Corrective Action Plans

Office of the State ControllerFinding Number 2022-203: Errors in the elimination process between state agencies resulted in misstatements to the Schedule of Expenditures of Federal Awards (SEFA) totaling $14,656,928 for direct awards and $14,278,362 for expenditures provided to subrecipients.Federal Programs:21.027 - State and Local Fiscal Recovery Fund84.334S - Gaining Early Awareness and Readiness for Undergraduate ProgramsRelated to Prior Finding: N/AAgency?s view: The Office agrees with this finding.Corrective Action: We will improve our elimination and reporting process by adding the following steps:? We will add an additional tab to our SEFA Master file to cross check all COVID-19 related funding to ensure agencies are not double reporting expenditures.? We will add additional steps to our SEFA preparation and review checklist outlining specific steps for completing the subrecipient elimination process, and identify higher risk areas that require the most scrutiny.? We will also improve our current elimination tab (awards received from other state agencies) and reconciliation procedures for subrecipients.Anticipated Corrective Action Date: Errors identified were corrected prior to issuance of the Single Audit report. Changes to the subrecipient reporting process will occur for FY23 reporting.Responsible for Corrective Action: Ethan Draves, Reporting and Review Bureau ChiefEdraves@sco.idaho.gov 208-334-3100

Finding Number 2022-207: The amount reported as passed through to subrecipients on the Schedule of Expenditures of Federal Awards (SEFA) closing package was overstated by $331,500.Federal Programs:15.605 - Sport Fish Restoration15.611 - Wildlife Restoration and Basic Hunter EducationRelated to Prior Finding: N/AAgency?s view: The Department agrees with this finding.Corrective Action: The Department will provide additional training and update its procedural documentation to ensure that expenses are thoroughly vetted before they are reported as subrecipient expenditures on the SEFA. Each expenditure identified as a subrecipient expense will be tied back to a specific subaward, further limiting the possibility of non-subaward expenses being reported in the subrecipient portion of the SEFA.Anticipated Corrective Action Date: This corrective action plan will be implemented by the end of August 2023.Responsible for Corrective Action: Michael Pearson, Chief, Bureau of Administrationmichael.pearson@idfg.idaho.gov(208) 287-2800Jon Oswald, Financial Managerjonathan.oswald@idfg.idaho.gov(208) 287-2820

ULMS Corrective Action Plan for FY 21-22 Audit FindingsULMS faced significant challenges with the departure of its longtime CFO two months post fiscal year 2021. In addition, the third-party management company who had been responsible for the Partnership accounting, ceased the relationship abruptly without opportunity to smoothly transition the responsibility in-house to ULMS. Our external auditor does not prepare a Management Letter typically used to communicate with the Board of Directors and Governance issues that may not elevate to a finding. As such, significant findings are reflected in Section III ? Federal Award Findings and Questioned Costs.FY 2021 was the organization?s first single audit reporting requirement. ULMS engaged a third-party CPA to review past audit and current documents needed to commence the FY 2022 audit. However, due to an emergency there was limited independent review of documents prior to being submitted to the auditor due to time constraints. ULMS continues to strengthen its accounting team and has hired a new Controller in July 2023. The new Controller is a licensed CPA with over 30 years accounting experience and over 10 years? experience as an independent auditor for a range of organizations including non-profits. The Controller will collaborate with the CFO to ensure there is accuracy in reporting, especially for major federal programs. Finding #: 2022-002Contact Person: Mansour Camara? Management has determined that the finding as written is misleading. The Schedule of Expenditures of Federal Awards (SEFA) prepared by ULMS initially contained errors. However, all errors were corrected by the time the draft financial statements were presented. There was no financial impact on the organization and the most significant issue on the SEFA schedule was a result of miscommunication with ULMS? funding source including the lack of clear identification of the funding source within the contract.Actions to be taken: ULMS migrated to a new and more sophisticated accounting system. This new system has more reporting and tracking capabilities which will enhance grant tracking and review of activities. These additional tools will aid management in overseeing future endeavors. In addition, ULMS will proactively contact the CFO or contract signer of the funding entity and confirm the source of funding for all grants over $100,000. ULMS will participate in more nonprofit conferences on a regional and national level.

Public Health’s Accounting Office will generate the FI$Cal Year End Close report (KK_12 expenditure) and collaborate with the ELC program to ensure that all expenditures captured are complete and accurate, ensuring timely reporting of the SEFA data for FY 2023-24 and beyond. Please note that the ELC program has been reported in the FY 2022-23 SEFA. Additionally, we will update the procedures to document the SEFA reporting for the ELC program. Estimated Implementation Date: September 2024 Contact: Jennifer Chan, Accounting Administrator II Federal Reporting Unit, Financial Management Division California Department of Public Health

EDD agrees with this finding. The deferred transition to FI$Cal and the difficulties experienced thereafter have continued to cause EDD to be late with submitting year-end financials and its ability to submit timely the cash basis expenditures into the Single Audit Expenditures Reporting Database (Database). In addition, the onset of the COVID-19 pandemic created additional issues which ultimately impacted the EDD’s ability to submit timely year-end financials. However, the EDD continues to make progress to gain ground in the department’s efforts to follow the State’s deadlines for submitting year-end financials and entering the cash basis expenditures into the Database. During fiscal year 2022-23, the EDD completed a restructuring within the accounting area which realigned workload amongst the units and provided additional resources in critical areas. These changes will have a lasting effect and help the department to be better positioned going forward in processing the accounting workload and ultimately be able to catch up and submit year-end financials and enter the cash basis expenditures into the Database by the State’s deadlines. In addition, the EDD took lessons learned from the financial audits from the prior two fiscal years to update processes and procedures and applied that knowledge going forward. Also, staff continue to participate in various trainings offered by the Department of Finance and the Department of FI$Cal. In addition, staff work with the control agencies when issues arise that would impact our accounting functions. While the EDD has been behind in submitting year-end financials for prior years, the department is making great progress on catching up. The EDD submitted the last of its fiscal year 2021-22 financials in May 2023 and submitted the last of its fiscal year 2022-23 financials in January 2024. The department is now working on identifying the ineligible payment data needed in order to accurately reflect the cash basis expenditures to enter into the Database. The EDD’s goal is to submit fiscal year 2023-24 financials in November 2024. Similar to the 2020-21 financial audit, the EDD will take the knowledge learned during prior audit seasons and continue to engage with the control agencies, and continue to train and develop staff in order to keep progressing towards the department’s goal of becoming timely with the submission of the year-end financials and the entering of the cash basis expenditures into the Database.

During 2022, there was a change in accounting staff which led to difficulty in tracking and preparing the SEFA. Once management became aware of the issues, changes have been made to internal processes to allow for proper SEFA tracking moving forward.

In the future, to ensure that all grant activity is included on the SEFA in the proper year per the UG, Miami University will: Create a new year end folder called “Future Fiscal Year Agreements FYXX” and save any new documents that have a future fiscal year start date in the file. At the beginning of the new fiscal year review the documents that are in the file and if fully executed agreements have been received, create the new grant with the appropriate start date in the current fiscal year. Not set up the grant or fund prior to the grant agreement start date unless pre-award spending is allowed. A “review upcoming fiscal year agreements” reminder will be added to the calendar to ensure that the grant is set up in the correct fiscal year and that expenses are charged in the appropriate fiscal year.When the SEFA is prepared each year, check to make sure any new agreements that were in the fiscal year folder are captured on the report if there were expenses for that year. Contact person responsible for corrective action: Linda Manley, Director Grants and Contracts.

Finding 2022-002: Emergency Watershed Protection Program - Reporting Program: AL 10.923 - Emergency Watershed Protection Program - Reporting Corrective Action Planned: The County will ensure County personnel obtain training to ensure there is a proper understanding of the Federal reporting requirements and preparation of the Schedule of Federal Awards. Anticipated Completion Date: Ongoing Responsible Party: Dixon County Board of Supervisors: Don Andersen, Deric Anderson, Roger Peterson, Neil Blohm, Lisa Lunz, Terry Nicholson, and Steve Hassler

2022-001 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S. Department of Education Program Names: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555 and 10.559 Award Period: June 30, 2022 Recommendation: The Board of Education and management should review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Action Taken (Unaudited): Management plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the preparation of the schedule as required by Uniform Guidance during years in which the District incurs federal expenditures above the threshold required by Uniform Guidance. Contact Name – Tim Beying Expected Completion Date - 06/30/2024

2022-002 – Completeness and accuracy of the Schedule of Expenditures of Federal Awards- Significant Deficiency Cluster: Not applicable Federal Granting Agency: Department of Homeland Security and Emergency Services Award Name: COVID-19 – Disaster Grants- Public Assistance (Presidentially Declared Disasters) Pass-Through from New York State Department of Homeland Security and Emergency Services Assistance Listing #: 97.036 Assistance Listing Title: COVID-19 - Disaster Grants- Public Assistance (Presidentially Declared Disasters) Pass-Through from New York State Department of Homeland Security and Emergency Services Award Year: January 1, 2022- December 31, 2022 Management of Maimonides Medical Center did not correctly interpret the rules in regards to the review and approval process by FEMA and New York State Department of Homeland Security and Emergency Services for the requirement to record FEMA funds. Management has consulted with their auditors on the proper timing to recognize and record the revenue. The Medical Center has reviewed the FEMA portal to ensure all FEMA project funds obligated and expended are reported in the proper period. Responsible Individual: Robert Palermo, Executive Vice President Chief Financial Officer

The District will review the Uniform Guidance requirements and ensure all expenditures are accurately reported on the Districts federal schedule.

Action Taken: During 2023, Range Mental Health Center, Inc. and Subsidiaries had experienced turnover in key financial functions. In response to this we have outsourced its CFO function and hired internal staff with a greater level of expertise to facilitate improved reporting. As a result, we anticipate an improvement in timeliness of our financial records.

Finding 2022-002 Federal Program Information: Federal Grantor: United States Department of the Treasury Pass-Through Entity: Smith County, Texas and the City of San Marcos, Texas Assistance Listing No.: 21.027, Coronavirus State and Local Fiscal Recovery Funds Pass-Through Award Numbers: Trinity Mother Frances, Pass-through Smith County: Not available Santa Rosa, Pass-through the City of San Marcos: Not available Award Periods of Performance: Trinity Mother Frances, Pass-through Smith County, October 1, 2021 – November 30, 2021 Santa Rosa, Pass-through the City of San Marcos, March 03, 2021 through December 31, 2026 Corrective Action Planned: Management agrees that the Department of Treasury awards passed through Smith County and the City of San Marcos were not included in the Schedule of Expenditures of Federal Awards. However, grant management identified the oversight and took corrective action to inform external auditors immediately upon the discovery. We have reviewed our processes that led to the initial oversight. We have instituted a new process to obtain confirmation from each CFO that their Ministry’s reported amounts on the Schedule of Expenditures of Federal and State awards is complete and accurate. Responsible party: Lee Sonne, Vice President of Finance and Controller, jointly with the Melissa Crenwelge-Nedbalek, Accounting Director responsible for Grant Reporting Implementation Date: January 2024 prior to the final reissuance of the FY 22 Uniform Guidance Reporting Package.

The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial, but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. To ensure all employees are paid according to pay dates established in our various labor agreements and recorded correctly in the general ledger, we will continue the payroll transaction validation process that assures the payroll expenses recorded are allowable and accurately stated in the SEFA and balance to the general ledger. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.

2022-006: Material Weakness and Noncompliance – Preparation of Schedule of Expenditures of Federal Awards (SEFA) Statement of Condition/Criteria: The Code of Federal Regulations requires a nonfederal entity to prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section 200.502(a) and must reconcile amounts reported in the SEFA to the amounts reported in the auditee’s financial statements. Planned Corrective Action: County management will develop a closing process to ensure all federal expenditures are identified, recorded, and reconciled on the SEFA. Contact person responsible for corrective action: Ashleigh Young, County Controller/Administrator Anticipated Completion Date: March 2024

Finding Number: 2022-002 Condition: The Corporation did not prepare a complete and accurate SEFA for the year ended June 30, 2021. Planned Corrective Action: While technically considered a significant deficiency and audit finding in accordance with CFR guidance for federal award audit compliance purposes, management considers this finding to be an isolated incident. Management had prepared and provided a SEFA summary that properly identified all federal funding, including all of the CARES Act funding, received as of June 30, 2021. Management also prepared and provided information regarding amounts of the CARES Act funding expended and recognized as revenue within the financial statements for the years ended June 30, 2020 and 2021. However, there was interpretation that the amount that was supposed to be reported for the CARES Act funding on the SEFA for the period ended June 30, 2021, should be the amount expended and recognized as revenue as of the financial statements ended June 30, 2020, to align with the Period 1 portal reporting. As such, the amount reported for the final SEFA used for the June 30, 2021 compliance audit excluded $1,271,104 that was appropriately reported as deferred grant revenue liability as of June 30, 2020. The amount of CARES Act funding for the Period 1 portal reporting correctly included the $1,271,104. There was a significant amount of collective confusion regarding the Period 1 CARES Act portal reporting which was for the period ended June 30, 2020, in relation to the SEFA reporting and compliance audit reporting for that same period of time, which was unusually deferred by the federal government from June 30, 2020 to June 30, 2021. The results of the auditors procedures demonstrated that all the information management populated in the CARES Act portal for the June 30, 2020 reporting compliance Period 1 was accurate and that there were no other findings. Contact person responsible for corrective action: Bob Stillman, Chief Financial Officer Anticipated Completion Date: March 31, 2023

Corrective Action Plan Finding No. 2022-001: HRSA COVID-19 Claims Reimbursement for the Uninsured Program Corrective Action Plan Since the inception of the program, the Organization reported the HRSA COVID-19 for the Uninsured based on payment date rather than on date of service/ incurred date. Once the error was identified, management properly reported and corrected the SEFA for the year ended June 30, 2022 to reflect the total amount of claims for services provided during the year ended June 30, 2022 for the Uninsured Program. Corrective Actions Taken Management has implemented the above corrective action. The VP of Patient Financial Services is providing the HRSA COVID-19 for the Uninsured based on date of service/incurred date, therefore the SEFA is properly reported for the year ended June 30, 2022. Completion Date: June 30, 2022 Contact Persons: Deborah Gaugler, Controller Jeffrey Hinkle, VP Patient Financial Services

Finding Number: 2022-005 Condition: The SEFA was not appropriately reconciled to federal grant revenues and expenditures recorded in the financial statements. Planned Corrective Action: The City will work to improve closing processes and communications with various departments and consultants to ensure the SEFA is complete and accurate. Contact person responsible for corrective action: Finance Director and Treasurer Anticipated Completion Date: 6/30/2023

Audit Finding Reference: 2022-003 Planned Corrective Action: The Society agrees with the auditor's finding. As previously noted, the Society experienced turnover in the Chief Financial Officer position. A new Chief Financial Officer was hired on June 27, 2022. New procedures have been adopted to strengthen the monthly close cycle. The Society has also implemented additional controls to ensure proper cut-off and alignment with the Society's SEFA and SESFA. Name of Contact Person: Bruno Cellucci/bcellucci@chsofnj.org/(609) 695-627 4, Ext. 135 Anticipate Completion Date: Spring 2023

Finding 2022-003 Grantor: Department of Agriculture and Department of Health and Human Services Federal Program: Various Assistance Listing #: Various Title: Schedule of Expenditures of Federal Awards Award Year: Fiscal year 2021 1/1/2022 ? 12/31/2022 Award Number: Various Management agrees with the recommendation. Management will implement the following changes to the management of the Schedule of Expenditures. Corrective Action Plan and Anticipate Completion Date Management?s corrective action plan includes: ? Review and validate that grants are listed under the correct cluster. Responsible Person: Aaron Ufferman, Director, Sponsored Projects, Natasha Collins, Director of Research Accounting Completion Date: December 31, 2023

2022-004 - Aging Cluster - Significant Deficiency in Internal Controls over Compliance Recommendation: We recommend that Metro Meals on Wheels track when Federal funds are disbursed to subrecipients and report these expenditures on the SEFA in the period of disbursement. Planned Action Metro Meals on Wheels will track when Federal funds on a cash basis.

Finding Number: 2022-013 Federal Program, Assistance Listing Number and Name: ALN 21.023, Department of Treasury, COVID-19 Emergency Rental Assistance Program (ERAP); ALN 20.205, Department of Transportation, Highway Planning and Construction Cluster, Highway Planning and Construction (Federal-aid Highway Program); ALN 20.505, Department of Transportation, Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research; ALN 93.323, Department of Health and Human Services, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC); ALN 97.036, Department of Homeland Security, COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) ALN 93.268, Department of Health and Human Services, Total Immunizations Cooperative Agreements, ALN 93.145, Department of Health and Human Services, HIV Related Training and Technical Assistance; ALN 93.686, Department of Health and Human Services, Ending the HIV Pandemic: A Plan for America ? Ryan White HIV/AIDS Program Parts A and B Condition: Original Finding Description: The schedule of expenditures of federal awards (SEFA) was not complete, accurate or prepared timely Contact Person Responsible for Corrective Action: Regina Greear and Keisha Pierce Anticipated completion date: July 2023 Planned Corrective Action: As part of the City Audit finding Corrective Action Plan (AFCAP), in fiscal year 2022 the City developed a checklist to help ensure all Federal expenditures are properly reported. The City will implement additional preparation and review procedures that will include specific timelines and guidelines to ensure completeness, validity and accuracy of the final SEFA reporting. In addition, the City will implement the AFCAP plan to further document the procedure requirements and train the appropriate staff.

2022-002 Internal Controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number: 21.027 Recommendation: The Organization should develop written policies for the internal control over compliance of federal awards. Action Taken (Unaudited): Management plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the preparation of the schedule as required by Uniform Guidance. This policy includes adding another control by a third-party accountant to review federal award financial management. Contact Name ? Rebecca Buford Expected Completion Date ?12.31.23

Views of Responsible Officials The Department of Administrative Services (DAS) concurs. Financial management of individual federal awards is decentralized throughout state agencies which centralizes annually in the culmination of the State?s SEFA. During this process, each agency is required to complete a standardized SEFA analysis and reconciliation tool for review by the DAS prior to the incorporation of the data into the State?s SEFA. This process also includes an annual Single Audit training and update session organized by the DAS. Additionally, the DAS notes all contracts, including subawards, entered by state agencies over a designated threshold are required to be authorized by the State?s Legislative Fiscal Committee and the Governor and Executive Council. The DAS will examine each of these processes to identify additional control activities to improve the accuracy and completeness of the pass through element of the SEFA. Anticipated Completion Date: April 30, 2024 Contact: Steven Giovinelli, Federal Grants and Cost Allocation Administrator, Department of Administrative Services

U.S. Department of Education Mississippi Valley State University (MVSU) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS 2022-006: SEFA Reporting (MVSU) Education Stabilization Fund - Assistance Listing No. 84.425F Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Student Accounts Supervisor will make sure that all mandatory reports are provided and posted correctly. If adjustments are required to be made to the initial submission, the Student Accounts Supervisor will submit all adjustments after specifying any changes or updates, noting the date of the change, and post adjustments after the approval of the Vice President of Business and Finance in a timely manner for review and verification prior to the deadline for submission. Name of contact person responsible for corrective action: Brittney Manuel Planned completion date for corrective action plan is July 15, 2023. If the Department of Education has questions regarding this plan, please call Brittney Manuel at 662-254-3914.