Corrective Action Plans

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.

Program: AL 84.287 – Twenty-First Century Community Learning Centers – Subrecipient Monitoring Corrective Action Plan: The NDE was provided written guidance from the U.S. Department of Education (USED) regarding source documentation required for the NDE’s review of preliminary documentation required to make payment whereas this effort is not associated with the NDE’s Grant Compliance Section performing the fiscal monitoring activities applying the required pass-through activities contained within 2 CFR 200.332. To make payment, the USED guidance states, “Uniform Guidance does not require the NDE to obtain specific source documentation from its subrecipient prior to making payments and the NDE’s Grant Guidance states that for certain reimbursement requests, such as credit card purchases, travel expenses, and personal reimbursements, subrecipient are always required to submit supporting documentation. For other expenditures, including personnel costs, and time and effort certification, supporting documents need to be retained by the subrecipient for at least three years and must be available for auditing and monitoring purposes”. For the reimbursement request tested to make payment, additional source documentation was acquired from the subrecipient upon the APA’s request and submitted for review on March 1, 2024. Contact: Jen Utemark, Administrator, Office of Budget & Grants Management Anticipated Completion Date: March 1, 2024

2023-003 Internal Control Over Financial Reporting Management Response: Management concurs with the recommendation above. Management will ensure policies and procedures over financial reporting which capture all required adjustments necessary to fairly present consolidated financial statements. Since their inception, the Academies had outsourced its accounting function to an outside company. Management has now moved that function in-house and hired a full-time finance director to oversee all accounting functions. The finance director will be responsible for monitoring all financial policies and procedures. Responsible Person: Preston Castille, Jr., Helix Community Schools, President Anticipated Remediation Date: Fiscal year ended June 30, 2024

Condition: The SEFA for the year ended June 30, 2023 was not accurately prepared, as it originally included federal expenditures that were not on the cash basis. Planned Corrective Action: The corrective action has been implemented to revise internal procedures to prepare the SEFA on a cash basis for future fiscal years. This includes the creation of a reconciliation schedule to the financial statements which are prepared on an accrual basis. Contact person responsible for corrective action: Jeremy Baker, Director of Finance Anticipated Completion Date: 1/15/2024

Condition: The SEFA for the year ended June 30, 2023 was not accurately prepared as it originally included expenditures that were improperly excluded from the SEFA for the year ended June 30, 2022. Planned Corrective Action: Additional Supervisory Review of Expenditures Contact person responsible for corrective action: Deanna Korth Anticipated Completion Date: 09/30/2023

Finding: 2023-001: SEFA – Material Weakness The SEFA prepared by management included an incorrect Assistance Listing (AL) number for one grant. Federal grant AL NO. 20.513 Enhanced Mobility of Seniors and Individuals with Disabilities was incorrectly identified as AL No 20.507 Mobility Management. While both grants are from the Federal Transit Agency, they fall under different clusters in the Office of Management and Budget’s Compliance Supplement and thus have different audit requirements. Auditor Recommendation: We recommend management verify with the grantor the AL number of the grant. This can be done by obtaining the information from grant documents, or direct communication with the grantor. We further recommend the SEFA be reviewed for accuracy by an individual not included in the SEFA preparation process. Review should be notate with initials and date. Contact Person Responsible for the Corrective Action: Lisa Cappellari, Chief Financial Officer, LisaC@paratransit.org Management Response and Corrective Action Plan: After the end of Fiscal Year 23-24 on 6/30/2024, Jody Wadley, Finance and Grants Manager, will start the preparation of the FY24 SEFA and make sure all components are correct. Lisa Cappellari, Chief Financial Officer, will review the SEFA for accuracy, checking grant documents and directly contacting the granting agency if necessary. Once each component of the SEFA is thoroughly reviewed, Lisa Cappellari will initial and date.

Failure to Inform Auditors of the Need for A Single Audit Recommendation: We recommend that Counseling Clinic updates and maintains a SEFA or other tracking protocol of total expenditures on a federal level throughout the year. Action Taken: Management is now properly tracking grant expenditures and can accurately state quantities of grant expenditures.

UCCAC has retained services of an outside service provider who will ensure schedule of expenditures of federal awards is reconciled to general ledger and includes all federal and pass-through federal grants awarded. The schedule will also be reviewed by program director for accuracy and completeness. Responsible Person: Controller and program directors Timeline: 30-60 days

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.

Finding 2022-004 Activites Allowed or unallowed and Allowable Costs/Cost Principles ALN 84.425 Elementary and Secondary School Emergency Fund Program United States Department of Education Passed through State of Louisiana Department of Education 2022 Funding Status: Resolved Planned Corrective Action: The Interim Director of Finance has designed and implemented better policies and procedures and maintain all documentation for federal reimbursement requests. Person(s) Responsibile: Odie Johnson, Interim Director of Finance Anticipated Completion Date: June 30, 2025