Corrective Action Plans

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.

The Agency updated procedures for developing the SEFA in accordance with 2 CFR 200.502 which states, “The determination of when a federal award is expended must be based on when the activity related to the Federal award occurs.”The Agency is required to comply with 2 CFR 200.403 which indicates that allowable costs must be determined in accordance with accounting principles generally accepted in the United States of America (GAAP). The Agency updated procedures for developing the SEFA in accordance with both 2 CFR 200.502 and 2 CFR 200.403 to include the following process improvement: The agency has modified its current process to ensure the direct and indirect costs charged to the federal programs include only the costs incurred during the current fiscal year.

The Agency updated procedures for developing the SEFA in accordance with 2 C.F.R. 200.510 (b) to include the following process improvements: The agency has modified its current process in determining the value of federal awards expended for the various federal loans in Federal, which will include all Federal loans within their affordability period in the compliance period. The compliance period requirements under the guidance §200.502 (b) are any new loans made or received during the audit period that are still within their affordability period. Add an additional process step regarding the requirements for the SEFA to be presented accurately when an expenditure is reclassified to another general ledger account across all programs to ensure the SEFA presentation accounts for the correct expenditures during the audit period. The agency has modified its current process to ensure the direct and indirect costs charged to the federal programs include only the costs incurred during the current fiscal year.

Condition: The schedule of expenditures of federal awards (SEFA) contained inaccuracies and incomplete information that was identified during the audit. Planned Corrective Action: The School District will develop a SEFA checklist to help ensure all federal expenditures are properly reported. Additional processes will be put in place by management to review the SEFA in advance of the annual audit to effectively meet audit report timelines and help ensure completeness, validity, and accuracy of the final SEFA reporting. Contact person responsible for corrective action: Patricia Carion/Piper Bognar Anticipated Completion Date: 07/31/2025

Finding 2024-004 U.S. Department of Treasury Federal Award Year Ending June 30, 2024 COVID-19: Coronavirus State and Local Fiscal Recovery Funds Lack of internal controls over the preparation of the Schedule of Expenditures for Federal Awards Finding: The Schedule of Expenditures for Federal Awards for the year ended June 30, 2024, was initially overstated by $529,900 due to an improper subrecipient verses beneficiary determination for the COVID-19 coronavirus state and local fiscal recovery funds. Corrective Actions Taken or Planned: When reviewing revised grants, particularly pass-through grants, look for any new language in the updated review that could affect the classification of the grant as a federal award and update any relevant schedules accordingly. Look into other alternatives for additional reviews on grants. Contact person responsible for corrective action: Heather Brouse, CFO, and Melissa King, Accountant

A review and training of the award set up process is being conducted to ensure all team members in Office of Sponsored Programs (OSP) follow the correct procedures for moving an advance fund number into a fully executed award. Implementation of a new electronic research administration system, Novelution, is currently underway. Internal controls will be incorporated into this system to track advance awards and their conversion into fully executed awards. This control will improve tracking and communication via systems to avoid the duplication of fund numbers for the same award. On a quarterly basis, Research Accounting Services (RAS) will send reports of advance funds to OSP to follow up on the status. RAS is also incorporating additional reviews during the SEFA preparation process. They will review advance funds to check with OSP to see if the fully executed agreements have been received from the sponsor and if any updates are needed. Novelution will also be a more robust system that will provide full grants management for agreements in order to provide more transparency across central units that will minimize these types of errors from occurring in the future. This is expected to be completed prior to the close of FY2025.

RECOMMENDATION: Marshall Jones recommends that the School establish a process to track the expenditures of federal awards during the year, including awards for which purchases are made on the School’s behalf by the passthrough grantor. This will better enable the School to timely prepare a complete and accurate SEFA. RESPONSE: DeKalb Preparatory Academy intends to hire a Chief Financial Officer (CFO) to oversee financial operations. The CFO will be responsible for ensuring accurate tracking and management of all revenues and expenditures, including those from state, local, and federal sources.

CDCU’s CFO, Sarah Beaumont, 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). The CFO, Sarah Beaumont, will draft the federal grant and loan management policy and procedures which will be reviewed and approved by the Board of Directors. CDCU’s Finance Manager, Traci Norton, 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). The Finance Manager, Traci Norton, will update federal grant and loan information in the electronic repository. Repository will be reviewed quarterly by the CFO, Sarah Beaumont, and reviewed and approved by the CEO, Todd Reeder.

CDCU’s CFO, Sarah Beaumont, 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). The CFO, Sarah Beaumont, will draft the federal grant and loan management policy and procedures which will be reviewed and approved by the Board of Directors. CDCU’s Finance Manager, Traci Norton, 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). The Finance Manager, Traci Norton, will update federal grant and loan information in the electronic repository. Repository will be reviewed quarterly by the CFO, Sarah Beaumont, and reviewed and approved by the CEO, Todd Reeder.

Response: Management agrees with the finding and will reevaluate internal processes and procedures. This error highlights the need for better oversight and timely communication between our organization and its subrecipients to ensure accurate reporting. The root cause of this issue was insufficient monitoring and communication between the subrecipient and our grants management team. To address this, we are implementing several corrective actions. These include establishing a stricter communication schedule with subrecipients to ensure timely submission of invoices and expense reports and strengthening our internal monitoring procedures by tracking submission deadlines more closely. Additionally, we will improve guidance and capacity-building efforts for subrecipients to ensure they understand reporting requirements, and we will conduct quarterly reviews of subrecipient expenses to proactively identify and mitigate reporting delays. Contact person responsible for corrective action: Lynne Duong, Post Award & Compliance Manager Anticipated completion date: December 31, 2024

Carl Biber Chief Financial Officer 317 Western Boulevard Jacksonville, North Carolina 28546 Anticipated Completion Date: June 30, 2025 Annually, the Authority will perform additional verifications of the completeness of the Schedule of Expenditures of Federal awards by confirming directly with the mortgagee the balance as of year-end and activity for the year then ended.

2CFR 200.510(b) requires organizations 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 of federal awards as determined in accordance with 2 CFR 200.502. The original SEFA prepared by the School District was not complete and accurate. The School District will implement a procedure to ensure that accounting records are closed timely, internal accounts are reconciled, and appropriate workpapers are prepared to support SEFA balances. The School District will implement these procedures for the 2025 fiscal year end.

Corrective Action Plan: Management agrees with the Auditor’s recommendations. The City has discussed this finding with our former auditors. Accounting staff and City grant personnel will work with third parties working with grants for the City to more frequently receive information and update the City's records accordingly. Person(s) Responsible (Name, title): Donald Harris, City Treasurer and Shelly Munks, City Clerk Timing for Implementation: Ongoing

Finding No: 2023 001 Federal Agency: U.S. Department of Homeland Security Federal Emergency Management Agency Assistance Listing Number: 97.036 Program: COVID 19 – Disaster Grants Public Assistance (Presidentially Declared Disasters) Award Year: July 1, 2022 to June 30, 2023 Compliance Requirement: Other – Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the entity’s financial statements which must include the total federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non federal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal control should include procedures to ensure federal expenditures are accurately and completely reported on the SEFA. Conditions Found The System did not have adequate controls related to the identification and reporting of federal expenditures for the COVID 19 – Disaster Grants Public Assistance (Presidentially Declared Disasters) program on the SEFA. Specifically, the System lacked controls to ensure expenditures incurred for COVID 19 Disaster Grants Public Assistance (Presidentially Declared Disasters) program were recognized on the SEFA when obligated. As a result, $16,310,090 of FEMA expenditures were omitted from the June 30, 2023 SEFA. Cause Management did not perform appropriate risk assessment procedures related to federal awards that have unique recognition criteria such as FEMA. Specifically, there was not a control in place to ensure FEMA expenditures were recognized on the SEFA based on when the FEMA award was both obligated and expenditures were incurred. Effect Failure to establish effective internal controls over the preparation of the SEFA may prevent the System from reporting accurate program information and completing an audit in accordance with the Uniform Guidance. Questioned Cost Not applicable Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year Not a repeat finding. Recommendation We recommend that the System strengthen its processes and internal controls over ensuring that proper recognition of expenditures have been reported completely and accurately on SEFA. View of Responsible Official Wellstar Health System, Inc. has implemented a control and process to ensure that expenditures are properly reflected on the SEFA. Corrective Action Plan Wellstar Health System, Inc. has implemented a control and process to ensure that expenditures are properly reflected on the SEFA at time of obligation. Anticipated Completion Date: Wellstar Health System, Inc has already implemented the corrective action. Name of Contact Person for Corrective Action: Beth Loudermilk, VP Financial Planning & Analysis