Corrective Action Plans

Program:Various, including AL 20.509 – Formula Grants for Rural Areas and Tribal Transit Program – Reporting Corrective Action Planned: The transit will continue to provide training to all the personnel who handles the information needed to properly calculate the SEFA amounts for future audits. Anticipated Completion Date: June 30, 2024 Responsible Party: Christy Warner, Transit Administrator

Corrective Action Plan: Management concurs with the Auditor’s recommendation and will review with the third-party North Central Illinois Council of Governments (NCICG) to establish appropriate City monitoring and review. City will also review with prior City Auditors to ensure proper overall procedures are in place to ensure all grants in the aggregate are monitored. Person(s) Responsible (Name, title): Donald Harris, City Treasurer and Shelly Munks, City Clerk Timing for Implementation: 7/31/2024

2023-006 – Completeness and accuracy of certain programs on the Prior Year Schedules of Expenditures of Federal Awards (SEFA) - (Significant Deficiency) Cluster: Not applicable Sponsoring Agency: Department of Health and Human Services (DHHS) - Health Resources and Services Administration (HRSA), Department of Education (ED) and Federal Emergency Management Agency (FEMA) Award Names: COVID-19 Provider Relief Fund and ARP (ARP) Rural Distribution (PRF), COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Portion, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) and Maternal and Child Health Federal Consolidated Programs Award Numbers: Various Assistance Listing Titles: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters), COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion, COVID-19 HEERF Institutional Aid Portion, COVID-19 HEERF Minority Serving Institutions, and Maternal and Child Health Federal Consolidated Programs Assistance Listing Number: 93.498, 97.036, 84.425E, 84.425F, 84.425L, 93.110 Award Year: 2020-2021, 2021-2022, 2019-2020, 2021-2023 Pass-through entity: Not applicable Management has implemented additional reconciliation and review procedures over the last two years to improve the accuracy and completeness of the SEFA. · UCOP implemented an annual SEFA review process to include the systemwide Controller and campus Controllers. UCOP also distributed one interim SEFA draft to the External Fund Managers (EFMs) that had historically been tasked with only a year-end review. · UCOP continued to reconcile atypical federal programs (e.g., PRF, FEMA, etc.) and included in the fiscal year 2023 SEFA drafts for campus Controller review. Beginning in FY 2024, UCOP will implement more comprehensive financial reporting controls as follows: · Interim SEFA reports, inclusive of atypical programs, will be prepared centrally and distributed to campuses for review and alignment with campus records. Campus management will be tasked with the responsibility for overall review and signoff for both interim and final SEFA reports. · The Systemwide Controller will also be included in the review process by performing an overall review and signoff for both interim and final SEFA reports. With respect to the specific findings in FY2023 for atypical / nonrecurring federal programs, the following actions have been and/or will be taken: • FEMA: A reconciliation process was implemented within UCOP in FY2023, the result of which was the discovery of the understatement referenced in the finding. FEMA expenses are now reconciled to, and obligation dates retrieved from, the Federal FEMA Grants Portal to ensure project expenses are accurately reported in the proper fiscal year. Data from the State portal is distributed to campuses for validation. UCOP has also reminded campus and medical center Controllers of the reporting requirements and will cover this topic again in future trainings. Additionally, UCOP will remind campuses and medical centers of the requirement to account for the FEMA project in the federal fund range at the time of obligation to trigger SEFA reporting. • PRF – A reconciliation process was implemented by UCOP in FY2022 and the reconciliation itself was completed in FY2023, the result of which was the discovery of the understatement referenced in the finding. PRF expenses reported by campuses are now reconciled to the HRSA online portal which will continue for the duration of the program. UCOP has also reminded campus and medical center Controllers of their responsibility to report on these dollars for their entire enterprise (Faculty Practice Group, School of Medicine, etc.). As with all other federal funding, PRF amounts will continue to be part of the SEFA reports distributed to campuses for review and signoff. Coordination between campuses and medical centers will be expected for this review and signoff. • HEERF – while the program ended in FY2023, UCOP will apply lessons learned to any future “special” funding. When atypical programs such as this are awarded in the future, UCOP will provide more consistent guidance upfront and establish more consistent accounting and reporting requirements for campuses and the medical centers to follow. Requirements will include regular reporting of these dollars to UCOP with a reconciliation of campus ledgers to any sponsor reporting. As with all other federal funding, amounts will be part of the SEFA reports distributed to campuses for review and signoff. • Program Income – UCOP will develop and conduct expanded training to campus Controllers, EFMs and their staff to include SEFA requirements generally, including treatment for program income (and other SEFA exclusions), new review procedures, etc. UCOP will target training for the spring of 2024. For inquiries regarding this finding, please contact Barbara Cevallos at barbara.cevallos@ucop.edu who is responsible for the corrective action.

Condition: The SEFA for the year ended June 30, 2023 was not accurately prepared, as it originally included federal expenditures that were not on the cash basis. Planned Corrective Action: The corrective action has been implemented to revise internal procedures to prepare the SEFA on a cash basis for future fiscal years. This includes the creation of a reconciliation schedule to the financial statements which are prepared on an accrual basis. Contact person responsible for corrective action: Jeremy Baker, Director of Finance Anticipated Completion Date: 1/15/2024

Federal Program Title: Research and Development Cluster ALN: Various Recommendation: We recommend the University evaluate its cutoff procedures to ensure federal costs are identified and reported in the correct fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Boise State University will evaluate our cutoff and accrual procedures to ensure costs are identified and reported in the correct fiscal year. Name(s) of the contact person(s) responsible for corrective action: Jen Lutke, Assistant Director, Post Award: jenniferlutke@boisestate.edu Planned completion date for corrective action plan: June 2024

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Department of Environmental Protection (DEP) Assistance Listing Number 15.252 Effective March 2024, DEP will develop and implement a standard operating procedure to track indirect costs. DEP will create a separate spreadsheet to track indirect costs to be included in the year ending SEFA reporting. DEP will attend training sessions conducted by the West Virginia Financial and Accounting Reporting Section to ensure all expenses are reported correctly on the SEFA. Additional training from accredited educational institutions will also be researched if necessary.

CORRECTIVE ACTION PLAN - FY 2023 AUDIT FINDING 2023 - 001 BASIS FOR DETERMINING FEDERAL AWARDS EXPENDED - SEFA EXPENDITURES Finding: Department of Agriculture - Rural Development Loan was not recorded correctly on the SEFA Expenditures Report. District 4 Human Resources Development Council Response: The Council concurs with the finding and understands the importance of appropriately including and measuring loans and loan guarantees in accordance with 2 CFR § 200.502(b) and (c) of the Uniform Guidance. The oversite has been corrected and the loans have been accounted for correctly on the current SEFA. The Council will ensure the loans are correctly reported on the SEFA in the future.

January 31, 2024 U.S. Department of Education Washington, D.C. Unified School District No. 458 respectfully submits the following corrective action plan for the year ended June 30, 2023. SSC CPAs, P.A. 3025 Cortland Circle, Suite 201 Salina, Kansas 67401 Audit period: Year ended June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section I of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENT AUDIT None. FINDINGS-FEDERAL AWARD PROGRAMS AUDIT 2023‐001 Internal Controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: Department of Education Program Name: Special Education Cluster (IDEA Assistance Listing Numbers: 84.027 and 84.173 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 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. Contact Name – Tyler Bacon Expected Completion Date -06/30/2024 If the U.S. Department of Education has questions regarding this plan, please call Tyler Bacon at 913-724-1396. Sincerely yours, Tyler Bacon Business Manager/Board Clerk Unified School District No. 458

Condition: The schedule of expenditures of federal awards (SEFA) was not complete and accurate. Planned Corrective Action: The City will be implementing a procedure whereby the Controller’s Office receives copies of all contracts to ensure all reporting requirements are met and financial deliverables are completed according to the schedules. Contact person responsible for corrective action: Brandy Ruth Anticipated Completion Date: June 2024

Program Name: 14.239 Home Investment Partnership Program Corrective Action #1 ‐ CDCU will implement federal grant and loan management policies and procedures and provide training to staff responsible for completing the Schedule of Expenditure of Federal Awards (SEFA) to ensure all federal grants and loans are included in the SEFA (pursuant to Section 200.502(b) of 2 CFR Part 200). Response Responsible Parties – The CFO will draft the federal grant and loan management policy and procedures which will be reviewed and approved by the Board of Directors. Corrective Action #2: CDCU will create and maintain a repository (electronic file) of relevant federal grant and loan information that contains key information relating to each federal program to assist in preparing the SEFA (pursuant to Section 200.502(b) of 2 CFR Part 200). Response Responsible Parties – The Finance Manager will update federal grant and loan information in the electronic repository. Repository will be reviewed quarterly by the CFO and reviewed and approved by the CEO.

Program Name: 21.027 Coronavirus State and Local Fiscal Recovery Funds Corrective Action #1 ‐ CDCU will implement federal grant and loan management policies and procedures and provide training to staff responsible for completing the Schedule of Expenditure of Federal Awards (SEFA) to ensure all federal grants and loans are included in the SEFA (pursuant to Section 200.502(b) of 2 CFR Part 200). Response Responsible Parties – The CFO will draft the federal grant and loan management policy and procedures which will be reviewed and approved by the Board of Directors. Corrective Action #2: CDCU will create and maintain a repository (electronic file) of relevant federal grant and loan information that contains key information relating to each federal program to assist in preparing the SEFA (pursuant to Section 200.502(b) of 2 CFR Part 200). Response Responsible Parties – The Finance Manager will update federal grant and loan information in the electronic repository. Repository will be reviewed quarterly by the CFO and reviewed and approved by the CEO.

Condition: The SEFA for the year ended June 30, 2023 was not accurately prepared as it originally included expenditures that were improperly excluded from the SEFA for the year ended June 30, 2022. Planned Corrective Action: Additional Supervisory Review of Expenditures Contact person responsible for corrective action: Deanna Korth Anticipated Completion Date: 09/30/2023

Condition: The schedule of expenditures of federal awards (SEFA) was not complete. Planned Corrective Action: The School District will develop a checklist, or a report downloaded from the General Ledger, of all federally funded grants, and will compare the grants listed on this report with the grants listed on the Schedule of Expenditures of Federal Awards (SEFA) to ensure that all grants are reflected on both documents. Additionally, the Assistant Superintendent will review, date and sign a copy of the SEFA document prior to its submission, and the Business Office will retain this signed paper copy in its audit file annually. Contact person responsible for corrective action: Michael Zopf Anticipated Completion Date: June 30, 2024

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