Corrective Action Plans

2022-034 Oregon Housing and Community Services Ensure review of subrecipient requests for funds verifies immediate cash needs are supported Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Families Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program 93.568 Low-Income Home Energy Assistance Program (COVID-19) Federal Award Numbers and Years: 2001ORE5C3, 2020 (COVID-19); 2102ORLIEA, 2021; 2102ORE5C6, 2021 (COVID-19); 2202ORLIEA, 2022 Compliance Requirement: Cash Management Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR ? 200.305(b), (b)(1); 2 CFR ? 200.508 Federal regulations require that auditees maintain documentation as needed for the performance of audit procedures related to the Single Audit. Additionally, regulations require payment advances should be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the subrecipient for carrying out the approved program. We reviewed 60 sample cash draws and were unable to obtain adequate supporting documentation for 4 subrecipient requests for reimbursement/advances demonstrating they were appropriate and for immediate cash needs. We also identified an advance payment for which there was not an adequate explanation indicating why an advance was needed. These 5 exceptions totaled $124,304 in expenditures. Department management cited a breakdown in control process and communicated their intention to train relevant staff to ensure adequate support is obtained. Without adequate verification of cash needs, the department could be sending funds to subrecipients that are not for a reimbursement of expenditures or immediate cash needs. We recommend department management strengthen internal controls to ensure support for subrecipient requests for funds adequately documents they are appropriate and for immediate cash needs. MANAGEMENT RESPONSE: We agree with this recommendation. Strong internal controls exist and costs were eventually substantiated and allowable, however OHCS had significant staff turnover and newer staff processing these advance requests did not gather the level of detail required by OHCS to substantiate draws in a timely manner. Training has been completed for FY23. Anticipated Completion Date: June 30, 2023 Contact: Beth Brown, Accounting Manager

SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (SEFA) Workforce West Virginia (WWV) Assistance Listing Number 17.225, COVID-19 17.225 Fiscal and Administrative Management had a meeting in January 2023 to discuss SEFA preparation processes to ensure all resources needed for accurate SEFA reporting are available.

Views of Responsible Officials: As noted previously, management notes that expenditures of ongoing state and federal programs are internally reviewed and reconciled monthly, and required reporting to funding entities has been completed and submitted consistent with relevant reporting deadlines. However, transitions in systems and personnel as well as several large programs unique to the recent pandemic period challenged management to gather these details in the SEFA format early in the audit. In addition to continued monthly reconciliations, management will establish an additional more formal reconciliation quarterly during fiscal year 2023, and the more formalized grants reporting infrastructure we?re developing as well as upcoming additional staffing in finance and development will also strengthen our capacity for the timely preparations of the SEFA going forward.

FINDING ? FEDERAL AWARD PROGRAMS AUDIT 2022-002 ? 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: ? All funds for WIC were listed under agreement CD4-21-4655B. A significant amount of these funds was provided under agreement CD4-22-4655. ? TANF expenditures were understated by $12,215. ? TANF was incorrectly identified as part of a cluster. ? ERA funds were reported as being funded through US DHHS. ? Head Start was not identified as being part of a cluster. ? CACFP expenditures were understated by $35,656. ? CACFP expenditures were listed as being passed though ME DHHS. This agreement is through ME DOE (education). ? WIC expenditures were understated by $179,782. ? Several COVID-19 programs did not include the appropriate prefix. Recommendation: Management should seek additional training for the fiscal department on preparation of the SEFA standards. In addition, review processes over the SEFA should be strengthened. Both the preparer and reviewer should have a clear understanding of the required minimum elements. As part of the review, all required minimum elements should be vouched to original source documents including copies of awards, reporting, and the trial balance. Any inconsistencies should be resolved before beginning the audit. Management's records should require the identification of the preparer and reviewer as well as the dates each of those tasks were performed. Management could consider requiring a preparation and review process checklist as required documentation for the Organization's reporting records to help ensure key processes are performed and reviewed. Responsible Person for Corrective Action: Lindsay Mitchell, Director of Fiscal & Facilities Corrective Action to be Taken: To enroll new accounting team members in a GAAP training webinar through the CPE website. If there are no webinars provided that we can schedule, Management will look at Wipfli's training webinars to enroll in as a member. More professional development will be provided. There will be a checks and balance review of any schedule or report submitted to funding source and auditors. With initials of reviewer on the back up. Clear understanding of grant requirements and audit requirements will be the departments' goal. The anticipated completion date for this corrective action is September 30, 2023.

Finding Number: 2022-005 Condition: The SEFA required adjustments related to expenditures that were both improperly included and excluded, resulting in revisions to correct the SEFA. Planned Corrective Action: Proper accrual accounting will be followed with regard to reporting SEFA expenditures, with period recognition more closely monitored. Contact person responsible for corrective action: Matt Zeilstra ? Financial Controller Anticipated Completion Date: 07/27/2023

Recommendation: Procedures should be implemented to create a materially accurate schedule of expenditures of federal award financial statement, which should include ascertaining between loan and grant expenditures, and understanding the process for reporting loan balances on the SEFA. Views of Responsible Officials and Planned Corrective Actions: In order to create a materially accurate schedule of expenditures of federal 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 SEFA.

ACT FOR ALEXANDRIA MANAGEMENT CORRECTIVE ACTION PLAN For the Year Ended December 31, 2022 TO: MARCUM LLP 1899 L Street NW, Suite 850 Washington, DC 20036 Finding 2022-001: Revenue Recognition ? Conditional Contributions; Finding 2022-002: SEFA Preparation Condition and Context: During our audit, we identified a conditional contribution that ACT had recorded as revenue upon receipt of the advanced funds and before the applicable barrier to recognition had been satisfied. In addition, the full amount of advanced funds was presented on the schedule of expenditures of federal awards (SEFA). As a result, net assets without donor restrictions were overstated in the financial statements and expenditures were overstated on the SEFA. Recommendation: We recommend management review policies and procedures over contributions received to ensure timely and effective review for any barriers to recognition and over preparation of the SEFA to ensure completeness and accuracy of the SEFA. Views of Responsible Officials and Planned Corrective Action: ACT agrees with the finding and the auditors? recommendation. One ACT?s fiscal sponsorship funds received advance payments of conditional awards. This is a rare circumstance. As a result, there was a learning curve on our part related to when fiscal sponsorship fund revenue should be recognized related to conditional award advances. Going forward, we will ensure that fiscal sponsorship fund conditional awards are reported as revenue and expense only once barriers are fully satisfied. This will allow for accurate reporting for both financial statement and SEFA purposes. For further discussion, please contact Heather Peeler, President and CEO at heather.peeler@actforalexandria.org, 703-739-7778. Heather Peeler President and CEO

CORRECTIVE ACTION PLAN July 14, 2023 U.S. Department of Health and Human Services Crisis and Counseling Centers, Inc. respectfully submits the following corrective action plan of the year ended June 30, 2022. Name and address of independent public accounting firm: One River CPAs 46 FirstPark Drive, Oakland, ME 04963 FINDING ? FINANCIAL STATEMENT AUDIT None FINDING ? FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Health and Human Services 2022-001 Noncompliance and Material Weakness in Internal Control over Compliance: Requests required to complete the audit were not submitted within sufficient time to allow for audit and reporting prior to the deadline. The following errors and missing required elements were noted and corrected as a result of auditing procedures on the SEFA: ? Expenditures under agreement MHC-22-322B under CFDA 93.665 were not included. ? Expenditures under agreement CBH-22-1003A under CFDA 93.958 were not included. ? Expenditures under Period 4 of Provider Relief Funds (PRF) were included in error. ? There were two instances of COVID-19 programs that did not include the appropriate prefix. ? Subtotals were not included for the following CFDA numbers 93.958; 93.104; and 93.243. ? Expenditures under agreement CDM-21-4462A under CFDA 93.243 were shown included under CFDA 93.959 in error. Recommendations: Management should seek additional training for the fiscal department on preparation of the SEFA standards. In addition, review processes over the SEFA should be strengthened. Both the preparer and reviewer should have a clear understanding of the required minimum elements. As part of the review, all required minimum elements should be vouched to original source documents including copies of awards, reporting, and the trial balance. Any inconsistencies should be resolved before beginning the audit. The compliance supplement should be reviewed for reporting guidance on new Federal programs. Responsible Person for Corrective Action: Timothy D. Floyd, Chief Financial Officer Management will seek additional training in preparation of the SEFA and the applicable standards. The anticipated completion date for this corrective action is December 31, 2023. If the U.S. Department of Health and Human Services has questions regarding this plan, please contact Timothy D. Floyd, Chief Financial Officer at 207-626-3448 or tfloyd@crisisandcounseling.org. Sincerely, Timothy D. Floyd, Chief Financial Officer

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER FINANCIAL REPORTING: Finding 2022-002 - Schedule of Expenditures of Federal - Awards CFDA Title and Number: 93.600 - Head Start and Early Head Start - Federal Agency: Department of Health and Human Services - Internal Control over Financial Reporting and Compliance: Auditee Responsibilities - Organization's Response 2022 and Corrective Action Plan: The Organization concurs with the recommendation and had already released updated financial policies and procedures as of September 2022. Further revisions will be made in 2023 and include specific instructions for particular grants including federal and state. Additional training is needed for all levels of the fiscal team as well as for program managers to better understand the fiscal requirements of each grant. It is acknowledged that the fiscal team must be expanded and restructured and we have already started the process of recruiting a new CFO. The new CFO will be expected to consistently maintain a comprehensive matrix including all grant requirements. During this time we are seeking a consultant to help us establish better processes, controls and systems and assist until a permanent CFO is established. Other consultants may be obtained for supportive services as needed/recommended in the future. All applicable staff (fiscal and management) will be trained regarding procedures to review grant expenditures for compliance with terms of the grant, and to maintain sufficient records that reconcile to amounts reported as grant expenditures. Further, a new accounting system, Blackbaud, with enhanced cost recording, reporting and budgeting capabilities, has been approved by our Board of Directors to be implemented at the start of the next fiscal year. This implementation includes extensive training for fiscal and program staff. The fiscal committee and the Board will receive monthly updates on the progress being made in these areas. (Current responsible party: Renee Hungerford, Executive Director/CEO) Auditor's Response to Organization's Response 2022 and Corrective Plan: We have noted the Organization's response which appears sufficient and appropriate in the circumstances, and we further note the certain referenced steps already taken in discussion with management.

Michael Fields Agricultural Institute will work with O'Leary & Anick for implementing correct process and record proper cost reports, financial closing procedures, and the SEFA. Contact Person: Shannah Schmitt, MFAI and Kevin O'Leary, O'Leary & Anick. Anticipated date of Completion: December 2023

Finding Number: 2022-002 Condition: Internal controls were not adequate to ensure the Schedule of Expenditures of Federal Awards (SEFA) was complete. Planned Corrective Action: DESC has replaced and expanded the number of members on the fiscal/accounting team, including an experienced Accounting Manager and Senior Accountant, and implemented a training program to ensure each fiscal/accounting team member is aware of and understands their duties and responsibilities as it relates to the reconciliation of the grants in their portfolio, which is the basis for the creation of the SEFA. Additionally, audit procedures are being put in place to ensure that the SEFA is created and reviewed, at minimum, on a semi-annual basis. Contact person responsible for corrective action: Angela Smith, Accounting Manager Anticipated Completion Date: 06/30/2023

Finding 2022-006 Programs: All 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 reported. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City. Completion Date: June 2024

Action Taken/to be Taken: Accounting staff will be responsible for the preparation of the SEFA in the future, this had been done by operations staff in the past. Appropriate training will be sought as necessary. An outside accountant will be consulted for guidance and recommendations on the 2023 SEFA prior to submission.

Responsible Official's Response: The NEWDB fiscal team will undergo supplementary training on MIP reporting procedures, which is currently in the scheduling phase and will occur within this quarter. Furthermore, as part of their ongoing professional development, the fiscal team will also engage in additional training related to governmental and fund accounting processes. Corrective Action Planned: The NEWDB Fiscal Team will undergo supplementary training on MIP reporting procedures.

We will adopt procedures and implement to ensure accurate reporting of expenditures on the SEFA and to ensure compliance with federal requirements.

The Board of County Commissioners, with the cooperation and participation of all elected officials, rev iews, develops and implements policies and procedures to create a strong internal control environment. Addit ionally, the Board of County Commissioners conducts meetings with all elected officials and officers responsible for the receipt and/or expenditure of county funds. These meetings address fiscal matters, including but not limited to, pol icy d iscussions and implementation, financial reports, budget oversight, SEF A reporting, and legal compliance. Policies and procedures, combined with fiscal oversight meetings, are intended to: I) prevent or detect material misstatements in the financial statements; 2) prevent or detect fraud within the county; 3) increase communication between the Board of County Commiss ioners and those elected officials and officers respons ible for the receipt and/or expenditure of public funds; 4) provide oversight over the fiscal concerns of the county; 5) identify and address risks related to financial reporting; 6) ensure the accuracy of Rogers County's financial statements, Estimate of Needs, the Schedule of Federal Awards ("SEFA"); and 7) ensure compliance with all applicable federal and state laws, regulations, and/or codes. The Board of County Commissioners, with the cooperation of all elected officials and officers responsible for the receipt or expenditure of county funds, will evaluate the processes and procedures currently in place to detect and identify material misstatements in Rogers County's financial statements, detect fraud, and identify and address risks related to Rogers County's financial processes and procedures will be implemented to identify fraud, detect material misstatements in the financial statements, and address risks related to financial reporting.

Through the assistance of the Oklahoma State Auditors and Inspectors Office, we have received appropriate instruction on how they wish the appearance of the SEF A to be. We believe this issue to be resolved and will be reported as instructed from this point forward.

Finding 2021-003: Reconciliation of Accounts Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1524963 (11/1/2015 – 9/30/2021), 1812860 (9/1/2018 – 8/31/2020) Condition: The year-end schedules for federal grants receivable, for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $80,978 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 10/15/2024 Responsible Official: Michael Brosnan, CFO

Finding 2021-003: Reconciliation of Accounts Federal Program: Research and Development Cluster: 47.076 Condition: The year-end schedules for federal grants receivable, for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $73,057 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by April, 30,2024 The remaining balance was earned in 2021. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO

The County Clerk, Treasurer, and BOCC Executive Assistant are tracking and monitoring all Federal expenditures closely to ensure the SEFA is more accurately reported.

Management will work together to design and implement a system of internal controls to ensure an accurate reporting of revenues and expenditures on the SEFA, that the notes to the SEFA are prepared, and compliance with all applicable federal requirements.

Finding 2021-002 Program: Various, including AL 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) – Reporting Corrective Action Planned: To make sure and have proper education and obtain training to ensure County personnel are aware of the Federal reporting requirements and understanding of the schedule of expenditures of Federal awards. Anticipated Completion Date: Fiscal Year End 2023-2024 Responsible Party: Garfield County Board Scott Krause Garfield County Board Chairman

The Board of County Commissioners, with the cooperation of all elected officials and officers responsible for the receipt or expenditure of county funds, will evaluate the processes and procedures currently in place to track federal awards and to ensure all income and expenditures relating to federal awards are properly overseen, tracked, and reported. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same.

Finding 2020-003: Reconciliation of Accounts Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023) Condition: The year-end schedules for federal grants receivable, for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $73,057 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by April, 30,2024 The remaining balance was earned in 2021. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: October 15, 2024 Responsible Official: Michael Brosnan, CFO

Finding 2020-003: Reconciliation of Accounts Federal Program: Research and Development Cluster: 47.076 Condition: The year-end schedules for federal grants receivable, for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $73,057 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by April, 30,2024 The remaining balance was earned in 2021. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 05/01/2024 Responsible Official: Michael Brosnan, CFO