Corrective Action Plans

The RIEMA Recovery staff will conduct an additional review of all projects prior to obligation including both small and large projects. This review will include not only that the state required documentation is included but will also review the FEMA final validation report submitted with the project. We acknowledge the errors which were reported by the State audit review of project number 694201 for federal disaster declaration DR-4505-RI. The agency will contact the Office of Housing and Community Development of the finding and they will be required to reimburse FEMA the unallowable costs. Anticipated Completion Date: RIEMA is implementing this immediately for all project reviews. Contact Person: Lawrence Macedo, Recovery Branch Chief, Rhode Island Emergency Management Agency lawrence.macedo@ema.ri.gov

DHS has a policy for subrecipient monitoring, which includes documentation required to be submitted by a subrecipient. The documentation is based on assessing the risk of each subrecipient. There is no requirement in the Uniform Grant Guidance in regard to supporting documentation requirements. The invoice needs to be certified by an authorized agent and the expense needs to have been reasonably incurred. DHS ensures compliance in numerous ways, including monthly programmatic meetings, site visits, review of single audits and past performance. Additionally, DHS contracts include a budget narrative and allows for DHS to require additional documentation for audit purposes. If requested, DHS would have been able to produce more documentation to satisfy the allowability of costs. Anticipated Completion Date: Not Applicable Contact Person: Ben Quattrucci, Associate Director Financial Contract Management, Department of Human Services benjamin.a.quattrucci@dhs.ri.gov

2024-044a: Management agrees with this finding and will communicate the requirements for subrecipient monitoring and specifically the review of single audit reports to our agency partners for implementation. 2024-044b: Management agrees with this finding and will communicate the requirements for subrecipient monitoring and specifically the review of single audit reports to our agency partners for implementation. 2024-044c: Management agrees with this finding and will communicate the requirements for subrecipient monitoring; specifically, the documentation of expenses, and meeting notes. Anticipated Completion Date: Completed April 23, 2025 Contact Persons: Paul L. Dion, Director, Pandemic Recovery Office, Department of Administration paul.l.dion@doa.ri.gov Brianna Ruggiero, Chief of Staff, Pandemic Recovery Office, Department of Administration brianna.ruggiero@doa.ri.gov

Federal Fund Source liquidation is monitored monthly via the Fund Source Reconciliation Report and the Provider Utilization Report. Requests to close purchase orders associated with expiring federal fund sources are submitted to OPC accordingly. The Federal Financial Reporting Group will now have the right to close purchase orders with federal fund sources to expedite this process. Also, the Provider Utilization Report has been updated with Key Performance Indicators (KPIs), Contract End Date Exceeds Period of Performance and Payments Exceed Period of Performance, that specifically address the period of performance as of December 2024.

Georgia Tech management agrees that internal audit reports demonstrated departmental deficiencies in knowledge of policies and procedures that needed to be addressed. Upon disclosure of Internal Audit’s recommendations, the departments and central offices immediately responded with additional training, proactive compliance reviews, and re-enforcement of existing policies and procedures via Institute wide communications and enhanced reviews of support. New system controls regarding spend authorizations were put in place, with Georgia Tech’s Internal Audit department continuing to test these controls through the month of February. Central and departmental units within Georgia Tech will continue to work together to further enhance guidance and training to faculty and staff and to identify and test controls in our systems that will mitigate these issues.

1. Implement pre-approval controls; require date validation for all expenses against the award' s period of performance. Program Director or Executive Director or Accounting Director to review and approve. 2. Conduct training; educating staff on 2 CFR requirements and period-of-performance limitations. 3. Perform periodic reviews; monitor compliance quarterly to detect outliers.

1. Implement pre-submission controls; require Date validation for all expenses against the award's period of performance. Program Director or Executive Director or Accounting Director to review and approve. 2. Conduct training; educating staff on 2 CFR requirements and period-of-performance limitations. 3. Perform periodic reviews; monitor compliance quarterly to detect outliers.

Corrective Action Plan for finding number 2024-001 Corrective action to be taken: The COVID-19 Emergency Rental Assistance program ceased accepting new applications on March 28, 2025. Prior to that a quality control process was in place to review applications before they were approved for payment to try to catch errors such as this. No further benefit payments will be issued as the program is being closed out. We have created a new internal review section that will focus on reviewing all potential issues identified. We have also engaged KPMG, LLP to audit any payments made that may be subject to recapture. Anticipated completion date All efforts are already under way and every attempt will be made to recapture any overpayments prior to monitoring (yet to be announced) by the U.S Department of the Treasury. Contact for the corrective action S. Kyleen Welling, Chief of Staff and Chief Operating Officer

View of Responsible Officials and Corrective Action Plan We acknowledge the findings and appreciate the diligence of the audit team in identifying the discrepancies in our indirect cost calculations and reporting as outlined in the draft findings. The Veterans Integration Center (VIC) is committed to maintaining the highest standards of compliance with all federal regulations and grant requirements. Corrective Action Plan 1. Training and Guidelines: All relevant staff will undergo training to understand and implement the correct procedures for calculating indirect costs. Comprehensive guidelines will be developed and disseminated to ensure consistency across all calculations and reporting. 2. Completion of SF-425 Jointly: The COO, and VIC’s contracted Accountant will confirm the accurate Modified Total Direct Costs (MTDC) which is to be used in completing the SF-425, then prepare the GPD SF-425 jointly to ensure its accuracy. 3. Review and Approval Process: An additional layer of review and approval will be established for all indirect cost calculations before they are reported. This step will involve our Chief Executive Officer (CEO) to ensure accuracy and compliance. Corrective Action Plan Timeline • Staff Training and Guidelines Distribution: Completed by Q4 2025 • Completion of SF-425 Jointly: Starting Q3 2025 with SF-425 revision • Review and Approval Process: Effective immediately, with CEO, reviews starting Q3 2025 Designation of Employee Position Responsible for Meeting Deadline The Chief Operating Officer (COO) will be responsible for the oversight and successful implementation of the corrective action plan. The COO will coordinate with the contracted internal Accountant to ensure all actions are taken within the stipulated timelines and report directly to the Chief Executive Officer on the progress.

2024-032 Department of Justice Ensure program expenditures are supported Management Response: The Oregon Department of Justice agrees with the finding and provides the following information regarding the cause of this error and corrective action planned for implementation by June 30, 2025, which will be implemented by the Interim Financial Services Manager Richard Rylander. This error was caused through a lack of secondary validation of expenditures which resulted in incorrect expenditures being entered into the system. The correction action plan will update the Secondary Review of Expenditures and Batch Entry Process to ensure that the secondary review identifies and prevents errors which caused the finding above. Anticipated Completion Date: June 30, 2025 Contact person: Richard Rylander, Interim Financial Services Manager

2024-032 Department of Justice Ensure program expenditures are supported Management Response: The Oregon Department of Justice agrees with the finding and provides the following information regarding the cause of this error and corrective action planned for implementation by June 30, 2025, which will be implemented by the Interim Financial Services Manager Richard Rylander. This error was caused through a lack of secondary validation of expenditures which resulted in incorrect expenditures being entered into the system. The correction action plan will update the Secondary Review of Expenditures and Batch Entry Process to ensure that the secondary review identifies and prevents errors which caused the finding above. Anticipated Completion Date: June 30, 2025 Contact person: Richard Rylander, Interim Financial Services Manager

2024-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES Significant Deficiency Auditee’s Response and Planned Corrective Action FHA is retraining staff on procurement policy and reinforcing the requirement for pre-approval before payment. A checklist will be added to all invoices to confirm documentation is in place before submission for payment and a second signer will be responsible for signing invoices in the event of the absence of the Executive Director. Random monthly internal audits will be conducted to ensure continued compliance. Planned Implementation Date of Corrective Action: Immediate Person Responsible for Corrective Action: Benjamin Anako, Fiscal Officer

Corrective action plan: Management is in the process of implementing a method for employees to charge their time to grants, as needed, from the payroll system. Personnel responsible for corrective action: Timothy Jodway, Interim Chief Financial Officer. Estimated corrective action completion date: May 2025

Finding 2024-02: Indirect Costs (IDC) Views of Responsible Officials Management agrees with the finding and recommendations. Through the merger with Old Dominion University, additional controls have adopted around the processes and controls around the accuracy of the review over indirect costs calculation requirements. Corrective Action Plan Effective July 1, 2024, EVMS merged with ODU and the ODU Research Foundation became the fiscal and administrative agent for EVMS’s transferring sponsored programs on behalf of ODU. As per ODU’s Memorandum of Understanding (MOU) with the ODU Research Foundation, the ODU Research Foundation has policies and processes in place to manage how the indirect costs are calculated. The ODU Research Foundation uses its own system of internal controls for IDC calculation with no reliance on ODU systems for those processes and are audited separately. As a corrective action moving forward, ODU management will notify the ODU Research Foundation management of the audit findings, so they are aware of the internal control deficiencies. ODU will request the Research Foundation to provide a copy of their single audit report to monitor continued compliance with Uniform Guidance. The corrective action plan will be completed by March 31, 2025 and the contact person for this finding is Victoria Dean.

Management’s Views and Corrective Action Plan Management response to finding 2024-004: Review over cost transfers of subrecipient expenditures Cluster Name: Research and Development Federal Awarding Agency: Various Award Name: Various Award Number: Various Award Years: Various Assistance Listing Title: Various Assistance Listing Number: Various Pass-through entities: Various As described in Finding 2024-004, and as a result of improper training related to the implementation of the university’s new financial system in FY22, the university lacked adequate controls to identify the proper application of indirect costs as it relates to subrecipient expenses when using the cost transfer process to make corrections. Additionally, the university failed to properly apply its policy for the classification of subawards versus direct expenditures. As such, while cost transfers are a small percentage of overall transfer activity, an update to training materials will be made by June 2025 to educate cost transfer initiators on the proper method to use for this subset of subrecipient expenditures. Since February 2025, the Sponsor Projects Accounting (SPA) representative responsible for central office review of cost transfers now reviews to ensure that all intended grant related attributes are in effect before approving any subrecipient cost transfers. Additionally, as of February 2025, the university reinforced its policy regarding the classification of subawards versus direct expenditures with both the Procurement department and the SPA staff to ensure the proper expenditure classification is set up during the onboarding process of a contractor. The SPA team has completed its analysis and review of all previous subrecipient cost transfers to verify and correct the improper application of indirect cost limits and expenditure classifications. As of March 2025, all subrecipient cost transfer errors have been identified and corrected, resulting in questioned costs of approximately $587,000. Separately, this resulted in an under-recovery of $306,000 of indirect costs that were not charged to the original award. As all awards impacted are still open and active, the correcting expenditure adjustments were applied to the awards impacted that will affect future draw downs. Contact Person: Cindy Lee, Director, Sponsored Projects Accounting, cmlee@usc.edu

Management’s Views and Corrective Action Plan Management response to finding 2024-003: Unallowable costs – Cost transfers based on budgeted amounts Cluster Name: Research and Development Federal Awarding Agency: Department of Health and Human Services Award Name: Leveraging natural phenotypic variations of heterogenous ALS populations-in-a-dish to enable scalable drug discovery Award Number: 5R01NS131409-03 Award Years: 2022-2025 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders Assistance Listing Number: 93.853 Pass-through entities: Not applicable As described in finding 2024-003, the university inadvertently processed a cost transfer moving expenses from one grant to another based on budgeted figures instead of actual expenses incurred. This resulted in an amount transferred that was greater than the actual costs incurred. The administrator in question has been identified and further review of this administrator’s work has been performed to determine if additional instances occurred. Upon review of the administrator’s work, it was determined that no additional corrections were required as no other instances of this nature were identified outside of the total questioned costs. As part of the department’s efforts to minimize further cost transfer errors, training was provided to all their grant administrators beginning November 1, 2024. This training will now be held annually to ensure the department responsible for administering the award is current on the University’s existing compliance policies. Furthermore, to support accuracy and transparency, the department will allocate separate time commitments during weekly administration meetings to review any required cost transfers. This time will be dedicated to ensuring proper documentation is in place, confirming the appropriateness of the transfer, and ensuring full compliance of the transaction(s). This updated review process involves representatives from Grant Administration, Keck School of Medicine Finance Office, and Purchasing, to ensure a full comprehensive review of each transfer. As such, beginning November 2024, a cost transfer will not move forward until it has been reviewed by the group. Contact Person: Andres Chan, Director, FBS Financial Analysis, andres.chan@usc.edu

The Board has developed procedures to ensure that all purchase orders are approved before orders are placed, all expenditures are properly authorized by the respective program director and supporting documentation is adequately maintained. The Board is using a requisition form in Droplet to achieve this goal. All employees authorized to make or approve purchases have been trained on purchasing procedures outlined in the Purchasing Policies and Procedures Manual for Local Educational Agencies in the State of West Virginia by the WVDE Office of School Finance on 2/23/2024.

Condition: During audit procedures, it was noted total reimbursements received exceeded expenditures. The Organization has charged costs to the program and received reimbursement; however, the products cost charged to the program had not been received prior to June 30, 2024. Corrective Actions: Going forward, the Organization will review all vouchers being charged to the program to make sure costs have been incurred before being charged to the program. Employee Responsible for Corrective Action: Michelle Clarke Completion Date: March 31, 2025

NCHE implemented a new policy in January 2025 regarding missing receipts. In January 2024, a new policy was instituted requiring receipt of vendor invoice before payment approval by the Accountant and Executive Director. All copies of approvals, receipts, and invoices, are now attached to each expense transaction in QuickBooks Online. In January 2025, NCHE required email documentation for any missing receipts, sent to the accountant for inclusion in QBO.

We appreciate the audit team’s diligence and acknowledge the reporting finding. This appears to reflect a difference in interpretation around when “final adjustments” to Weatherization Assistance Program contracts may occur. Based on our longstanding experience with the program and past guidance, we understood that adjustments could be made within the active contract period and up to 60 days after contract closeout. In this case, NWBCCC made an adjustment in 2024 to an active multi-year contract with a September 2025 end date, which we believed to be within allowable guidelines. However, based on the auditor’s definition of “final adjustment”, which is that every monthly voucher is a final adjustment, our action resulted in a finding. Going forward as a corrective measure, NWBCCC will treat each monthly voucher as a final submission for that period and enhance internal review processes to avoid retroactive changes. Where adjustments are necessary, we will coordinate with HCR to ensure proper documentation and compliance.

FINDING 2024-010 Subject: Special Education Cluster (IDEA) - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-027-PN01, 22611-027-ARP, 22619-027-ARP, 23611-027-PN01, 23619-027-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Huntington County Community School Corporation will establish an Internal Control Standards manual by July 1, 2025, along with the Segregation of Duties chart by August 1, 2025. These standards will include items that detail the procedures and processes along with the checks and balances needed to ensure proper oversight, prevention, detection, correction, or errors. Our process will also ensure reporting compliance is followed. The Internal Control Standards manual will include special tests and provisions. To ensure accuracy and efficiency, future reporting will be prepared by the grant administrator, reviewed by the Grants Specialist then approved by the Corporation Treasurer or Chief Operating Officer before submission. The wages for stipends will be established by the grant administrator and conveyed to the business office prior to the first payroll of any stipend payments. Anticipated Completion Date: Huntington County Community School Corporation will establish the Internal Control Standards by July 1, 2025, and train administration and staff in August 2025

Finding Number: 2024-003 Equipment Property Management Recommendation: The University needs to enhance the precision of the controls over equipment purchases to ensure that a property record is created within the system containing the required information for all federally funded equipment. Management concurs with the auditor’s recommendation. The University has taken immediate steps to comply with 2 CFR 200.313 and is in process of implementing the following actions: Planned Corrective Action (1): The University is incorporating an additional worktag into the procurement approval workflow for asset management, enabling the identification of asset purchase orders and ensuring their proper routing to the Asset Management team for asset record creation. Anticipated Completion Date: May 2025 Responsible Contact Person: Eric Hughey, Fiscal Manager, Asset Accounting & Surplus/Nataliya Samodov, GCA Director Planned Corrective Action (2): The University will be implementing Multi-book functionality in the Workday ERP to improve asset management including creation of multiple asset books to meet different accounting standards as well as tracking of the assets from acquisition to disposal. This implementation will provide active monitoring of assets to ensure compliance. Anticipated Completion Date: Fall 2025 Responsible Contact Person: Eric Hughey, Fiscal Manager, Asset Accounting & Surplus/Nataliya Samodov, GCA Director

FINDING 2024-004 Finding Subject: A sample of 14 payroll population from the School's ESSER disbursement population was selected for testing to verify if the transactions were for allowable costs. An employee was paid 50% of the ESSER grant and no documentation was provided. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school is assuming that time & effort documentation was required for the one individual paid 50% with ESSER funds. That is occurring now, and always has with the only current federal fund that partially pays for staffing (Title 1.) It is unknown why this individual did not archive this information as they served as the Title 1 director as well during this time. No corrective plan is needed. The grant is closed, no funds are available, no further transactions will occur from this grant. Anticipated Completion Date: 3/11/2025 (the grant is closed)

FINDING 2024-003 Finding Subject: A portion of the School Corporation's Special Education allocation was required to be set aside for mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the non-proportionate share reservation. The required amount to be set aside was indicated in the Special Education grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. The School Corporation did not separate the earmarking for mandatory CEIS reservation from the non-public proportionate share. The same expenditures in the amount of $2,647 were earmarked in both earmarking categories. In addition, the school corporation did not have actual expenditure amounts to account for the FY2021 pre-school grant non proportionate share amount. The expenditures used were a percentage of total expenditures. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school will review all current and future Special Education grant application and set aside the required amounts for the mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the non-proportionate share reservation. The Special Education Director and Corporation Treasurer will determine this amount and enter it in the appropriate documentation. They will also separate the earmarking for mandatory CEIS reservation from the non-public proportionate share. The school can do nothing to correct the absence of actual expenditure amounts to account for the FY2021 preschool grant non proportionate share amount since this grant has long since closed and passed through prior audit periods. For current and future pre-school grants, the Special Education Director and Corporation Treasurer actual expenditure amounts to account for pre-school grant non proportionate share. Anticipated Completion Date: June 30, 2025

Finding 2024-006 – Allowable Costs/Cost Principles Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: With recent personnel changes, project managers with adequate knowledge of allowable costs are responsible for tracking all costs. In collaboration with the Treasury Department, new internal controls have been implemented, ensuring clear and effective tracking methods are maintained and practiced regularly. Proposed Completion Date: June 30, 2025