Corrective Action Plans

View of Responsible Officials and Corrective Action Plan We acknowledge that the purchase of gift cards was not an allowable expense under federal grant guidelines. During the COVID-19 pandemic, our staff were tasked with responding to urgent and overwhelming public health demands, particularly as the New Mexico Department of Health became overextended. To recognize staff who went above and beyond to ensure timely case reporting and investigations for tribal communities, gift cards were used as a form of appreciation. Corrective Action Plan Timeline Moving forward, we will ensure full compliance with federal grant requirements. Specifically: 1. We will adhere strictly to the cost principles and allowability guidance outlined in federal regulations and the terms of each Notice of Award. 2. In instances where the allowability of an expense is unclear, we will proactively seek guidance and written approval from our Federal Grant Management Officer before incurring the cost. 3. We will provide refresher training to program and fiscal staff on allowable costs under federal awards to prevent recurrence of similar findings. These corrective actions will ensure future expenditures are fully compliant with federal guidelines and that staff recognition practices remain appropriate, allowable, and consistent with award terms. Corrective Action Plan Timeline • Immediate (Already in Effect): Ceased use of gift cards and other unallowable incentives. • Within 30 Days: Finance and program leadership will review current grant guidance and distribute a written summary of allowable/unallowable costs to all program managers. • Within 60 Days: Refresher training on federal cost principles (2 CFR 200) and Notice of Award guidance will be provided to all program and fiscal staff. • Ongoing: When ambiguity exists regarding allowable costs, staff will consult with the Federal Grant Management Officer prior to obligating or expending funds. Designation of Employee Position Responsible for Meeting Deadline Program Managers/Directors, Finance Officer, and Accounting Manager.

WHRSD has recently redesigned its Chart of Accounts and deployed a current ERP software program to assist in controls of expenditures of all accounts including grants. WHRSD will be completing a comprehensive review of all Business Office Procedures in the fall of 2025, and plans to update/implement updated standard operating procedures to ensure compliance with Local, State, and Federal laws.

WHRSD has recently redesigned its Chart of Accounts and deployed a current ERP software program to assist in controls of expenditures of all accounts including grants. WHRSD will be completing a comprehensive review of all Business Office Procedures in the fall of 2025, and plans to update/implement updated standard operating procedures to ensure compliance with Local, State, and Federal laws.

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.

The Organization agrees with the finding and acknowledges the need for strengthened internal controls and documentation related to time and effort reporting, as well as the allocation of expenditures to federally funded grant programs. To address the deficiencies noted, the Organization is developing and implementing formal time and effort reporting procedures to ensure that personnel costs charged to federal grants are supported by actual activity records and certified by employees on a regular basis. This will include the adoption of time distribution systems that comply with 2 CFR Part 200 Subpart E and the requirement for supervisory approval of time reports. Additionally, the Organization will revise its expenditure review and approval processes to require that all costs charged to federal programs are supported by appropriate documentation, including vendor invoices and receipts. Staff involved in grant management and accounting will receive training on federal cost principles, documentation requirements, and period of performance compliance. A document retention policy in accordance with 2 CFR 200.334 will also be established to ensure that all supporting documentation is maintained and readily available for audit and program oversight. Organization Contact Person Responsible for Corrective Action: Joseph Koehler, Director of Finance Anticipated Completion Date: June 30, 2025

The HS program has established an internal process of requester/approver in place to review the transaction requested. Documents then get reviewed again by HR or Finance staff based on the transaction type before getting processed. Responsible party: Bonnie Foroudi, Finance Director Estimated completion date: December 31, 2025

Finding 2022-008 – Allowable Cost Determination and Subaward Monitoring In response to the finding, GEM enhances subaward monitoring by instituting the following. GEM updated its sub awardee procedures to require supporting documentation of actual costs to ensure appropriate recording of grant expenses in GEM’s records. Anticipated date of completion: This was implemented September 30, 2023. Responsible party: Dr. Marcus Huggans Principal Investigator

Finding 2022-007 – Allowable Cost Documentation In response to the finding, GEM addressed allowable cost documentation by instituting the following: GEM established a formal credit card policy in the employee handbook that explains the policy and procedures for turning in receipts monthly. Anticipated date of completion: This policy has been in effect since September 30, 2023. Responsible party: Jamie Hicks, Senior Accounting Manager

Views of Responsible Officials and Planned Corrective Action: East End’s accountant added another accounting procedure for the agency and started to upload copies of expense receipts to the Microsoft One Drive Cloud for files in September 2022. It was found that East End was not filing the expense receipts, invoices and reports. All East End’s receipts, etc. that the accountant received are now uploaded and saved to the Microsoft One Drive Cloud to keep East End in compliance with the Federal government and other grantors for audit purposes. Anticipated Date of Completion: Ongoing analysis; expected to be completed by September 1, 2025.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Jessica Martinez, Deputy Director Joel Rusco, Chief Financial and Administrative Officer Corrective Action Plan: In response to FY21 Corrective Action Plan, CFSC implemented an updated Reporting Policy in June 2024 to strengthen internal controls prior to review and submission of invoices and drawdown/payment requests to funders. To ensure further compliance with 2 CFR 200.414(c), 2 CFR 200.403(d), and 2 CFR 200.302(b)(3), CFSC will implement the following corrective actions: 1.Verification of Indirect Cost Rate Before Submission: a.CFSC will require that all invoices, including indirect costs, be reviewed by the CFAO to confirm that the rate used is in accordance with an approved provisional or final NICRA agreement. b.Any invoice for federal funding lacking an approved indirect cost rate will be flagged and returned for correction before submission. 2.Pre-Submission Approval Process for Invoicing Indirect Costs: a.All invoice requests containing indirect costs must be reviewed and approved by the CFAO prior to submission. b.The Finance Department will verify and document that the rate applied is consistent across all federal awards and matches the NICRA. 3.Indirect Cost Rate Agreement Tracking & Documentation: a.CFSC Finance will establish an Indirect Cost Rate Agreement tracker to ensure that: i.All provisional and final indirect cost rate agreements are maintained on file. ii.Indirect cost rates used on invoices are consistently aligned with approved agreements. 4.Quarterly Internal Audits of Indirect Cost Rate Compliance: CFSC Finance Department will conduct quarterly reviews of a sample of drawdown/payment request invoices to confirm: a.The correct indirect cost rate was applied b.The rate was consistently applied across all federal awards Anticipated Completion Date: These corrective actions will be fully implemented by the end of Quarter 2 of FY25

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Jessica Martinez, Deputy Director Corrective Action Plan: The corrective actions for this finding are identical to those outlined in finding 2022-005. Please refer to the correction action plan for finding 2022-005, which includes specific measures to address this finding. Anticipated Completion Date: These corrective actions will be fully implemented by the end of Quarter 2 of FY25.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Corrective Action Plan: The corrective actions for this finding are identical to those outlined in finding 2022-004. Please refer to the correction action plan for finding 2022-004, which includes specific measures to address this finding. Anticipated Completion Date: These corrective actions will be fully implemented by the end of Quarter 2 of FY25.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Corrective Action Plan: In response to the FY21 Corrective Action Plan, CFSC implemented a Subrecipient Monitoring Policy in June 2024 to ensure compliance with the Uniform Guidance for monitoring subrecipients of federal funding, including audit requirements and the verification of suspension and debarment status. To further strengthen compliance and ensure timely verification, CFSC will implement the following actions: 1.Mandatory Pre-Award Verification Timing & Documentation: a.Suspension and debarment status must be verified on SAM.gov by the assigned Grant Specialist before the execution of any subaward agreements. b.The verification data and results will be documented by the assigned Grant Specialist and included in the Risk Assessment process prior to award issuance. c.Any subrecipients flagged as high risk due to past audit findings will undergo enhanced pre-award due diligence before subaward execution to be carried out by the assigned Grant Specialist. 2.Grant Compliance Oversight & Approval: a.The Grants Manager (or designee) will review and approve all subrecipient compliance checks before final award execution. b.Any exceptions or delays in verification must be documented and approved by the CFAO & Deputy Director before proceeding. 3.Quarterly Compliance Audits: a.The Grants Manager (or designee) will conduct quarterly internal audits of subrecipient monitoring files to confirm that suspension & debarment verification was completed timely before subaward execution. b. The Grants Manager will be responsible for reporting any identified deficiencies to senior management and ensuring timely correction for policy reinforcement. Anticipated Completion Date: These corrective actions will be fully implemented by the end of Quarter 2 of FY25, with ongoing monitoring and enforcement thereafter.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Corrective Action Plan: To mitigate the risk of error in payroll allocation and ensure compliance with allowable cost provisions, CFSC will enhance its payroll review process with the following corrective actions: 1. Enhanced Payroll Verification Process: a. CFSC will implement an additional cross-checking step in the payroll entry process by requiring finance staff to a run a “Program Summary by Projects Lists” report in the timekeeping system (i.e., Clicktime) before submitting for payroll. b. This report will allow finance staff to verify that total hours worked per project per employee align with the grant allocation and employee timesheets before payroll is processed. 2. Regular Internal Audits & Compliance Checks: a. Finance will conduct quarterly internal payroll audits to identify any discrepancies in time tracking and grant allocations. Anticipated Completion Date: These corrective actions will be fully implemented by the end of Quarter 2 of FY25.

Consortium’s Fiscal Agent will ensure that supporting documentation will be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost.

Consortium’s Fiscal Agent shall maintain all invoices and proof of payment for all financial transactions and records should be maintained in an orderly manner to support all transactions.

CONDITION: During the calendar year 2022, the City did not utilize a formal general ledger system of accounting to track the financial activity (financial position and results of operations) for several ‘Funds’ held at the City. The activity of these funds is either 1) maintained in spreadsheet fashion similar to a checkbook used in personal finances, 2) recorded partially (expenses only with no revenue), or 3) not tracked at all. As these funds are not maintained using the City’s accounting software package, management does not have the ability to efficiently generate financial reports necessary to provide management with the proper fiscal oversight. This condition included the American Rescue Plan Act (ARPA) funding known as the Coronavirus State and Local Fiscal Recovery Fund. However, it should be noted that City personnel were able to prepare spreadsheets to document which expenditures were utilized to prepare the necessary quarterly reporting requirements to the Department of Treasury. This is a repeat finding (2021-002) from the prior year. CRITERIA: Prudent internal control procedures in the areas of general ledger management and financial reporting include maintaining a formal general ledger system of accounting to track the activity of all ‘Funds’ maintained by the City. In specific as it relates to federal programs, Section 2 CFR 200.403(g) of the Uniform Guidance requires that federal costs must be adequately documented which would include the maintaining of a formal general ledger system of accounting for all ‘Funds’ of the City. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will assess the current workload and expertise of the City’s business office personnel in an effort to determine a feasible timeframe to continue the process of creating a formal general ledger system of accounting for all City ‘Funds’ that are not already entered into the software accounting system. The timeframe for completion of this review will occur during the first nine months of calendar year 2025 with the intention of having the City be in full compliance with Section 2 CFR 200.403(g) of the Uniform Guidance which requires federal costs to be adequately documented which would include the maintaining of a formal general ledger system of accounting for all ‘Funds’ of the City.

CONDITION: During the calendar year 2022, the City did not record the necessary adjustments to the various ‘Fund’ general ledgers of the City to properly reconcile the balance sheet accounts, such as cash, receivables, payables, and payroll-related liabilities to the underlying supporting documentation available at the City (which includes reconciliations of cash prepared independently by City personnel but do not agree to amounts reported in the various general ledgers). This included ‘Funds” containing significant federal funding such as the City’s Community Development Block Grant (CDBG) Program and American Rescue Plan Act (ARPA) funding known as the Coronavirus State and Local Fiscal Recovery Fund. CONDITION (Continued): As a result, the financial position and results of operations as shown throughout the calendar year were inaccurately stated. However, it should be noted that the Community Development Department of the City and other City personnel maintain separate financial reporting for these federal funds, independent of the aforementioned ‘Fund’ general ledgers sufficient to ascertain the revenues and expenditures of the federal programs. This is a repeat finding (2021-001) for the prior year. CRITERIA: Prudent internal control procedures in the areas of general ledger management and financial reporting include the reconciliation of all general ledger account balances to underlying supporting documentation monthly with independent oversight and approval as part of the process. In specific as it relates to federal programs, Section 2 CFR 200.403(g) of the Uniform Guidance requires that federal costs must be adequately documented which would include the applicable general ledgers of the City. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will review the recommended options as presented by the Audit Firm’s recommendation for feasibility considering current manpower, expertise, and budgetary constraints. In addition, the City plans to ensure that written procedures for all accounting functions are implemented, reviewed and updated as necessary with the objective of ensuring that all balance sheet account balances are supported by the underlying documentation available at the City. The timeframe for completion of this review will occur during the first nine months of calendar year 2025 with the intention of having the City be in full compliance with Section 2 CFR 200.403(g) of the Uniform Guidance which requires federal costs to be adequately documented which would include the applicable general ledgers of the City.

FA 2022-002 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund, COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D210012 (Year: 2021) S425W210011 (Year: 2021) Questioned Costs: $58,415 Description: A review of expenditures charged to the Elementary and Secondary Emergency Relief Fund program revealed that the School District's internal control procedures were not operating to ensure that expenditures were appropriately documented to support allowability. Corrective Action Plans: District office will review payroll process and develop a procedure to ensure proper documentation is kept in an orderly manner. Estimated Completion Date: December 31, 2024 Contact Person: Terrance H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: SO10A200010 (Year: 2021) SO10A210010-21A (Year: 2022) Questioned Costs: $23,398 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Title I Grants to Local Educational Agencies program. Corrective Action Plans: District office has put procedures in action to make sure that all drawbacks are in line with expenditures. All draw down packets will be viewed and signed off by federal program director. This packet will included detail expenditure sheet for the month, year to date expenditure report and a cover sheet. Estimated Completion Date: December 31, 2024 Contact Person: Terrance H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) Questioned Costs: $189,893 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Management has implemented internal controls procedures to ensure transactions are properly processed and reported. Additional procedures have been established to review transaction to make they align with the approved budget. Estimated Completion Date: June 30, 2024 Contact Person: Georgette Evans Telephone: 478-374-3783 Email: gevans@dodge.k12.ga.us

Finding 2022-008 – Allowable Cost Determination and Subaward Monitoring In response to the finding, GEM enhances subaward monitoring by instituting the following. GEM updated its sub awardee procedures to require supporting documentation of actual costs to ensure appropriate recording of grant expenses in GEM’s records. Anticipated date of completion: This was implemented September 30, 2023. Responsible party: Dr. Marcus Huggans Principal Investigator

Finding 2022-007 – Allowable Cost Documentation In response to the finding, GEM addressed allowable cost documentation by instituting the following: GEM established a formal credit card policy in the employee handbook that explains the policy and procedures for turning in receipts monthly. Anticipated date of completion: This policy has been in effect since September 30, 2023. Responsible party: Jamie Hicks, Senior Accounting Manager

2022-001 – Internal Controls over Allowable Costs Individuals Responsible for Corrective Action Plan: J. Neal Bolton, Director of Revenue Management & Budget Shemaine Rose, Controller Anticipated Completion Date: December 2024 In order to ensure expenses are only counted once, a check will be added to future reporting to ensure the total of all expenses equals the total amount of expenses allocated by category. This check will be confirmed by two individuals independently before submission.

2022-002 – INTERNAL CONTROLS OVER COMPLIANCE – ALLOWABLE COSTS/COST PRINCIPLES Material Weakness/noncompliance Auditee’s Response and Planned Corrective Action DeMarco has hired an in-house finance coordinator who works closely with the DeMarco finance team to make sure all the contracts and files are maintained and updated for all invoices and receivables. Expenditures are now being coded to the proper line items and properties. Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation