Corrective Action Plans

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 As part of the digitization project process, ADSEF seeks to standardize procedures and ensure the organization and proper location of documents within the files. For this Digitalization project we have available matching funds of approximately 7 million dollars. IMPLEMENTATION DATE Awaiting System Implementation RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

VIEWS OF RESPONSIBLE OFFICIALS In Process Develop an operational procedures manual for each program under Uniform Guidance. Include flow outlining key processes. Assign personnel responsible for each function and establish periodic review mechanisms. 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. 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)

The Organization acknowledges this repeat finding and will take steps to address the deficiencies noted. Since the prior year's audit, management will implement updated procedures to strengthen internal controls around documentation of allowable costs charged to federal awards. These measures include the development of a formal time and effort reporting system, which requires all grant-funded employees to submit periodic certifications that reflect actual hours worked and funding source allocation. Supervisors are now required to review and approve these certifications to ensure alignment with actual program activities. Additionally, the Organization will reinforce its invoice documentation and review process. All expenditures charged to the Block Grant and Opioid STR programs must now be supported by detailed invoices and documentation that clearly demonstrate allocability, allowability, and consistency with the approved grant budget and period of performance. These requirements are monitored through monthly reviews by the finance department. The Organization has also adopted a document retention policy aligned with 2 CFR §200.334, and relevant staff have received training on documentation and compliance requirements for federal awards. These corrective actions are being actively monitored by the Director of Finance to ensure full implementation and ongoing compliance. Organization Contact Person Responsible for Corrective Action: Joseph Koehler, Director of Finance Anticipated Completion Date: June 30, 2025

Recommendation: Implement enhanced procedures for the systematic maintenance and retrieval of all financial records related to expenditures, including staff training on these protocols. Action Taken: Management agrees with the auditor’s finding and recommendation. The newly appointed Deputy Director of Finance will oversee the implementation of these enhanced procedures.

Inadequate Controls Over Expenditures Condition: During our testing of a sample of 40 expenditures of McKinney Education for Homeless Children grant funds by the Regional Office of Education #56, we noted that six expenditures totaling $52,005 did not have any supporting documentation. In addition, for those expenditures with supporting documentation, none of the invoices were stamped “paid”. During our testing of an additional sample of 40 expenditure transactions of the Regional Office of Education #56 for purposes of testing controls over financial reporting, we noted the following: ∙ No documentation was available for four expenditures ∙ No supporting invoices, but only purchase orders, were available for three expenditures ∙ One invoice was not stamped “paid”. Plan: We agree with the finding. Expenditures of federal funds will be more closely monitored, more adequately supported, and paid invoices will be marked as paid. Uniform Guidance will be more closely followed. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Dr. Lisa Caparelli-Ruff, Regional Superintendent

Assistance listing number and program name: 21.023 COVID-19 - Emergency Rental Assistance Program Agency: Arizona Department of Economic Security (DES) Name of contact person and title: Molly Bright, DES CCSD Assistant Director Anticipated completion date: June 30, 2025 Agency’s response: Concur The Department of Economic Security will address the audit recommendations as follows: The Department will prepare and retain detailed documentation including system reports, queries, screenshots, and other evidence supporting the program information being reported to the federal agency for each Emergency Rental Assistance Program (ERAP) award. DES will also abide by its policies and procedures to retain all records relating to federal awards for a period of 5 years after all the federal funds are expended. For future related programs with this requirement, the Department will develop and implement internal control policies and procedures that ensure systems properly display complete and accurate data on the federal reporting dashboard as instructed by the federal agency’s reporting guidelines. Additionally, these policies and provisions will ensure that any future ERAP award funding received by the Department will be separately reported to avoid commingling. Finally, the Department will require that ERAP personnel verify the reported program information to ensure all report element sections are complete and accurate, and that it matches the underlying benefits and financial systems data. The Department sunset the ERAP program on October 13th, 2023, due to an exhaustion of ERA 1 and ERA 2 funding.

Assistance listing number and program name: 17.225 Unemployment Insurance Agency: Arizona Department of Economic Security (DES) Name of contact person and title: Tracy Raymer, DES Business Analyst Manager Anticipated completion date: June 30, 2025 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: Develop and implement written policies and procedures to ensure it prepares and retains detailed documentation, such as system reports, queries, or screenshots, to support the program information it reports to the federal agency for the UI program for a period of at least three (3) years. Beginning July 2024, the Department has assembled and retained all detailed supporting source documentation that supports the data provided in the 9050 - Time Lapse of All First Payments except Workshare report and will retain it for a period of no less than three (3) years.

Assistance listing number and program name: 14.267 Continuum of Care Program Agency: Arizona Department of Housing (DOH) Name of contact person and title: Lori Moreno, DOH Human Resources and Procurement Administrator Anticipated completion date: March 31, 2025 Agency’s Response: Concur The Department will update written policies and procedures related to procurement to incorporate applicable aspects of Federal Regulations 2 CFR §§200.321, 200.322, 200.323, and 200.327. The updated policy will address competition through competitive bids, sole source selections, and retention of procurement documents. In addition, the policy will state the Federal requirements that are to be included in purchase orders and contracts.

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the eligibility determination of a child receiving meals. The School Corporation could not provide documentation supporting the eligibility for 10 of 40 students that received free or reduced-price meals for fiscal year 2022-2023. Of the 30 students for which documentation was provided, the School Corporation could not provide documentation that the one student’s benefits were calculated properly. Due to the lack of supporting documentation we were unable to determine the School Corporation's compliance with the Eligibility compliance requirement. Contact Person Responsible for Corrective Action: Juli Windsor Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This will include all reimbursements which are submitted to the treasurer must be signed by the school cafeteria managers and the food service director. The school will also implement policies to ensure that the Verification of Free and Reduced-Price applications have an adequate internal control to ensure the validity of the free and reduced applications. This will provide for segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Anticipated Completion Date: April 2024

FINDING 2023-006 Finding Subject: Community Development Block Grants/ State’s program and non-Entitlement Grants in Hawaii Reporting Summary of Finding: Reporting - Material Weakness, Modified Opinion Supporting documentation was not retained to be able to verify the information presented in the CDBG-CC Report on Jobs Retained report. Contact Person Responsible for Corrective Action: Heather Huff Contact Phone Number and Email Address: 812-274-3866 heather.huff@jeffersoncounty.in.gov Views of Responsible Officials: We concur with the findings. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: The original Corrective Action plan from 2021 audit was not followed once the previous employes was no longer with Jefferson County. The current employee will be documenting all reporting requirements with the Auditor’s Office and retaining a copy of the balance. Jefferson County is also working with Department of Housing and Urban Development to eliminate the loan cycle and establish a one time grant. Anticipated Completion Date: 12-31-2024

2023-005 Allowable Costs/Cost Principles – Indirect Costs U.S. Department of Education Education Stabilization Fund – Assistance Listing No. 84.425 Pass-Through Agency: Arizona Department of Education Pass-Through Number(s): All Pass-Through Numbers Present in the SEFA Recommendation: We recommend management to incorporate a management review control to ensure the calculation is complete and accurate and all supporting documents including the general ledger used for the calculation is retained in accordance with UG. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The district will have a process in place to update all documentation related to indirect costs and the calculations from the general ledger. Name(s) of the contact person(s) responsible for corrective action: Clementina Carlyle, Chief Financial Officer.

Planned Corrective Actions: MARR will retain a CPA consultant to implement a document retention policy that is consistent with federal document retention requirements.

The Bureau was unable to provide documentation that their annual report was submitted to the Kentucky Department of Tourism and as such, the report was unable to be tested. Mary Watkins and Julie Kirkpatrick will ensure that copies of all reports submitted to the Kentucky Department of Tourism, and documentation of timely submission will be retained.

ALN: 17.225, Corrective Action Plan: Inaccurate Federal Reporting - UI - DLI - Since the new Unemployment Insurance system launched (MUSE), the Montana Department of Labor and Industry has worked with its system vendor (FAST) to generate additional system reports, which are used to reconcile fiscal activity. The department has also procured the services of a vendor who will complete a reporting accuracy and efficiency assessment of the Unemployment Insurance program. The department has reconciled accounts and is working to document new processes. The department is also currently reviewing and, if necessary, revising reports. Person(s) Responsible for Corrective Measures: Jay Phillips, Administrator, Montana Department of Labor and Industry, Target Date: 12/31/2024

ALN: 84.010, Corrective Action Plan: Inadequate Subrecipient Monitoring - Title I - OPI - The Montana Office of Public Instruction Program Supervisor and Federal Grants Coordinator will create a new process to track and monitor Local Educational Entity (LEA) reviews, monitor findings, corrective actions identified, and whether corrective actions were completed and submitted within 90 days. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Inaccurate Federal Reporting - ESSER - OPI - The Montana Office of Public Instruction will update current data collection tools for the Elementary and Secondary School Emergency Relief Fund (ESSER) to validate data within a range. Validation criteria, including but not limited to data range, type, and values, will be applied to data collection template used for upcoming years of the grant. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

ALN: 84.371, Corrective Action Plan: Noncompliant Federal Reporting - Literacy- OPI - The Montana Office of Public Instruction grant staff and Literacy Program Instructional Coordinator will document reports and expenses in a single file to reduce duplication and to confirm expenditures are properly recorded. The reports will be gathered and reviewed quarterly. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

ALN: 93.575, 93.596, Corrective Action Plan: Inadequate Subrecipient Monitoring - CCDF - DPHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs will develop monitoring procedures to coordinate state plan requirements with contract requirements and make amendments to contracts when State Plan changes. Person(s) Responsible for Corrective Measures: Tracy Moseman, Administrator, Montana Department of Public Health and Human Services, Target Date: 12/31/2024

ALN: 93.575, 93.596, Corrective Action Plan: Inadequate Subrecipient Monitoring - CCDF - DPHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs have updated their 2023 contracts to include required disclosures. Risk assessments were completed annually, as required. However, the 2022 risk assessments were accidently copied over when completing the 2023 risk assessments. Controls have been updated to ensure copies of each risk assessment are now saved with procurement files to ensure files are not accidentally replaced. Person(s) Responsible for Corrective Measures: Tracy Moseman, Administrator, Montana Department of Public Health and Human Services, Target Date: Completed

Management agrees with the recommendation and will implement stronger processes to ensure that all records are organized and maintained for ease of timely and complete review and consultation when needed. The processes to organize and secure files will be executed by program staff, with oversight by the Vice President of Community Building and Neighborhood Resources, Executive Vice President of Housing and Community Programs, Vice President of Family Empowerment and Self Sufficiency, Chief Financial & Operating Officer, and Sr. Director of Finance. Due to timing of receiving this finding, remediation processes began in fiscal year 2024 and will be applied fully to the fiscal year 2025, beginning 7/1/2024, files.

Management agrees with and will implement the recommendation that processes be in place to review and confirm the completeness and accuracy of intake forms within the regulations while also considering the needs and choices of the program participants. The previous year’s finding was received after FY23 was substantially complete and making the necessary changes was not possible, resulting in recurrence. These file completeness processes will be executed by program staff, with oversight by the Vice President of Community Building and Neighborhood Resources, Executive Vice President of Housing and Community Programs, Vice President of Family Empowerment and Self Sufficiency, Chief Financial & Operating Officer, and Sr. Director of Finance. Due to timing of receiving this finding, remediation processes began in fiscal year 2024 and will be applied fully to the fiscal year 2025, beginning 7/1/2024, files.