Corrective Action Plans

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.

SEFA Preparation Recommendation: We recommend that management design and implement effective internal controls over compliance related to SEFA preparation, including assigning responsibility to personnel with appropriate training in federal award requirements. Management should also implement a documented review process, performed by a knowledgeable individual, to ensure the SEFA is complete, accurate, and compliant with Uniform Guidance prior to submission for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reached out to HUD Granter, Third Party Accounting Firm and in 2023. Followed up with a briefing from Auditor in 2025 for this audit. Name(s) of the contact person(s) responsible for corrective action: Sharon Maggard Planned completion date for corrective action plan: Completed

2023-009-Reconciliation of accounts Suggested Action: Ensure proper month end close, including reconciliation of major accounts. Responsible Official: Assistant Controller Completion Date: 4/30/2026

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

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