Corrective Action Plans

Finding 2024-003 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education CFDA Title and Number 84.010 Grants to Local Education Agencies (Title I) Name of Federal Agency: U.S. Department of Education Compliance/Internal Control over Compliance: Auditee Responsibilities Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the total Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit on an untimely basis, and with values that were not reconciled with the general ledger. Cause: The District staff had insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Errors in recording and reporting of revenues and expenditures of federal awards may not be detected and/or corrected. Because the Auditee’s SEFA that was presented for audit was completed incorrectly, and not reconciled to the general ledger, the SEFA was materially misstated, prior to auditor's correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following:  SEFA was originally presented for auditors with incorrect information.  SEFA was not presented for auditors on a timely basis.  No reconciliation between federal expenditures reported on the GL and the SEFA was presented. Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFA reports. Planned Implementation Date: August 1, 2025 Responsible Person: Director of Business Services, Yamhill County School District No. 8

Chaffee County will establish internal controls over grants management and SEFA preparation processes during the year to make sure the Federal expenditures are properly reflected on the information used to prepare the SEFA and match the accounting records.

Auditee Corrective Action Plan Finding 2024-001: Schedule of Federal Awards (SEFA) Preparation – Significant Deficiency Audit Finding: During our audit, we noted that the Schedule of Expenditures of Federal Awards (SEFA) initially prepared by Western Landowners Alliance did not include the required Assistance Listing Numbers (formerly CFDA numbers) for each federal program, and the amounts of federal expenditures reported contained inaccuracies. We understand this was Western Landowners Alliance’s first year preparing a SEFA and that staff are still becoming familiar with the detailed requirements of the Uniform Guidance (2 CFR Part 200). As the SEFA is a critical component of the Single Audit reporting package and serves as the basis for major program determination and compliance testing, it is essential that it be prepared accurately and in accordance with Uniform Guidance. We recommend that management enhance its understanding of SEFA preparation requirements, consider additional training on Uniform Guidance, and implement review procedures to help ensure the completeness and accuracy of the SEFA in future reporting periods. Audit Recommendation: We recommend that management enhance its understanding of SEFA preparation requirements, consider additional training on Uniform Guidance, and implement review procedures to help ensure the completeness and accuracy of the SEFA in future reporting periods. Management’s Response and Corrective Action Plan: Western Landowners Alliance (WLA) acknowledges and agrees with the finding, and have taken the following corrective actions to address the issue: (1) Implementation of SEFA Template: given the diversity of awards WLA receives (primary, subawards, and awards with both federal/non-federal funding), a standardized template has been developed and implemented to ensure accurate tracking and reporting of awards, funding sources, and expenditures. (2) Proactive Collection of Assistance Listing Numbers: WLA will proactively request and document the Assistance Listing Numbers (formerly CFDA numbers) from funding agencies upon receipt of awards to ensure compliance, and complete and accurate reporting. (3) Documentation of Expense Allocation Process for Awards with Federal and Non-Federal Funding: WLA’s financial policies and procedures have been updates (as of August 2025) to document the process for allocating expenses on awards that include both federal and non-federal resources. Documentation of this process will ensure consistent and appropriate allocation in accordance with federal requirements. (4) Per recommendation from RGO, Robinson has enrolled in two trainings: Uniform Guidance Training Part 1 and Part 2-Single Audit Training-the importance of the SEFA, hosted by Illumeo, to augment knowledge to support future compliance. Contact and Completion Date: Rachael Robinson, 505-466-1495, rrobinson@westernlandowners.org, is the primary contact, and the Chief Operating Officer at Western Landowners Alliance. The corrective action is currently in effect and trainings will be completed by August 31, 2025, to ensure compliance with the current fiscal year. Please reach out with any questions. Rachael Robinson Chief Operating Officer Western Landowners Alliance 505-466-1495

Finding 2024-004 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.041 Impact Aid Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Sched-ule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the to-tal Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipi-ents. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements.   Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger, and contained inaccuracies, including: • Overclaimed revenues for Title I • Inability to provide sufficient documentation of Impact Aid revenues and specific Impact Aid program infor-mation • Incorrect reporting of state and federal revenues for National School Lunch Program. Cause: The District does not have effective internal control over the preparation of the Schedule of Expenditures of Federal Awards. The district did not reconcile the expenditures reported on the SEFA with the amounts reported on the district's general ledger. Effect or Potential Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected and corrected. Because the SEFA was completed incorrectly, and not reconciled to the general ledger, the financial statements were materially misstated prior to the auditor's adjust-ments. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting re-sulted in the following: SEFA was originally presented for auditors with incorrect information, and not reconciled to the general ledger Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or cor-rect errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and re-view the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identi-fied and reported accurately on future SEFAs. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager Section IV—Summary Schedule of Prior Audit Findings There were no findings for the fiscal year ended June 30, 2023.

Responsible Official’s Response and Corrective Action Planned: We have implemented procedures to ensure that the SEFA includes all federal expenditures incurred during the reporting period, regardless of whether reimbursement has been requested. Reconciliation of the SEFA amounts are completed monthly. Management will also offer and require training to all personnel responsible on the Uniform Guidance requirements for SEFA reporting.

Reference Number: 2024-005 – Incomplete Schedule of Expenditures of Federal Awards Name of Contact Person: Chia Lor, Accounting Manager Corrective Action: Management agrees with the finding and recommendations. The City will begin to implement policies and procedures to assist with monthly reconciliations and review processes to mitigate these errors in the future. Proposed Completion Date: December 31, 2025

Recommendation: Controls should be implemented so that a complete understanding of grant compliance requirements should be obtained and monitored to ensure that the appropriate audits and financial statements are prepared and issued. Management Views: Management agrees with the finding as the issue was identified during the 2024 fiscal year audit. Action Planned: Controls have been implemented so that compliance requirements of grants are documented, reviewed, and monitored on a regular basis to ensure that appropriate audits are performed and financial statements are prepared and issued. A single audit was performed and appropriate financial statements were issued. Anticipated Completion Date: Complete Responsible Party: Catina Downey, CPA with oversight of Heidi Hooker, Executive Director

Condition: The schedule of expenditures of federal awards (the "SEFA") was not accurate. Planned Corrective Action: To improve accuracy and completeness of the SEFA, the City will enhance its master grant tracking spreadsheet to ensure all grant expenses are calculated correctly and consistently. In addition, quarterly reviews will be conducted in partnership with departments to confirm that all federal awards are current and accurately captured. These improvements, along with the updated required quarterly report and request for reimbursement procedures, will allow the City to compile a complete and accurate SEFA. Contact person responsible for corrective action: Grant Accountant and Accounting Manager Anticipated Completion Date: 7/31/2025

Reference: Finding 2024-002 Access Restricted to Documentation for Various Compliance Requirements – Research & Development Cluster; Noncompliance – Period of Performance, Procurement (Micro Purchasing), Subrecipient Monitoring, and Equipment and Real Property Management Contact: Erica Classing, Controller; classinge@battelle.org; 614-424-3372 Views of Responsible Officials: Battelle acknowledges this finding is the result of access restrictions to classified contract documents imposed by federal agencies that are beyond Battelle’s control. Battelle does not have the authority to grant auditor access to classified programs without the proper security clearance and program permissions, rather this authority resides with the federal awarding agency, in accordance with applicable federal security regulations. These restrictions prohibited access to classified contracts for required audit procedures in those areas noted in Finding 2024-002. Classified contracts are a small subset (10%) of Battelle’s total reportable expenditures. Battelle provided all unclassified documentation required to support transactions selected for testing. In addition, Battelle provided all documentation necessary to audit compliance with requirements on all non-classified contracts selected. Management upholds high standards of compliance and transparency and continues to support audit processes to the fullest extent possible. Battelle agrees to explore options to satisfy audit requirements while maintaining compliance with classified contract security regulations. Corrective Action Plan: Summary of finding: During compliance testing of period of performance, procurement (micro purchasing), subrecipient monitoring, and equipment and real property management, access to classified contracts was restricted. The auditor was unable to view federal award documents to confirm the following information: • Period of performance (5 of 50 selections) - unable to confirm the authorized project period • Procurement (micro purchasing) (2 of 40 selections) - unable to review applicable requirement relating to consent to subcontract • Subrecipient monitoring (2 out of 40 selections) – unable to inspect subaward information and applicable terms • Equipment and real property management (3 out of 50 selections) – unable to obtain proof of active use and safeguard of the classified equipment and validate whether the equipment disposal was handled properly in accordance with the contractual terms and conditions. Root cause: Access to classified contracts is subject to confidentiality requirements mandated by external regulators, requiring appropriate security clearance levels and verified need-to-know status. If the classified contract is a special access program, obtaining program-specific approvals from the awarding agency in addition to possessing the appropriate security clearance and need to know is required. There is no guarantee that the federal awarding agency will ultimately grant cleared auditors access to the classified contract. Corrective action: Battelle is taking the following steps to address the finding: • Internal Review: We conducted an internal review of the areas affected by the scope limitation to validate each selection complied with the applicable contractual and regulatory requirements. This action was completed by December 19, 2024 and did not identify any instance of non-compliance with applicable rules, regulations, or contractual requirements. • We have existing monitoring mechanisms in place to ensure compliance in the areas affected by the scope limitation. • Early coordination with external auditor: We are collaborating with our external audit team to identify any classified contract audit selections earlier in the annual audit process. A proactive approach will allow Battelle extra time to engage clients for required approvals to either gain access to the classified information or obtain appropriate alternative audit evidence. In addition, any other related steps that can be completed in advance such as verifying auditor clearance types and levels will be performed early to help mitigate any delays. This corrective action requires the audit firm to provide auditors with the appropriate security clearances. • Engagement with regulatory agencies: We are in dialogue with impacted federal awarding agencies to explore options to provide necessary audit evidence. • Enhanced documentation: We are enhancing our audit support procedures to provide guidelines on how, within the bounds of regulatory restrictions, we can provide access to audit evidence for future audits. Overall Anticipated Implementation Date: December 31, 2025

Reference: Finding 2024-001 Qualified Auditor’s Opinion for Allowable Costs and Activities Allowed and Unallowed and Special Tests and Provisions for Research & Development Cluster Due to Material Scope Limitations Contact: Erica Classing, Controller; classinge@battelle.org; 614-424-3372 Views of Responsible Officials: Battelle acknowledges the scope limitation is the result of access restrictions to classified contract documents imposed by federal agencies that are beyond Battelle’s control. Battelle does not have the authority to grant auditor access to classified programs without the proper security clearance and program permissions, rather this authority resides with the federal awarding agency, in accordance with applicable federal security regulations. These restrictions prohibited access to classified contracts for required audit procedures in those areas noted in Finding 2024-001. This limitation was only on classified contracts which is a small subset (10%) of Battelle’s total reportable expenditures. Battelle provided all unclassified documentation required to support transactions selected for testing. In addition, Battelle provided all documentation necessary to audit compliance with requirements on all non-classified contracts selected. Management upholds high standards of compliance and transparency and continues to support audit processes to the fullest extent possible. Battelle agrees to explore options to satisfy audit requirements while maintaining compliance with classified contract security regulations. Corrective Action Plan: Summary of finding: During testing of allowable costs and special tests and provisions, access to classified contracts was restricted. The auditor was unable to view federal award documents to determine allowability terms and conditions, security clearance requirements, or other special provisions for sample selections of classified contracts. Consequently, this restriction on access to the source contract document resulted in a material scope limitation for these testing areas. Root cause: Access to classified contracts is subject to confidentiality requirements mandated by external regulators, requiring appropriate security clearance levels and verified need-to-know status. If the classified contract is a special access program, obtaining program-specific approvals from the awarding agency in addition to possessing the appropriate security clearance and need to know is required. There is no guarantee that the federal awarding agency will ultimately grant cleared auditors access to the classified contract. Corrective action: Battelle is taking the following steps to address the finding: • Internal Review: We conducted an internal review of the areas affected by the scope limitation to validate each selection complied with the applicable contractual and regulatory requirements. This action was completed by December 19, 2024 and did not identify any instance of non-compliance with applicable rules, regulations, or contractual requirements. • We have existing monitoring mechanisms in place to ensure compliance in the areas affected by the scope limitation. • Early coordination with external auditor: We are collaborating with our external audit team to identify any classified contract audit selections earlier in the annual audit process. A proactive approach will allow Battelle extra time to engage clients for required approvals to either gain access to the classified information or obtain appropriate alternative audit evidence. In addition, any other related steps that can be completed in advance such as verifying auditor clearance types and levels will be performed early to help mitigate any delays. This corrective action requires the audit firm to provide auditors with the appropriate security clearances. • Engagement with regulatory agencies: We are in dialogue with impacted federal awarding agencies to explore options to provide necessary audit evidence. • Enhanced documentation: We are enhancing our audit support procedures to provide guidelines on how, within the bounds of regulatory restrictions, we can provide access to audit evidence for future audits. Overall Anticipated Implementation Date: December 31, 2025

Finding 2024-003: SEFA Preparation – Subrecipient vs. Subcontractor Determinations Name of Responsible Official: Nikolos Oakley, CFAO Anticipated Completion Date: 09/30/2025 Condition: Subcontractor amounts were improperly included in the Amounts Provided to Subrecipients column on the Schedule of Expenditures of Federal Awards (SEFA). Context: Management made improper subrecipient vs. subcontractor determinations, resulting in inaccurate SEFA preparation. This resulted in $2.6 million being removed from the Amounts Provided to Subrecipients column in the original SEFA provided to the auditors by management. Views of Responsible Officials and Planned Corrective Action: IntraHealth acknowledges the finding regarding the improper inclusion of subcontractor amounts in the Amounts Provided to Subrecipients column on the Schedule of Expenditures of Federal Awards (SEFA). We will improve our reporting and review processes to ensure subcontractor amounts are not incorporated under Amounts Provided to Subrecipients column in SEFA. Corrective Action: • Implement a more rigorous review process to ensure that only true subrecipients are included in the Amounts Provided to Subrecipients column of the SEFA. Subcontractor amounts will be reported separately as required. We will also improve training for the finance and grants management teams to ensure they fully understand the regulations. IntraHealth is committed to ensuring the accuracy of future SEFA reports and will complete the corrective actions by 09/30/2025. We will also continue to monitor the effectiveness of these changes to prevent future misclassifications.

2024-003 – Significant Deficiency – Internal Control Significant Deficiency in Internal Control: Management is responsible for preparing an accurate Schedule of Expenditures of Federal Awards (SEFA). Low-Income Home Energy Assistance expenditures were understated by $54,831 as federal LIAP and Assurance 16 funds were not included on the prepared SEFA. Insufficient internal controls over the preparation and review process for the SEFA to ensure all federal funds were included. Recommendation: The Organization should strengthen its review process to ensure that federal award program revenue reported in the statement of activities reconciles to the amounts reported on the SEFA. As part of this review, all required minimum elements should be traced to original source documentation, including award letters, grant reports, and trial balance profit and loss reports. Responsible Person for Corrective Action: Lindsay Mitchell, Director of Fiscal & Facilities Corrective Action to be Taken: The Finance Director has initiated a training process to ensure that all fiscal team members are equipped to review contracts, grants, and Memorandum of Understanding (MOUs). This includes verifying that all applicable Assistance Listing Numbers (ALNs) are properly identified and that related revenue is accurately tracked within the accounting system. Additionally, a new revenue code has been established to separately track Low-Income Home Energy Assistance Program (LIHEAP) funds from other federal revenues. This ensures accurate reporting and proper classification of federal awards on the Schedule of Expenditures of Federal Awards (SEFA). The anticipated completion date for this corrective action is 9/30/2025.

Finding 2024-002 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 10.555 National School Lunch Program cluster Name of Federal Agency: U.S. Department of Agriculture Compliance/Internal Control over Compliance: Auditee Responsibilities Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the total Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger. Cause: The District relied on individuals with insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have sufficient training or monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Expenditures of federal awards and not be detected and corrected. Because the Auditee’s SEFA was completed incorrectly, and not reconciled to the general ledger the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following: • SEFA was originally presented for auditors with incorrect information. • No reconciliation between federal expenditures reported on the GL and the SEFA was presented. • Recording of State vs Federal activities was not posted to the GL correctly, requiring adjustments during the audit. • Not all grants were recorded in separate and identifiable GL accounts. Repeat of a Prior-Year Finding: Yes Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. City’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Planned Implementation Date: October 1, 2025 Responsible Person: Director of Business Services, Myrtle Point School District No. 41

Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Auditee’s Corrective Action Plan: The city’s legacy financial system did not collect data required for SEFA. Agencies had to provide most details manually and work between spreadsheets and multiple systems to input and track receipt grant awards and spend on personnel, supplies and services and sub-recipient awards related to grants. The steps to address this legacy finding have been phased and include the technology implementation, staff training and additional oversight. As noted, the City implemented Workday, an Enterprise Resource Planning (ERP) system, across workstreams so that Financial Accounting, Grants, Procurement, Supplier Accounts, Banking, Payroll and Human Resources are all in one system. As with any ERP, an ongoing process of evaluation and updates are needed to continuously align workflow and business processes. This approach has led to continued improvement over the years as the grants management module is fully implemented in Workday. Since implementation, additional enhancements have been adopted and utilized with a robust workflow process for grant approval, grant budget tracking, and invoice scheduling. In addition to the technology adoption, an increase in citywide grants training and oversight has been implemented. The progress is detailed below: • FY 23 represented the first year in the new system. To compile the SEFA, the City used a hybrid approach to leverage Workday and Agency provided data. o There were some data accuracy challenges from data entry errors. To address those data entry challenges the award modification business process was improved post-implementation to add a GMO review and approval step of award modifications. o As of May 2024, all award modifications now require centralized GMO review to verify data accuracy. o Additional process changes in FY 23 included implementation of the requirement as part of the FY 24 budget preparation process that grant worktags must be created and budgeted for during the City’s annual budget process. The grant worktag creation process includes approvals at the agency program and fiscal levels, as well as at the Department of Finance level. • In FY24 further Award Module enhancements were adopted to provide key new data points in Workday. o Each grant award now includes information: Federal Assistance Listing Number (fna CFDA#), Passthrough Agencies & Passthrough Identifier. o Additionally, in FY 24, GMO, in collaboration with BAPS launched the Grants Workstream Training sessions. These monthly citywide virtual live trainings are on a variety of grant management related topics, averaging 60 attendees per session. Attendees are city agency grant managers and city agency fiscal staff. • In FY 24 and FY 25 the topics covered included: o FY 24 Grant Work tag Preparation o FY 24 SEFA Preparation o Grant Accounting Best Practices and Workday Billing o Award Set-up Best Practice & Potential Pitfalls o Extra Features in Workday (including reporting and how to set up award tasks and deadlines) o Subrecipient Monitoring Best Practices o Cost-reimbursable grant invoicing in Workday o FY 25 SEFA preparation o FY 26 Grant Work tag Preparation o Grant Management Roles and Responsibilities o Specific training on the SEFA, including information on understanding the importance of the SEFA, what information is included and how to review SEFA data, was conducted. Citywide training sessions were held in FY 24 and FY 25 to ensure that the reporting is understood by city agencies, with special emphasis on subrecipient payments being reported properly. The training schedule is ongoing and continuous. • To improve SEFA reporting data, in FY 25 there is an emphasis on subrecipient set up and spending to ensure that functionality is refined to improve uniformity in subrecipient set up. GMO, in conjunction with BAPS, the Bureau of Procurement and city agencies will work to refine subrecipient set up, spending and monitoring, including improved reporting. o GMO has hosted three subrecipient monitoring and management–related trainings since December 2024. Additionally, to improve subrecipient managing and monitoring, GMO modified the award setup business process in Workday to include verification of subaward status before final award setup approval. In FY 25, GMO provided training on how to setup subawards accurately in Workday. As discussed above, these trainings will be ongoing. • Additionally, GMO and the BBMR will collaborate on a subaward dashboard to monitor subrecipient spending data in real time. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City Completion Date: FY26 3rd Quarter- • Design and complete a grants management dashboard within Workday • Ongoing and continuous - GMO will continue to conduct trainings on SEFA reporting and subrecipient management and reporting.

Management attempted to contract with multiple accounting consultants for creating the SEFA but they were already at full capacity and were not available to assist with the creation of the report. When the relevant contract or grant award did not include the necessary information, SCEC management and program staff reached out to our contracting agencies to confirm whether federal funds were part of each award and to find out CFDA numbers and other contract information necessary to complete the form. Nevertheless, there were several errors that in the SEFA submitted to our auditors for review. For the two IRP and RMAP lending programs, the prior year balances were carried over into the FY 24 SEFA through a clerical error. The errors in item 11.037 and 11.419 are related to information we received from the contracting agency. In particular, 11.037 was listed under US Economic Development Administration according to the contracting agency and we were given the description of Economic Adjustment Assistance. The description for 11.419 was given to SCEC by the contracting agency as CDS – Congressionally Directed Spending. Finally, we provided two CFDA’s for the STEM Education award with the submission of the SEFA as we were waiting for confirmation from Program Managers about the correct CDFA numbers. The auditors were informed that we were waiting for these numbers when the SEFA was submitted. In FY24, SCEC had 29 different federal funding sources, from 14 different agencies. We are working to improve our capacity to report these awards without error before the review of our auditors.

Condition: The SEFA for the year ended June 30, 2024 was not accurately prepared, as it originally included federal expenditures that were not on the cash basis. Planned Corrective Action: The corrective actions implemented for capital grants will be expanded to include the operating grants. Contact person responsible for corrective action: Joseph Khouzami Anticipated Completion Date: March 1, 2025

Community Health Services will add a historical tracking mechanism for multi-year grants so that Assistance Lising numbers are tracked each year with explanations for changes. The tracking mechanism will be updated with contracts, contract amendments and purchase order releases. The tracking mechanism will feed into the annual Schedule of Expenditures of Federal Awards preparation spreadsheet that is provided to Yavapai County Finance.

Management will review and update processes and procedures over reporting and additional training will be provided as needed to prevent future findings.

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

2024-003 – Material Weakness – Internal Control Material Weakness in Internal Control: The following errors were noted and corrected as a result of auditing procedures on the SEFA: • CRA program federal expenditures (CFDA #14.228) were understated by $23,893. • ACL Independent Living State Grants federal expenditures (CFDA #93.369) were overstated by $21,856 due to errors in SEFA preparation. • Several presentational errors including incorrect identifying numbers listed, incorrect award terms listed, and incorrect CFDA #’s listed for multiple awards. Recommendation: Management should continue to seek additional training for the fiscal department on preparation of the SEFA and reporting standards. In addition, review processes over the SEFA and supporting reports should be strengthened. Both the preparer and reviewer should have a clear understanding of the required minimum elements and instructions. As part of the review, all required minimum elements should be vouched to original source documents including copies of awards, grant reporting, and the trial balance profit and loss reports. Steps should be taken to prevent further adjustment of supporting profit and loss reports once reconciled without the express review and approval of the Fiscal Director. Review of the standards for supporting grant reports should be strengthened to prevent errors in reporting leading to errors on the SEFA. Any inconsistencies should be resolved before beginning the audit. Management has taken steps to identify and seek training in areas they have identified as needing improvement. Responsible Person for Corrective Action: Thomas Newman, Executive Director Corrective Action to be Taken: Management acknowledges the audit findings and the material weakness related to the preparation of the Schedule of Expenditures of Federal Awards (SEFA). The errors identified stemmed from insufficient internal controls over the preparation and review process. Additionally, there were inconsistencies in how the SEFA was prepared in previous years, compounded by a quick turnover to a new controller at year-end, which disrupted continuity and contributed to the lack of clear guidance in the SEFA preparation process. To address these challenges, management has implemented immediate corrective actions, including enhanced training for all staff involved in the SEFA preparation to ensure a thorough understanding of federal reporting standards and the required minimum elements. Furthermore, all SEFA components will be reconciled with original source documents, such as grant awards and trial balances, prior to submission for audit. Management believes that, with the new internal control measures and training in place, these errors are not expected to occur in future years. The anticipated completion date for this corrective action is 6/30/2025.

Condition: Controls in place were not adequate to ensure the schedule of federal expenditures was complete and accurate. Planned Corrective Action: Management fully understands the importance of internal controls to ensure the schedule of federal expenditures is complete and accurate. The Grants Department will amend its current written processes regarding award establishment to include requiring documentation indicating an award is federal funds prior to establishing the project in Infor CloudSuite Financials & Supply Management (Accounting software). Additionally, the Grants Department will routinely audit the database the department utilizes to record awards to ensure the field to note federal awards is properly updated. Furthermore, the SEFA will be reviewed with documented sign-off by each member of the Grants Team prior to submission. Contact person responsible for corrective action: Stephanie Cihon Anticipated Completion Date: October 31, 2025

The Board of County Commissioners, with the cooperation of all elected officials and officers responsible for the receipt or expenditure of federal funds, will evaluate the processes and procedures currently in place to ensure the accuracy of SEFA reporting and detect potential inaccuracies and/or misstatements.

2023-02 Expenditures of Federal Awards Corrective Action Plan: Develop and implement procedures to maintain adequate accounting records that accurately track expenditures by individual Federal programs, ensuring compliance with reporting requirements and transparency in fund utilization. 1. Immediate Assessment: Conduct a comprehensive assessment of current accounting practices and records to identify deficiencies in tracking expenditures by Federal programs. Determine the scope and extent of inaccuracies or gaps in documentation. 2. Engage Accounting Expertise: Engage a third-party CPA firm experienced in governmental accounting and Federal grant compliance to assist in resolving the issue. 3. Review Federal Program Requirements: Review the requirements of each Federal program under which funds are received. Identify specific reporting and expenditure tracking requirements mandated by each program. 4. Develop Chart of Accounts: Develop or revise a detailed chart of accounts that clearly distinguishes expenditures by each Federal program. Assign unique codes or identifiers to transactions associated with each program. 5. Implement Segregation of Expenditures: Implement procedures to segregate expenditures by Federal program at the time of recording. Ensure all transactions are allocated accurately to the appropriate program based on the chart of accounts. 6. Document Expenditure Allocation: Document the allocation of expenditures to specific Federal programs clearly and comprehensively. Maintain supporting documentation such as invoices, receipts, and payroll records that substantiate the allocation. 7. Training and Capacity Building: Conduct training sessions for accounting staff involved in recording and reporting expenditures. Train them on the new procedures, chart of accounts, and the importance of accurately tracking expenditures by Federal program. 8. Regular Reconciliation and Reporting: Implement a process for regular reconciliation of expenditures with Federal program requirements. Ensure reconciliation is performed monthly or quarterly to identify discrepancies promptly. 9. Internal Controls and Monitoring: Strengthen internal controls to prevent future inaccuracies in expenditure tracking. Assign responsibility for oversight and monitoring of compliance with the new procedures. Timeline for Implementation: Ongoing: Maintain vigilance over compliance and adjust as needed. Conclusion: By implementing this corrective action plan, we aim to establish robust accounting practices that accurately track expenditures by individual Federal programs. This will ensure compliance with reporting requirements, enhance transparency in fund utilization, and mitigate risks associated with inaccurate financial reporting. This plan outlines our commitment to addressing the current deficiencies and establishing a sustainable framework for future operations. Responsible Party: Kimberley Chaffin, Executive Director Date of Implementation: October 1, 2023

Finding Number: 2023-007 Condition: Controls in place were not adequate to ensure the schedule of federal expenditures was complete and accurate. Planned Corrective Action: Reports in Workday along with new reconciliation workpapers will be utilized to ensure a complete and accurate SEFA in FY2025. Contact person responsible for corrective action: Laura Randall Anticipated Completion Date: 06/30/2025

COVID-1 9 Coronavirus State and Local Fiscal Recovery Funds — Assistance Listing No. 21 .027 Recommendation: We recommend the District design controls to ensure an adequate review process over the invoices recorded and presented on the schedule of expenditures of federal awards to determine compliance with the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District’s policies will be updated and approved if needed to conform to federal guidance. Name(s) of the contact person(s) responsible for corrective action: Ron McEachern, General Manager or Delia Stoor, Accounting Manger Planned completion date for corrective action plan: September 30, 2024