Corrective Action Plans

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildlife.nh.gov Audit Report Reference: 2024-007 – Activities Allowed or Unallowed/Allowable Costs/Costs Principles Anticipated Completion Date: Unknown Corrective Action Planned: To have the ability to use NHFIRST for grant accounting in the future. Hopefully, the migration to CloudSuite will offer this option. We concur in part with the finding; A. The Department does recognize the NHFIRST system is the official financial system of the state of NH, however, at this time NHFIRST does not allow for us to be able to charge grants individually for staff working on grant funded projects through the NHFIRST system. Therefore, we use QuickBooks as a ‘calculator’ for these grant costs. The Department uses a calculated rate based on the employee’s pay rate, benefits and years of service. While it is an arduous and complicated task, there is currently no other option for capturing all costs of the employee to the programs. B. We do not concur with part B as we did supply the support to substantiate the payroll costs but it was not used for testing. C. We did provide a specific sample for testing but again not in the timeliness requested. The Department does perform reconciliations and pre-audits of information entered into QuickBooks to verify data is complete and accurate. Payment vouchers are entered into QuickBooks by the Federal Aid Accountant and verified by the Supervisor. The Supervisor also verifies payroll and Indirect. We do not agree there are questioned costs of $11,409.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Kathy LaBonte Title: Business Division Chief Telephone: 603 271-2274 E-mail address: kathy.a.labonte@wildlife.nh.gov Audit Report Reference: 2024-006 – SEFA Reporting Anticipated Completion Date: Completed Corrective Action Planned: Improved internal controls to evaluate amounts reported on the SEFA have been implemented. We concur in part with the finding: A. Out-of-period expenditure amounts were incorrectly included on the SEFA. These amounts have been identified and corrections have been made. B. Same as above. C. The Department partially concurs. For one grant, W108-L2 / F21AF04030, the amount understated is actually $5,431. As previously explained, a portion of the amount listed as understated, was a Donation to the purchase of property, and not a direct Department Expenditure. ($112.500.00). Corrections have been made to the SEFA. D. Only the total Federal share of expenditures were reported on the SEFA. The Department does perform reconciliations and pre-audits of information entered into QuickBooks to verify data is complete and accurate. Improved internal controls to evaluate the amounts reported on the SEFA have been implemented.

Finding Reference: 2024-001 - SEFA Reporting (ASU) Responsible Official: Sabrena Johnson, Director of Grants and Contracts Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $298,151 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, Alcorn State University has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: May 31, 2025 Finding Reference: 2024-001 - SEFA Reporting (DSU) Responsible Official: Jacnita Robinson, Grant Accountant Corrective Action Planned: Delta State University acknowledges the audit finding related to errors in the Schedule of Expenditures of Federal Awards (SEFA) reporting. The federal award in question was not intentionally omitted from the SEFA. At the time of SEFA preparation, Delta State University believed the award would be reported on the Mississippi Department of Finance and Administration’s SEFA, as they were identified as the recipient of the award. The University’s intention was to prevent the duplication of expenditures and avoid double-booking the same federal funds on both SEFAs. To prevent this type of error in the future, Delta State University will review and revise its internal controls and procedures for identifying and classifying federal awards. Additional training will be provided to the staff responsible for award set-up and SEFA reporting to ensure proper classification and communication with state agencies regarding the reporting responsibilities for pass-through and beneficiary awards. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (JSU) Responsible Official: Dr. Almesha Campbell, Vice President for Research and Economic Development Corrective Action Planned: Jackson State University will follow the procedures outlined for preparing the Schedule of Expenditures of Federal Awards. Such procedures include, but are not limited to the following: • Verify the ALN provided on the award documents and cover page and then enter it in Banner during the award set-up process. In addition, review the ALNs for continuation awards. If errors are identified during this process, they will be corrected. • Review previous year’s SEFA report and data support to ensure the report is in the format requested by IHL • Correspond with the Division of Business and Finance to include additional expenditures. Currently, the expenditures to include are 1) Direct Loans, 2) Expenditures with ALN 21.027, and 3) Perkins Loans Expenditures • The Director for Fiscal Reporting and Compliance will complete a subsequent review after the Director for Grants and Contracts prepares the report for submission. Furthermore, the newly created Oversight Committee will review the SEFA before submission to ensure that the Federal Perkins Loan program expenditures are included on the SEFA. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (MUW) Responsible Official: Rachel Sudduth, Assistant Director of University Accounting Corrective Action Planned: University Accounting will review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified, this would also include federal expenditures made through Mississippi Bureau of Buildings. Estimated Completion Date: March 21, 2025 Finding Reference: 2024-001 - SEFA Reporting (MVSU) Responsible Official: Mr. Samuel Melton, Director of Sponsored Programs/Title III Corrective Action Planned: Mississippi Valley State University will ensure that federal awards are correctly coded when preparing the Schedule of Expenditures of Federal Awards using the following procedures: • The Office of Business and Finance and Office of Sponsored Programs will verify the ALN provided on the award documents provided by the sponsor (i.e., federal agency and/or pass-through entity). If errors are identified during this process, they will be corrected. • The Director of Accounting will complete a subsequent review after the designated Staff Accountant prepares the report for submission. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (UM) Responsible Official: Dr. Steven G. Holley, Vice Chancellor for Administration and Finance Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024, was revised to include $131,454 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN 21.027. Additionally, the University of Mississippi has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 30, 2024 Finding Reference: 2024-001 - SEFA Reporting (USM) Responsible Official: Andrea Phillips, Controller Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $597,135 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, USM has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 23, 2024 Finding Reference: 2024-001 - SEFA Reporting (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: UMMC engaged with a Workday certified consulting firm to review the operational effectiveness of the configuration of Workday, review reports available, and assess processes and procedures. As part of the engagement, this firm also evaluated various operational processes within the contract and grants office. The engagement began in June of 2024 and has made significant changes to Workday to bring operational efficiency into our processes and configurations; as well as, developed reports that identify variances and differences that need to be researched and corrected. The team also corrected reports that were pulling data inaccurately and trained internal UMMC IT staff on how to address system corrections going forward and the methodology to develop/modify IT reports. The firm also revamped our award setup process in Workday and built checklists along with Standard Operating Procedures that bring efficiencies and accuracy into our Award setup process. We also built in roles for review of an award at the time of setup to ensure that errors are quickly identified and corrected in the system. Estimated Completion Date: June 30, 2025

The County acknowledges the importance of proper documentation for subrecipient monitoring. To address this finding, the County will implement the following: 1. Enhanced Review Process – County departments responsible for subrecipient agreements will conduct a thorough review of subrecipient monitoring activities to ensure compliance with federal and regulations. This will include verifying that all required monitoring steps, including risk assessments and are properly conducted and documented. 2. Documentation and Record-Keeping Improvements – County departments will be required to maintain clear and consistent documentation of all subrecipient monitoring activities. This includes risk assessments, financial reports, site visit records (if applicable), and any corrective actions taken.

The City internally identify improvement opportunities in managing grants. As a part of the City’s grant oversight improvement efforts, the City began implementing various processes and internal controls surrounding grant monitoring, which improves the SEFA drafting process and mitigates risks of future inaccuracies. These efforts began in early 2024 and include the following: • Creation of a grant policy that provides City staff with guidance, information, and expectations surrounding grants. • Creation of a master grants database that lists the general ledger fund, applicable project ledger references, status, grant type, start/end dates, granting agency, pass-through agency, grant name, assistance listing numbers, grant amounts, and the grant manager for each grant. This database is now used to verify the completeness and accuracy of the SEFA (beginning FY24). • Formal quarterly monitoring. Each quarter, the City will formally review the grants database with department contacts and grant managers to verify the completeness and accuracy of the database. The City is formalizing this process and plans to include department signoffs evidencing the review process. If any items are missing, the missing component will be identified and added to the database on a timely basis. The City will also utilize this quarterly process to review the grants policy to ensure grant managers are aware of the requirements related to their grants. • The City is in the process of formalizing the SEFA drafting process utilized during the FY24 SEFA preparation, which includes additional mitigating procedures such as reviewing all next FY federal receipts to ensure none of them relate to the SEFA year federal expenditures. Personnel Responsible for Implementation: Marvin Lopez Position of Responsible Personnel: Deputy Administrative Services Director (Fiscal Services) Expected Date of Implementation: June 30, 2025

Department: Education Title: Internal control over the submission of CNC Schedule of Expenditures of Federal Awards information needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has updated the SEFA Review Procedure to include more specific information regarding the calculation of amounts reported for the Special Milk Program and noncash assistance and the classification of payments made to a school as direct payments rather than subrecipient expenditures. Completion Date: March 10, 2025 Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

Condition: Out of our 40 samples tested for allowability in the Special Education Cluster (IDEA), the University improperly included 2 expenditures for goods and services incurred or received in a prior year on the schedule of expenditures of federal awards (SEFA) in the current year. Out of our 40 samples tested for allowability in the Research and Development Cluster (R&D), the University improperly included 1 expenditure for goods and services incurred or received in a prior year on the schedule of expenditures of federal awards (SEFA) in the current year. Planned Corrective Action: The university implemented a new financial enterprise software system that allows each department within the university to improve its ability to monitor and track status of invoices as well as reduce processing time by the Accounts Payable Department to vouch approved expenditures. Contact person responsible for corrective action: Karen Mushong, Controller Anticipated Completion Date: 06/30/2025

Corrective Action Plan: The unaudited statements were corrected for FY2024 and are reflected in the audited statements. FY2023’s were corrected through the retained earnings that show on the FY2024’s audited statements as well in the prior year’s number on the statements. The FY2024 Single Audit reflects these changes as well. Management invoices at the times allowed upon the different grant funders based upon percentage of completion of the project/s. We will review all on-going projects at the end of each fiscal year during the audit with the auditors to determine what reporting has to be done in order to comply with the requirements of the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance), Subpart F, Audit Requirements.

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 2024-001 Information on the Federal Program: Federal Program: HIV - Related Training and Technical Assistance - Aids Education and Training Centers Assistance Listing: 93.145 Federal Agency: U.S. Department of Health and Human Services – Health Resources and Services Administration (HRSA) Grant Award Number:6 U1OHA30535-08-01 Award Periods: July 1, 2023 through June 30, 2024 Pass-Through Agency: Columbia University Grant Award Number: U1SHA46532 Award Periods: September 1, 2023 through August 31, 2024 Corrective Action Plan: Department of Health and Human Services – Health Resources and Services Administration (HRSA) updated the award template utilizing a new federal format. Modification of this federal award template has allowed HRSA to indicate/flag (item 18 in the Notice of Grant Award - R&D “no”) whether the federal program is R&D in a manner not previously recorded or visible. This indicator flag now indicates AETC is non-R&D, therefore, we have reflected it appropriately in the FY24 SEFA. We will strengthen our controls for monitoring the cluster to ensure appropriate classification paying attention to any indications in the Notice of Grant Award. Paula Yarbrough, VUMC Director – Grants and Contract will be responsible for the implementation by fiscal year-end 2025.

Condition: The System obtained a loan from the Department of Housing and Urban Development ("HUD") during their fiscal year June 30, 2021. The proceeds of the loan were used to repay a loan with another financial institution during that same year. The HUD loan includes continuing reporting requirements, which require the loan to be reported on the Schedule until it is repaid. The System improperly excluded the HUD loan balance from their Schedule in previous years. The beginning of the year loan balance has been reported on the System's Schedule for the year ended June 30, 2024, in accordance with 2 CFR 200.502(b). Planned Corrective Action: Management will put procedures in place to identify federal reporting requirements for federal loans and grants. Contact person responsible for corrective action: Michael Haynes, CFO and Debbie Caldwell, Controller Anticipated Completion Date: 06/30/2024

Management agrees with the findings and will take the necessary corrective actions. The Organization will create an internal control mechanism to track Federal Awards throughout the year in order to prevent and detect any potential material misstatements and make it available to the auditors at the end of the year.

Office of Management and Budget Response/Corrective Action Plan: The Office of Management and Budget agrees with this finding. OMB agrees but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. Contact Person: Elizabeth Roger, Account Budget Specialist Anticipated Completion Date: December 2026

A.    DESE has informed us that if this situation ever comes up in the future, asking for a federal extension if buses were not going to be delivered in a timely manner, in this case by January 10, 2025. The manufacturer assured us that the buses would be delivered by November 4, 2024 so we didn’t asked for the extension.

B.     In the future, we will wait until buses are on site to write checks.

C.     We do not anticipate any ESSER ARP money to be issued in the near future.

Condition: Expenditures of federal funds representing <0.25% of total expenditures of federal funds for the year ended September 30, 2024 were charged to various federal programs and were not reported on the Schedule of Expenditures of Federal Awards (SEFA) for the period ended September 30, 2024. Planned Corrective Action: Management will document a formal control to ensure proper reconciliation of the SEFA to the financial statements. The control will include the following: A report in substantially the same form as the annual SEFA will be developed at least quarterly and will include a reconciliation of grants receivables activity. Meetings will be help at least quarterly to review grant activity, including the aforementioned report, and assess impacts to the financial statements. These meetings will be conducted by Treasury and Accounting staff and evidence of document review will be maintained. A centralized repository of information pertaining to federal grants activity will be maintained to ensure timely access to grant and expenditure data for relevant staff. Contact person(s) responsible for corrective action: VP, Treasury Management Controller Anticipated Completion Date: Control will be documented by March 31, 2025 and operational for the quarter ending by June 30, 2025.

2024-003 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Program Name: Child Nutrition Cluster; Education Stabilization Fund Assistance Listing Number: 10.553, 10.555 and 10.559; 84.425 Award Period: June 30, 2024 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 have the Board Clerk and the Board Treasurer complete the Schedule of Expenditures together and to ensure that the correct expenses are being reported. Contact Name – Kristy Dyche Expected Completion Date – 6/30/2025

Prince George's County Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: June 30, 2024 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 U.S. Department of EducationStudent Support and Academic Enrichment Program– Assistance Listing No. 84.424 We recommend that the School system review its procedures to ensure that amounts reported on the SEFA are in accordance with 2 CFR part 200.502 and 510. Explanation of disagreement with audit finding: We agree with the finding in part. As the auditors noted, Grant Number 20157201, ended on 9/30/22. There were additional FY23 invoices and payroll processed to this grant after the grant was closed out by the Grant Accountant. The corrections to remove these expenses, though they caused a net effect of zero, were recorded in fiscal year 2024. The adjustments for $27,799 were mistakenly reported on the fiscal year 2024 SEFA. These additional amounts were never reported in the MSDE AFR system, because as noted, they resulted in net zero change. Reporting in the MSDE AFR system is always done with a report from Oracle, the school system’s financial reporting system, and only actual expenses are reported. In addition, at year end, the full report is reconciled to our Grants Roll Forward Report, which allows us to ensure the correct information is reported for each grant. Action taken in response to finding: The $27,799 will be removed from the FY24 SEFA. In an ongoing effort to ensure that all grants are reported correctly and in line Grant’s Administrator will hold regular meetings (at least quarterly) with the Budget Analyst and/or Grants Accountant assigned to these grant funds. The Grants Accountant will also provide transaction and payroll detail reports to the Grants Administrator on a regular basis for review and correction when necessary. Planned completion date for corrective action plan: March 2025 Contact person(s) responsible for corrective action: Department of the Division of Student Services: Elizabeth Faison, Associate Superintendent of Student Services, Ph.D., NCC, LCPC Grant Financial Management Office: Darrell Haley, Supervising Budget Analyst Claire Taylor, Supervising Grants Accountant, CPA, CGFM, CGMS

2024-004 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Award Period: June 30, 2024 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 work with a third-party consulting fitm to address issues an improve protocols. Contact Name – Dr. Jessica Dain Expected Completion Date – 06/30/2025

Finding 2024-004: Schedule of Expenditures of Federal Awards (SEFA) – Material Weakness Condition: While performing our audit procedures, we noted that CAFB included the a $5 million grant from Fairfax County on their SEFA even though CAFB is considered a beneficiary related to this grant. Views of Responsible Officials and Planned Corrective Actions: As stated in the report, the Organization respectfully disagrees with both the substance and the severity of the finding. In RSM’s proposal to the Organization, the firm indicates that it offers proactive advice to its clients: “Specialists RSM has a deep bench of specialists locally and nationwide available to advise CAFB and the engagement team on issues as they arise. Relevant specialists cover areas such as: unrelated business income from alternative investments, multi-state taxation, Federal single audits, and information technology. Proactive resolution of accounting issues We find that year-round communication and a proactive approach to accounting issues help clients avoid surprises at the end of the audit process. For this reason, we encourage clients to call us to discuss new transactions as they arise.” [emphasis added] We agree that the independent auditor cannot be part of the Organization’s internal controls. In this instance, the Organization conducted its own research into the nature of the beneficiary agreement and reached a conclusion that it should not be included on the SEFA. During audit planning, we discussed this position with the audit partner and manager who recommended that it should be included on the SEFA. Following the resignation of the engagement partner and manager, a new resource assigned to conclude our engagement by the firm disagreed with that position and raised this finding. Had the initial audit team remained and we excluded the grant, we assume that we would have received a finding for its exclusion. As to the severity of the finding, we disagree that the instance rises to the level of a material weakness. Although we concede the amount of the award ($5 million) is significant, its inclusion/exclusion from the SEFA did not impact the selection of major programs and was a singular decision-making instance of an unusual form of award, irrespective of the amount involved. As for corrective action, considering the infrequency of beneficiary agreement awards to non-profit organizations, it is improbable that the Organization will receive such an award again. Nevertheless, if the Organization encounters an unusual transaction or award, we will continue to perform our own research on the award/transaction and form our independent conclusion (as we did in this instance) and refrain from taking actions that might imply the independent auditor is part of the Organization’s internal control structure.Anticipated Completion Date: February 2025

Corrective Action: - The Organization will issue new letters of confirmation requests to all counties under contract that are to be sent to the audit firm and the Chief Financial Officer of the Organization, who is the responsible party. - The Organization has established policies and procedures to understand and ensure compliance with the Organization’s contractual obligations.- The Organization has implemented procedures to determine the source of funding received through various county contracts. - The Organization has implemented review procedures to ensure the Schedule is complete, accurate, and prepared in accordance with the requirements set forth within 2 CFR 200.510(a).

Corrective Action: Management will continue to stress the importance of following the detailed procedures for preparation and review of the SEFA. The SEFA checklist is updated to include a thorough review of expenditure details to ensure no prior-year expenses are reported. Responsibility for compiling the SEFA was assigned to a Senior Program Accounting Manager who is tasked with assuring the schedule and all the 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). Estimated completion date: June 30, 2025 Individual Responsible for Corrective Action Plan: Contact: Reginald Gregory Title: Executive Director/Controller Phone Number: 202-772-4300

Internal controls will be reviewed and modified as needed to ensure compliance with federal statutes, regulations and the terms and conditions of the federal award. DED will increase future communication with the Office of the State Comptroller when reporting expenditures of the SSBCI program to insure proper categorization of technical assistance expenditures.

Office of the State Comptroller will review the instructions provided to State Agencies with the Sub-Schedules and consider changes to make them clearer that State Agencies should review and include all Federal expenditures for their Agency. OSC will also review the process used for determining if any additional programs should be included on State Agency Sub-schedules.