Corrective Action Plans

The University will review and enhance its procedures and internal controls to ensure the SEFA is complete and accurate.

The City will implement a standardized grant reporting procedure to ensure all departments, including Finance, are promptly informed of grant awards. This will include a centralized grant tracking system and regular interdepartmental meetings to enhance communication and oversight. Additionally, training will be provided to department staff on grant notification protocols to prevent similar oversights in the future.

2023-001 Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: Metropolitan Transportation Commission Award Year: 2023 Grant Award Number: MTC/STP Agreement Compliance Requirements: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b)- Schedule of expenditures of Federal awards Recommendation: VTA should establish policies and implement internal controls to ensure all federal expenditures are accurately identified on the Schedule of Expenditures of Federal Awards (SEFA). Corrective Action: VTA will reinforce its system of internal control in communicating timely the Catalog of Federal Domestic Assistance (CFDA) number to the department preparing the SEFA. CFDA of direct and pass-through grants will be obtained from the Federal Transit Administration (FTA) and related grantors, respectively. If the CFDA number of a grant is not available at the time of preparation of SEFA, this will be identified accordingly. Responsible Party: The Fiscal Resources Manager and the Transportation Planners, Grants Implementation Date: March 31, 2025

Financial Statement Finding: 2023-008 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 controlsthat provide reasonable assurance over the completeness and accuracy of the SEFA. The SEFA is the basis for the auditor’s identification of major programs. Cause/Condition: The City does not have a method to accurately track the related expenditures for reporting. 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: 1. 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 on the initial SEFA for the year under audit: 1. ALN 20.600 / 20.616 Highway Safety Cluster 2. ALN 66.818 Brownfield Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements 3. ALN 66.458 Capitalization Grants for Clean Water State Revolving Funds 4. ALN 93.568 Low-Income Home Energy Assistance 5. ALN 97.039 (COVID-19) Disaster Grants - Public Assistance (Presidentially Declared Disasters) 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 receives. 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. 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. Corrective Action Plan: The City will include tracking of federal awards in the Capital Project tracking process. Capital projects will be reflected in a separate budget alongside the operational budget beginning in FY 2026. Anticipated Completed Date: July 31, 2025 for the tracking process; December 20, 2025 for the budget. Responsible Contact Person: Elizabeth Greenwood, Director of Administration & Finance

Consortium’s Fiscal Agent will ensure that supporting documentation will be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost.

The Village Treasurer will start preparing the Schedule of Expenditures of Federal Awards each year or contract with a CPA firm for assistance in preparing the Schedule of Expenditures of Federal Awards each year.

A grant manager and grant-financial coordinator have been hired to work with the finance team to communicate the whole gamut of applicable elements of ASC 606. Also, we are purchasing a grant management system—not a manual Excel sheet- that can scan grants and identify conditions and restrictions.

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

Condition: The fiscal year 2023 Schedule of Expenditures of Federal Awards (SEFA) that was initially provided to the auditors was incorrect because it included expenditures related to fiscal year 2022, as well as expenditures that were incurred before an executed grant agreement was in place. Planned Corrective Action: Expenditures will be reported on the SEFA only for grant programs with an executed award regardless of the year incurred. SEFA preparation procedures have been updated to ensure analysis of grant execution date. Contact person responsible for corrective action: Trevor Nash, Accounting Manager Anticipated Completion Date: 12/31/2024

All future federal expenditures will be reconciled to the disbursement ledger.

Corrective action planned – The Organization will reinforce and expand its policy of reviewing contracts for federal awards to include development properties and other forms of non-standard expenditures including non-cash assistance and loans. These policies and procedures will be added to the year-end financial statement reporting checklist which is reviewed and monitored by the Controller. During this process, the staff member assigned to completing the schedule of federal expenditures (currently the senior fiscal program analyst), will communicate with risk management to review incoming contracts during the year, as well as at year end to ensure that federal monies are accounted for, and that significant unusual transactions will be accounted for. The staff member assigned to completing this report will also communicate it to the Controller for review. Name(s) of contact person(s) responsible for corrective action – Richard Sroka, Senior Fiscal Program Analyst in charge of grant reporting Anticipated completion date – Implemented.

Finding 2023-004- Lack of Effective Controls Over Preparation of Schedule of Expenditures of Federal Awards Grantor: U.S. Department of the Treasury Assisstance Listing#: 21.027 Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Year: Fiscal year 2023 9/1/22-8/31/23 Award Number: Not Listed Management understands the importance of effective internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA). At the time of preparing the 2023 SEFA, $2 Million was improperly excluded causing the reported to be restated. Corrective Action Plan and Anticipated Completion Date: The total expenditures reported in error for the 2023 SEFA will be restated and the consolidated Financial and Compliance Report in Accordance with the Uniform Guidance will be re-sibmitted to the appropriate federal and state agencies. On a go forward basis, management's review will include a reconciliation of all grant expenses reported on the current SEFA to the grant awards listed on the State of Illinois Department of Public Health (IDPH) grant portal (EGrMS) to ensure all federal awards are reported.

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

Material Weakness and Noncompliance – Preparation of Schedule of Expenditures of Federal Awards (SEFA) Statement of Condition/Criteria: The Code of Federal Regulations requires a nonfederal entity to 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 CFR Section 200.502(a) and must reconcile amounts reported in the SEFA to the amounts reported in the auditee’s financial statements. Planned Corrective Action: County management will develop a closing process to ensure all federal expenditures are identified, recorded, and reconciled on the SEFA. Contact person responsible for corrective action: Ashleigh Young, County Controller/Administrator Anticipated Completion Date: March 2025

The Alliance team will establish a review process to verify the accuracy and completeness of the SEFA before submission. BGCA will utilize a checklist or other tools to ensure all required information is included in the SEFA.

Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes Auditee’s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is “live” as of August 2022, the City is currently working to refine the software and fully utilize functionality. The Workday grants modules requires the grant funding source be defined prior to grant approval and fields are available for the AL titles and numbers and sub-recipients’ information. The implementation of the Workday grants modules centralizes much of the grant management function by requiring the agencies to upload the grant documents into Workday. The City has: • Held weekly meetings for two years with agency grant representatives to design and configure the Workday grant module. • Uploaded the grant award, sponsor information and grant budget data into a Workday. • Implemented a “new grant” request which uses a Workday business process. • In the process of reviewing and correcting recoverable costs per grant award so it is properly recorded. • Within Workday we are able to track grant performance period, CFDA, manage and capture grant related expenditures and calculate automated billing to sponsors on recoverable costs Business processes have been developed and implemented in Workday’s grant management module to include: Definition of the grant funding source by creating a system-generated grant work tag (identifier) upon receipt of the Sponsor’s Notice of Award; populated fields in Workday with passthrough award data with Prime Sponsor and Bill to sponsor Billing data, and modification of the create award process to add the Grants Management Office to final approval. In FY 24 the City implemented a citywide Grants Management Committee coordinated by the Mayor's Office of Performance and Innovation. Through feedback from this workgroup we identified an expanded scope of responsibility for the Grants Management Office; including oversight and compliance, technology, training and budget monitoring. In the short term a new Grants Director position was created and onboarding is to occur in the first quarter of FY25. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City. Completion Date: June 2024

Condition: The Authority did not identify that they were subject to an audit under the Uniform Guidance (U.G.) and a schedule of expenditures of federal awards (SEFA) was not prepared by management. Recommendation: The Authority should review federal, state, and local grants to determine if they are federally funded and, if federally funded, utilize the account number outlined in the State of Michigan chart of accounts to track federal funding. Planned Corrective Action: A schedule of federal awards will be created to track total costs covered by federal awards beginning in FY24. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024

The Treasurer will review the Schedule of Expenditures of Federal Awards to ensure all federal awards are being reported and the expenditures are properly reported.

Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Finding: 2023-011 Contact Person: Sarah Castillo Grants Accounting Officer Emergency Operations Center (EOC) Finance Division Phone: (562) 570-5479 Email: Sarah.Castillo@longbeach.gov Planned Actions: The Emergency Operations Center (EOC) Finance division acknowledges there has been deficiencies in the manner we report expenditures related to a declared disaster on the SEFA, which will be addressed by issuing a Financial Management Disaster Procedure Manual that will include a narrative on this specific matter. The manual will be published on our City Intranet and utilized for all City Staff as a resource for all future disasters that occur. Revisions to the Procedure Manual will be made as needed to ensure we are up to date with the latest compliance changes. Expected Completion Date: 12/31/2024

2023-004 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, 2023 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 firm to address issues and improve protocols. Contact Name – Dr. Jessica Dain Expected Completion Date - 12/31/2024

Individuals Responsible for Corrective Action Plan: BGCA Fiscal Team-Shelby Mahoney; Alliance Director Corrective Action: Review all federal grant contracts to determine if any separate funding sources should be listed for total funds received. Anticipated Completion Date: December 31, 2024

2023-008 - Significant Deficiency in Internal Control and Non-material Noncompliance - Schedule of Expenditures of Federal Award Awareness and Preparation WPHW understands this finding and has already taken steps to ensure this issue does not come back up for FY24. The follow process has been put in place to ensure compliance: 1) Director of Accounting and Grants Director will ensure they have appropriate training and work collaboratively to develop documentation process a. The Grant Director will update all grants as they are received, to ensure an accurate list of grants b. The Director of Accounting will update all of the financial data for each grant 2) The Director of Accounting will be responsible for the review and submitting document to the auditing firm For FY24, the Director of Accounting and Grant Director will jointly build the document and review to ensure completeness and accuracy. In FY25, the schedule of expenditures of federal award will be prepared as the year progresses.

Finding 2023-002 Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Medicaid Assistance Program HIV Emergency Relief Project Grants ALN: 21.027 / 93.778 / 93.914 Grady Memorial Hospital Corporation’s CFO and VP of Fiscal Services/Controller have reviewed the reporting from KPMG relating to the Uniform Guidance. We understand the recommendation set forth by KPMG and will update our controls and processes to include additional review of expenses incurred during the relevant audit period. Grady’s corrective action plan: Going forward the SEFA will be reviewed to ensure that all related expenses for the audit period are incorporated. Contact person/s responsible for the corrective action: David Noble, Director, Grant Administration Anticipated Completion Date: Consistent with 2024 Financial Audit Reporting

Finding 2023-001 – Reporting Assistance Listing Multiple In the immediate term, management will work with the grant consultant to modify the existing report to capture all the costs in the general ledger related to grants. Management will start a quarterly review process of the report with reconciliation to the grant detail. In addition, prior to the UG audit, management will start a year-end review process to ensure accurate and timely reporting. Responsible Official: Annaliza Villamin, System Director of Accounting, Endeavor Health

2023-001 – Preparation of the Schedule of Expenditures of Federal Awards Individual Responsible for Corrective Action Plan Jennifer Maher, CFO Londilia McCoy-Scott, Director of Contract and Grant Accounting Anticipated Completion Date: December 31, 2024 Corrective Action Plan: In reconciling the 2023 grant expenditure activity, management identified that some grant expenditures from 2022 were not included in the 2022 Schedule and self-disclosed this anomaly to the auditor. These expenditures were then incorporated in the 2023 Schedule to ensure that they were reported as timely as possible. Grants management staff from Finance and Program departments are meeting monthly to ensure that the expenditures are recorded in the appropriate year.