Corrective Action Plans

MANAGEMENT’S PLANNED CORRECTIVE ACTION: Management has contracted with a third-party – J. Martin & Associates, LLC to perform certain of the District’s business office functions, as well as provide general oversight in all areas of the business office. One such function will be the timely preparation and submission of federal grant Final Expenditure Reports in compliance with PDE rules and regulations. The timeframe for implementation of these duties is effective immediately.

2023-003 Cash Management / Period of Performance – Control Deficiency View of Responsible Officials Management appreciates the opportunity to respond to the findings of the audit. The Hawaii State Public Library System (HSPLS) makes every attempt to meet all federal laws and guidelines for funding that is received. Many factors outside our control directly impacted the timely payment of vendors as noted in the audit. Specifically: 1) Federal budget uncertainty; delay in receiving federal funding. For the past several years, Congress has not been able to pass a comprehensive federal budget, and instead has funded the Grants to States fund via continuing resolutions making it difficult to plan out expenditures with any certainty. In addition to lacking the certainty of when and/or if funding will be available, the Grants to States funds have not been released to states in a timely manner, including during the audit period. Instead of at the beginning of the federal fiscal year around October 1st, funding has been received months later, leaving States with a lot less time to procure, process and receive purchases. This means we do not have access to the funding for the full grant cycle and directly impacts if/when we are able to procure goods and services. 2) Supply chain and shipping issues. The State of Hawaii procurement requirements do not allow us to pay for goods and services until we receive the products or the services are rendered satisfactorily. HSPLS continues to face significant supply chain and shipping issues which affects the timely payment of vendors. As an island state in the middle of the Pacific Ocean, there are often delays in receiving an entire shipment on time in full, even post-pandemic. For large products or orders, sometimes the order and/or related parts are not shipped together further delaying completion of the order by the vendor and issuance of the invoice. In many instances, vendors do not send their invoices in a timely manner, preventing HSPLS from dispersing funds in a timely manner. 3) Federal agency guidance. We would also like to note that in the past, we have contacted our funding federal agency and let them know that we have had challenges with supply chain and shipping issues. We were advised that it was understood, and that as long as we had encumbered the funds by September 30, that we would be able to use the funding that was allotted to us even if the invoice is received after the close of the federal fiscal year. Corrective Action Plan We will do our best to continue to monitor and minimize any untimely disbursements of federal funds. Contact Person: Stacy A. Aldrich State Librarian Hawaii State Public Library System Anticipated Completion Date: Ongoing

Department: Education Administrative and Financial Services Title: Internal control over Special Education period of performance needs improvement Questioned Costs: Known: $2,446,391 Likely: Undeterminable Status: Corrective action in progress Corrective Action: In FY22, Maine DOE implemented a new grants management system. The implementation of the new system and staffing created delays in final payments. The Office of Special Services and Inclusive Education will review and implement stronger internal controls to monitor final payments for timeliness. Completion Date: June 30, 2024 Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

FINDING: 2023-004 Internal Control and Compliance over Period of Performance Recommendation: We recommend the Partnership establish procedures to ensure the funds are obligated and utilized in the proper period of performance. Action taken: Community Partnership is working with our state association, CAAP, to update internal controls and fiscal policies. Procedures to ensure that obligated funds are spent and utilized within the proper period of performance will be included in updated fiscal policies. Most of these issues resulted from the separation with our previous accounting/fiscal services provider who managed our fiscal and accounting services in the 2022 funding period. CP has worked to satisfy almost all outstanding obligations from this separation during the 2023 CSBG funding period, and currently has no outstanding obligations from the 2023 CSBG funding period. Moving forward, CP staff will work diligently with our selected vendor and board of directors to ensure that all funds are spent down within their designated funding periods.

Finding 2023-002 – Significant Deficiency Assistance List Number: 97.039 – Hazzard Mitigation Grant Pass-through Agency: California Governor’s Office of Emergency Services, FEMA-4344-DR-CA. Compliance Requirement: Reporting. Condition: The District did not provide project closeout materials to the pass-through agency within 90 days of the end of the period of performance so the pass-through agency could prepare the closeout reporting within 120 days of the end of the period of performance. Criteria: The Notice of Funding Opportunity indicates: “In addition, pass-through entities are responsible for closing out their subawards as described in 2 C.F.R. § 200.344; subrecipients are still required to submit closeout materials within 90 calendar days of the period of performance end date. When a subrecipient completes all closeout requirements, pass-through entities must promptly complete all closeout actions for subawards in time for the recipient to submit all necessary documentation and information to FEMA during the closeout of the prime award.” Cause: The District’s staff were waiting for a requested extension for the period of performance from the pass-through agency and assumed the closeout reporting would not be necessary. Effect: The District is not in compliance with the terms and conditions of the federal award. Recommendation: We understand the District provided the information necessary to complete the closeout reporting to the pass-through agency on November 30, 2023. Views of Responsible Officials and Planned Corrective Actions: As indicated in the recommendation, the District provided the information necessary to complete the closeout reporting to the pass-through agency on November 30, 2023. Furthermore, on March 22, 2024, the District heard from the pass-through agency that FEMA received the requested extension, and it is in the queue for final approval and signature. The corrective action has been completed.

Finding Number: 2023‐004 Federal Program, Assistance Listing Number and Name: ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Condition: Original Finding Description: The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days. Contact Person Responsible for Corrective Action: Terri Daniels (ODG), Regina Greear (ODFS), Denise Fair Razo (DHD) Anticipated Completion Date: June 2023 Planned Corrective Action: During the AFCAP process, the OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved and processed timely and accurately for payment prior to the 60 liquidation requirement period.

Finding Number: 2023-001 Planned Corrective Action: The Dayton Early College Academy will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 07/01/2023 Responsible Contact Person: Steven Hinshaw, Treasurer

Finding No.: 2022-042 AL Program: 97.036 - Disaster Grants - Public Assistance (Presidentially Declared Disasters) Area: Period of Performance Questioned Costs: $423,234 Contact Person(s): Patrick Guerrero, Governor’s Authorized Rep., PAO Corrective Action Plan: Condition 1: 1. Regarding the finding related to DR4235MP, PW 95, the Public Assistance Office agrees that the liquidation was processed after the liquidation deadline. 2. Regarding the finding related to DR4396MP, PW 4, the Public Assistance Office disagrees with this finding. Liquidation was done prior to the closeout deadline of December 31, 2022. 3. Regarding the finding related to DR4511MP, PW 27, the Public Assistance Office disagrees with this finding. Liquidation was done prior to the closeout deadline of June 30, 2025. 4. Regarding the finding related to DR4511MP, PW 8, the Public Assistance Office disagrees with this finding. Liquidation was done prior to the closeout deadline of June 30, 2025. As of Fiscal Year 2024, the Public Assistance Office initiates drawdown requests, allowing for more timely processing. The office will implement better financial monitoring procedures to ensure obligations are liquidated within the required liquidation period. Staff will also be refreshed on liquidation requirements to ensure compliance. When delays are anticipated, the office will coordinate with subrecipients and promptly request necessary time extension approvals from Grantor to maintain compliance. Proposed Completion Date: Ongoing Condition 2: The Public Assistance Office respectfully disagrees with this finding. • Regarding the finding related to DR4235MP, PW 49, the Public Assistance Office disagrees with this finding. The invoice was dated and recorded after the period of performance (June 30, 2022), but date of actual work completed as shown on the Megger Test was May 20, 2022. The Public Assistance Office acknowledges that the record of the Megger Test had not been submitted to the auditors when submitting documentation. The Public Assistance Office will continue to exercise diligence in reviewing project documentation to ensure that all work is verified and completed prior to payment/reimbursement. The office will continue to monitor performance timelines to confirm that work is completed on or before the established period of performance deadlines. This process will include periodic internal reviews and coordination with subrecipients to ensure compliance. When delays are anticipated, the office will coordinate with subrecipients and promptly request necessary time extension approvals from Grantor to maintain compliance. Proposed Completion Date: Ongoing

Finding No.: 2022-035 AL Program: 93.767 - Children’s Health Insurance Program Area: Period of Performance Questioned Costs: $38,556 Contact Person(s): Geroge J. Cruz, Medicaid Director Corrective Action Plan: The CNMI Medicaid Office respectfully disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, the office maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Proposed Completion Date: Ongoing

Finding No.: 2022-024 AL Program: 21.023 - Emergency Rental Assistance Program Area: Period of Performance Questioned Costs: $26,329 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: Condition 1: The Office of Grant Management (OGM) respectfully disagrees with this finding. OGM recollects prior guidance and program discussions indicating that U.S. Territories administering ERA were afforded greater flexibility in the period of performance, in recognition of their geographic remoteness and the additional time required to receive technical assistance and implement compliant systems. This understanding informed OGM’s administration of ERA funds. Additionally, several disbursed checks were returned, which created reconciliation delays and made it difficult to ascertain the true unobligated balance of the grant until sufficient time had passed for all transactions to clear. To address compliance concerns, CNMI officials traveled to Washington, D.C. in February 2025 to meet with U.S. Treasury representatives and resolve outstanding ERA1 documentation issues. Following those meetings, OGM submitted the necessary reports and initiated the closeout process for ERA1 in accordance with federal requirements. The questioned cost of $26,329 reflects expenditures that were directed toward eligible households impacted by COVID-19. These expenditures were necessary, reasonable, and allocable under 2 CFR 200.403, and fully aligned with the statutory purpose of ERA to prevent housing instability. Disallowing these costs would effectively negate assistance that was properly delivered to beneficiaries and undermine the program’s objective. For these reasons, OGM respectfully requests that the questioned cost be removed. Proposed Completion Date: Ongoing Condition 2: The Office of Grant Management (OGM) respectfully disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, OGM maintain all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Proposed Completion Date: Ongoing

Finding No.: 2022-016 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Period of Performance Questioned Costs: $494,836 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1 (E. Cabrera): The Office of Grant Management (OGM) respectfully disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, OGM maintain all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Based on our records, grant award D20AP00005 remains active with a period of performance extending through September 30, 2025, while grant award D20AP00037 was closed on September 30, 2024. Both grants remained operational well beyond the originally prescribed September 30, 2022 deadline. Given the extended period of performance authorized by the awarding agency, all associated questioned costs ($494,660.00) are supported by active grant activity and should be deemed allowable. Accordingly, OGM respectfully requests that these questioned costs be removed, as they reflect legitimate expenditures incurred within the approved grant periods. Proposed Completion Date: Ongoing Condition 2 (N. Karakaya): CIP agrees with the finding. To address the finding and prevent recurrence, CIP will: - Revise and strengthen written financial management policies to clearly define documentation requirements to substantiate expenditures and ensure costs are within the award’s period of performance. - Incorporate federal regulation references, including 2 CFR 200.303 (Internal Controls) and 2 CFR 200.344 (Closeout). - Implement a standardized checklist for technical analyst and program managers to confirm that all expenditure documentation includes dates verifying that costs were incurred within the period of performance. - Require a secondary review and sign-off by the CIP Administrator prior to submission of documentation to auditors. - Conduct mandatory annual training for program on federal period of performance requirements and required supporting documentation standards. - Provide refresher sessions before each audit cycle. - Establish a quarterly self-audit of grant files to verify that documentation is complete and properly supports expenditures. - Document results of each review and address deficiencies immediately. The responsible official will report progress on corrective actions to the CNMI leadership and maintain documentation of all implemented changes. Evidence of compliance (updated policies, training records, and self-audit reports) will be provided to the auditors upon request. Proposed Completion Date: December 31, 2025

The Government concurs with the auditor's findings and recommendations. As part of the close-out process, all open purchase orders are now submitted to the Department of Finance to be closed. Additionally, the grant close out process has now shifted to OMB to ensure the grant is no longer available for transactions entries or liquidations. Additionally, a dedicated Fiscal Analyst is being inserted into the workflow to ensure compliance.

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 2022-003, Cash Management - Repeating Finding 2021-003 Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Corrective Action: We agree with the auditor's comments and actions stated in the recommendation. CMSDC will update its policies and procedures to include procedures for reconciling expenditures to cash drawdowns monthly. Contact Person: Jose Robles Michelena, Executive Vice President Completion Date: June 30, 2024

Management agrees with the findings and has already initiated corrective actions. Moving forward, budget-to-actual comparisons will be prepared monthly, and any discrepancies will be addressed promptly. The organization will work closely with the cognizant agency to arrange for the return of any unobligated funds or, if applicable, seek authorization to retain the funds for use in other similar programs. This process will ensure proper financial management and compliance.

Invoices that are received will be scanned to “invoices”. This will direct them to our electronic software, Docuware. The item will then be forwarded to the appropriate Program Director for approval, and they will indicate the appropriate cost centers / allocations. Bookers will then review the approved coding and entered fiscal software. If there is a question or concern about approved coding by the bookkeeper they will speak with Director of Finance, Ethan Terrio. Once invoices are entered into fiscal software, checks will be printed. The check stub and invoice will be attached to each other and filed in the fiscal department. Paper documents will continue to be maintained in fiscal until we go 100% paperless, then all documents will be stored in Docuware.

Dear Mr. Waguespack,We appreciate the opportunity afforded to review and respond to the revised audit finding regarding the "Weakness in Controls over Research and Development Project Closeouts and Accounting Records".Finding: Weakness in Controls over Research and Development Project Closeouts and Accounting RecordsManagement concurs with the finding listed in the report.Response to Finding and Corrective Actions:We agree with the finding that the audit identified ledger transactions incurred outside of 120 days from project end dates. Although LSUHSC-NO has made considerable progress in rectifying the weakness by implementing corrective plans identified in prior findings, significant turnover in departmental business managers and difficulty in recruiting personnel have impacted the complete resolution of the issue.Despite the considerable progress made, your office identified three (3) projects as being non-compliant. Of these projects, the FFR/final invoice was submitted within federal guidelines of 120 days. Thereafter, a credit was applied resulting in a revised FFR/final invoice and refund to the sponsor.It should be further noted that of the remaining seven (7) projects with control issues, none had questioned costs and are summarized below:? Four (4) projects had no effect on the Federal Financial Report (FFR) submitted or drawdown of funds. The expenditures included on the FFR and the requested funds were reasonable, allocable, allowable, and within the project closeout timeline.? One (1) project had transactions due to the month end indirect cost allocation process which was within the posting guidelines for the institution and within the period included in the 120 days .? Two (2) projects were authorized for an extension as supported by the documents provided to the auditor.LSUHSC-NO is committed to continued fiscal responsibility, partnership and training as evidenced by the following corrective actions:1) Sponsored Projects Accounting ("SPA") will initiate training for Departmental Business Managers and School Fiscal Deans to review single audit compliance requirements, project management, and SPA related reports and expectations.Responsible Personnel for #1: Sponsored Projects AccountingAnticipated Completion Date: June 30, 20232) Accounting Services will investigate the feasibility of implementing automated system controls in PeopleSoft to prevent costs from being charged to projects beyond close out periods or the feasibility of providing SPA with the authority to close out projects not addressed by the Schools in a timely manner.Responsible Personnel for #2: Executive Director of Accounting ServicesAnticipated Completion Date: December 31, 20233) In recognition of the significant turnover in Business Managers, LSUHSC-NO has increased the salaries of the departmental business managers to attract and retain effective team members. SPA has recently hired two new positions in response to the previous years' finding. Additionally, LSUHSC-NO will commit to hiring a third new position in SPA.The Director for Financial Reporting , Asset Management & Sponsored Projects Accounting position was recently created to provide a higher level oversight in the department. The director is reassessing the roles and responsibilities of the existing staff in the department and has identified opportunities for better utilization of the employees.Responsible Personnel for #3: Executive Director of Accounting ServicesAnticipated Completion Date: December 31, 2023Furthermore, LSUHSC -NO will continue the following ongoing corrective actions previously implemented:4) The Fiscal Dean of each School or his/her designee will continue to review and monitor departmental compliance with Chancellor Memorandum ("CM-21"), which includes the responsibilities of the required financial management of an individual project or group of projects.5) The Fiscal Dean of each School or his/her designee will ensure their Business Managers are properly trained on the following: monitoring budgets and timely collections of overruns, project closeout procedures, and account reconciliation in compliance with CM-21.Responsible Personnel for #4 and #5: School Fiscal DeansAnticipated Completion Date for #4 and #5: June 30, 20216) SPA will continue to provide PeopleSoft Financials error reports to applicable Business Managers and Fiscal Deans for immediate action with errors such as: projects with an end date that has passed, projects in deficit, or projects not setup to accept personnel expenses.Responsible Personnel for #6:Departmental Business Managers School Fiscal Deans Sponsored Projects AccountingAnticipated Completion Date for #6: February 20227) SPA will continue to escalate and follow-up on requests to correct projects with expenditures posting beyond 90 days that are not addressed in a timely manner to the Principal Investigator, Department Head, Dean, and Chancellor as necessary.Responsible Personnel for #7: Sponsored Projects AccountingAnticipated Completion Date for #7: January 5, 2023If you have any additional questions or concerns, please do not hesitate contacting me.

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.

Suggested Action (s)- Create an SR (Service Request) with Oracle to prevent transactions coming from subledgers after the award expiration date. Update and share the award closeout checklist under the ERP platform emphasizing the critical activities and timelines to ensure successful and timely closure of awards. Develop additional reports in ERP system to support the analysis of expenses charged to the awards after their expiration dates for timely remedial actions. Responsible Official- Global Controller Senior Director Finance Systems & Operations Regional Finance Officers Country Program SMT. Completion Date- September 30th, 2023.

2022-006: Internal Control Over Compliance and Compliance with Period of Performance Management is emphasizing prompt period closing to ensure that know Items are recorded in the wrong period. New layers of internal control have been added to ensure detailed review of accounting transactions. The ERM department is in the process of hiring an international compliance director, whose team will work as the second set of eyes (internal audit function) to ensure compliance. Individual(s) Responsible for Corrective Action Plans: Simon Peter Kabogoza, Controller, Heartland Alliance International skabogoza@heartlandalliance.org Anticipated Completion Date: 12/2023 Anticipated Completion Date:

Finding 2022-005: Internal Control Over Compliance and Compliance with Period of Performance Management through the local offices has already developed a policy to ensure that the period of performance is adhered too. Management is in the process of hiring another international compliance officer in both US and Iraq to particularly focus on grants performance requirements and sub-recipient grants management. Management through its Enterprise risk management is planning to schedule trainings for various departments concerning period of performance. Individual(s) Responsible for Corrective Action Plans: Simon Peter Kabogoza, Controller, Heartland Alliance International skabogoza@heartlandalliance.org Anticipated Completion Date: 12/2023

FINDING 2022-005 Contact Person Responsible for Corrective Action: George ann Ewald, Director of Finance & HR Contact Phone Number: (574) 277-4452 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Assistant Fire Chief will ensure that all required reimbursement requests, quarterly performance reports, and semi-annual SF-425 ?Federal Financial Reports to the Federal Emergency Management Agency (FEMA)? are completed thoroughly, accurately, and on-time. The Fire Chief will direct the Assistant Fire Chief to complete the reports via the FEMA GO website. Once each of the reports have been submitted, the Assistant Fire Chief will print the completed documents and obtain signatures from each of the following individuals: 1. Prepared By: (NAME), Assistant Fire Chief 2. Submitted By: (NAME), Assistant Fire Chief 3. Reviewed & Approved By: (NAME), Fire Chief Anticipated Completion Date: ? Implementation: June 2023

Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Corrective Action Planned: To date all grants required to be closed out have been completed. Anticipated Completion Date: 2022-2023 school year Contact: Thad King, Superintendent of Schools

Finding: 2022-021 Department of Human Services Response/Corrective Action Plan: The Department of Health and Human Services agrees with the recommendation. The Department will run reports from AWARE quarterly to identify any payments made from the system that were charged to the incorrect period of performance. Contact Person: April Haring, Program Accountant for Vocational Rehabilitation Anticipated Completion Date: The Department began running the report in December 2022.