Corrective Action Plans

The Organization is aware that the required date of the SEFA follows the Organization's calendar year and does not align with the Government fiscal year. The SEFA has been prepared as of December 31, 2023.

Views of Responsible Officials and Planned Corrective Actions: The Organization will prepare a current Scheduel of Expenditures of Federal Awards, listing awards by federal agency, total federal awards expended, name of pass-through entity, assistance listing number, and total amount provided to subrecipients. Monique Johnson, Executive Director of Allen County Drug & Alcohol Consortium, is responsible for this corrective action. The anticipated completion date is April 15, 2025.

Condition: The schedule of expenditures of federal awards (SEFA) was not accurate. Planned Corrective Action: The City will review its process for identifying and communicating Federal Grant expenditures to its auditors. Contact person responsible for corrective action: Robert McMahon, City Administrator Anticipated Completion Date: 09/30/2025

Finding 2023-004 - Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Management (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education 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: 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 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. • Inadequate 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 SEFAs. Planned Implementation Date: November 1, 2024 Responsible Person: District Business Manager

The Organization’s Accounting Department, under the direction of the Chief Executive Officer, Connie Franks, will ensure that there’s proactive communication, dedicated resource allocation, and regular status checks on the deadline. He should ensure everyone involved understands the deadlines and responsibilities to avoid any delays. Completion of the referenced corrective action will be implemented by January 2025.

Views of Responsible Officials: Effective 10/01/2024 HIPS have structured its chart of accounts in a way to clearly identify Federal Revenue separately and distinctively from other revenue (local funds and private foundations funds). Finance Manager has been tasked with SEFA preparations and reconciliations against TB revenue prior submitting SEFA for audit. Policies have changed to clarify with funders the source of federal vs non federal funds at the grant acceptance stage so that all grants are properly classified within the chart of accounts, easing reporting.

The Board of Directors hired Gorman Management Company (GMC) on March 1, 2024, to operate the property, Ardmore Village. GMC has extensive experience in the on-site and financial management of properties like Ardmore Village. Specifically, GMC has procedures in place to maintain compliance with the regulations applicable to the Section 8/202 program and the FHA Section 223f program. GMC is well versed with CFR §200.512 (single audit data collection form), HUD Handbooks 4350.3, 4370.2 and 4381.5. GMC manages over 40 properties that have similar reporting and auditing requirements. All of the issues related to these findings will cure through GM C's policies and procedures.

Due to no fault of Southern Workforce Board, Inc., and circumstances beyond the previous CAP's control, the audit report for the period ending 6/30/2023 was not completed as required. Upon notification of prior audit firm closing, Southern Workforce Board, Inc. performed an immediate procurement by soliciting a Request for Proposal to 13 audit firms. Upon completion of the procurement, Michael Green, CPA was selected to perform the 6/30/2023 audit as soon as their schedule would allow. Upon successful completions of 6/30/2023 audit report, the audit process for the period ending 6/30/2024 will proceed on time. Southern Workforce Board, Inc. will ensure in the future that the audit firm selected will be able to perform the planned audits in a timely manner in the future.

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

Views of Responsible Officials and Planned Corrective Actions: USTTI will prepare its SEFA on a quarterly basis, and we will reconcile the expenses reported on the SEFA with general ledger amounts. We will also review the chart of accounts coding to be sure all eligible expenses are clearly identified.

Finding 2023-002 - 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 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. 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 SEFAs. Planned Implementation Date: October 1, 2024 Responsible Person: Director of Business Services, Yamhill County School District No. 8

Finding 2023-002 - 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 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. 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 SEFAs. Planned Implementation Date: October 1, 2024 Responsible Person: Director of Business Services, Yamhill County School District No. 8

Finding 2023-002 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 66.468 Drinking Water State Revolving Fund Name of Federal Agency: Environmental Protection Agency 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 not presented for audit. The City was unaware that funds borrowed through Business Oregon were federally sourced. Cause: The loan documents that were provided to the City were modified and date back several years. No individual, including those employed by the City, project managers engaged by the City, and pass-through managers were apparently aware that the loan proceeds were from federal sources. Consequently, no internal controls were designed or implemented regarding accounting for or preparation of the SEFA. The City did not provide a reconciliation of the expenditures of federal awards with amounts reported on the City’s general ledger. 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: • No SEFA was originally presented for auditors. • No reconciliation between federal expenditures reported on the GL and the SEFA was presented. Repeat of a Prior-Year Finding: Yes 2022-002 Recommendation: We recommend that the City 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 City should provide appropriate training to staff who are assigned to prepare and review the SEFA. City’s Response: The City acknowledges the deficiencies. Corrective Action Plan: The City will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Planned Implementation Date: October 1, 2024 Responsible Person: City Manager

Highway Planning and Construction - Assistance Listing No. 20.205; Passed through Pennsylvania Department of Transportation, Grant Period - Year Ended December 31, 2023. Corrective Action, Person Responsible, and Anticipated Completion Date: See deficiency 2023-002. SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Condition: Although management prepared a draft of the SEFA, it was incomplete and contained inaccurate information. Corrective Action: We will correct the process of preparing the draft SEFA for next year’s audit and now know the proper way to complete it. Persons Responsible: Bill Burdett, Township Manager Anticipated Completion Date: Beginning January 1, 2025

Views of Responsible Officials and Action Taken: FCE agrees with the finding and has implemented a corrective action plan that requires the accounting and reporting to be performed by an outside CPA firm with expertise in accrual basis accounting, cost allocation and grant accounting concepts. During FCE’s monthly financial review, we examine each grant/class level in QB, ensuring that expenses are properly charged to the correct grant in the correct period of performance.

Management will continue to ensure that the Schedule of Expenditures of Federal Awards is complete. Inspiration did prepare the 2023 SEFA, and it was delivered to the auditors immediately in April 2024 at the beginning of our audit.

Views of Responsible Officials: Management concurs with the recommendation. See the corrective action plan.

Recommendation: Procedures should be implemented to create a materially accurate Schedule of Expenditures of Federal and State award financial statement, which should include ascertaining between loan and grant expenditures, and understanding the process for reporting loan balances on the SEFSA. Views of Responsible Officials and Planned Corrective Actions: In order to create a materially accurate Schedule of Expenditures of Federal and State award financial statement, the Authority will establish procedures to ascertain loan and grant expenditures, as well as taking into account the Uniform Guidance requirement for presenting loan balances on the SEFSA.

Views of Responsible Officials and Planned Corrective Actions: In 2024 during the SEFA analysis and in discussion with auditors it was determined that a USG-funded contract, attached to a grant, was incorrectly left off the SEFA. This was amended as soon as the mistake was noted. AL is required to submit financial statements to a non-US Government donor by June of each calendar year. To comply with this grant stipulation AL starts pre-audit document checks in early January and full fieldwork in mid-February following our financial year close on December 31. While the majority of our annual financial statement is complete by mid-January we have one outstanding USG grant which only reports at the end of February for an end-of-January quarter close. As a result, we are only able to provide a preliminary SEFA when the auditors request the first document checks in January. For FY 2025 we will request that the auditors start with a basic audit of Financial Statements and then submit the SEFA once all the quarterly reports have been submitted to USG. Anticipated Completion Date: Already decided for FY 2024 audit. Responsible Officials: Chief Innovation and Operations Officer and Finance Manager.

Finding: 2023-002 - Deficiency in Internal Controls Over SEFA Preparation and Material Adjustments Auditor Description of Condition and Effect: During the course of our federal single audit, it was observed that the Schedule of Expenditures of Federal Awards (“SEFA”) was prepared by the auditor instead of the Township. Although the Township reviewed and accepted the SEFA, the preparation was not independently performed by the Township. Additionally, the auditor proposed and the Township accepted material proposed audit adjusting journal entries that impacted the federal awards reported on the SEFA. Reliance on the auditor to prepare the SEFA and to propose material audit adjustments indicates a deficiency in the Township’s internal controls over financial reporting. This situation increases the risk that the SEFA may not be accurately or completely prepared if the auditor does not perform these tasks. Additionally, this reliance could potentially result in a significant deficiency or material weakness in the Township’s internal control over financial reporting. Auditor Recommendation: To correct this finding in the future, we recommend that the Township take the following actions: • Provide additional training to current staff on the requirements and preparation of the SEFA to build the necessary skills and knowledge internally. • Develop detailed procedures and guidelines for preparing the SEFA, including checklists and timelines, to assist staff in the accurate preparation of this schedule. • Establish a robust review and approval process where a knowledgeable individual within the organization reviews the SEFA for accuracy and completeness before submission. • Enhance internal controls over financial reporting to ensure that material audit adjustments are minimized and that the financial statements and SEFA are prepared accurately and independently. Corrective Action: We agree with the finding and will implement the following steps to address the issue: • Provide additional training to staff on the requirements and preparation of the SEFA. • Develop and document detailed procedures for SEFA preparation. • Establish a review and approval process for the SEFA. • Improve internal controls over financial reporting to reduce reliance on auditors for material adjustments. Responsible Person: Joshua Sutton, Clerk Anticipated Completion Date: December 31, 2024

Views of Responsible Officials: NDRN’s finance staff turnover, coupled with the staff’s lack of formal training with NDRN’s accounting system, resulted in a lack of knowledge on how to prepare the actual schedule. However, it did not affect the staff’s ability to properly identify and categorize expenditures for invoicing purposes to the Federal government. Moving forward, NDRN finance fiscal staff will conduct regular internal SEFA reporting as part of the monthly reporting indicated in Finding 2023-002 above.

We provided the NOAA Award label and CFDA# as soon as we were able to obtain it from the program manager. We corrected the CFDA# for the Highway Planning and Construction as soon as we were able to obtain them from the MEDOT. The contract documents did not include that information. We reported the revenue for the State and Local Recovery Funds in the award column. We now know to put the unspent revenue in deferred. We did not know the $310,000 was Federal Funds, we will know for the future. We will be sure to include Covid-19 labels and all the award dates in the future. We will look for training to prepare a SEFA document, it will be on our professional development list in this year.

The Department of Behavioral Health (DBH) agrees with the findings. DBH will work to ensure that the time management/payroll system accurately shows where an employee’s cost is being charged. An employee was not charged to the grant even though they were noted as key personnel (100% to be charged to the grant). DBH will work with the OCFO to make sure Peoplesoft can assign attributes that can be reported to show that they were charged to the grant. In addition, DBH will review with program staff the process to have a “Letter of Temporary Detail” noting when an employee is assigned to work on the grant so that their time can be charged to the grant. DBH will have the grants management system configured so that the PDF of the Letter of Temporary Detail can be attached to the grant file. Contact - PeopleSoft Set-up: Adran Reid, DBH Agency Fiscal Officer and Michael Neff, DBH Chief Operating Officer, Letter of Temporary Detail: Sharon Hunt, State Opioid Treatment Authority , Grants Management System Configuration: Michael Neff, DBH Chief Operating Officer Estimated Completion Date - Grants Management System, Uploading Documents to Grant File: January 1, 2025 See Corrective Action Plan for chart/table

Responsible Person for Corrective Action: Lindsay Mitchell, Director of Fiscal & Facilities. Corrective Action to be Taken: All Fiscal team members will be attending various training courses around GAAP reporting guidelines. Training will be through the CPE website, also any other sources management can engage in through WiPFLi or CAPLAW. Reports will all be submitted after a review and approval from the Director of Fiscal and Facilities. Policies and procedures will be updated with the assistance of a fiscal consultant to ensure that these policies and procedures are followed through. Back up will be required for every entry and entry and backup will be scanned to a permanent document folder so it can be referenced so if there are any changes made there will be an audit trail for follow up. These new policies and procedures will be initialed by the fiscal team for acknowledgement of changes, and it will be part of the performance evaluation process. The anticipated completion date for this corrective action is September 30, 2024.

We concur with the issue, and accept the recommendation provided by the auditor. We will strengthen the system of internal controls for identifying federal awards and expenditures, including TIFIA funds and the associated reporting requirements which are subject to single audit inclusion.