Corrective Action Plans

Contact: Reginald Gregory Title: Executive Director/Controller Phone Number: 202-772-4300 Estimated completion date: June 30, 2024 Corrective Action: Management will continue to stress the importance of following the detailed procedures for preparation and review of the SEFA. Responsibility for compiling the SEFA was assigned to a Senior Program Accounting Manager who is tasked with assuring the SEFA and all support reconciliation are complete and accurate. Both the Director of Program Accounting and the Executive Director of Finance/Controller will review the SEFA for completeness, accuracy, and compliance with CFR Section §200.510(b).

Views of Responsible Officials and Planned Corrective Action: The School agrees with this finding. Lisa Hendricks, the Director of Finance, and the 3rd party accountant will work closely to develop a grant tracking system that determines the source of the grant funds prior to expending any of the funds.

Recommendation: We recommend that Minnesota Land Trust review its internal controls to ensure the SEFA captures all federal awards expended at the correct amounts in accordance with 2 CFR 200.510(b) Schedule of expenditures of Federal awards and CFR 200.502, Basis for determining Federal awards expended. Actions to be Taken: The Minnesota Land Trust will add additional internal controls to ensure a complete listing of federal expenditures is easy to provide and that the listing is reviewed by the Finance Department prior to audit fieldwork. Timeline for Completion: A complete listing of federal expenditures to be available from our accounting software (i.e., automatically) by October 31, 2023. Contact person responsible for corrective action: Claire Colliander

Recommendation: We recommend that the Authority implements a control to ensure that the preliminary SEFA is mostly accurate so that the correct programs are tested. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to facilitate timely and accurate preparation of the SEFA for the Harris County Housing Authority (HCHA) March 31 fiscal year end, a reconciliation of pass-thru revenues in the general ledger will be performed. In addition, HCHA will make sure to include grant-specific coding in the charts of accounts in order to identify specific and eligible items. The HCHA will also review grants included in the previous year’s SEFA to determine if they should be included in the current year SEFA. In situations where expenditures reported in the SEFA are not the same as the expenditures reported in the general ledger (due to outstanding loan balances, timing of grant awards, expenditures incurred in a prior period, etc.), a reconciliation will be provided to the as notes to the SEFA. Name(s) of the contact person(s) responsible for corrective action: Melissa Quijano, Executive Director Planned completion date for corrective action plan: March 31, 2024

Description of Finding: The school did not adequately track its expenditures of federal awards and did not prepare a complete SEFA as of the year end. Statement of Concurrence or Nonconcurrence: The school agrees with the audit finding as presented. Corrective Action: While the school’s chart of accounts includes specific accounts for grants and Title I funds, the chart of accounts did not explicitly list all federal revenue (Title I, ESSER Grant, USDA, and Federal Facility Grant). The school has already updated the chart of accounts to account for all federal funds with appropriate identification of revenue sources. This will allow the school to accurately account for monthly revenue and expenditures relating to federal funding sources, along with accurate monthly financial reporting of federal fund usage and expenses. Name of Contact Person: Chaz Patterson-Ellis, Chief Financial Officer, 678-466-7300, chaz.patterson@chatthillscharter.org. Projected Completion Date: Sept 30, 2023. Chaz Patterson-Ellis, Chief Financial Officer.

Management agrees with the finding and is in the process of revising internal controls to address SEFA preparation.

Judge Lucas Response: This was an oversight on our part. Steps have been taken to fully comply with all SEFA reporting in the future.

2022‐002—PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (SEFA) Response: Management concurs with the finding. Corrective Action Plan: Management will implement a documented SEFA preparation process that derives the SEFA directly from the general ledger and supporting grant schedules. A line-by-line reconciliation will be performed by the financial advisor and independently reviewed prior to finalization by the Executive Director. Documentation supporting the reconciliation and final SEFA will be retained to demonstrate accuracy and completeness. Designation of Employee Position Responsible for Meeting Deadline: Financial Analyst — by December 31, 2023.

The Board of County Commissioners, with the cooperation of all elected officials and officers responsible for the receipt or expenditure of federal funds, will evaluate the processes and procedures currently in place to ensure the accuracy of SEFA reporting and detect potential inaccuracies and/or misstatements.

Management concurs with the finding and will implement a proper expenditure reporting process, reconciled monthly, to avoid recurrence during future audits.

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.

Criteria: The Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee's financial statement. It is the responsibility of the auditee's management to design and implement internal controls that provide reasonable assurance over the completeness and accuracy of the SEFA. The SEFA is the basis for the auditor's identification of major programs. Condition: The City's initial SEFA provided for the audit was incomplete and contained inaccurate program expenditure amounts. In particular, there were multiple federal programs that were not identified, or had inaccurate amounts reported, on the initial SEFA for the year under audit: ALN 16.554 National Criminal History Improvement Program (NCHIP) ALN 20.600 State and Community Highway Safety ALN 66.458 Capitalization Grants for Clean Water State Revolving Funds ALN 93.568 Low-Income Home Energy Assistance ALN 97.044 Assistance to Firefighters Grant ALN 97.067 Homeland Security Grant Program Cause: The City does not have a method to accurately track the related expenditures for reporting. Effect or Potential Effect: A Uniform Guidance compliance audit is based on the premise that management must comply with federal statutes, regulations and the terms and conditions of the federal awards it received. Without identifying the funds as federal, the auditee may not have complied with those requirements. In addition, there is increased risk regarding the accurate reporting of grant expenditures and noncompliance with policies and procedures surrounding the recording of federal awards. Questioned Costs: None Context: The City was aware of the requirement to prepare a SEFA prior to the audit; however, they were not able to accumulate the appropriate records to correctly identify the source of funding for all ongoing projects. In addition, management was unable to accurately determine the amounts to be reported on the SEFA in accordance with 2 CFR §200.502. The adjustments to the SEFA amounted to an increase in Total Federal Expenditures reported of $892,160. Repeat Finding: This is a repeat finding; it was previously finding 2021-006 and 2021-007. Recommendation: We recommend the City develop and implement procedures to ensure that information related to all federal awards is accumulated to assist in the preparation of the SEFA. In addition, we recommend management of the City verify the completeness and accuracy of the amounts reported on the SEFA. Response: The City agrees with the finding, and will develop a method for accurately tracking federal expenditures. Anticipated Completed Date: June 30, 2025 Responsible Contact Person: Elizabeth Greenwood, Director of Administration & Finance City of Cortland, 25 Court Street, Cortland, NY 13045 (607) 758-8373

Management’s Planned Corrective Action: Disagree: We have established a cost center or “Department” for each federal program that clearly identifies federal expenditures. Our funders request monthly copies of receipts and payment issued to verify expenses. Responsible Party: Beaulieu Accountancy Corporation, Accountant Completion Date: 9/25/2024

Finding no.: 2022-003 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: The SEFA was assigned to be prepared internally, but unfortunately was not submitted due to staff turnover during the course of the audit. This oversight will be corrected by improving procedures around internal task assign-ments when employee turnover is experienced in the Fiscal department during the course of the audit. Anticipated completion date: December 2023

Consortium’s Fiscal Agent will ensure that supporting documentation will be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. In addition, Fiscal Agent will complete corrective action for 2022-005 & 2022-006

Condition: The schedule of expenditures of federal awards (SEFA) was not accurate. Planned Corrective Action: The City will review its process for identifying and communicating Federal Grant expenditures to its auditors. Contact person responsible for corrective action: Robert McMahon, City Administrator Anticipated Completion Date: 09/30/2025

Finding Number: 2022-003 Condition: Controls in place were not adequate to ensure the schedule of federal expenditures was complete and accurate. Planned Corrective Action: The federal funding was not received until fiscal year 2023 while some expenditures were incurred in fiscal year 2022. The timing of events contributed to the oversight on the 2022 SEFA. WakeMed has reeducated staff on the preparation of the SEFA in order to prevent this error from reoccurring.Contact person responsible for corrective action: Lynn Bailey Anticipated Completion Date: 12/5/2024

Action Taken: Management is in the process of instituting additional procedures to ensure all awards are assessed not only to identify whether sources of funds are Federal, requiring inclusion on the SEFA, but also to identify continuing compliance period when applicable. Management has also conducted internal training relative to applicable 2 CFR 200 regulations and requirements and will continue to provide periodic staff training to ensure continued compliance. Anticipated Completion Date: Management estimates that additional processes will be in place by December 31, 2024.

The Township Fiscal Officer will prepare the SEFA or contract with a CPA firm to have the SEFA prepared going forward.

Management accepts this finding. A detailed set of procedures was documented immediately after the discovery of this error in preparing the Schedule. Included in these procedures, a query is run of research projects. This query is sent to Sponsored Research Services (SRS) to review to verify the reporting status and AL numbers, and other items are correct and complete. Once SRS has verified the data in the query is complete and accurate, then the Controller’s office will proceed with preparing the Schedule as well as reconciling it to the Statement of Activities (SOA) In the procedures, we have added that SRS and the Controller, and/or Chief Financial Officer review the Schedule prior to initiation of the audit review process.

Internal communication processes for direct pay projects were used in conjunction with ODOT reports to capture these offsetting revenues and expenditures as well as the additions to capital assets in 2023.

Federal Award Finding and Questioned Costs Finding Reference: 2022-004 – Other finding – SEFA Preparation Federal Program Information Federal Agencies: United States Department of Homeland Security Awards: Assistance Listing Number 97.036 – COVID-19 – Disaster Grants - Public Assistance (Presidentially Declared Disasters) Award Periods: January 20, 2020 – May 11, 2023 Description: Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control Over Compliance Recommendation The System should update its policies and procedures and internal controls, specifically the process to accumulate and report FEMA expenditures of federal awards to be in accordance with the FEMA Schedule requirements outlined above. View of responsible officials The System agrees with the comment and has developed a plan to correct the finding. Corrective Action Planned The System has trained all applicable staff on the appropriate interpretation of FEMA Public Assistance Grant Program guidance for reporting Assistance Listing 97.036 expenditures in the SEFA. Name(s) of the Contact Person(s) Responsible for Corrective Action: Christopher T. Smith, Vice President of Finance and Corporate Controller, 571-472-8122. Planned completion Date for Corrective Action Planned: Ongoing with completion date of December 31, 2024

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

The District has hired a consultant, a CPA firm with experience in Uniform Guidance reporting, to ensure the District is in compliance with Uniform Guidance compliance requirements.

AUDIT FINDINGS 2022-001: There were not adequate controls related to the reporting of expenditures on the schedule of expenditures of federal awards (Schedule) for the COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) program (FEMA). Specifically, review controls over the accuracy and completeness of the Schedule were not designed to operate at an appropriate level of precision for the discretely presented component unit. As a result, $1,795,854 of FEMA expenditures was inadvertently omitted from the December 31, 2022 Schedule. Name of Contact Person: Daria Heimerman, Director of Financial Reporting, dtheimerman@evergreenhealthcare.org Corrective Action Planned: Implement a control of management review at an appropriate level of precision for the discretely presented component unit in order to ensure the accuracy and completeness of the Schedule. Anticipated Completion Date: September 2023 Statement of Concurrence or Nonconcurrence: Management concurs with audit finding 2022-001.