Corrective Action Plans

FINDING 2025-001 Finding Subject: Summary of Finding: Earmarking for Non-Public proportionate share was improperly calculated based on budgeted percentage. Contact Person Responsible for Corrective Action: Quinnlyn Van Rys Contact Phone Number and Email Address: (219) 850-1914 - qvanrys@pces.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hours are calculated, a percentage based on total hours worked for each member school will be used to allocate the provider/employee time for each member school. This documentation will be attached to each reimbursement request. Anticipated Completion Date: This finding was corrected in January, 2024.

2025-003. Payroll and Disbursement (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster: Special Education Grants to States: IDEA Part B ALN: 84.027 Education Stabilization Funds COVID 19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U Condition: As required under Subpart E, 2 CFR §200.403 through §200.405 and §200.430, and Subpart D, 2 CFR §200.302, which require a financial management system to provide effective control over accountability for federal funds, and to identify the source and application of funds. During the year, we noted that the District recorded journal entries transferring payroll and disbursement related expenditures from the General Fund to the Special Aid Fund under the Special Education Cluster and Education Stabilization Funds grant codes. These journal entries lacked adequate supporting documentation to demonstrate approvals and if the costs were allowable and allocable to the applicable federal awards. Consequently, we were unable to obtain sufficient appropriate audit evidence to conclude whether the journalized transactions were properly charged to the federal programs in order to comply with Subpart E, 2 CFR §200.403 through §200.405 and §200.430, and Subpart D, 2 CFR §200.302. Planned Corrective Action: The District will implement procedures to ensure that all payroll and disbursement transactions charged to federal awards through journal entries are properly supported. This will include maintaining original time and effort documentation for payroll, as well as invoices and supporting records for disbursements. Additionally, the District will establish a review and approval process for journal entries transferring expenditures between funds to verify that amounts are allowable, reasonable, and allocable to the appropriate federal awards. Staff will be trained on federal documentation requirements under 2 CFR §200.430 and §200.302 to prevent recurrence and ensure that all financial records support compliance with federal guidelines. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Jean Mingot Assistant Superintendent for Business Southampton Union Free School District 70 Leland Lane Southampton, New York 11968-5089

The Department agrees with the recommendation. The Center for Accounting (CFA) and the Office of Transportation Safety (OTS) have coordinated to implement updated reviews and controls. This implementation involves reviewing current processes to ensure supporting documentation is vetted and grant compliance is verified prior to payment. It also includes assessing the need for increased monitoring to ensure initial program reviews are complete and accurate. This remediation effort was finalized on June 30, 2025, following the September 2024 transaction in question. Additionally, the Department plans to review the remediation plan with all relevant staff again this season. This will ensure that all supporting documentation is thoroughly vetted and that expenditures comply with the applicable award period of performance.

The Colorado Department of Transportation (CDOT) agrees with the recommendation. The Center for Accounting (CFA) and the Office of Transportation Safety (OTS) have coordinated on its implementation. The Department has assessed and updated training for staff responsible for reviewing and approving invoices for Highway Safety Cluster grants, with a specific focus on the period of performance. This training plan will be revisited and reviewed with all staff involved by April 2026.

The Department of Local Affairs (Department) agrees with the recommendation to strengthen internal controls over the financial management of federal Coronavirus Capital Projects Fund grant expenditures and the accuracy and completeness of the Exhibit K1, Schedule of Federal Assistance. The Department will develop a corrective action plan that includes enhanced procedures for the performance of year-end estimates/accruals. The Department will create and implement staff training for staff that are responsible for preparing and reviewing the estimates/accruals, the Exhibit K1, grant transactions and enhancements.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Katie Elliott Contact Phone Number and Email Address: katieelliott@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: While the School Corporation completed the required Time and Effort logs, a time study was not completed and documented to justify the allocation of costs related to the compensation and fringe benefits of the food service director. The School Corporation Food Service Director is now documenting the hours spent each day completing food service activities. Anticipated Completion Date: This Corrective Action Plan will be put in effect January 2026.

FINDING 2025-005 Finding Subject: Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Audit Findings: Significant Deficiency, Other Matter Contact Person Responsible for Corrective Action: Chrystal Street Contact Phone Number and Email Address: cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district has implemented procedures requiring written documentation whenever federally funded materials, equipment, or property are reassigned, repurposed, or disposed of due to project changes. This documentation includes the reason for the change, approval by district administration, the new use or location of the materials, and verification that the use remains allowable under the grant. These records will be maintained with grant documentation and reviewed as part of internal control procedures to ensure compliance moving forward. Anticipated Completion Date: January 2026

Corrective Action Plan: While Elkhorn Slough Foundation performs SAM.gov suspension and debarment checks for all contracted vendors, documentation evidencing these checks was not consistently maintained. The Foundation will implement enhanced documentation and record‑retention procedures to ensure verification records are retained in compliance with the Foundation’s Procurement Policy and 2 CFR § 180.995. Contact Person: Mark Silberstein, Executive Director and Administrative Director with review by outside CPA. Contact: 831‐728‐5939 Anticipated Completion: June 30, 2026

2025-017 ALLOWABLE COSTS/COST PRINCIPLES DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.659 DOHS maintains a multi-layered review process for P-card payments. While documentation for the two specific transactions totaling $26 was unavailable at the time of the audit, these transactions were processed through the same automated financial system that enforces budgetary limits and eligibility checks for all validated cases. Due to current system configurations, P-card transactions must be processed even when documentation is missing. According to the internal controls, any transaction not properly reconciled is marked “Admin Not Reconciled”. This designation indicates the DOHS is aware of the missing documentation, which, according to policy, becomes the cardholder’s responsibility. The Office of Shared Administration (OSA) P-card Division provides reconciliation dates and notifies coordinators of any unreconciled transactions. If a cardholder loses a receipt, they are permitted to submit a lost receipt memo detailing the purchase, accompanied by a supervisor’s signature. The P-card Division has recently begun working closely with the DOHS’s internal purchasing card audit section within the OSA Office of Accountability and Management Reporting (OAMR) to mitigate reconciliation errors. OAMR reviews transactions for accuracy and completeness. Through this coordinated effort, missing documentation or errors are investigated and brought to management’s attention. DOHS will continue to issue monthly notifications to staff emphasizing that all P-card expenditures must be reconciled with proper documentation within one week of the cycle end date. Reconciliations must be electronically reviewed and approved by a supervisor to verify the allowability of costs. To mitigate noncompliance, the P-card Division will work with OAMR to monitor repeated occurrences. Persistent failure to provide documentation or obtain approval may result in the temporary suspension of purchasing privileges. These measures ensure that documentation is maintained, reviewed, and readily available for future audits.

2025-016 ALLOWABLE COSTS/COST PRINCIPLES DEPARTMENT OF HEALTH & HUMAN SERVICES (DOHHS) Assistance Listing Number: 93.658 DOHHS maintains a multi-layered review process for P-card payments. While documentation for the two specific transactions totaling $50 was unavailable at the time of the audit, these transactions were processed through the same automated financial system that enforces budgetary limits and eligibility checks for all validated cases. Due to current system configurations, P-card transactions must be processed even when documentation is missing. According to the internal controls, any transaction not properly reconciled is marked “Admin Not Reconciled”. This designation indicates the DOHHS is aware of the missing documentation, which, according to policy, becomes the cardholder’s responsibility. The Office of Shared Administration (OSA) P-card Division provides reconciliation dates and notifies coordinators of any unreconciled transactions. If a cardholder loses a receipt, they are permitted to submit a lost receipt memo detailing the purchase, accompanied by a supervisor’s signature. The P-card Division has recently begun working closely with the DOHHS’s internal purchasing card audit section within the OSA Office of Accountability and Management Reporting (OAMR) to mitigate reconciliation errors. OAMR reviews transactions for accuracy and completeness. Through this coordinated effort, missing documentation or errors are investigated and brought to management’s attention. DOHHS will continue to issue monthly notifications to staff emphasizing that all P-card expenditures must be reconciled with proper documentation within one week of the cycle end date. Reconciliations must be electronically reviewed and approved by a supervisor to verify the allowability of costs. To mitigate noncompliance, the P-card Division will work with OAMR to monitor repeated occurrences. Persistent failure to provide documentation or obtain approval may result in the temporary suspension of purchasing privileges. These measures ensure that documentation is maintained, reviewed, and readily available for future audits.

2025-015 ALLOWABLE COSTS/COST PRINCIPLES, ELIGIBILITY DEPARTMENT OF HEALTH & HUMAN SERVICES (DOHHS) Assistance Listing Number: 93.658 DOHHS’s corrective action plan from the prior audit indicated that a system change was made during FY 2025 to prevent future payments to psychiatric facilities from being charged to the Foster Care program. This change did go into effect on September 19, 2024. However, this provider was an anomaly. The facility was a Residential Treatment Facility which was Title IV-E eligible until they received Psychiatric Residential Treatment Facility (PRTF) status in August of 2024, however, they did not provide DOHHS documentation until February 2025. Immediate action was taken by a call ticket to the Technical Call Center to ensure that the PRTF was not continuing to show as IV-E eligible. The staff from the Division of Regulatory Management will continue, as part of their annual licensing review will ensure wvPATH provider records are updated to reflect timely licensing status as well as ensuring that child specific agreements do not lapse. The previously stated Corrective Action Plan remains in place and will continue.

The entity has implemented new procedures for the preparation and review of reimbursement requests.

FA 2025-001 Strengthen Controls over Employee Compensation Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Allowable Costs/Cost Principles Significant Deficiency Nonmaterial Noncompliance U.S. Department of Education Georgia Department of Education 84.027 - Special Education Cluster Grant to States 84.173 - Special Education Cluster Preschool Grants H027A230073 (Year: 2024), H027A240073 (Year: 2025), H173A240081 (Year: 2025) $1,283 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 Special Education Cluster. Corrective Action Plans: The District concurs with the finding and is committed to strengthening internal controls. While the identified discrepancies were isolated, we recognize the need for enhanced reconciliation during personnel transitions. The Human Resources and Finance departments will enhance our review process. This pre-payroll validation step will ensure that all salary adjustments and position changes align with Board authorized pay documentation prior to disbursement. Estimated Completion Date: 3/31/2026 Contact Person: Julie Wiley, Chief Financial Officer Telephone: 229-316-1878 Email: juliewiley@lowndes.k12.ga.us

Finding Number 2025-002 Condition: The District could not provide supporting documentation for one (1) invoice charged to the program. Management Response/Plan: The District acknowledges the finding and has strengthened internal controls over disbursements by implementing centralized invoice retention procedures and requiring verification of supporting documentation prior to payment approval. Staff have been retrained on documentation requirements, and periodic monitoring will be conducted to ensure all expenditures are properly supported and maintained. Anticipated Date of completion: June 2026 Name of Contact Person: Dr. Joe Mullikin

Finding Number 2025-001 Condition: The District was unable to provide documentation for three invoices charged to the program. The District was also unable to provide supporting documentation for one employee time card. Management Response/Plan: The District acknowledges the finding and has strengthened internal controls over disbursements by implementing centralized invoice retention procedures and requiring verification of supporting documentation prior to payment approval. Staff have been retrained on documentation requirements, and periodic monitoring will be conducted to ensure all expenditures are properly supported and maintained. Anticipated Date of completion: June 2026 Name of Contact Person: Dr. Joe Mullikin

Material weakness in internal control over compliance - Lack of control over monitoring of excess costs Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of excess costs during the year. Program staff and business office personnel will meet regularly to identify any potential issues for noncompliance with excess costs and develop a plan accordingly to ensure compliance is met. Staff training and utilization of the calculation tools provided by TEA will be provided to ensure all involved gain the necessary understanding. Responsible Contact Person: Farrah Jernigan, Chief Financial Officer Anticipated Completion Date: June 30, 2026

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will document the allocation methods used for employees and expenses.

The City concurs with the finding. The Department of Health, Housing & Homelessness will review the allocation of fringe benefits to grant payroll charges on a quarterly basis to ensure fringe benefits are properly allocated to funding sources. The reconciliations will be prepared by fiscal staff and approved by the Fiscal Manager. Additionally, the DFAS Grant Administrator will perform a semi-annual review of excess leave payouts to ensure they are charged to the correct grant funding string.

Recommendation: CLA recommends the Agency follow established policies to maintain supporting documentation for expenses incurred including their review and approval. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: We have established a policy to maintain our supporting documentation in our expense management software. We lost our access to Concur when we terminated the contract in March 2025. This finding is related to the Concur system, which we have no access to. Going forward we have the Ramp expense management software that retains all the relevant supporting documentation. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Completed as of January 1, 2025 for all future transactions, implemented via Ramp Software.

The University concurs that costs charged to federal awards must be incurred within the approved period of performance in accordance with Uniform Guidance and the OMB Compliance Supplement. The instances identified during the audit were attributable to personnel turnover within Research and Sponsored Programs (RSP), which resulted in isolated lapses in the consistent application of existing period of performance review procedures during the period under audit. Upon identification of these items, the Office of the Controller (OoC), in its oversight role for financial reporting and compliance, coordinated with RSP to address the questioned costs. RSP initiated the process to remove the costs from the affected grants and, where applicable, to consult with the sponsor and refund the disallowed amounts. As part of the corrective action plan, RSP will reinforce existing period of performance controls through targeted communication and training with responsible personnel involved in grant administration and expenditure processing. RSP will continue to perform pre- and post-expenditure reviews to ensure that costs charged to federal awards are incurred within the approved budget period and are appropriately documented. These actions are focused on reinforcing the timing review of expenditures charged to federal awards and are intended to ensure ongoing compliance with Uniform Guidance requirements and to prevent recurrence of the condition.

Context and Cause – During the year ended June 30, 2025, a severance payment was issued to an employee that worked on more than one federal program. The payment was an allowable cost, but was not allocated across the other federal programs based on time and effort per their policy. While internal controls and procedures have been established for payroll expenses, the procedures were bypassed when processing the severance payment. It should be noted that the employee spent the majority of their time on the program the severance was allocated to, and the transaction was isolated. Recommendation – The Organization should follow establish written policies and procedures for allocation of costs. Allocation spreadsheets currently used for the allocation of payroll should be used for all payroll related costs. Action Taken: OMEP will utilize standard allocation procedures for all payroll related payments going forward. Responsible parties: Controller. Anticipated completion date: June 30, 2026.

FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our earmarking for the future. Description of Corrective Action Plan: Although Merrillville Community School Corporation left Northwest Indiana Special Education Cooperative (NISEC) as of July 1, 2024 we continue to track time and effort logs for individuals servicing our non-public students with disabilities. These are housed in the special education office located at Pierce Middle School. Since staff are performing special education duties only, reports are logged semiannually. NISEC has reported that for the 2023-2024 school year the corrective action plan was implemented fully. Anticipated Completion Date: This was completed fully as of July 1, 2024.

Response and Corrective Action Plan prepared by: Leanne Green Person Responsible for Implementing the Corrective Action: Leanne Green Anticipated Completion Date of Corrective Action: Vickie Dunaway, School Nutrition Director, corrected and resubmitted the claim in question, as soon as the issue was revealed. USDA paid the difference owed on October 28, 2025. Planned Corrective Action: Once the School Nutrition Director completes the monthly claim, Leanne Green, Finance Director, reviews the paperwork, verifying that all is correct before the claim is filed.

Management at SAHA PM notes its responsibility to establish and maintain effective internal control over financial reporting to provide reasonable assurance that transactions are properly recorded, processed, and summarized to permit the preparation of reliable financial statements in accordance with generally accepted accounting principles (“GAAP”). We plan to establish a checklist for the property accounting team that includes a comparison of gross rent potential to the HUD approved rent schedule.

Audit Finding: The Authority did not have sufficient internal controls to ensure that payroll expenditures submitted to FEMA were incurred within the applicable period of performance prior to submission of the project worksheet. Recommendation: The Authority’s policy and procedures should be designed to strengthen the internal controls over the review of the submissions to ensure accurate reporting as required by the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 1. Enhanced Review of Period of Performance (POP): The Authority will implement a formal verification step requiring the Finance Department to confirm that all costs included in FEMA project worksheets were incurred within the approved period of performance prior to submission. This verification will specifically address payroll costs that span multiple pay periods. 2. Payroll Cost Allocation Controls: Payroll expenditures that cross fiscal periods or project periods of performance will be allocated based on actual days worked within the applicable period. Payroll reports will be reviewed to ensure that only eligible dates are included in each FEMA project. 3. Secondary Review: The Authority will require a secondary review by a finance staff member not involved in the initial preparation of the FEMA project worksheet to ensure accuracy, completeness, and compliance with FEMA eligibility requirements. 4. Correction of Identified Error: Management has corrected the duplicated payroll costs of $104,434 by removing them from the project ending June 30, 2022 and ensuring they are only reported in the project beginning July 1, 2022. Total FEMA expenditures reported on the Schedule of Expenditures of Federal Awards were adjusted accordingly. In addition, VCUHSA has voluntarily prepared a letter to VDEM to alert them of the identified issue and request assistance on next steps to return the funds that were received in error. The letter will be followed up by an email. The Finance team has also notified the CFO of both the findings of the audit and the related corrective actions. Name(s) of the contact person(s) responsible for corrective action: Min Cummings, VP of Finance and Accounting, 804-827-0545 Planned completion date for corrective action plan: Notification of error to be sent to VDEM within 60 days of audit completion. All other planned actions to be implemented immediately for any future costs and expenditures.