Corrective Action Plans

Corrective Action Plan: The identified conditions relate to the proper application and calculation of indirect cost rates for federal research grants. Further items relate to the assignment of the proper fringe rate for federal research grants. To mitigate future occurrences of possible incorrect rates applied to such contracts, the College has strengthened its internal controls and oversight by reviewing and reperforming calculations. Timeline for Implementation of Corrective Action Plan: These corrective actions were implemented by spring 2025.

Views of Responsible Officials: Federal grant requests and reporting is the function of three teams: Programs, Development and Finance. Prior to the hiring of the VP-Finance, the Associate Director, Grants Management and Compliance met with the Associate Director, Partnerships on a quarterly basis to discuss required program spend reimbursements and projected program cash needs prior to submitting the formal requests. With the onboarding of the new VP-Finance, internal review processes were changed to incorporate more robust segregation of duties, alignment with the internal cash management policies and procedures and formal review of drawdown requests prior to submission. The VP-Finance became a permanent employee in October 2024 and since then all submissions have obtained the appropriate approval prior to submission.

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

Effective August 2023; new sub-awards and pass thru grant agreements have elements specified in the respective agreement as required by Uniform Guidance, Part 200.332. In addition, Iowa Workforce Development is in the process of reaching out to grantees whose awards did not clearly state that the specified award is research and development, and that there will be no indirect costs assumed for reimbursement, as this was assumed given the nature of the projects as well as discussions that were had during the awarding process.

Effective late fiscal year 2024; new sub-awards and pass thru grant agreements utilize a cover sheet to ensure all required elements listed in 2 CFR 200.332 are clearly included in the subaward agreements.

2024-009 Research and Development Cluster – Federal Assistance Listing Nos. Various – Indirect Cost Rate Recommendation: We recommend management and the applicable grant individuals to properly validate the rate being used in the calculation to the grant agreement. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: Restricted Funds Accounting (RFA) team will ensure updated SOPS include checks and balances to include a review process to make sure that the IDC amount matches the award documents. Automate process within the ERP systems, as applicable. Name(s) of the contact person(s) responsible for corrective action: Director of Accounting, Tonya A. Cardwell Planned completion date for corrective action plan: December 2026

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 93.568 Low-Income Home Energy Assistance State Agency: Department of Energy Audit Contact: Leonard Rautio Title: Chief of Operations Telephone: (603) 271-6008 E-mail address: leonard.j.rautio1@energy.nh.gov Audit Report Reference: 2024-021, 2023-015, 2022-025,2021-027 – Subrecipient Monitoring Anticipated Completion Date: Complete Corrective Action Planned: Concur The Department has put into place processes and updated our procedures to prevent this from happening in the future. However, we were unable to change amendments that were completed prior to the implementation of these procedures. All new contracts and amendments since the change in procedures include the required information. The Department has made changes to processes and personnel to ensure the data compiled and utilized for the Annual Report on Households Assisted by LIHEAP is verified, complete, and accurate. While a federally approved third-party completed the report reviewed for this audit, the Department successfully completed the most recent Annual Household Report (due December 2024).

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildlife.nh.gov Audit Report Reference: 2024-008 - Matching Anticipated Completion Date: June 30, 2025 Corrective Action Planned: To have revised procedures in place to include additional documentation to ensure accuracy from the subrecipient. We concur with the finding; A. In-kind match documentation earned requires additional documentation to support subrecipient match contribution. Revised procedures will be implemented to include additional documentation from the subrecipient to ensure accuracy. B. Internal review of volunteer in-kind match calculations are in place, however, in one instance, prior year rates were used resulting in under reported in-kind match earned. The Department does review and track match received from the subrecipient. We do not agree there are questioned costs of $201,250.

The Organization will update its subrecipient monitoring policies to ensure all required elements as defined in 2 CFR § 200.332 (a)(1) are included in subrecipient agreements, Additionally, a checklist will be established to perform a risk assessment process to evaluate subrecipient risk prior to contract execution and annually thereafter and to verify each subrecipient’s that meets the audit threshold and if required has a current Single Audit on file or is otherwise in compliance.

The District will discuss the results of this audit with our ESC to establish protocols and receive copies of their annual audit reports for review.

2024-002 Indirect Costs Responsible Official Mary Chase, Director of Finance Plan Details We will adjust our grant award billings to the grantor to reflect the corrected indirect cost charges to each award and return any excess grant funds received. Additionally, management will update its procedures for calculating modified total direct costs and related indirect cost charges to federal grant awards. Anticipated Completion Date The corrective action is in the process of being implemented and expected to be completed in 2025.

Corrective Action Plan Finding 2024-001 Finding Summary: The Center did not exclude charges for patient care when calculating modified total direct costs (MTDC) in accordance with Uniform Guidance and TxGMS and thus the indirect rate used in calculating the indirect amount charged to the grant was not consistently accurate. Corrective Action Plan: The Center has historically calculated the indirect amount using the same methodology over time. Given the small volume of patient receipts, the impact on the total indirect amount is minor. We believe that had we modified our calculations, we would have had enough modified total direct costs to cover the change in the calculation. The Center will modify all future calculations to ensure alignment. We will also review the fiscal year covered under this audit to understand what the impact of the change would have been on the split between cost types. Note that since we are midway through our next fiscal year, and we consider the differences minor, we have determined that we will correct for any future reimbursement requests, but will not modify prior reimbursement requests. Similarly, we will conduct a review of that fiscal year to determine the impact of the change and verify it is not significant. Responsible Individuals: Rusty Taylor, CFO Joe Carrington, Director of Financial Planning and Analysis Anticipated Completion Date: August 2025

Views of Responsible Officials and Planned Corrective Action: The Department will execute an amendment to the grant agreements for all ARPA funding not disbursed as of 7/1/2024 to include the missing data as detailed in the finding. Staff will be trained on Uniform Guidance requirements. Anticipated Completion Date: June 30, 2025 Contact Person: Debby Dickson Water Development Division Manager Arkansas Department of Agriculture-Natural Resources Division 1 Natural Resources Drive Little Rock, AR 72205 (501) 225-1598 Debra.Dickson@agriculture.arkansas.gov

Views of Responsible Officials and Planned Corrective Action: In 2023, ASBO sent out Amendment #1 for all SLFRF subgrants. This amendment was a one-page sheet providing information for all the requirements listed in 2 CFR § 200.332(a)(1). The subrecipient listed in this finding, Extreme Broadband, did not acknowledge or return their amendment. We will begin to request acknowledgement from this provider on a continuous quarterly basis. Anticipated Completion Date: March 4, 2025 Contact Person: Glen Howie, Jr. Director, Ark State Broadband Office Department of Commerce 1 Commerce Way Little Rock, AR 72202 (501) 682-1123 Glen.Howie@Arkansas.gov

Corrective Action: The Business Manager will calculate the indirect \ cost rate using the rate provided by MDE for the expenditures occurred. The calculation will be reviewed and signed off on by the Federal Programs Director and Child Nutrition Director. This calculation will take place at year end once expenditures are booked. Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: February 18, 2025

Food Distribution Cluster US Department of Agriculture / Oregon Department of Human Services / Farmers Market Fund Federal Assistance Listing Number: 10.565, 10.568, 10.569, 10.182, 10.331 Federal Program Name: Food Distribution Cluster, Local Food Purchase Assistance Cooperative, Gus Schumacher Nutrition Incentive Program OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Starr Yurkewycz, Director of Partnerships and Programs; Nathan Harris, Director of Community Philanthropy; Shannon Oliver, Interim Director of Operations Corrective Action Plan: Finance will assess requirements and establish procedures and internal controls to ensure the consistent application, billing, and reporting of indirect cost rates across all federal awards. This will include collaborating with grant writing staff during the pre-application and pre-award phases to centralize grant preparation and ensure indirect rates are accurately applied in grant proposals and budgets. Multiple dedicated review steps in the grant lifecycle will be developed to both ensure accuracy of the rates charged and address any changes from the Federal Government. Existing strengths, tools, and capacity will be reviewed to support this process, including alignment with subrecipient indirect cost practices. Training will be provided to individuals responsible for these controls to ensure accurate implementation and ongoing compliance. These actions will improve our ability to manage indirect costs effectively and ensure compliance with federal requirements. The anticipated completion date is June 30, 2026.

State Treasurer’s Office Response/Corrective Action Plan: The Office of State Treasurer does agree with finding that our grant award template did not make subrecipients aware of all required grant award information for the Mineral Leasing Act as required. The Office of State Treasurer will review and update its grant award templates to ensure that subrecipients are made aware of all required grant award information. Contact Person: Nicole Krivoruchka, Director of Finance Anticipated Completion Date: December 31, 2025

Management’s Response or Department’s Response The County agrees with the finding and recommendation. Views of Responsible Officials and Corrective Action Plan The County will implement a formalized monitoring program and agreement template to identify subrecipients based on criteria in § 200.332. The County will provide a comprehensive training to program managers to implement the monitoring program and subrecipient agreement template. In addition, the County will include direction to project managers to review current awards to identify existing subrecipients that were not provided a subrecipient agreement with all of the required elements from CFR § 200.332. Anticipated Completion Date/Completion Date June 30, 2026 Contact Information of Responsible Official Name: Donald McNair Title: County Clerk & Auditor-Controller Phone: 209-533-6593

Upon receiving results of the FY21 audit (completed in FY24), TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal billing records (approximately 7.5% additional uplift) was not allowable as it was being calculated. TAS is allowed a 10% de minimis rate on noted FY22 Federal awards, some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimis rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation. After the presentation of this finding in mid-2024, TAS adjusted federal billing for administrative expenses to the de minimis rate (10%) as a percentage, unless otherwise noted in the agreement. Anticipated completion date: In effect.

2023-005 Indirect Cost Rate Agreement (NICRA) Recommendation: Auditors recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed. Specifically, auditors recommend that CIES modify internal controls to include a review and approval process for submission of all invoices submitted to grantors, including showing the indirect cost rate calculations. Criteria: 2 CFR 200.414(c) – Federal award recipients must negotiate an indirect cost rate with the cognizant agency for indirect costs, which is typically the federal agency that provides the most funding to the recipient. 2 CFR 200.403(d) – The negotiated rate must be applied consistently across all federal awards to ensure uniformity in cost allocation. 2 CFR 200.302(b)(3) – Recipients must maintain adequate documentation to support indirect costs charged to federal awards, ensuring compliance with the cost principles outlined in the regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Project invoices will be prepared by a member of the CIES administrative staff with enough details to show direct and indirect cost rate calculations. Invoices will be reviewed and approved by either the Chief Operations Officer or the Executive Director. Review and Signature approvals will be added to all invoices to meet the criteria identified in this finding. Name(s) of the contact person(s) responsible for corrective action: Michael Parker, Executive Director Planned completion date for corrective action plan: April 2026

Finding 2023-003 – Indirect Cost Allocations In response to the finding, GEM will improve program costs allocation documentation by instituting the following controls and procedures: GEM allocated indirect costs to the NSF program based on actual expenses incurred and monthly allocations approved by the program administrator. These indirect costs are recorded separately in the accounting system. Formal written procedures are now in place, and we will maintain active oversight to ensure full adherence to all established policies. Anticipated date of completion: Monthly journal entry is set up with calculations for determining the dollar amount. The date of completion was October 2022 and have been updated since then. Responsible party: Jamie D. Hicks, Senior Accounting Manager

Finding Number 2023-006 Subject Heading (Financial) or AL no. and program name (Federal) 93.658 – Foster Care Planned Corrective Action The risk assessment cannot be completed until we have actual data and performance needed to make that assessment. Subrecipient risk assessments are completed at the beginning of the fiscal year based on prior year data and performance. The changes to all of the subrecipient agreements identified have been in process and were completed during State fiscal years 2024 and 2025. Additional findings are expected for the 2024 audit since the audit timing is currently almost two years in arrears. Anticipated Completion Date February 2025 Responsible Contact Person Kevin Haddock

Finding Number 2023-096 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action The State agrees with this finding. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. Finally, OMES Finance has developed processes which provide for a more thorough coding of expenditures and proper review of expenditures when reporting on their GAAP Z. The State disagrees with the finding. The State had two Grant Award Notifications in place with the Boys and Girls Club which reflects the monies awarded to be used on the capital improvements and Club on the Go Mobile Clubhouses. This indicates the funds were obligated during the covered period. Per the email from the Keri for Jill Geiger Consulting, no signatures on the GANs were required and the Uniform Guidance does not require the GAN to be signed. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

The City will review the process for identifying federal awards to minimize the likelihood of errors in preparing the schedule of expenditures of federal awards to minimize the likelihood of errors in preparing the schedule of expenditures of federal awards. This will include inquiries of the Engineer’s Office.

The School District will review the Uniform Guidance requirements and ensure all expenditures are accurately reported on the School District’s Schedule of Expenditures of Federal Awards.