Corrective Action Plans

The Administrative Services Office and the Student Affairs Office, or the Grant Manager/Principal Investigator responsible for any specific grants going forward, will work closely with the granting agency to ensure that any unanticipated changes/reductions in funding periods are communicated in time to allow the College to effectively close out the grant, or to obtain permission for funding of expenditures that will not be incurred/and or liquidated timely. Anticipated Completion Date: N/A Contact Person(s): Willie Noseep, Vice President for Administrative Services Coralina Daly, Vice President for Student Affairs

Planned Corrective Action 1.Corrective Action Already Taken •Staff involved in ARP-ESSER closeout have been briefed on the specific compliance failure and the regulatory requirement under 2 CFR § 200.344(c). 2.Corrective Actions to Prevent Recurrence A . Strengthened Reimbursement Request Review Process •No reimbursement request may be submitted without a two-step compliance review: 1.Grant Coordinator Review – Verifies liquidation occurred before the federal deadline and confirms documentation accuracy. 2.Finance Director Approval – Confirms federal compliance and signs off before submission. •Claims based solely on obligation without liquidation confirmation are now prohibited. B. Staff Training and Compliance Reinforcement •Annual training on federal grant compliance—including obligations, liquidation, period of performance, and closeout requirements under 2 CFR Part 200—will be provided to all finance, grants, and program staff. •Staff with direct responsibility for reimbursement claims will receive targeted training on liquidation rules. C. Internal Monitoring and Audit Review •Quarterly internal audits will be conducted to ensure: oExpenditures are liquidated within allowable periods. oThe new controls are functioning as intended. oAny exceptions are immediately corrected and reported to the Superintendent. 3.Person(s) Responsible for Corrective Action •Finance Director – Oversight of grant compliance, monitoring, approvals, and reporting. •Grant Coordinator – Daily oversight of liquidation timelines, tracking logs, documentation, and extension requests. 4.Anticipated Completion Date •Initial corrective actions implemented: March 2026. •Full implementation of revised policies, procedures, training, and documentation: June 30, 2026.

Finding Number: 2024-032 Audit Type: Single Audit Finding Title: Delayed Final Reimbursement Due to Unresolved Agency Requests Related Finding: 2024-023 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will designate a grants coordinator to monitor agency requests and ensure timely responses. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will improve communication with funding agencies. 5. Status of Prior Year Finding This is a newt finding.

Finding 2024-010 – Period of Performance (Material Weakness) Finding: The Organization did not have good controls to ensure the period of performance requirements was met due to staff turnover. Management Response: Management concurs. Corrective action plan: •Implement a grant compliance checklist and training for staff by the end of 2025 to ensure expenditures are within the grant period. •Require pre-approval for all expenditures near grant end dates. •Quarterly compliance reviews. Responsible Party: CFO Completion Date/Status: Expected to be Implemented by end of 2025; ongoing review.

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants,

Management has reinforced the effective execution of existing controls around proper documentation of all expenditures and record retention for these expenditures. Monthly and year-end procedures have been updated to ensure compliance with these procedures. Anticipated completion date: June 30, 2025.

2023-002: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout procedures, consequently, the district will monitor closely all grants spending throughout each grant cycle. For both state-administered and direct grants, regardless of the period of availability, the District must liquidate all obligations incurred under the award Reports not later than 90 days after the end of the funding period unless an extension is authorized. These procedures are included in the Financial Procedures Manual (pages 226-230 under Section G— Timely Obligation of Funds) Key Control Key Actions Resources Needed Timeline Outcome Grants Management Use appropriate resources to mitigate any errors, omissions and ensure timely maintenance of records and reporting Grant Management Form Grant Award Letter Internal Controls Guide GEM$ Trainings FY24, FY25 ongoing Implementation of preventive controls for ALL grant funding Contacts: School Business Manager & Town Accountant Submitted by, Annette Colón, Business Manager MBA, MCPPO, Notary Public Clinton Public Schools 150 School St. Clinton, MA 01510 (978) 365-4200 x 12241 colona@clinton.k12.ma.us

The Foundation immediately paid the vendor the full amount upon learning of this finding from the auditor and verified that the vendor received the payment. The recording of Grant Revenue/Accounts Receivable and Grant Expenses/Accounts Payable is now done for each grant expense immediately upon approval from the Foundation and submission to New York State for reimbursement. This was previously not done. The changes to the recognition of revenue and expenses are already in effect and should eliminate any future finding related to the non-payment of expenses that have been reimbursed through grants.

Finding Number 2024-007: Period of Performance – Material Weakness in Internal Control over Compliance and Noncompliance Corrective Action: To ensure compliance with 2 CFR §200.344(b), Management will implement formal policies and procedures requiring that all financial obligations under federal awards be liquidated within 120 calendar days after the end of the period of performance. Grants Accounting will establish a documented review and tracking process to monitor grant deadlines, identify outstanding obligations, and ensure timely payments. These actions are intended to strengthen controls, ensure timely liquidation of expenditures, and prevent recurrence of prior year findings. Name of Responsible Individual(s): Jason Brenier, Shelly Courtois, Judy Bokhari, and Sandra Shannon Anticipated Completion Date: September 2025

Communicate with the Budget Board regarding this finding. We have already introduced to the budget board, a form guideline called "Payne County Grant Administration Plan" to aid in proper documentation, repo1ting and proper spending of all grant awards, including creating a capital outlay sub account as recommended.

Management will ensure Federal expenditures are obligated during proper period and reported appropriately.

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: 2024-035 -Six of seven award extensions for the NGMOMP program were untimely. Additionally, one award was not closed timely. Questioned Costs: None Assistance Listing Number: 12.401 Assistance Listing Title: NGMOMP Views of Responsible Officials (state whether your agency agrees or disagrees with the finding if you disagree, briefly explain why): DMVA concurs with the finding. Corrective Action (corrective action planned): Administrative Services has consistently provided notification and set clear deadlines to the Federal and State Program Managers of an expiring award under the Cooperative Agreement (CA). This notification has included a financial report detailing posted expenses and open obligations and when applicable, a copy of the most resent approved extension for reference. Due to inconsistent and untimely responses, the Finance officer in conjunction with the Administrative Services Director will update and strengthen written procedures, elevating responsibility for follow-up when responses are not received to ensure timely submission of extension requests and award closeouts following 2 CFR 200.303(a), 2 CFR 200.308(e), and 2 CFR 200.344. Updated documented procedures and training will be provided to the components under the CA. Completion Date (list anticipated completion date): 06/30/2025 Agency Contact (name of person responsible for corrective action): Bob Ernisse Pamela Wiederspohn

Finding: The Housing Finance Commission did not have adequate internal controls over reporting requirements for the Homeowner Assistance Fund program. Questioned Costs: Assistance Listing # 21.026 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: To address the deficiencies identified by the auditors in completing annual performance reports, the Commission has taken the following corrective actions to strengthen controls over reporting for the Homeowner Assistance Fund (HAF) program: • Updated procedures to require: o Homeownership Division and Finance Division staff to perform regular reconciliation of records to identify any discrepancies and to ensure all records are complete and accurate. o Supporting data obtained for reporting be vetted by the contractor and the Homeownership Division staff. o Leadership (division manager or above) to perform final review of data as well as the quarterly or annual report prior to submission to the grantor. • Designated the records maintained by the Finance Division, specifically the general ledgers, as the source of financial data for the quarterly and annual reports for the Washington HAF program. • Required third parties to develop or update a program manual regarding data used for reporting purposes. The manual incorporated recommendations of the audit finding. As of June 30, 2024, the Commission consulted with the U.S. Department of the Treasury to determine if revision and resubmission of the reports are necessary to correct amounts reported. No corrective action was required. The conditions noted in this finding were previously reported in finding 2023-025. Completion Date: June 2024 Agency Contact: Lucas Loranger Senior Finance Director 1000 Second Ave, Suite 2700 Seattle, WA 98104-3601 (206) 464-7139 Lucas.Loranger@wshfc.org

Significant Deficiency Other Matter – Non-Major Federal Award Program 2024-002. Questioned Costs United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Pass-through Entity Number: 0032-23-0415 Condition: The District received total reimbursement for its 2022-2023 IDEA, Part B (Section 611) Federal grant award that exceeded the program’s final total expenditures, but did not notify the pass-through entity of the overpayment to refund the overpayment. Planned Corrective Action: The District’s Assistant Business Administrator will contact the NYSED for instructions to submit a corrected final expenditure report, and begin the overpayment refund process. Responsible Contact Person: Mr. Ivono Stintug Assistant Business Administrator Freeport Union Free School District 235 North Ocean Avenue Freeport, New York 11520 Tel: (516) 867-5235 Email: istintug@freeportschools.org Anticipated Completion Date: April 30, 2025.

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

Period of Performance Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Explanation of disagreement with audit finding: NO Action taken in response to finding: Review grant related procedures to ensure all expenditures take place during the grant period. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Crimer, Patrick Fletcher, & Kyera Pope. Planned completion date for corrective action plan: 6/30/25

Dear Mr. Waguespack, Please find below the University's management response to the audit finding titled “Noncompliance with Period of Performance Requirements." Management Response: The University concurs with the audit finding. Expense Posting Delay ($28,833): This salary charge reflects work performed within the approved award period. The delay occurred because the Personnel Action Form was received after the June payroll run, resulting in disbursements in July and August. Although the work was completed on time, the payroll posting did not align with the period of performance requirements. We are reviewing our processes to ensure all required documentation is received and processed promptly. Liquidation of Obligations ($34,957): The University failed to liquidate obligations totaling $34,957 within 120 days following the period of performance. This shortfall is due to staffing challenges in the Sponsored Programs Finance Administration and Compliance (SPFAC) Department. The University is actively exploring strategies to attract and retain qualified grant accountants to improve timely fund closeouts. Additional Mitigation Measures 1. Engaging External Consultants: o The University will engage an outside consultant to assess the university's research and administration structure, identifying opportunities to enhance processes and ensure compliance. o The University is retaining interim professional staffing to assist with invoicing and pre-audit review and to provide functional and technical expertise. 2. Deployment of an Electronic Research Administration System (eRA) o The University has begun identifying and implementing an electronic research administration system to transform grant management by offering a centralized platform that automates the entire lifecycle from proposal to closeout, minimizing manual errors while ensuring policy compliance and providing clear portfolio visibility through comprehensive reporting capabilities. The SPFAC Director will oversee the implementation of these corrective actions.

RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions or withholding of grant monies from PDE as a result of not filing these reports in a timely manner. MANAGEMENT’S PLANNED CORRECTIVE ACTION: The StoRx School District will implement procedures for timely and accurate reporting of the Final Expenditure Report (FER). The financial information in the FER will accurately reflect internal reporting information according to the Manual of Accounting and Financial Reporting for Pennsylvania Local Educational Agencies and the PA Chart of Accounts. The timeframe for completion will be effective for the 2024-2025 fiscal year.

A.    DESE has informed us that if this situation ever comes up in the future, asking for a federal extension if buses were not going to be delivered in a timely manner, in this case by January 10, 2025. The manufacturer assured us that the buses would be delivered by November 4, 2024 so we didn’t asked for the extension.

B.     In the future, we will wait until buses are on site to write checks.

C.     We do not anticipate any ESSER ARP money to be issued in the near future.

Corrective Action Plan-In our commitment to due diligence and adherence to compliance requirements for the expenditure of funds from a federal grant, the School District contacted the responsible representatives at the Rhode Island Department of Education (RIDE) to seek guidance on establishing a multi-year contract for curriculum materials. The budget description submitted to RIDE for approval indicated that the School District adopted the Bridge program in March 2024. It detailed that the associated expenses would be incurred under a six-year contract covering licenses and consumables, classified as High-Quality Curriculum Materials. This expense received both programmatic and budgetary approval from the Rhode Island Department of Education.Moving forward, the School District will request all supporting documentation to ensure compliance to the laws and regulations governing any federal or state grant.Anticipated Completion Date – June 30th, 2025Contact Person – If you have any additional questions, please feel free to contact me.Taisabel Lopez,District Treasurer401-397-5125 x 2021Taisabel_Lopez@ewg.k12.ri.us

Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Questioned Costs: $125,035.65 The costs in question were not billed to or collected from the awarding agency. Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2023 audit report in May 2024. The 2023 audit was completed after substantially all of Fiscal Year 2024 had elapsed, so there was not adequate time for the University to fully implement corrective action. The University is strengthening the close-out process of federal awards to halt expenditures thus reducing redistributions and cost-transfers. Name(s) of the contact person(s) responsible for the corrective action: Mr. Robert Dixon, Director, Grants and Contracts Fiscal Administration at Oklahoma State University and Mr. Chris Kuwitzky, Vice President for Fiscal and Administrative Affairs. Planned completion date for corrective action plan: March 2025