Corrective Action Plans

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

RE: Single Audit Corrective Action Plan The City of Hartwell, Georgia respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Williamson and Company, CPAs 611 N Tennessee Street Cartersville, GA 30120 Audit Period: Year ended December 31, 2022 The findings from the December 31, 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 2022-001 Clean Water State Revolving Fund – ALN: 66.458 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 Hartwell will record all expenditures on the schedule of federal expenditures going forward on for all federally funded projects. Please call or write if there are any questions/suggestions that you may have to help us further enhance the City’s operations. Sincerely, Audrey Segars Finance Director City of Hartwell, Georgia

Finding 2021‐001 Federal Agency: United States Department of Housing and Urban Development (HUD) Planned Corrective Actions: Responsible Official – Darryl Johnson, Deputy CFO Anticipated completion date – October 2025 Management will review its controls and update standard work documentation to ensure that all loans and expenditures related to the Housing Trust Fund are appropriately accumulated and reported in the schedule of expenditures of federal awards (SEFA) for the period covered by the New York State Housing Finance Agency’s financial statements in accordance with Uniform Guidance 2 CFR section 200.502. All staff working on SEFA preparation and review, will receive additional education in reporting for federal programs.

We will adopt procedures and implement to ensure accurate reporting of expenditures on the SEFA and to ensure compliance with federal requirements.

Corrective Action Plan Finding 2021-006 and 2021-007 Identification of Federal Awards and Preparation of a Complete and Accurate Schedule of Expenditures of Federal Awards (SEFA) 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 materially misstated; including the following major federal program for the year under audit: ALN 14.228 Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii In addition, there were multiple federal programs that were not identified, or had inaccurate amounts reported, on the initial SEFA for the year under audit: ALN 10.664 Cooperative Forestry Assistance - not identified ALN 97.036 Disaster Grants - Public Assistance (Presidentially Declared Disasters) - inaccurate amounts reported ALN 21.027 (COVID-19) Coronavirus State and Local Fiscal Recovery Funds - inaccurate amounts reported 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 $366,330. Repeat Finding: This is not a repeat finding. 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

The Board of County Commissioners, with the cooperation and participation of all elected officials, rev iews, develops and implements policies and procedures to create a strong internal control environment. Addit ionally, the Board of County Commissioners conducts meetings with all elected officials and officers responsible for the receipt and/or expenditure of county funds. These meetings address fiscal matters, including but not limited to, pol icy d iscussions and implementation, financial reports, budget oversight, SEF A reporting, and legal compliance. Policies and procedures, combined with fiscal oversight meetings, are intended to: I) prevent or detect material misstatements in the financial statements; 2) prevent or detect fraud within the county; 3) increase communication between the Board of County Commiss ioners and those elected officials and officers respons ible for the receipt and/or expenditure of public funds; 4) provide oversight over the fiscal concerns of the county; 5) identify and address risks related to financial reporting; 6) ensure the accuracy of Rogers County's financial statements, Estimate of Needs, the Schedule of Federal Awards ("SEFA"); and 7) ensure compliance with all applicable federal and state laws, regulations, and/or codes. The Board of County Commissioners, with the cooperation of all elected officials and officers responsible for the receipt or expenditure of county funds, will evaluate the processes and procedures currently in place to detect and identify material misstatements in Rogers County's financial statements, detect fraud, and identify and address risks related to Rogers County's financial processes and procedures will be implemented to identify fraud, detect material misstatements in the financial statements, and address risks related to financial reporting.

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.

Through the assistance of the Oklahoma State Auditors and Inspectors Office, we have received appropriate instruction on how they wish the appearance of the SEF A to be. We believe this issue to be resolved and will be reported as instructed from this point forward.

Finding: In accordance with 2 CFR 200 200.510(b), 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 2 CFR 200.502. The Corporation’s Schedule of Expenditures of Federal Awards for the year ended June 30, 2021 was initially prepared without federal expenditures totaling $1,222,859 for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund, Assistance Listing number 93.461. Corrective Actions Taken or Planned: In July 2023, the Corporation has provided education and training to the staff regarding how to identify programs and costs that need to be reported on the annual SEFA. This includes a process to enhance internal controls around the timely identification of federal awards and the reconciliation of the SEFA to ensure that it is accurate and complete. Name of contact person responsible for corrective action: Rose Rosario, Director of Patient Financial Services.

Program: Transportation Infrastructure Finance & Innovation Action (TIFIA) Program (ALN 20.223) Finding: 2021-002 Contact Person: Wei Chi Director of Finance City of Long Beach Harbor Department Phone: (562) 283-7594 Email: wei.chi@polb.com Corrective Action Plan: Going forward, the Harbor Department will ensure that federal loans are reported on the SEFA. The expected completion date for implementation of these planned actions is no later than June 30, 2025.

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

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. Additionally, we will update the procedures to document the SEFA reporting for the ELC program.

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 is making progress and continues 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. By the end of fiscal year 2021-22 and into fiscal year 2022-23, the EDD did 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 fiscal year 2019-20 financial audit to update processes and procedures and applied that knowledge going forward. Also, staff have been participating in various trainings offered by Finance and the Department of FISCal and staff continue to work with the control agencies when issues arise that would impact our accounting functions. While the EDD is still behind, the department is making great progress on catching up. The EDD submitted the last of its fiscal year 2020-21 financials in July 2022 and is targeting to submit the last of its fiscal year 2021-22 financials by the end of March 2023. The EDD’s goal is to submit fiscal year 2022-23 financials by the end of December 2023. Similar to the 2019-20 financial audit, the EDD will take the knowledge learned during the 2020-21 audit season, 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 entering of the cash basis expenditures into the Database.

The County Clerk, Treasurer, and BOCC Executive Assistant are tracking and monitoring all Federal expenditures closely to ensure the SEFA is more accurately reported.

In collaboration with the audit team, we will correct the procedures used to develop the Schedule of Expenditures of Federal Awards to ensure that it is completed correctly and accurately .Anticipated Completion Date April 30,2024.Responsible Contact Person-Kathleen Boyce, CFAO

Management will work together to design and implement a system of internal controls to ensure an accurate reporting of revenues and expenditures on the SEFA, that the notes to the SEFA are prepared, and compliance with all applicable federal requirements.

Finding Number: 2021-002 Condition: Controls in place were not sufficient to ensure the accuracy and completeness of the SEFA. Planned Corrective Action: In order to assure the accurate classification of federal grant expenditures, the Federation staff implemented the following controls as part of their accounting review process: 1) The Senior Accountant responsible for grant accounting and the Senior Director of Finance will perform a complete review of all grant agreements, to determine whether the grants are funded with federal or state funds. 2) The quarterly workpapers will include a copy of the signed grant agreement, a current SEFA schedule, and a general ledger that correctly corresponds to the totals included on the included SEFA. 3) The staff will perform a quarterly review of the State of Michigan website (Michigan.gov/MDHHS) to confirm the funding sources of all existing grants. Contact person responsible for corrective action: Rebecca Stasch, Senior Director of Finance Anticipated Completion Date: 05/31/2023

The BOCC will work to design and implement internal controls to ensure accurate reporting of federal expenditures on the Schedule of Federal Awards (SEFA) and ensure compliance with federal requirements.

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

Finding 2020‐001 Federal Agency: United States Department of Housing and Urban Development (HUD) Planned Corrective Actions: Responsible Official – Darryl Johnson, Deputy CFO Anticipated completion date – October 2025 Management will review its controls and update standard work documentation to ensure that all loans and expenditures related to the Housing Trust Fund are appropriately accumulated and reported in the schedule of expenditures of federal awards (SEFA) for the period covered by the New York State Housing Finance Agency’s financial statements in accordance with Uniform Guidance 2 CFR section 200.502. All staff working on SEFA preparation and review, will receive additional education in reporting for federal programs.

The Board of County Commissioners, with the cooperation of all elected officials and officers responsible for the receipt or expenditure of county funds, will evaluate the processes and procedures currently in place to track federal awards and to ensure all income and expenditures relating to federal awards are properly overseen, tracked, and reported. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same.

Program: Highway Planning & Construction (ALN 20.205) Finding: 2020-001 Contact Person: Wei Chi Director of Finance City of Long Beach Harbor Department Phone: (562) 283-7594 Email: wei.chi@polb.com Corrective Action Plan: The Harbor Department will ensure that federal expenditures are accurately and completely reported on the SEFA. The expected completion date for implementation of these planned actions will be completed Fiscal Year 2024.

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

Finding 2019‐001 Federal Agency: United States Department of Housing and Urban Development (HUD) Planned Corrective Actions: Responsible Official – Darryl Johnson, Deputy CFO Anticipated completion date – October 2025 Management will review its controls and update standard work documentation to ensure that all loans and expenditures related to the Housing Trust Fund are appropriately accumulated and reported in the schedule of expenditures of federal awards (SEFA) for the period covered by the New York State Housing Finance Agency’s financial statements in accordance with Uniform Guidance 2 CFR section 200.502. All staff working on SEFA preparation and review, will receive additional education in reporting for federal programs.

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