Corrective Action Plans

Finding Number 2023-001: Allowable Cost/Cost Principles: Grant Award Period Year Ended December 31, 2023. Condition: In testing performed under Air Forces Defense Research Sciences Program, the Auditors indentified a deficiency that was the result of subrecipients expenses being recorded in accordance with GAAP rather than CFR compliance for the purposes of the single audit. (SEFA). View of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. The Organization revised its review procedures and controls so that subrecipient expenditures are recorded in the proper accounting fiscal year according to 2 CFR Part 200 Subpart F section 200.502, whereby amounts will be reported as expended when the disbursement is made to the subrecipient for single audit purposes. These steps should correct the deficiency. Contact Person: Stephanie Peluso, Senior Staff Accountant Finance (760-802-7554) and/or Diane Peluso, Senior Contract Advisor (760-522-5300) Propsed Completion Date: This action plan was completed on 5/17/2024.

2023-002 – Internal Control over Compliance and Compliance with Period of Performance Contact Name – Jeff Kaufman Position – Global Controller Contact – jkaufman@corusinternational.org Estimated date of completion: September 30, 2024 Corrective Action Plan – Corus management concurs with this finding and reaffirms its commitment to responsible stewardship of funding awarded to Corus by the United States Government and other donors. There are occasions when Corus may anticipate successfully negotiating a program extension with the USG or other donors. In the event there are immediate needs of the program’s potential beneficiaries, Corus may decide to utilize its own unrestricted funds in expectation that if the extension is obtained, these funds will be reimbursable under the terms of the extension. Corus recognizes that there is no guarantee that the program will be extended; thus, it understands that it incurs the expenses at its own risk. As a point of emphasis, while the expenses referenced in this finding were incorrectly coded such that this spending was erroneously included on the SEFA, Corus did not draw on USG funding to recover these expenses, the expenses were funded by Corus’ own unrestricted resources. Action steps to be implemented during the Corus 2024 fiscal year include: • The steps outlined in response to 2023-01 should also ensure proper account coding of expenses and timely monitoring of program spending against available obligated funds as well as program expiration dates.

2023-002 - Internal Controls Over Compliance and Compliance with Reporting - Preparation of the Schedule of Expenditures of Federal Awards Contact Name: Charlie Feeney Position: Chief Financial Officer Telephone Number: (202) 796 2496 Corrective Action Plan – Management is establishing additional review procedures to ensure that SEFA schedule is accurate and fairly stated when submitted. Estimated Completion – September 30, 2024

In response to the reported deficiency of internal controls over compliance with the preparation of the Schedule of Expenditures of Federal Awards (SEFA), ANSER will implement the following Corrective Action Plan:

1.      During the Kick-Off meeting of new awards or modifications, the contracts staff will provide the proper Federal Assistance Listing Number (FALN) to be associated with the new activity from the Catalog of Federal Domestic Assistance produced in SAM.gov by the GSA.

2.      Accounting staff will include the FALN in the Project Setup in the Project Accounting system.

3.      ANSER will also perform a more rigorous review of all elements of the SEFA in advance of submitting the document to external auditors. This will include participation by contracts and accounting staff.

Individual(s) Responsible for the Corrective Action Plan: Rick Clark, Corporate Controller, Kate Edwards, Director of Contracts & Pricing.

Anticipated Completion Date: May 2024

Ryan White HIV/AIDS Program Part A SEFA reporting Management’s Views and Corrective Action Plan Management’s Views and Opinion Sunset Park agrees that the draft SEFA amount for this program was not reflective of the total reimbursement received under this award. Sunset Park also agrees with the recommendation to ensure that grants reimbursed by methods other than cost reimbursement are reported and aligned with deliverable or allowable activities for SEFA purposes. Corrective Action Plan Sunset Park will conduct semi-annual reviews in January and May for awards that are not based on cost reimbursement. The purpose of these reviews is to ensure that the amounts reported on the SEFA align with the allowable activities that are not based on cost reimbursement. This process will ensure proper reporting that is in line with the reimbursement policies of the granting agency. Furthermore, the Director of Grants and the Grants Fiscal Team will review all award terms to ensure an accurate reporting structure for accounting and SEFA reporting purposes. Timeline for Action Plan Date of Completion: 08/31/2024 Responsible Individual Leonardo Arias Email: Leonardo.Arias@nyulangone.org

Tapestry 360 Health will improve the timely submission of the Single Audit Reporting Package by ensuring that grant programs are tracked and reported in detail monthly, resulting in fewer errors for the SEFA. Tapestry will also perform a hard close semi-annually that will allow us to perform a mid-year analysis and reconciliation. Furthermore, contracts will be stored in a central, organized manner to facilitate the consistent use of the documents as reference. Finance and the Grants Development team will meet monthly regarding grant programs to review dates, terms, budget, for each program. The anticipated completion date to correct the Finding 2023-002 is August 15th, 2024.

Tapestry management will review the SEFA and its corresponding contracts to aide in the attestation of compliance. To further enhance timely submission, Tapestry will use technology and automation to aid the tracking and organization of grant programs. Technological upgrades include using the general ledger to uniquely identify Federal grants and enhance fiscal reporting, using software to store and organize contracts. The anticipated completion date to correct the Finding 2023-004 is August 15th, 2024.

Prior to submitting the SEFA each year, a Staff Accountant in ATCC’s Finance & Accounting team will prepare the SEFA, it will be reviewed and approved by ATCC’s Federal Solutions Finance team and the CFO/Controller for completeness, accuracy, and compliance with CFR Section 200.510(b), confirm consistency with the trial balance, and correct any inconsistencies prior to submitting the SEFA report.

Finding Reference Number: 2023-001 Description of Finding: The schedule of Expenditures of Federal Awards (SEFA) was not complete, and expenditures reported on the SEFA were revised during the single audit. Statement of Concurrence or Nonconcurrence: Operation Care agrees with the finding as stated above. Corrective Action: Beginning immediately, Operation Care will keep a running, updated SEFA. As soon as Operation Care receives a grant agreement, the Fiscal Director and Executive Director will review it to see if there are federal funds. If so, the Fiscal Director will enter the grant, along with the CFDA number and all other pertinent information into the SEFA. At the end of the grant year, the SEFA will then be updated to reflect Federal Expenses. The updated SEFA will then be provided to the Executive Director. Name of Contact Person: Ashley Carnicello, Executive Director, (209) 223-2897 ashley@operationcare.org Bruce Platt, Fiscal Director (209) 223-2897 bruce@operationcare.org Projected Completion Date: SEFA will be updated by June 15, 2024 and will continue to be updated as needed.

Finding Number: 2023-004 Condition: The schedule of expenditures of federal awards (SEFA) was inaccurate. Planned Corrective Action: Management would like to point out that this finding is related to finding 2023-001. The accrual of additional grant invoices resulted in parallel updates to our SEFA schedule. Therefore, this finding is a direct result of finding 2023-001. As an aside, our current process for reporting SEFA is manual. We are investing in a new accounting system, in which the SEFA information will not require manual intervention and thus reduce any potential entry errors in the future. Contact person responsible for corrective action: Colette Champine, CFO Anticipated Completion Date: Already completed

The migration to a new general ledger financial reporting system is an isolated incident and given the improved reporting capabilities the change in product provided a positive impact. UWGC experienced turnover for the program manager position that created a learning curve that was addressed but resulted in audit completion delay. UWGC has an experienced manager currently overseeing the program who will follow policies and procedures as prescribed and on a timely basis to allow for prompt reporting submission.

UWGC experienced a staffing turnover during the 2024 fiscal year of the manager responsible for the reporting on the SEFA. The manager tracked financial reports on a cash basis causing a timing difference with not recognizing accounts payable. The finance team accounted for expenses in the appropriate period, therefore the Finance team will crosscheck reports for timing difference prior to submission to governing agency.

Finding Number: 2023-003 Condition: The schedule of expenditures of federal awards (SEFA) was not complete. Planned Corrective Action: The College will ensure that the schedule of federal awards (SEFA is reviewed for completeness. Going forward, the SEFA will be compared with the prior year SEFA and a separate schedule of new awards for the current fiscal period. The results of this comparison will be reviewed by the grants office, the controller’s office and the Vice President’s office. This will increase the level of reviews to a three-tiered process which should address issues of completeness of the SEFA. Contact person responsible for corrective action: Ms. Jackie Brown, Ms. Deborah McKenzie, and Dr. Sharron T. Burnett Anticipated Completion Date: 06/30/2024

The YWCA will implement the following changes in its accounting procedures: The Schedule of Expenditures of Federal Awards (SEFA) will be reviewed for accuracy by either the CFO or CEO after it is produced, to ensure that all federal awards are included, and that the amounts on the schedule are accurate.

Views of Responsible Officials: IW has developed and implemented enhanced procedures for the preparation of the SEFA. These procedures include detailed steps for ensuring that all costs related to Federal awards are fully allocated in the general ledger at the time of transaction and prior to SEFA preparation. This process is designed to prevent any future discrepancies between the SEFA and the general ledger. To further strengthen our internal controls over Federal award management, IW has instituted regular monthly reviews of expenditures charged to Federal awards. This review process includes verifying that expenditures are correctly allocated and supported in the general ledger, thereby ensuring the accuracy and completeness of the SEFA.

MNCASA and MACC will implement a review process for accruals and reversals; this review process will occur at the end of each month and the end of the fiscal year. This process will ensure that the ledger matches the SEFA reporting, accruals, and reversals and is done in a timely manner. MNCASA and MACC staff will also attend a training session on SEFA prepartation to increase our knowledge and ensure proper reporting.

Management response to finding 2023-001: Accuracy of expenditures on the Schedule of Expenditures of Federal Awards and submission of special reports for the Head Start Program Cluster Name: Head Start Federal Awarding Agency: Department of Health and Human Services Award Name: Head Start and Early Head Start, COVID (P.L. 116-260) Award Number: 09CH010228-05-05, 09CH011831-02-03, 09HE000328-01-00 Award Years: 2019-2021, 2021-2022, 2021-2023 Assistance Listing Title: Head Start Assistance Listing Number: 93.600 Pass-through entities: Not applicable As described in finding 2023-001, the University inadvertently charged and drew down budgeted capital expenditures from Head Start awards before actual expenditures were incurred by the University. Additionally, the University charged expenditures to a Head Start award after liquidation extensions had expired. The adjustments required to correct these errors were identified in the subsequent fiscal year, resulting in expenditures on the fiscal year 2023 Schedule of Expenditures of Federal Awards (SEFA) being overstated. The University will take the necessary corrective actions as described below to ensure the accuracy of expenditures reported on the SEFA. Finally, as described in finding 2023-001, the University did not identify and track reports required to be submitted for Head Start awards. The corrective actions described below will ensure all award specific reporting requirements are met. Although the University has limited federal awards that are utilized to fund capital expenditures, the Office of Sponsored Projects Accounting and Facility Planning and Management will perform a full review of the current Head Start capital construction accounting policies and practices to ensure they comply with the Uniform Guidance and the terms and conditions of federal awards before June 30, 2024. Reinforcement of the University’s policies and practices will ensure proper grant accounting, and thus, will prevent SEFA reporting adjustments from having to be made. Faculty leadership responsible for overseeing the Head Start program at the University will fill current vacant financial management positions within the Head Start program as soon as possible (with a three month target), undergo a full review of program requirements with all staff, and modify and develop new internal controls related to this finding. Specifically, before July 2024, Head Start fiscal personnel along with faculty leadership will develop a reporting schedule specific to Head Start awards, provide training and resources to staff involved with reporting, implement internal controls related to the reconciliation and validation of reported data prior to report submission, and strengthen internal controls related to the allocability of expenditures to awards (particularly in situations where liquidation extensions or expenditure carry forwards have been granted). Contact Person: Andres Chan, Director, FBS Financial Analysis, andres.chan@usc.edu

--Management Response to Finding 2023-001-- I, Heather Ficht, on behalf of EC Works' leadership acknowledge and take responsibility for the deficiencies in the use of internal procedures to accuracy of information reported on the SEFA. To immediately address this deficiency, effective March 1, 2024, all operations staff will be cross trained on the proper completion and submission of the SEFA; additional procedures will also be put in place to ensure grants and other financial awards are identified as federal or nonfederal at the time of receipt. Upon receipt of any grant agreement, the Chief Operations Officer shall be responsible for identifying and communicating the source of each grant/award with the leadership team. The Finance Director shall ensure accuracy of this information and is then responsible for the timely documenting of the information on the "Grant Schedule". The Finance Director shall also be responsible for working with the Senior Accounting Technician to ensure that the proper accounting codes are assigned to each award, indicating if the award is federal or non-federal. Accounting codes and the information contained on the "Grant Schedule" shall be reviewed by the Chief Operations Officer on an ongoing, and no less than quarterly basis. Lastly, the SEFA and all financial reports prepared by the Finance Director and/or the Senior Accounting Technician shall be reviewed and approved by the Chief Operations Officer for accuracy prior to submission.

Finding Number 2023-208: The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller (Office) included multiple errors. Federal Programs: 10.551 - Supplemental Nutrition Assistance Program (SNAP) 10.561 - State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (SNAP) 21.027 - Coronavirus State and Local Fiscal Recovery Funds 93.391 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises 93.558 - Temporary Assistance for Needy Families (TANF) 93.568 - Low-Income Home Energy Assistance 93.569 – Adoption Assistance 93.575 - Child Care and Development Block Grant (CCDF 93.658 - Foster Care Title IV-E 93.777 - State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare 93.778 - Medical Assistance Program Related to Prior Finding: 2022-211; 2021-206 Agency’s view: The Department agrees with this finding. Corrective Action: Since the implementation of LUMA, the department has been cognizant of the systematic challenges and risks and is acutely attentive to monitoring and review efforts. For example, due to LUMA, finance now has a new chart of accounts structure, meaning previously used reports for compilation of the SEFA are no longer a concern. The department held a required training on March 12-13, 2024, for all employees involved with grant administration where the determination of contractor vs. subrecipient, as well as proper account coding, were reiterated. Finance has efforts underway to strengthen compliance through report building and monthly monitoring of proper coding. The department will be moving forward with the implementation of Grant Management Software in SFY25, which finance believes will provide further assurances of data accuracy. Finance will confirm all expenditures and adjustments are completed before running reports when preparing the SFY24 and future SEFA’s. This confirmation will be documented via an email to the Financial Manager of the Budget section. The email response will be retained with the SEFA preparation file for audit purposes. Anticipated Corrective Action Date: Partial efforts already completed; full completion by June 30, 2025. Responsible for Corrective Action: Staci Phelan, Division Administrator Staci.Phelan@dhw.idaho.gov 208-334-0632 Kelly Combs, Bureau Chief, Compliance Kelly.Combs@dhw.idaho.gov 208-334-5814

Finding Number 2023-204: The Schedule of Expenditures of Federal Awards (SEFA) closing package understated the Education Stabilization Fund - Governor’s Emergency Education Relief (GEER II) by $1,039,753 and overstated the Education Stabilization Fund – Emergency Assistance to Non-Public Schools (EANS) program by the same amount. Federal Programs: 84.425C – Governor's Emergency Education Relief; 84.425R - Emergency Assistance for Non-Public Schools Related to Prior Finding: 2021-202 Agency’s view: The Board agrees with this finding. Corrective Action: The corrective action is to reclass any GEER II Project transactions in FY 2024 to EANS/GEER II Project. That will ensure there are no GEER II transactions in FY 2024 that would need to be adjusted. This was done on March 21, 2024. Anticipated Corrective Action Date: March 21, 2024 Responsible for Corrective Action: Patrick Coulson, Chief Financial Officer Patrick.coulson@OSBE.idaho.gov 208-332-1563