Corrective Action Plans

Federal Schedule Audit Comment: County Response Emergency Rental Assistance Program Timely Reporting: The County made every attempt through communications with the Treasury to upload annual reports for ERA 1, without being able to do so by the due date. The County did submit the documents manually by e-mail through dumps of the system. County staff worked with the US Treasury to address these issues. A resolution to the problem did not occur until second quarter of 2023. The Final report for ERA 1 has been submitted through the portal. Cumulative Expenditure/ Obligation Amounts: There was some misinterpretation on the part of County staff on whether the cumulative amounts to be reported was for the quarter or cumulatively for the grant program. It is to be noted that amounts in the County system were properly recorded and no exceptions were noted in the actual expenses/ obligations being for a valid grant purposes. Corrected on Final Report for ERA 1. State/ Local Federal Relief Funds Program Cumulative Expenditures/ Obligations Incorrectly Reported: There was some misinterpretation on the part of County staff on reporting the election of the $10,000,000.00 Revenue Replacement Funds for the SLFRF. It was thought that you could only show the $10,000,000.00 as obligated and expended once the election was made. This resulted in a net overstatement of obligations for any revenue replacements funds that were not yet obligated by resolution by the Board of Mahoning County Commissioners. The County tracked the individual projects by notes in the Treasury system to note the actual obligations. The County?s financial system tracks grants by fund, department and project codes. The funds in the County?s financial system were and are correctly obligated and tracked. The County will make the necessary corrections to the 2023 second quarter report to make sure the report agrees with the County?s financial system. It is to be noted that no exceptions were noted in funds being used for the stated purposes of the grant. Senior management will provide additional oversight to the reports prior to submitting to the US Treasury.

2022-004 ? Allowable Costs/Activities Allowed or Unallowed: Indirect Cost Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer. Corrective Action: Safe & Sound?s Finance team implemented policies and procedures to ensure the indirect cost rate is calculated based on modified total direct costs, which excludes amounts over $25,000 for subawards. We updated our formulas to ensure that we properly calculated indirect costs on a monthly basis, ensuring the exclusion of subawards over $25,000. Date Completed: 7/31/2023

DPH agrees with the finding and recommendations. DPH will notify its subrecipients about their subawards and include any changes in subsequent subaward modifications. DHSP will strengthen its review processes to complete and include the Notice of Federal Subaward Information form as part of the contract copy at the time of the contract execution.

Individuals Responsible for Corrective Action Plan: Jason Penegar, BGCA Vice President ? Controller Shelby Mahoney, Accounting Manager - State Alliances Corrective Action: Management will review grant agreements to confirm whether expenditures from pass-through entities are related to federal or state grants, and appropriately include applicable federal grants in the SEFA. Anticipated Completion Date: December 31, 2023

The City of Boston?s Age Strong Commission has revised the addendum that is attached to their award letters to include whether or not the award is R&D and a section on indirect cost rate. Anticipated Completion Date: June 30, 2022 Responsible Contact Person: Scott Finn, Assistant City Auditor, Grants Monitoring Unit scott.finn@boston.gov

Department of Health and Human Services 2022-002 Immunization Research, Demonstration, Public Information and Education, Training and Clinical Skills Improvement Projects - Assistance Listing No. 93.185 Recommendation: We recommend the Foundation attend training, review federal requirements, and fully understand the requirements over indirect costs Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: CFGF will engage with external firm to assist with fully understanding requirements related to indirect costs and federal requirements. CFGF will also work with external firm to assist in the identification and selection of additional training opportunities for staff who work on federal programs. Name(s) of the contact person(s) responsible for corrective action: Brett Hunkins Planned completion date for corrective action plan: December 31, 2023

The County agrees with the finding and recommendation. On September 12, 2022, the County issued the ?Notice of Federal Subaward Information Template and Subrecipient Monitoring? memo, which provided departments with a template to communicate the 14 subrecipient reporting requirements from 2 CFR ?200.332(a) to their subrecipients at the time of the subaward. The memo also reminded departments to provide all the required elements from 2 CFR ?200.332(a) to existing CRF subrecipients that were not initially provided all the requirements. In addition, the memo reminded departments that subrecipient agreements must include detailed expectations for periodic reporting and timing of reporting submission. On January 12, 2023, the County issued the ?CARES and ARP Act Funds Subrecipient Monitoring? memo, which reminded departments that subrecipient agreements must include data encryption requirements. The memo also reminded departments that existing subrecipient agreements without data encryption requirements will need to be amended by departments. In May 2023, during the Single Audit Kick-off annual meeting, the County will include the issued ?Notice of Federal Subaward Information Template? on the presentation slides and remind departments that the template should be used to communicate the 14 subrecipient reporting requirements. The County will also reiterate that departments need to maintain documentation that the template was provided to subrecipients at the time of the subaward and existing subrecipients that were not initially provided all the subaward requirements.

Management?s Response: Effective fiscal year 2022-23, the Association will follow section 2 of the CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. The costs, for which the benefit can be directly identified, will be charged to the benefiting grant and category. Shared/Joint costs will be charged based on employees? time reported (timesheet and labor distribution), units of services (meals, care management units, number of-participants, hours of service, etc.), square footage, or other method that will result in an equitable allocation of costs. Currently, direct-shared costs for the Child Care and the Senior Services Programs are pooled by program area. The direct-shared cost pool and pooled facilities costs are then allocated to each funder within the respective program. We have immediately implemented a change in procedures to recalculate our Cost Allocation Plan on a quarterly basis, based on using the previous quarter's payroll labor distribution report by program to calculate the FTE for the upcoming quarter cost allocation. However, if a funder disallows a particular expense item, after the determination of their portion, it is applied to Unallowable and paid with unrestricted funds of program or agency.

1. Excess indirect cost billing Three contracts identified with excess indirect cost billing will be corrected on the next invoice and prior to contract ending date. Assistance Listing (AL) No. 93.268 or 2103 CBO Contract and No. 93.391 or 2103 Health Equity Contract are ending by November 2023 and May 2024 respectively. Hawaii Public Health Institute (HIPHI) will submit up to date billing with corrections. As recommended by the auditors, the HIPHI team will 1) create a written procedure that describes in detail the process to prepare and review program billings, and 2) implement guidelines on how to record indirect costs. For all federally awarded programs, the Director of Finance and Operations and the program's lead manager, with direct knowledge of the requirements for the grants, will review the billing prior to submission to the funder. The Finance and Accounting Manager and/or other trained Finance and Operations staff will prepare the billings, provide financial reports as requested, and include any supporting documentation used, for the reviewers.

Name of Responsible Individual(s): Jason Penegar, BGCA Vice President ? Controller Shelby Mahoney, Accounting Manager - State Alliances Corrective Action: Management will review grant agreements to confirm whether funding received from private entities are federal funds that should be reported on the SEFA. Anticipated Completion Date: December 31, 2023

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) The SEFA as prepared by management did not originally include one federal grant with federal expenditures to be reported with the 2022 SEFA. Corrective Action Plan: The grant included in the finding was received from a local government entity which did not communicate any reporting requirements associated with the grant. The College will be more vigilant in future years in assessing any grants received for inclusion on the SEFA. Anticipated Completion Date: March 1, 2023.

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2022-004 Child and Adult Care Food Program ? Assistance Listing No. 10.558 Action taken in response to the finding: The Office for Food and Nutrition Programs (FNP) has moved from a paper based permanent agreement to a web form that exists on the DESE Security Portal. All existing and new Child Nutrition Sponsors will continue to sign off on the document via the web-based portal allowing for a more efficient collection and document retention process. The identified sponsors with missing permanent agreements for the time period selected now have signed permanent agreements via the web-based form. FNP will add the applicable FAIN numbers to the Financial Management portion of FNP?s public website. FNP will review and update these numbers annually as applicable. FNP, in conjunction with DESE?s Federal Accounting Unit, have embarked on a process to provide all Child Nutrition sponsors instructions and collect information related to UEIs. FNP will continue the process and outreach until all UEIs have been collected. Name of the contact person responsible for corrective action: Robert Leshin, Director of Nutrition, Jeffrey Benbenek, Director of Audit & Compliance Planned completion date for corrective action plan: July 1, 2023

2022-002 ? CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS ? NONCOMPLIANCE WITH SUBRECIPIENT GRANT AGREEMENT REQUIREMENTS ? ALN 21.027 ? OTHER NONCOMPLIANCE Condition: Burleigh County did not communicate and document all of the elements as outlined in 2 CFR 200.332(a) for the subrecipients of the Coronavirus State and Local Fiscal Recovery Funds program. During testing, we noted the following elements were not included: ? subrecipient's unique entity identifier ? federal award identification number ? federal award date (see definition of Federal award date ? 200.1) of award to the recipient by the Federal agency ? subaward period of performance start and end date ? name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity ? Assistance Listings number and Title ? identification of whether the award is Research and Development ? indirect cost rate for the Federal award (including if the de minimis rate is charged) per ?200.414 ? a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part, and appropriate terms and conditions concerning closeout of the subaward Corrective Action Plan: We agree with the recommendation. Burleigh County has implemented new policies and procedures in 2023 regarding subrecipient monitoring. Anticipated Completion Date: FY 2023

Finding 2022-005 Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 View of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County Commissioners are responsible for the American Rescue Plan project list along with that responsibility is to have a sub-recipient agreement in place with those outside entities that received American Rescue Plan grant monies from the County. An Internal Control is now in place that requires a sub-recipient agreement in place before a warrant can be paid to those outside entities. We will put procedures in place to ensure that money disbursed to sub-recipient is monitored. Anticipated Completion Date: October 1, 2023

Finding 2022-006 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes Auditee?s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is ?live? as of August 2022, the City is currently working to refine the software and fully utilize functionality. The Workday grants modules requires the grant funding source be defined prior to grant approval and fields are available for the AL titles and numbers and sub-recipients? information. The implementation of the Workday grants modules centralizes much of the grant management function by requiring the agencies to upload the grant documents into Workday. The City has: ? Held weekly meetings for two years with agency grant representatives to design and configure the Workday grant module. ? Uploaded the grant award, sponsor information and grant budget data into a Workday. ? Implemented a ?new grant? request which uses a Workday business process. ? In the process of reviewing and correcting recoverable costs per grant award so it is properly reported. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City. Completion Date: June 2024

Name of Responsible Individual(s): Jason Penegar, BGCA Vice President ? Controller Shelby Mahoney, Accounting Manager - State Alliances Corrective Action: The fiscal team will enhance its procedures and internal controls with respect to preparation and review of the SEFA. Grant agreements will be reviewed to confirm if expenditures from pass-through entities are related to federal or state grants, and appropriately include applicable federal grants and pass-through funds in the SEFA. Anticipated Completion Date: December 31, 2023

During 2023, the newly elected County Auditor took on an active role in tracking the Coronavirus State and Local Fiscal Recovery Funds by preparing and maintaining spreadsheets so that the Commissioners have the most current information for making decisions. The County Auditor attends or watches/listens to the Commissioners’ meetings to make sure that she is updating the spreadsheets with all action taken by the Commissioners. Before submitting the Schedule of Expenditures of Federal Awards for the 2023 audit, we will consult with the Commissioners’ Office and the County Auditor to make sure that we are reporting the transactions correctly based on the spreadsheets prepared and maintained for such purposes.

Views of Responsible Officials: Mary's Center now has a robust process where the agreed upon provisional indirect rate or (if applicable) the specific rate included in the final Grant agreement is the governing default rate used for each Grant. In any scenarios where a change in rate is being requested, the Program Manager alerts the Senior Grant Accountant assigned to the grant and provides supporting documentation from the Grant funder of an addendum to the existing Grant agreement. If for any reason the Finance team is using an upward or downward adjustment to the provisional indirect rate or what was agreed upon in the Grant agreement the EVP Finance and Director of Grants must approve this change and notify the EVPs of Health and Programs and Development prior to implementing this change. All changes are documented. In addition, to ensure the rate in the agreement is the same rate being used when invoicing Grant funders, the Finance team conducts a thorough reconciliation process during the year.

Individuals Responsible for Corrective Action Plan: Jason Penegar, BGCA Vice President – Controller Shelby Mahoney, Accounting Manager - State Alliances Corrective Action: The fiscal team will enhance its procedures and internal controls with respect to preparation and review of the SEFA. Grant agreements will be reviewed to confirm if expenditures from pass-through entities are related to federal or state grants, and appropriately include applicable federal grants and pass-through funds in the SEFA. Anticipated Completion Date: December 31, 2023

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to be Taken: nCASE has written policies and procedures that detail how management is to review and approve documentation relating to payroll and how reports are created that confirm charges are accurate, allowable, and properly allocated as well as allow for clear comparisons to estimates. Management created timekeeping documents to track employee labor, time and effort. nCASE’s accounting system matches charges listed to documentation used to collect and record time and effort by employees and apply designations to its respective project/label. The system can track direct, indirect, and fringe benefit designations. Accounting data now allows management to create clear reports on payroll. nCASE has implemented documentation that allows employees to track time and labor in detail of project. Management has written policies and procedures that direct employees on how to record time and labor. DoD has reviewed the matters covered in the audit report thoroughly, and the grant was closed out without any repayment of funds to DoD. Upon subsequent review and reconciliation, amounts were not overcharged.

Management feels that the SEFA wasprepared in accordance with guidance that was available at the time. We will continue to evaluate all federal programs’ expenditures and include on the SEFA as necessary. All federal expenditures will continue to be reconciled to College ledgers.

California Business, Consumer Services and Housing Agency (BCSH) The California Interagency Council on Homelessness (Cal ICH), an entity under the BCSH, would like to acknowledge a finding from the fiscal year 2020-21 Statewide Federal Compliance Audit of the State of California. This audit finding identifies lack of communication of required subaward information to Cal ICH subrecipients of the Coronavirus Relief Fund (CRF) program at the time of the subaward, or when the State became aware of changes in subaward information, including identification that the subaward funds represented federal funding. Cal ICH agrees with this finding and the recommendation to review all subawards provided which were funded using CRF program funds and determine whether the subrecipients properly reported their CRF awards and related expenditures in their respective schedule of expenditures of federal awards pursuant to Title 2 Code of the Federal Regulations 200.502. Additionally, while formal communication identifying that the subaward fund represented federal funding was not provided, many informal conversations were had with CRF grantees. These conversations were held during bi-weekly online Office Hours and through one-on-one calls with individual subrecipients and discussions of the substitution of federal awards with grantees originally provided with State funds could have occurred. Cal ICH will conduct review of the CRF subawards during mandatory desk reviews to verify that subrecipients properly reported their CRF awards and that expenditures of the federal awards were made pursuant to Title 2 Code of Federal Regulations 200.502. Additionally, Cal ICH has developed an improved communication system between leadership and program staff that will ensure changes are clearly communicated. This will also ensure the Council’s subrecipients are notified in a timely manner upon any changes in subaward information, such as identifying if subaward funds represent federal funding so that expenditures are spent in accordance with Federal statutes, regulations, and the terms and conditions of federal awards. Additionally, if in the future funding is changed, CDE will provide updated information to all recipients; this will ensure that expenditures are in line with the terms and conditions of the grant and/or funding source. Estimated Implementation Date: May 2023 Contact: Ellen Meuchel, Monitoring Unit Cal ICH Grant Operations and Suppor California Department of Education Concur. Education will review the relevant subawards funded under the CRF program and determine whether the subrecipients properly reported their CRF awards pursuant to 2 CFR 200.501. Estimated Implementation Date: July 31, 2023 Contact: Kelly Levario, External Audits Coordinator Audits and Investigations Division California Department of Social Services The California Department of Social Services (CDSS) acknowledges the Single Audit finding regarding the delayed communication of subaward information to the Department’s subrecipients of the Coronavirus Relief Fund (CRF) program. On December 21, 2022, CDSS released County Fiscal Letter 22/23-31 on the subject of “Federal Coronavirus Relief Funds That Replaced General Fund for COVID-19 Related Activities for Fiscal Years 2019-20 and 2020-21” to County Welfare Departments (CWDs) and federally recognized Tribal governments in California. This letter served as a formal documentation of the portion of expenditures that were funded with federal CRF. Additionally, although formal notice was not provided until December 21, 2022, informal notices and conversations took place between CDSS and the County Welfare Directors Association, as well as with CWDs, regarding possible situations in which the substitution of federal awards with grants originally provided with State funds could occur. On September 21, 2021, CDSS sent a notice to subrecipients requesting for their Data Universal Number System for the purpose of CRF federal subawards; thereby, communicating the use of CRF on the subrecipients’ behalf. CDSS will conduct a review of the CRF subawards during on-site fiscal monitoring reviews to verify that subrecipients properly reported their CRF awards and that expenditures of the federal awards were made pursuant to Title 2 Code of Federal Regulations 200.502. Moreover, CDSS will ensure that the Department’s subrecipients are notified in a timely manner upon any changes in subaward information, such as identifying if subaward funds represent federal funding so that expenditures are spent in accordance with Federal statutes, regulations, and the terms and conditions of federal awards. Estimated Implementation Date: April 2023 through June 2024 Contact: Elisa Tsujihara, Chief Fiscal Policy and Analysis Bureau

National Park Service Conservation, Protection, outreach, and Education – Assistance Listing No. 15.954 and Research and Development Cluster – Assistance Listing No. 15.608 and 15.945 Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Upon conducting the FY21 audit TAS was informed that the inclusion of the Biological Expertise line item on federal budgets (approx. 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY21 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 minimus 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. Moving forward TAS will be billing the de minimus rate (10%) as a percentage and will calculate the Biological Expertise line item as an hourly rate. Name(s) of the contact person(s) responsible for corrective action: Kim Lopez, Director of Finance & Operations Planned completion date for corrective action plan: effective immediately / in progress

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

Management and accounting personnel will create procedures to ensure that direct cost is charged at the actual amounts incurred and will develop a payroll cost allocation and allocable direct cost allocation methodology that ensures costs are charged in compliance with the applicable federal costs principles.