, we could not verify whether the reports were submitted to the awarding agency as required. Corrective Action: The Tribe has hired a full-time bookkeeper along with a new fiscal consultant to assist the bookkeeper in journal entries, bank statements, etc. on a monthly basis. All required reporting will be done within 30 days of the end of reporting date. Anticipated date of completion: April 1, 2026.

Views of Responsible Officials and Planned Corrective Action We will give instructions to the accounting staff in charge of the preparation of the quarterly progress reports of the Program, in order to comply with the FEMA reporting requirements. Responsible Official: Mrs. Irma M. Vargas Aguirre, Finance and Budget Director Implementation Date: December 31, 2025

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: As a measure of corrective action, I will be implementing a check sheet that will be attached to every claim sheet. This new procedure requires that you go through the check sheet and initial each item to ensure that all procedures have been followed correctly before submission. Additionally, I will also maintain a check sheet in my office since I am the last person to review each claim. This will help to ensure thoroughness and accuracy in our claims processing. Furthermore, moving forward, any grant funds will be placed into their own individual funds and distributed through an individual account. This approach will allow us to track payments for any expenses associated with these funds more effectively. Additionally, the BOT expenditure is done and in the future we will do a better job. Anticipated Completion Date: October 31,2025

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.

Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.

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.

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration.

FINDING 2023-002 Finding Subject: COVID‐19 ‐ Coronavirus State and Local Fiscal Recovery Funds ‐ Reporting Summary of Finding: The Elkhart County Health Department (Health Department) was awarded the Health Issues and Challenges Grant through the Indiana Department of Health (IDOH) financed through the Coronavirus State and Local Fiscal Recovery Funds The grant was funded through the American Rescue Plan Act that focused on the improvement of chronic disease, and more specifically, elevated blood lead level reduction. The Health Department was required to submit data through the online portal, National Electronic Disease Surveillance System (NEDSS) Base System (NBS) each month. The submitted data included program specific metrics related to patient case management of certified Elevated Blood Lead Levels (EBLLs). A Case Manager managed all aspects of an individual patient's care. A home visit and two assessments were completed by the Case Manager and input into the NBS. Once these steps were marked as complete in the NBS, the Clinical Manager reviewed each case and compiled data along with the cost reimbursement amount into a spreadsheet. The Clinical Manager provided the spreadsheet to the Manager of Administration who then completed and submitted the reimbursement invoice to the IDOH. The reimbursement invoice was submitted without a documented oversight, review, or approval process to ensure the accuracy of the data prior to submission. Beginning in October 2022, the Health Department was required to submit program specific metrics and work plan data through RedCap software on a quarterly basis. The Case Manager was responsible for tracking and compiling the necessary information for the quarterly reports. Of the four reports tested, two reports were submitted late. In addition, the quarterly reports were submitted by the Case Manager via the RedCap software without a documented oversight, review, or approval process to ensure timely submission. Recommendation: We recommend the Health Department implement a formal oversight and review process for all data submissions to ensure accuracy and completeness before they are submitted to Indiana Department of Health (IDOH). This would involve a secondary review by a designated individual or team to verify the data. Additionally, improving workflow coordination through clearly defined roles and responsibilities for each team member would help streamline the process and prevent delays. To further improve timeliness, the Health Department should implement a tracking and reminder system for report due dates and reimbursement deadlines to ensure timely submissions. Providing staff with thorough training on reporting protocols and maintaining detailed documentation will help ensure consistent adherence to procedures. Finally, establishing accountability measures through clear roles, deadlines, and regular audits would enhance the efficiency and effectiveness of the reporting process. These steps will help ensure the Health Department meets grant requirements, maintains data accuracy, and avoids potential delays or issues in future submissions. INDIANA STATE BOARD OF ACCOUNTS 29 Contact Person Responsible for Corrective Action: Concetta Sanfilippo Contact Phone Number and Email Address: 574.523.2101 csanfilippo@elkhartcounty.com Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: During the prior audit we were informed of the deficiencies in our controls over the reimbursement requests submitted to the Department of Health. Unfortunately, due to the timing of the finding being brought to our attention near the end of its lifecycle we were unable to implement controls. With only one month remaining between the audit finding results and the grant’s end date, implementing the stated corrective action plan was deemed impractical. The Elkhart County Health Department has internal controls and policies for the grants that are received. This grant was very different from the other grants we have received in the past. Since the Elevated Blood Lead Level Reduction grant differed significantly from previous grants received by the Elkhart County Health Department, moving forward, if the department chooses to pursue and secure another grant with a similar scope, enhanced controls and policies will be implemented to strengthen accuracy and accountability. Specifically, the Health Department will establish a formal data review process. All data submissions will undergo an initial review, followed by a secondary verification conducted by a designated staff member. This dual review procedure will apply to all future grants of a similar nature to ensure the integrity and reliability of submitted information. The goal is to ensure there is an appropriate system of checks and balances, as well as a remediation/correction step, in place for all tasks and documentation related to grant-funded duties and invoicing. Anticipated Completion Date: Effective June 30, 2025 the Elkhart County Department of Health will implement this practice for all newly accepted grants similar in scope to the Elevated Blood Lead Level Reduction.

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)

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)