Corrective Action Plans

2022-002 Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Auditor Recommendation: We recommend management attend Federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the Federal funds are reported accurately on the SEFA and that programs are reported under the correct assistance listing number. Corrective Action: The year ended August 31, 2022 was the first year in which the Center expended federal awards in excess of the limit that requires a Single Audit. Since receiving the EIDL loan, the Center maintained detailed tracking and documentation of all disbursements associated with the loan and understood such expenditures exceeded the $750,000 threshold for a Singe Audit during the fiscal year ended August 31, 2022. With the clarification of the specific rules surrounding the disclosure of EIDL loans on the SEFA, management will continue to review Federal Award guidance and requirements to ensure compliance with current and future federal awards. Name of Responsible Contacts: Larry Goodpaster, Director of Finance & Operations, and Kelly Martin, Accounting Manager Projected Implementation Date: May 1, 2023 and ongoing

Finding 2022-003 Federal Transit Cluster - SEFA Management?s or Department?s Response: Management agrees. Views of Responsible Officials and Corrective Action: SCRRA will document the process to review the SEFA from prior year. Compare the SEFA to the final Single Audit Report to ensure the ending balances tie back to the Single Audit Report, before starting the current year?s SEFA. Name of Responsible Person: Thelma Bloes Implementation Date: June 30, 2023

Corrective Action Plan For the Year Ended December 31, 2022 Finding: 2022?001 Inaccurate SEFA reporting Responsible Official: Michelle Maddox, CFO Corrective Action Plan: Management will implement additional controls to ensure the completeness and accuracy of amounts reported for expenditures of the Federal Transit Administration grants in the schedule of federal awards. These additional controls include the annual review of new implementation guides. Anticipated Completion Date: December 31, 2023

Finding Number: 2022-005 Condition: The SEFA required adjustments related to expenditures that were both improperly included and excluded, resulting in revisions to correct the SEFA. Planned Corrective Action: Proper accrual accounting will be followed with regard to reporting SEFA expenditures, with period recognition more closely monitored. Contact person responsible for corrective action: Matt Zeilstra ? Financial Controller Anticipated Completion Date: 07/27/2023

Finding Number: 2022-007 Condition: For SEFA reporting, expenditures were overstated for one program and understated for another. In addition, an ALN listed for expenditures was inaccurate. Planned Corrective Action: Grant documents will be reviewed upon receipt to determine the proper ALN and the federal portion of funding. All existing grants will also be reviewed. The ALN listed in each grant document will be used when completing the SEFA. A second staff member will verify the accuracy of the SEFA prior to submission. All ALN numbers will be reviewed upon receipt and verified with state analysts when applicable. The organization will ensure that the funding sources are verified to the most appropriate level at the state level to verify funds and funding sources. Contact person responsible for corrective action: Kelly Scott, Deputy CEO Anticipated Completion Date: 4/30/2023

Emergency Connectivity Fund Program ? Assistance Listing No. 32.009 Recommendation: We recommend that the district improve the review process over tracking and reporting reimbursements of federal expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: As the subject matter experts, the district grants accounting department will work with other district departments to ensure eligibility rules and requirements are fully met when seeking reimbursement for expenditures. Grants team members will further work to support departments who play an active role in obtaining and monitoring federal grants to seek reimbursement within a timely manner, and when possible, seeking such reimbursement by the close of the fiscal year or immediately thereafter. Specific guidance will be communicated with other department management and future updates to the district Financial Services Guide will include updated guidance for all departments to reference. The Grants Manager will be responsible for monitoring all correspondence with grant-making entities to ensure timely response to potentially disputed submissions. Name(s) of the contact person(s) responsible for corrective action: Andy Flinn, Grants Manager Planned completion date for corrective action plan: June 2023

County Judge/Executive?s Response: The fiscal court would like to point out that ARPA funds were properly distributed. During this time there was little guidance on how to manage the reporting. All reporting has been corrected.

Views of Responsible Officials: Connect Our Kids acknowledges the findings of the audit and will take immediate corrective action. Planned Corrective Action: All accounts will be reconciled in a timely manner for the following fiscal year. The federal grant revenue and expenditure cutoff will be maintained for the end of the fiscal year with any adjustments for accrual purposes no later than January 31st of the following year. Responsible Official: Cara Dobbins, CFO Anticipated Completion Date: 9/30/2023

As requested, the New Mexico Coalition to End Homelessness has completed its corrective action plan for the audit findings in the 2022 fiscal year annual audit report. We have reviewed the findings and have made a corrective action plan to address each of the findings with completion dates. 2022-002?PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Federal Agency: All presented in the Schedule of Expenditures of Federal Awards. Program Name: All presented in the Schedule of Expenditures of Federal Awards. Assistance Listing Nos. and Program Expenditures: All presented in Schedule of Expenditures of Federal Awards. Award Number and Program Award Year: All presented in Schedule of Expenditures of Federal Awards. Compliance Requirement: Other ? Schedule of Expenditures of Federal Awards preparation Type of Finding: E Questioned Costs: None Statement of Condition While conducting the audit, the following was reviewed; the Coalition?s Federal grants report for the fiscal year and identified the federal grants, Assistance Listing # (AL#) and the amounts of the federal expenditures and all of the other items required to properly present the Schedule of Expenditures of Federal Awards (SEFA). The finance staff of the Coalition confirm the correctness of the SEFA. Despite the confirmation of accuracy, additional federal expenditures and grouping of grant expenditures were identified after several reviews of the SEFA. Criteria 2 CFR 200.510 indicates that the auditee must 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 2 CFR 200.502 Basis for Determining Federal Awards Expended. Per 2 CFR 200.502 the determination of when a Federal award is expended should be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program establish and maintain effective internal controls over Federal awards that provides reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of Federal awards. Effect Without an established process governed by effective internal controls, the Coalition may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, the errors could result in improper selections of major program(s) for the single audit and a substandard single audit. Cause Historically, the Coalition has requested the auditor assist in identifying accruals related to federal grant expenditures as the organization has maintained these records on a cash basis. As the organization has taken more responsibility on maintaining its federal grant expenditures on an accrual basis, an incomplete SEFA has been provided. Recommendation It is recommended the Coalition prepare the Schedule of Expenditures of Federal Awards and submit this to the auditor for testing. The SEFA should include the name of the grant, name of grantor, the AL #, the pass-through number if applicable and a reconciliation of the federal revenues and expenditures to the Coalition?s general ledger. The Coalition staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2023 Fiscal Year and information will be given to the auditors when requested for the 2023 Audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately. When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by October 31, 2023 (Final copy of the SEFA will not be given to the auditors until requested for the 2023 Audit) Designation Of Employee Position Responsible For Meeting Deadline: Executive Director, Monet Silva will oversee this project and work closely with the auditors to make sure that the information saved and shared is correct. Thank you, Monet Silva Executive Director

This finding relates to the preparation of the SEFA for the disclosure of the loan balances under the Company?s Railroad Rehabilitation & Improvement Financing (RRIF) loan. In the initial version of the SEFA, Amtrak did not reduce the audit period loan balance by the FY21 loan repayment. An updated version of the SEFA corrected the balance presented. The presentation on the SEFA of the balance of the RRIF loan has specific federal regulation requirements. Amtrak will review and update its SEFA Preparation Guide to ensure full compliance with 2 CFR Part 200 specifically for presentation of the RRIF loan balance. Amtrak will also consider providing training to key grants management personnel on an annual basis to keep them up to date with federal regulations. The contact for this item is Lucia Butts, AVP Funding and Grants. The Company anticipates that the updated procedures and training will remediate this finding in the fiscal year ending September 30, 2023 and beyond.

Management agrees with this finding and is in the process of developing internal controls to ensure timely and appropriate actions are made on the deficiency noted.

Recommendation: Procedures should be implemented to create a materially accurate schedule of expenditures of federal award financial statement, which should include ascertaining between loan and grant expenditures, and understanding the process for reporting loan balances on the SEFA. Views of Responsible Officials and Planned Corrective Actions: In order to create a materially accurate schedule of expenditures of federal award financial statement, the Authority will establish procedures to ascertain loan and grant expenditures, as well as taking into account the Uniform Guidance requirement for presenting loan balances on the SEFA.

2022-008 Inadequate Schedule of Federal Expenditures Reporting ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CFO prepared the FY 21 SEFA in advance of the 3/31/2022 Single Audit deadline. CFO will prepare the FY 22 SEFA in advance of the 3/31/2023 Single Audit deadline. Name(s) of the contact person(s) responsible for corrective action: Ashley Chancellor, CFO Planned completion date for corrective action plan: 11/1/2022

Finding Number: 2022-004 Condition: The schedule of expenditures of federal awards (SEFA) initially presented for audit was not complete and accurate. Planned Corrective Action: A new report in Workday is being created to ensure all expenditures for federal awards are included. Contact person responsible for corrective action: Laura Randall Anticipated Completion Date: 10/31/2023

Finding 2022-006: Federal Financial Reporting Requirements (Significant Deficiency) Information on the Federal Program: U.S. Department of State ALN 19.040 Criteria or Specific Requirement: Code of Federal Regulations (CFR) Section 200.303(b) requires non-federal entities to establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. CFR Section 200.502(a) states that the determination of when a federal award is expended should be based on when the activity related to the federal award occurs. CFR Section 200.510 states that the auditee must prepare a schedule of expenditures of federal awards 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. Condition: The schedule of expenditures of federal awards for the year ended December 31, 2022, did not originally include indirect costs totaling $43,632. Cause: FCE's management prepared the schedule of expenditures of federal awards using only direct costs. However, FCE had applied the 10-percent de minimis indirect cost rate when submitting its financial reports. Effect or Potential Effect: The exclusion of indirect costs caused inaccurate amounts to be reported in the SEFA at the start of the audit. This could have caused an inaccurate major program determination. Recommendation: FCE should implement a process for preparing the SEFA that includes comparing amounts reported in the SEFA to amounts included in financial reports of expenditures that are submitted to federal agencies. Action Taken: FCE acknowledges the importance of proper Federal Financial Reporting. FCE will develop and implement formal accounting policies and procedures to ensure that Federal Financial Requirements are met. These will include the steps to follow for preparation of the SEFA, including comparing amounts reported in the SEFA to amounts included in financial reports of expenditures that are submitted to Federal agencies.

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

Corrective Action Plan: The Agency has recognized the need to improve our SEFA compilation process and has begun using a quarterly reconciliation process with all agencies and departments. We are currently reconciling data from VISION to the data submitted to the U.S. Treasury for ARPA-SLFRF Quarterly Reporting. We are using this new quarterly reconciliation process as a starting point to check Subrecipient expenditures against total expenditures, as well as reviewing Grant Accounts and reviewing Class Codes. We are checking all of our programs and looking at Beneficiaries vs. Subrecipients to ensure we are categorizing correctly at the macro level. There will be an enhanced collaboration internal to the Agency between the Department of Finance & Management and the Financial Services Division that will occur after agencies and departments submit their ACFR-9s used in the SEFA consolidation process to provide greater review and oversight. Scheduled Completion Date of Corrective Action Plan: Completed: February, 2023: Quarterly Reconciliation Process (VISION to Treasury) Expected: June, 2023: Subrecipient vs. Beneficiary classification review Expected: September, 2023: Collaboration between DFM and FSD for SEFA preparation

Audit Period: Fiscal year ended June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule of findings and questioned costs. Findings - Financial Statement Audit MATERIAL WEAKNESS None Reported SIGNIFICANT DEFICIENCY None Reported Findings - Federal Award Programs Audit MATERIAL WEAKNESS None Reported SIGNIFICANT DEFICIENCY None Reported Water and Waste Systems -ALN: 10.760 Finding: Schedule of Expenditures of Federal Awards Preparation Recommendation: Procedures should be implemented to ensure completion of an entry to the Schedule of Federal Expenditures of Federal Awards to achieve a reliable reporting of total expenditures for an audit period. Action Taken: We acknowledge our responsibility to present the Schedule of Expenditures of Federal Awards and related notes in accordance with Uniform Guidance requirements. To ensure future implementation of this requirement, the City of Cave Spring will record all expenditures on the schedule of federal expenditures.

CORRECTIVE ACTION PLAN YEAR ENDED DECEMBER 31, 2022 Finding No. 2022-002: Incomplete Schedule of Expenditures of Federal Awards- Material Weakness and Material Noncompliance Finding: During our audit, we identified a grant that is required to comply with the applicable requirements of 2 CFR Part 200 and thus should have been included in the Schedule of Expenditures of Federal Awards. Once this grant was properly included, the Organization exceeded $750,000 in qualifying federal expenditures thus meeting the requirement for a Uniform Guidance audit to be conducted. Corrective Actions Taken or Planned: Management has hired a Director of Grants Financial Management who is heading a team to ensure effective management and compliance with all awards in the agency. In addition, management has acquired an award management system and implemented new processes to identify Federal awards. These processes consist of (1) clearly identifying Federal awards on the new Grant Code Form, (2) conducting new award kick-off meetings within the Awards Management, Budget, and Compliance team, and (3) tracking all awards on an award and contracts matrix, as well as in the new awards management software system. For each new award, a Grant Code Form is created. The form allows the Awards Management, Budget, and Compliance team to direct the Accounting team to create a grant code for tracking purposes in the accounting financial system. When the Awards Management and Budget team complete the form, the grant will be clearly identified as a federal grant. In addition, when KIND receives a new award, the Awards Management, Budget, and Compliance team conduct kick-off meetings within the team to discuss award financial, programmatic and compliance requirements. During this meeting the team completes an awards summary template that clearly identifies an award as a Federal award and any related compliance and other requirements. In addition to the processes mentioned, the Awards Management, Budget and Compliance team has created a new contracts and awards tracking matrix. The awards tracking matrix identifies Federal grants, along with any related award requirements and other identifying information. This matrix is maintained and updated by the Awards Management, Contracts and Compliance Officer and reviewed by the Director, Grants Financial Management on a regular basis. The review includes existing procedures related to awards management and monitoring of processes. This is on-going and already in progress. In addition to the above-mentioned processes KIND will do the following: continuously review existing processes around clearly identifying Federal awards and make adjustments to strengthen internal controls as needed; review and discuss with the awards management software vendor, additional improvements that can be made to the system to better identify and report Federal awards and review the current awards matrix and make additional improvements that will better identify and track Federal awards. Name and Person Responsible: Rochelle Quillman, Director of Grants Financial Management Expected Completion Date: October 31, 2023

Corrective Action Plan Finding 2022-001 In response to the reported deficiency of internal controls over compliance with the preparation of the Schedule of Expenditures of Federal Awards (SEFA), Riverside is implementing the following Corrective Action Plan: 1. Upon notification from the Contracts Department of new awards or modifications, the Program Controller will review the Project Setup with an emphasis on ensuring the Project Type is correctly assigned. 2. Prior to approving the Project Setup in Cost Point by the Contracts Department, the Contracts Manager will ensure the Project Setup is accurate. 3. Riverside will perform a rigorous review of the SEFA in advance of submitting the document to our external auditors. This will include reviewing the Project Type of each project identified as required to be reported in the SEFA. Individual(s) Responsible for the Corrective Action Plan: Vivian Arthur, Controller, (703) 908-2135, Gary Van Gorder, (937) 427-7009. Anticipated Completion Date: December 2023

Community Development Block Grants ? Assistance Listing No. 14.228 Recommendation: We recommend that the Council record federal expenditures on the SEFA under the program in the year upon which the loan disbursement occurs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Council has revised their procedures so that loan disbursements will be recorded on the SEFA in the year in which they are disbursed. Name(s) of the contact person(s) responsible for corrective action: Anita Cameron, NLF Director, and Becky Walter, Fiscal Manager Planned completion date for corrective action plan: December 31, 2023

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.

Federal Grantor: U.S. Department of Health and Human Services, Family Violence Prevention and Services/State Domestic Violence Coalitions, State Coalition Technical Assistance and Training Program, Director Program, Federal Assistance List Number 93.591 Condition: Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) were revised during the single audit. Auditor Recommendation: The Partnership should work with its external accounting firm to ensure the SEFA is complete and accurate and expenses agree to federal revenues reported and ensure revenues and expenses for each federal grant are included in the appropriate grouping code for the grant so revenues and expenses claimed are accounted for separately in the general ledger. Partnership Contact Person Responsible for the Corrective Action: Aleese Moore-Orbih, Executive Director Management Response and Corrective Action Plan: The Partnership concurs with the finding and recommendation. We have begun the process of increasing the capacity of our finance department to include an Associate Director, who, like the Senior Director, will be familiar with Uniform Guidance and nonprofit grants management and accounting. They will work in collaboration with our accounting consultants to ensure the SEFA is complete and accurate and agrees to recorded revenue. The target date for hiring is September 1, 2023.

Finding 2022-002 ? Significant Deficiency Award No.: 97.083, Staffing for Adequate Fire and Emergency Response Federal Grantor: U.S. Department of Homeland Security, Federal Emergency Management Agency Compliance Requirement: Other compliance requirements. Condition: The schedule of Expenditures of Federal Awards (SEFA) was not complete, and expenditures reported on the SEFA were revised during the single audit. Recommendation: We recommend additional review procedures be implemented to ensure the SEFA is complete and accurate when the single audit begins. Management Response and Corrective Action Plan: The Finance division will work with other departments to ensure that data provided in the SEFA are complete and accounted for on an accrual basis. We will also implement efficiencies in our accounting systems to ensure expenditures are captured correctly to prevent errors and omissions. Additional review will be completed by the Finance Director for completeness.