Corrective Action Plans

Panthera implemented Chrome River which is a platform that enables electronic review and approval of invoices as part of Panthera’s expense management process. As Panthera expands its operations internationally we plan to implement more controls and procedures to ensure foreign affiliates are properly maintaining all required expenditures documentation and approvals on spending.

Responsible: Denice Hairston, Chief Quality, Compliance and Accountability Officer Corrective Actions: Update subrecipient award agreements to ensure the final approved scope of work or project description is specified. Completion Date: March 29, 2023 Explanation: Policies and procedures were updated in 2023 in response to an OJJDP/OCFO recommendation to ensure subaward files contain the requisite components for the award agreement. In addition to these updates, which include a master file checklist, National CASA/GAL has updated the subrecipient Terms & Conditions agreement to include CFR requirements as recommended.

Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Contact Person(s):Nicholas Lee, Chief Financial OfficerCorrective action planned:The Organization will provide additional training to employees responsible for incurring costs in accordance with 2 CFR200.403. Additional resources have been assigned to review and ensure documentation and policies are retained to supportthe distribution of charges between projects. Anticipated completion date:June 30, 2023

CORRECTIVE ACTION PLAN 2021‐2022‐ Finding 1: Significant Deficiency – Allowable Costs/Cost Principles Management’s Response: Delaware County Literacy Council has implemented and followed a cost allocation plan to share costs among different grants consistently. DCLC has instituted a timekeeping and reporting system that properly allocates the cost of salaries and benefits to programs and grants. Data gathered from this system includes the ratio of hours worked in each program to hours worked overall which is used to allocate other expenditures that are attributable to more than one program or grant. DCLC will be within compliance of U.S. Code of Federal Regulations (CFR), Title 2: Grants and Agreements, Part 200 – Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Subpart E – Cost Principles Sec. 200.405 Allocable Costs Completion Date: April 8, 2024 Name(s) of Person(s) Responsible: Colleen Duran, Executive Director

March 27, 2024 2022-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Cost (repeat Finding) Condition: Allocations of non-direct charged wage time (i.e., paid time off, bereavement, jury duty, holiday, medical paid time off, medical waivers) are managed through a labor allocation whereby amounts of non-direct charged wage time are charged to various programs incorrectly. Corrective Action: We agree with the finding. We have addressed this issue with management within the consortium to properly allocate non-direct wage time. This includes the current (March of 2024) procurement of a sufficient payroll and time keeping software to assist in the remediation of this finding. Contact Person: Shamar Herron: Sherron@mwse.org Completion Date: August 2025, procurement will be completed and system implemented. Respectfully, Shamar Herron

Views of Responsible Officials and Planned Corrective Actions: MARR will retain a CPA consultant to recommend to management the establishment of procedures and controls allocate costs between grants based on actual costs attributed to grant and the particular expenditure allowed by the grant. All such allocations will be supported by activity-level substantiation and be reviewed. Documentation of the allocation methodology, review and approval will be maintained in writing

COSA has already strengthened its procedures and documentation policies to ensure staff documentation are correct. Timesheets are being reviewed by management in the program and finance departments on a monthly basis.

Program: AL 20.509 ? Formula Grants for Rural Areas ? Allowability & Subrecipient Monitoring Corrective Action Plan: The Controller Division, Audit Section, will provide support through continued engagement and work collaboratively as an additional resource to the NDOT Transit staff and transit recipients. NDOT Transit staff in collaboration with the Controller Division will be improving the standard operating Procedures which will be utilized for the in-depth review of monthly invoices moving forward. Contact: Khalil Jaber Anticipated Completion Date: Ongoing

Program: Various, including AL 93.778 ? Medical Assistance Program ? Allowable Costs/Cost Principles Corrective Action Plan: The Print Shop will complete a detailed analysis on the analyzed data, and update rates. State Accounting will offset rates to spend down its fund balance to a 60-day operating level. Contact: Philip Olsen / Ann Martinez Anticipated Completion Date: June 30, 2025

Program: AL 93.558 ? Temporary Assistance to Needy Families; AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.658 ? Foster Care Title IV-E ? Allowable Cost/Cost Principles Corrective Action Plan: DHHS will continue to train staff on the proper RMTS procedures, which includes correct method of validation. Contact: Patrick Werner Anticipated Completion Date: 06/30/2023

Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and Development Block Grant ? Allowable Costs/Cost Principles Corrective Action Plan: Several areas within DHHS are currently working to improve upon the process of determining how staff are paid during the hiring process and when turnover occurs. Contact: Patrick Werner Anticipated Completion Date: 02/01/2024

CAP for Finding: 2022-704 Finding 2022-704: Research and Development Cluster?Unallowable Costs Planned Corrective Action: We agree with the condition that expenditures noted by the auditors were posted to federal awards in error. Our institution has robust policies and procedures in place along with multiple levels of review for transactions that post to awards. However, there may be rare instances where a transaction posts to an award for which it is not allowable or allocable. As noted by the auditors, they sampled from a population of $86.9 million from certain expenditure codes and only questioned $650 in costs. These expenditures have now been transferred off the awards to non-sponsored funding. To help Research Administrators manage Research and Development Awards, RSP (Research and Sponsored Programs) offers a variety of tools. RSP maintains a website that houses policies and procedures related to all relevant Research Administration topics. In addition to this, the RSP website has FAQ (Frequently Asked Questions) pages on a variety of Research Administration topics. RSP also offers a comprehensive training program called RED (Research Education Development). We offer courses that include topics such as a basic introduction to research administration, closeout of awards, cost-share, cost-transfers, and many others. We will remind administrators and their staff of all the relevant information our website houses and that they should take any pertinent RED. Lastly, we will remind staff that they can retake courses if they haven?t taken them recently and want to refresh their knowledge. Anticipated Completion Date: 5/31/23 Person responsible for corrective action: Kyle Everard, Manager of NSF-DOE Team Research and Sponsored Programs Kyle.Everard@rsp.wisc.edu

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Jamie Arce, Controller Contact Phone Number: 574-322-4863 Views of Responsible Official: Management agrees with the finding. Description of Corrective Action Plan: The City will review its existing policies and procedures surrounding adequate supporting documentation and will update policy as required. Training on this requirement will be provided to all City Staff involved in procurement. Anticipated Completion Date: October 31, 2023

Finding # 2022-007 Title of Finding Subrecipient Monitoring Contact Person Brook Hinzman Anticipated Completion Date June 2023 Corrective Action planned to be taken: Will comply and monitor subrecipient spending going forward.

Item: 2022-003 Assistance Listing Number: 14.241 Programs: Housing Opportunities for Persons with Aids Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 144347 Award Year: July 1, 2021 ? June 30, 2022 and July 1, 2022 ? June 30, 2023 Compliance Requirement: Allowable Activities and Costs Criteria: In accordance with 2 CFR ? 200.405 - Allocable costs ? a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost is incurred specifically for the Federal award, benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods and is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in subpart E. Condition: In fiscal year 2022, the Organization did not have an adequate process to review and approve employee cell phone costs charged to the program resulting in non-program costs being charged to the program. Name of Contact Person: Mike Fett, CFO Phone Number: (602) 265-8338 Anticipated Completion Date: September 30, 2023 Views of Responsible Officials and Corrective Actions: Southwest Behavioral Health Services, Inc. and Subsidiaries will establish additional policies and procedures to ensure adequate review of cell phone bills occurs and terminated and transferred employees are removed immediately. Additionally, we will implement proper review controls over the cost reimbursement reports to identify issues like these timely.

Item: 2022-002 Assistance Listing Number: 14.231 Programs: COVID-19 Emergency Solutions Grant ? Homeless Street Outreach Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 154962-0 Award Year: July 1, 2021 ? June 30, 2022 and July 1, 2022 ? September 30, 2022 Criteria: In accordance with 2 CFR ? 200.405 - Allocable costs ? a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. This standard is met if the cost is incurred specifically for the Federal award, benefits both the Federal award and other work of the non-Federal entity and can be distributed in proportions that may be approximated using reasonable methods and is necessary to the overall operation of the non-Federal entity and is assignable in part to the Federal award in accordance with the principles in subpart E. Condition: In fiscal year 2022, the Organization did not have an adequate process to review and approve employee cell phone costs charged to the program resulting in non-program costs being charged to the program. One employee's phone bill continued to be charged to the grant after they stopped working on the program. Name of Contact Person: Mike Fett, CFO Phone Number: (602) 265-8338 Anticipated Completion Date: September 30, 2023 Views of Responsible Officials and Corrective Actions: Southwest Behavioral Health Services, Inc. and Subsidiaries will establish additional policies and procedures to ensure adequate review of cell phone bills occurs and terminated and transferred employees are removed immediately. Additionally, we will implement proper review controls over the cost reimbursement reports to identify issues like these timely.

The allocation of costs between our two federal programs and other programs are made by the Program Director or after discussion between the Program Director and the Federal Grant Manager; then communicated to the accountant. In addition, our accountant has the program knowledge and ability to question cost allocations. Beginning mid-September, 2023, the basis for allocations will be documented on an invoice or other supporting documents. Effective June 2023, weekly payroll time records allocating hours to projects and programs are prepared by each employee. Those time records are approved by the Program Director or the Treasurer, as appropriate. The allocations are then reviewed by the Federal Grant Manager and entered bi-weekly into the accounting records.

Audit Finding Reference Number: 2022-002 Recommendation - South Shore should enhance its internal control processes related to preparation and review of the monthly claim for reimbursement. Corrective Action Plan - We have adjusted our policies and procedures to assure that every claim submission is reviewed by both the Controller and CFO prior submission. Claim form and appropriate documentation will be submitted to the Controller who will give initial review. Review will consider timeliness of items claimed as well as appropriateness for the particular federal grant. CFO will then provide final authorization in writing to both grants accountant and controller at which time claim for reimbursement can be submitted by grant accountant.

Nevada Urban Indians, Inc. (NUI) will implement an allocation disclosure on all backup documentation that is verifiable to program budgets. NUI will also implement a rolling 12-month allocation plan to ensure that all funds received are being spent appropriately and that there will not be a fund deficiency. This 12-month allocation will be reviewed monthly and allocations will be adjusted as needed. In the event that previous allocations need to be changed, NUI will shift costs per 2 CFR 200.405 (c) and (d) and provide additional backup documentation showing the change and why the change was made.

Finding 2022-004 ? Unallowable Use of Public Housing Program Funds Public Housing Program ? Assistance Listing No. 14.850a, Grant Period: Fiscal Year-End June 30, 2022 Corrective Action The Authority review allowable Public Housing Program versus COCC expenditures in HUD Handbook 7575.1 and refrain from charging COCC expenditures to the Public Housing Program. The Authority?s Executive Director, Africa Porter, has assumed the responsibility of executing this corrective action as of April 1, 2023.

Significant Deficiency in Internal Control over Compliance and Other Matters 2022-004 Unallowable Costs U.S. Department of Health and Human Services Child Care and Development Fund Block Grant (CCDF) ? CRSSA (Coronavirus Response and Relieve Supplemental Act) Assistance Listing Numbers: 93.575 Recommendation: We recommend the program work closely with ASD to ensure expenditures are tracked and mapped to the appropriate federal award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The ECECD ASD Director, CFO and Grants Manager will work with the Federal Program Team to develop formal policies and procedures for grant management to ensure compliance with programmatic grant requirements and track expenditures to ensure costs charged to grants are allowable, necessary, and reasonable. Name(s) of the contact person(s) responsible for corrective action: Ron Lucero, ASD Director; Carmel Pacheco-Aragon, Chief Financial Officer; Grants Manager (TBA); ECECD Program Managers. Planned completion date for corrective action plan: June 30, 2023

Finding 2022-003: Activities Allowed or Unallowed Federal Agency: U.S. Department of Education Special Education Cluster (IDEA) Federal Assistance Listing Number 84.027, Special Education ? Grants to States Federal Assistance Listing Number 84.173, Special Education ? Preschool Grants Condition One of the eight payroll samples selected for testing had incorrect salary percentages applied to the grant when compared to the tasks completed and approved budget for the grant. Corrective Action Planned The District will put procedures in place to verify all expenditures, including payroll, that flow through the federal grants for accuracy. Anticipated Completion Date November 2022 Individual Responsible for Corrective Action Plan Lisa Raymond, Assistant Superintendent of Business

The Organization billed the federal government for amounts of costs that had not yet been incurred and is at-risk for noncompliance with allowable activities and allowable costs, as well as cash management requirements. Statement of Concurrence or Nonconcurrence: Flower Hill has been billing the US Department of Agriculture 100% of its annual expenses in equal monthly amounts whether the total amount billed was expensed or not. According to audit, this is not allowable under a cost reimbursable contract. The organization agrees with, understands this finding and has already implemented corrective action to this finding. Questioned Costs $186,089 Corrective Action: Corrective action has been taken. FHI has discussed this finding with grantor (USDA Department of Agriculture) as has Auditor. To date, there has been no action taken by the USDA. As of July 2023, FHI has been billing only reimbursable amounts for direct costs incurred and for the approved 10% indirect rate. Name of Contact Person: Person responsible for completing the corrective action plan is Nicole Mast, Director of Operations, nmast@flowerhill.institute. Projected Completion Date: July 2023 Oversight: Billings will be monitored on a monthly basis to ensure full implementation through the end of the current contract (currently March 2026).

Corrective Action Plan: VDH has updated its accounting structure and cost allocation plan to ensure that costs not otherwise eligible under federal grant awards are not attributed to the VDH administrative cost pool and allocated to federal grant programs. Scheduled Completion Date: 10/1/2022 Contacts for Corrective Action Plan: Megan Hoke, Financial Director, Vermont Department of Health Peter Moino, Director of Internal Audit, Vermont Agency of Human Services

Recommendation: We recommend that the District implement procedures to review that expenditures claimed under the program are allowable and are not already claimed. Action taken: Cathy Meher, treasurer, reviewed this with the external auditors and those questioned costs had not been claimed for reimbursement and will be reviewed prior to submission to Grants Finance for reimbursement. Dr. Christopher Wojeski, Assistant Superintendent, will also review the expenditures to ensure they are allowable costs. With the addition of a new staff member in the Business Office, this will be addressed and corrected immediately. Anticipated completion date: 11/1/22