Corrective Action Plans

Supportive Services for Veteran Families Assistance Listing No. 64.033 Recommendation: We recommend that the Corporation implement internal controls over the reconciliation of payroll reports to grant expenditures. This should include regular reconciliations and reviews to ensure that all payroll costs charged to the grant are adequately supported by detailed payroll records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A payroll salary reconciliation report will be completed after each payroll issued and will be verified against the grant reports, accounting system class coding and employee-specific payroll file(s). Printed reports will be maintained on file in the Finance Department for historical reference. Name of the contact person responsible for corrective action: Karen Harshman Planned completion date for corrective action plan: 06/12/2025

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1099 (Year: 2024), 245GA324N1199 (Year: 2024) Questioned Costs: $77,285 Prior Year Finding: FA 2023-001 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: Berrien will look at the current procedures for expenditures and make sure that every program is following the same protocols. We have a system in place to ensure that we can check suspension and debarment. Also, we have protocols in place to make sure all contracts are current. Estimated Completion Date: 9/30/2025 Contact Person: Jamie Taylor, Finance Director Telephone: 229-686-2081 Email: jamie.taylor@berrien.k12.ga.us

Finding: 2024-036 -A review of 25 FY 24 Disaster Grants payments found that 14 payments (56 percent) lacked required supporting documentation. Specifically, six payments lacked pay policy and/or fringe benefit calculations and eight payments lacked procurement contracts that included all federal requirements. Additionally, two of the eight payments lacked a complete or signed contract on file. Questioned Costs: AL - 97.036: $96,758; AL - 97.036 COVID-19: $2,159 Assistance Listing Number: 97.036 Assistance Listing Title: Disaster Grants — Public Assistance (Presidentially Declared Disasters) 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): To ensure compliance with federal regulations and effective management of federal awards, the Finance Office in conjunction with the Homeland Security Director will develop and implement written procedures that provide a clear framework for managing federal awards and ensure compliance with federal regulations. DMVA will: • Clearly outline federal requirements under 2 CFR 200.327, 2 CFR 200 .403(g), and Homeland Security Acquisition Regulation Class Deviation 15-01. • Specify the documentation required to support reimbursement requests, including expectations related to discrepancies and follow-up actions. • Outline the procedures for Homeland Security for reviewing and certifying work completed by contractors, where applicable, prior to reimbursement to subrecipients. Completion Date (list anticipated completion date): October 31, 2025 Agency Contact (name of person responsible for corrective action): Bryan Fisher

Finding: 2024-034 - The State’s accounting system was not updated for changes to the FFY 24 federally certified Facilities Inventory and Support Plan, which is used to allocate costs to the National Guard Military Operations and Maintenance Projects (NGMOMP program. Questioned Costs: AL 12.401: $88,984 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): Army Guard turnover stabilized in fiscal year 2024. The FISP is annually certified each spring for the following federal year. The Army Administrative Officer (AO) reviewed the certified 2024 Facilities Inventory and Support Plan (FISP) and requested updates to the State accounting system. Administrative Services Revenue office will make requested updates and provide a financial report to the AO for the purpose of identifying expenses posted to prior FISP percentages. The AO will submit correcting adjustments (CH8) to rectify any discrepancies. Future federal year structure will only be activated by the Revenue office once the AO has certified the review is complete and identifies needed changes. Completion Date (list anticipated completion date): 06/30/2025 Agency Contact (name of person responsible for corrective action): Pamela Wiederspohn Tanya Iskra

Federal Award Finding: 2024-002 Material Weakness in Internal Control and Noncompliance – Allowable Costs/Cost Principles: Indirect Costs Name of Individual Responsible for Corrective Action: Sara Kinjo-Hischer, Tribal Administrator Corrective Action: Skagway Traditional Council will work closely with the contract accountant to ensure that indirect costs charged to each grant are within the grant’s budget and are in accordance with the terms and conditions of each grant award and with Uniform Guidance. Planned Completion Date: September 30, 2025

The Department of Behavioral Health (DBH) concurs with the finding. OCFO will confirm and ensure that the amount accrued for prior year liabilities are reversed according to the amounts accrued for both automatic and manual accruals. This process will entail performing a detailed analysis by fund, award, program, and purchase orders to eliminate the occurrence of unallowable costs. Contact: Barbara S. Roberson, Accounting Officer, Human Support Services Cluster Estimated Completion Date: October 2025 See Corrective Action Plan for chart/table

The Office of the Deputy Mayor for Planning and Economic Development (DMPED) does not concur with the auditor’s finding regarding the allowability of rent per the CPF guidance. DMPED’s current grant procedures include a legal review and analysis by its Office of General Counsel (OGC) to determine activities that are allowed or unallowed and allowable costs/cost principles to ensure only allowable expenses are charged to federal programs as required under 2 CFR Section 200.403. Before DMPED approved the payment of rent for the Whitman-Walker Saint Elizabeth’s Expansion project, DMPED OGC had conducted legal analysis and determined that payment of rent qualifies as an allowable cost. DMPED had also received Treasury approval the summer prior (July 2024) for ancillary costs needed to operationalize the capital asset. As part of its Corrective Action Plan, DMPED will commit to seeking expressed approval from the awarding Federal agency in cases where the project guidance may be unclear and where DMPED OGC has interpreted the guidance, in order to validate DMPED’s interpretation. As a result, DMPED will take the following steps outlined below: 1. Evaluate its procedures in identifying Activities Allowed or Unallowed and Allowable Costs/Cost Principles to ensure only expressly allowable expenses are charged to the program as required under 2CFR Section 200.403. Estimated Completion Date: July 6, 2025 2. Add internal controls and policies that include clearer protocols around seeking awarding Federal Agency approval in cases where DMPED OGC has interpreted the guidance, in order to validate DMPED’s interpretation of generalized categorical guidance. Estimated Completion Date: August 6, 2025 Contact: Darya Razavi, Program Manager, Office of the Deputy Mayor for Planning and Economic Development See Corrective Action Plan for chart/table

Title: Capital Fund Program Grant Draws Program Name: Public Housing Capital Fund ALN:14.872 Description: During our audit procedures over revenue recognition for the Capital Fund Program (CFP), we identified drawdowns of federal funds for which the client was unable to provide adequate supporting documentation. Specifically, the expenditures associated with the draw requests lacked invoices, contracts, or other substantiating records to demonstrate that the costs were allowable, allocable, and incurred in accordance with applicable federal requirements. Planned Corrective Action: Today’s Marlboro County Housing Authority management acknowledges the auditor’s finding that documentation to support certain CFP drawdowns was incomplete or missing and concurs that this represents a failure to comply with Uniform Guidance documentation requirements under 2 CFR §200.302 and §200.403. The Authority recognizes the importance of maintaining complete and accurate supporting records—such as invoices, contracts, and payment documentation—to substantiate costs charged to federal programs and ensure allowability and allocability under the Capital Fund Program. Effective October 1st, 2024, all draw requests under the Capital Fund Program ARE supported by: • Approved contracts or purchase orders • Invoices or other source documents • Proof of payment (e.g., canceled checks, ACH confirmations) • Documentation clearly linking each expense to an approved activity in the CFP Annual Statement

As already indicated, income from tenant payments were not being properly applied to the correct revenue streams, all monies received were being coded to dwelling rents and not extra utility and cable charges as applicable. See response to 2024-001. Also, we have raised the fee charged to the tenants for cable to ensure that the expense is being adequately covered.

This discrepancy resulted from a lack of understanding by the CFO in processing grant related funding. Grant policies have been updated, and personnel trained to direct and understand the role of independent accounting by funding sources through class codes. Anticipated completion date: 8/31/25. Responsible contact person: John Carroll, CFO

Finding 2024-007 Personnel Responsible for Corrective Action: Grant Principal Investigators and Grant Accountant – Charme Benson Anticipated Completion Date: June 30, 2025 Corrective Action Plan: All expenses must be supported by documentation and comply with Generally Accepted Accounting Principles (GAAP) standards. A pre-review checklist will be required for all charges against FIPSE grants. Prepaid items must be recorded in the prepaid ledger and amortized appropriately. Documentation will be retained in alignment with the University Record Retention policy. Management will implement a formal review and approval process to ensure that all allowable costs are verified for compliance with applicable regulations and approved by designated personnel prior to reimbursement or payment.

2024-002 Twenty-First Century Community Learning Centers - Assistance Listing No. 84.287 Significant Deficiency in Internal Control Over Compliance and Noncompliance - Appropriate Review of Expenditures Claimed B. Allowable Costs/Cost Principles Recommendation: The Auditors recommend that management strengthen its review procedures over expense cutoff to ensure that expenditures are recognized on the SEFA in alignment with GMP. Additionally, training should be provided to accounting personnel on Uniform Guidance compliance and GMP requirements related to expense recognition. Planned Corrective Action: We agree with the recommendation and plan to have the corrective action implemented by August 2025.

CORRECTIVE ACTION PLAN Year Ended June 30, 2024 Finding Number: 2024-001 Planned Corrective Action: Cleveland Play House has had difficulties with finding a long-term replacement for the Director of Finance roll and thus the position has experienced much turnover since June of 2023. During this time period, practices have been put in place for the reviewing of grant draws and the approval of time and effort logs. However, the turnover has led to inconsistency with the application of these practices. While the Director of Finance position remains temporarily staffed, there has been improvement in the following of industry best practice for the monitoring of time and effort and grant expenditures. Based on the reduction in questioned costs down from prior year findings and with the continued adherence to best practices for grant costs, Cleveland Play House continues to work towards a clean audit for the fiscal 2025 year ending June 30th, 2025. Anticipated Completion Date: June 30, 2025

Finding & Recommendation 2024-004: As per C.R. 170.2 of the Commissioner's Regulations, Purchase Orders must be established to encumber approved budget items for each expenditure in advance of the expenditure. For the ARP Summer Enrichment grant, Purchase Orders were created after the dates of service and the district did not have sufficient internal controls in place to ensure Purchase Orders are created in accordance with the above noted regulation. It is recommended that the District's written procedures addressing internal controls with respect to program requirements be followed to ensure the District is in compliance at all times. Corrective Action: The district concurs and understands the importance of maintaining internal controls in accordance with Commissioner Regulations. By June 30, 2025, Assistant Superintendent Christopher Carballo will review with Business Office Staff the existing procedures for the creation of purchase orders in advance of the expenditure. Additionally, Asst. Superintendent Carballo will review these procedures with clerical staff across the district involved in the creation of purchase orders and will remind district administrators at the start of the new fiscal year that purchase orders need to be established in advance for all expenditures.

MASSACHUSETTS EMERGENCY MANAGEMENT AGENCY 2024-039 COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Recommendation: We recommend the Agency review and enhance procedures and controls to ensure that costs charged to the program are allowable, approved, and accounted for properly in the Commonwealth’s accounting system. Action taken in response to finding: MEMA is recognizing the importance of documentation and internal controls. This current fiscal year an Internal Control Group was formed to review, create and overhaul what is needed or needed to be updated. The team primary stakeholders is made up of the CFO, Legal Counsel, Assistant Director for Recovery and Mitigation and Emergency Management Grants Supervisor. We are making the completion of updated Policies and Procedures a priority to address the findings such as the ones being pointed out as a critical piece to the success of the agency going forward. We have found that there has been much to update, and we are doing our best to deliver these much-needed documents as soon as possible. Name(s) of the contact person(s) responsible for corrective action: Randall Lui Planned completion date for corrective action plan: End of the Federal Fiscal Year 9/30/2025

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2024-012 WIOA Cluster - Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: We recommend the Agency review and enhance procedures and controls to ensure that costs charged to the program are allowable, approved, and accounted for properly in the Commonwealth’s accounting system. Action taken in response to finding: During the review, supporting documentation for certain expenditure adjustments (EX) could not be located. Since then, the department has taken steps to strengthen internal controls and improve documentation practices. Under new management, enhanced oversight procedures have been implemented, requiring all expenditure adjustments to undergo review and approval by multiple levels of management and staff. To ensure transparency and audit readiness, all supporting documentation is now stored in a centralized and accessible SharePoint repository. Additionally, revised procedures are being integrated into the department's standard operating protocols to support ongoing monitoring. These updates are designed to ensure that all future adjustments are properly documented, allowable under applicable federal regulations, and readily available for review. Name(s) of the contact person(s) responsible for corrective action: Ken Luke Planned completion date for corrective action plan: 9/30/2025

2024-002 a. Contact person responsible for corrective action: Police Chief Jeff McCutchen and Kim Richardson b. Description of corrective action to be taken: The City has already implemented additional controls for verification of attendance lodging and travel reimbursements. c. Anticipated completion date of corrective action: This was implemented on October 11, 2024.

FA 2024-001 Improve Control over Employee Compensation Compliance Requirement: Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: $102,234 Prior Year Finding: 2023-004 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Corrective Action Plans: The District is developing correction action to strengthen controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: June 30, 2026 Contact Person: Connie Walker, School Nutrition Executive Director Telephone: 678-676-1780 Email: Connie_R_Walker@dekalbschoolsga.org

During the fiscal year under audit, NASF hosted two events at the same hotel – one charged to a nonfederal program and the other related to a federal program. Initially, all event-related cost were charged to the nonfederal program. Subsequently, $28,500 was reclassified to the Federal program. As a result, $18,387 was incorrectly charged to the Federal award. The Executive Director and Chief Financial Officer have established the following corrective action plan to be completed in May, 2025 and going forward: 1. Include individual grant Profit & Loss statements to the monthly close review process to help strengthen internal controls over expenditures and make sure all cost charged to the programs are allowable under 2 CFR 200.403. 2. Provide training to NASF staff and contractors on the requirements for allowable cost. 3. NASF has informed the funder (U.S. Forest Service) - Lynne Sholty (Supervisory Grants and Agreements Specialist) about the unallowable cost of $18,387. At time of this response, we are awaiting invoice so NASF can repay the balance in full. This corrected action has an anticipated completion day of 60 days (June 30th, 2025) by the Chief Financial Officer (Rafael Chapman) in conjunction with Executive Director (James Farrell).

FA 2024-001 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: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $72,595 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund programs revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were properly recorded. Corrective Action Plans: Our office was unaware our financial program could automatically generate employee's supplemental checks in addition to standard monthly checks. Now that we are aware, Ivey McLendon and I will monitor our financial program's automatically generated claims closely to adapt our manual accrual entries. Estimated Completion Date: June 30, 2025 Contact Person: Sherry Gray, Financial Director Telephone: (229) 524-2433 Email: sgray@seminole.k12.ga.us

Activities Allowed or Unallowed; Allowable Costs and Cost Principles Auditor's Recommendations: We recommend that the Organization obtains a better understanding of allowable and unallowable costs for federal awards. We also recommend that the Organization implement a system of internal control that can detect noncompliance prior to charging costs to the federal award. Corrective Action: Executive Director, Faith Brown, will develop a process for checking and charging costs to federal awards as required per the compliance policy. The Executive Director will be responsible for verifying that all internal controls are operating and will have been checked for unallowable prior to disbursing future federal funds. Timing of remediation completion: Executive Director, Faith Brown, will complete by September 29, 2025.

Aging Cluster – Special Programs for the Aging, Title III, Part B – Assistance Listing No. 93.044 Recommendation: We recommend that the Organization consider updating its salaries and wages cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations based on employees’ time and effort records, effective compensation during work periods, and that are calculated in a consistent manner. We also recommend that the Organization maintain contemporaneous documentation supporting all cost allocations. Explanation of Disagreement With Audit Finding: Management does not agree with this finding. LSC program letter 22-5 emphasizes the importance of reconciliations of timekeeping reports with labor costs, distribution report or alternative reports. CLS prioritizes this practice of reconciliation and used it during the last months of 2024 to improve internal controls and minimize potential errors. We do not believe that CLA fully and fairly considered CLS’s thorough and complete reconciliation. A “material weakness” is defined as a deficiency “such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or detected and corrected, on a timely basis.” Given that reconciliation is part of our internal control process used to prevent and detect/correct any errors, it should have been fully considered and is unfairly excluded from the review. For this reason, CLS considers that this is not a material weakness as the reconciliation caught and corrected these errors. Finally, the total amount of this finding is very low and should not rise to the level of material weakness. Action Taken in Response to Finding: The Organization will review this finding and current methodology and propose corrections as part of a broader review of its technologies. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization consider updating its cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities, and that are reflective on employees’ time and effort records Explanation of Disagreement With Audit Finding: Management partially agrees with this finding. First, 45 CFR Part 1635 codifies the timekeeping requirement. CLS keeps track of every case and time dedicated by staff in strict compliance with this requirement. Additionally, the distribution of expenses in the general fund, which includes LSC and two other funding sources, represents a fair method and allocation. Regarding the questioned costs, CLS disagrees with the finding of material weakness given the extremely low total dollar value. Action Taken in Response to Finding: The Organization will review this finding and current methodology and propose corrections as part of a broader review of its technologies. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026

Finding 2024-001: Inclusion of Out-of-Period Costs in Current Year (Significant Deficiency): During the audit of federal award expenditures for the fiscal year ended December 31, 2024, it was discovered that costs incurred in prior periods were improperly charged to the current year’s federal awards. Name of Contact Person: Lucy Maddock, Chief Financial Officer email: lrm@ams.org Corrective Action Plan: The AMS processes payroll on a bi-weekly schedule. During the 2024 audit, we discovered that an initial payroll allocation for grant supported labor costs included days from the prior month that did not fall within the approved dates of the grant agreement. To ensure that this does not happen again the following procedures are being put into place effective immediately: 1. The grant accountant will review the payroll register at the beginning of each grant period and determine the actual percentage of payroll to allocate to the grant so that time periods are aligned. This may involve adjusting entries to accrue payroll into correct time periods. This will ensure costs incurred in prior periods are not charged to current year federal awards. 2. Grant payroll entries will be reviewed and approved by the Controller. 3. At the conclusion of the grant, all payroll entries will be reviewed one final time. Should any differences be found between the dates and amounts authorized by grant budget and those recorded in the G/L, correcting entries must be made before the final report is submitted to the cognizant agency. Anticipated Completion Date: These steps are being implemented effective immediately.

CONDITION: The District did not comply with the laws and regulations related to its participation in it’s various federal grant program reporting requirements. Personnel did not complete and submit the required ‘quarterly cash on hand reports’ and ‘final expenditure report’ (FER) for the grant programs based on supporting accurate general ledger expenditures as required by Section 2 CFR 200.403(g) of the Uniform Guidance. CRITERIA: The PA Department of Education (PDE) and Section 2 CFR 200.403(g) of the Uniform Guidance requires the completion and submission of a ‘quarterly cash on hand report’ quarterly as needed and a ‘final expenditure report’ (FER) at the conclusion of each grant program year (including any carryover period) based on information contained in the School District’s financial management system and supported by all underlying documentation. MANAGEMENT’S CORRECTIVE ACTION PLAN: The School District concurs with the above noted finding. The School District has employed a new Business Manager whose responsibilities include the oversight of accounting records and preparation of all required financial reports related to PDE federal grant programs in a timely manner, and to ensure that the information reported to PDE is supported by the underlying documentation contained in the District’s general ledger. Procedures will be put into place during the remaining months of the 2024-2025 fiscal year, and all subsequent years, for ensuring federal program reports are prepared accurately and agree with the financial management system and supported by all underlying documentation.