Corrective Action Plans

CAP for Finding: 2022-103 Auditor Recommendation: Further evaluate federal grant expenditures reported in the STAR General Ledger as it prepares its schedule of expenditures of federal awards and ensure it is adjusting expenditures for all prior-year transfers of expenditures in the current year. Planned Corrective Action: The Wisconsin Department of Administration (DOA or Department) Bureau of Financial Management (BFM) will evaluate federal grant expenditures reported in the STAR General Ledger as it prepares its schedule of expenditures of federal awards (SEFA) and ensure it is adjusting expenditures for material prior-year transfers of expenditures in the current year in a manner consistent with requirements of the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance or Guidance) and additional guidance, if any, provided by the Department?s State Controller?s Office (SCO). The Uniform Guidance requires the preparation of a SEFA for the period covered by the State's financial statements that includes total federal awards expended [ref. 2 CFR 200.510 (b)]; the determination of when a federal award is expended to be based on when the activity related to the federal award occurs [ref. 2 CFR 200.502]; and that the financial statements and SEFA are for the same audit period [ref. 2 CFR 200.514]. As the auditors noted, in preparing DOA?s SEFA, DOA BFM sought to reflect the amount of federal awards expended for DOA?s grant programs based on the amounts reported in the STAR general ledger. Together with reporting negative expenditures resulting from the transfers of FY 2019-20 and FY 2020-21 expenditures within the Notes to the SEFA, which are an integral part of the SEFA and required by 2 CFR 200.510 (b)(6), and absent OMB guidance that prescribes a uniform method for reporting a transfer of prior year grant expenditures, DOA BFM believed its approach was consistent with the requirements of 2 CFR 200.502 and 2 CFR 200.510 (b), more generally. DOA BFM later modified its SEFA to exclude negative expenditures resulting from the transfers of FY 2019-20 and FY 2020-21 expenditures consistent with the manner in which a prior period adjustment would be reflected within current-year activity in financial statements prepared in accordance with generally accepted accounting principles (GAAP), as described in the criteria and recommended by the auditors. The increased expenditures for the Coronavirus Relief Fund (Assistance Listing number 21.019) and Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing number 21.027) in the SEFA of $241.3 million and $192.1 million, respectively, together with any future exclusions of negative expenditures resulting from the transfer of prior-year expenditures, will cause the lifetime expenditures on the SEFA schedule for these programs to reflect more expenditures than federal funding received. The Notes to the SEFA were also modified to indicate that the SEFA does not reflect a reduction for the prior year transferred expenditures. Anticipated Completion Date: Concurrent with the submission of the FY 2022-23 SEFA, which is anticipated to be November 2023 Auditor Recommendation: Carefully assess the transfer of prior-year expenditures in the current year to determine any potential effects on the total federal expenditures for the prior-year and the effect on the major program expenditures. Planned Corrective Action: DOA BFM will assess the transfer of prior-year expenditures in the current year to determine any potential effects on the total federal expenditures for the prior-year and the effect on the major program expenditures. It has been the practice of DOA BFM to assess the transfer of prior year expenditures in the current year and DOA BFM will continue to prioritize decisions with respect to the same to allow the Department to maximize the availability of federal funding for the purposes intended. Anticipated Completion Date: June 30, 2023 Person responsible for corrective action: Colleen Holtan, Director Bureau of Financial Management Division of Enterprise Operations colleen.holtan@wisconsin.gov

CAP for Finding: 2022-302 DATE: March 27, 2023 TO: Carolyn Stittleburg, Deputy State Auditor for Financial Audit Legislative Audit Bureau FROM: Barry Kasten, Director Bureau of Fiscal Services Department of Health Services SUBJECT: Corrective Action Plan ? Multiple Grants ? Reporting in the Schedule of Expenditures of Federal Awards Department staff has reviewed the Legislative Audit Bureau?s (LAB) interim audit memo for Finding 2022-302: Multiple Grants - Reporting in the Schedule of Expenditures of Federal Awards. This is the department?s Corrective Action Plan. ? Recommendation (2022-302): Multiple Grants ? Reporting in the Schedule of Expenditures of Federal Awards We recommend the Wisconsin Department of Health Services further evaluate federal grant expenditures reported in the STAR General Ledger as it prepares its schedule of expenditures of federal awards and ensure it is: ? adjusting expenditures for prior-year transfers of expenditures in the current year. Wisconsin Department of Health Services Planned Corrective Action: DHS adjusted the expenditures for prior-year transfers of expenditures as recommended by LAB though DHS believes that there is no clearly defined direct authoritative guidance provided by OMB mandating a uniform method for reporting a transfer of prior year grant expenditures. Because of this, DHS believes it is prudent to seek confirmation of this treatment from the federal government going forward. LAB, in describing the effect, indicates that ?the State under-reported expenditures for the ELC grant by $55.9 million.? These expenditures were previously reported in prior fiscal years. Upon approval of the State?s FEMA project workbook, and in accordance with the compliance supplement, these previously reported expenditures were reported in FY 2021-22 under the Disaster Grants?Public Assistance (Presidentially Declared Disasters) (Assistance Listing number 97.036) grant. Without a matching reduction in expenditures to the ELC grant by $55.9 million, DHS is concerned that the lifetime expenditures on the SEFA schedule for these grant programs are going to reflect more expenditures than federal funding received. Additionally, because there is not direct authoritative guidance currently provided by OMB mandating a uniform method for reporting a transfer of prior year grant expenditures, DHS will work with DOA to seek clarification from the Federal Government on the proper treatment and reporting of transfers of prior year expenditures on the SEFA. Anticipated Completion Date: November 1, 2023 We recommend the Wisconsin Department of Health Services further evaluate federal grant expenditures reported in the STAR General Ledger as it prepares its schedule of expenditures of federal awards and ensure it is: ? properly identifying applicable COVID-19 expenditures; ? reporting all federal expenditures for each federal grant program, regardless of whether the agency has received reimbursement from the pass-through entity; and ? removing repayments of prior-year overpayments of expenditures from current-year expenditures. Wisconsin Department of Health Services Planned Corrective Action: DHS will ensure that it reviews the instructions that are received from DOA and present the proper amounts in the SEFA. This will include a review of adjustments made to grants open in prior state fiscal years and verification that they have not already been reported on the SEFA in a prior year, such as the WIC adjustment identified. Anticipated Completion Date: November 1, 2023 Person responsible for corrective action: Barry Kasten, Director Bureau of Fiscal Services, Division of Enterprise Services barry.kasten@dhs.wisconsin.gov

See Corrective Action Plan for chart/table

Finding Number: 2022-001 Program Name/Assistance Listing Titles: Crime Victim Assistance; Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services Assistance Listing Numbers: 16.575, 93.671 Contact Person: Jessica Bryson, Finance Administrator Anticipated Completion Date: Completed effective October 2022 Planned Corrective Action: During the audited fiscal year, the organization experienced significant staff turnover in the Finance Department. As a result, the methodology of accounting relative to class/customer tracking changed part-way through the year. This resulted in the inability to immediately produce documentation from the financial reporting software that corroborated the grant billings. Although the organization is confident that expenses were billed to appropriate grants throughout the year (due to backup documentation in the grant billing portals), the organization?s financial software did not directly reflect this. To correct this problem, a new class/customer tracking system has been established to ensure that the financial reporting software more accurately tracks expenditures related to Federal Awards and organizational programs. Furthermore, grant billings are regularly reviewed by an independent accounting firm, the organizations Treasurer, and/or the Executive Director to ensure proper coding/tracking.

INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE OUT AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START PROGRAMS LOW-INCOME HOME ENERGY and WATER ASSISTANCE PROGRAM CFDA # 93.600, 93.568 and 93.499 (Questioned Costs - Undetermined) Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the agency?s financial funding sources, the agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst?s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and uniform guidance regulations. The new automated financial system, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2023.

Finding Number: 2022-004 Condition: The schedule of expenditures of federal awards (SEFA) was not complete and accurate. Planned Corrective Action: Additional training for those individuals responsible for grant accounting has and will continue to be conducted, in addition to creating additional policies and procedures in FY23. Contact person responsible for corrective action: Kristen St. Peter Anticipated Completion Date: June 2023 Management Response: Management concurs with the finding and additional training for those individuals responsible for grant accounting has and will continue to be conducted as well as incorporating additional levels of review to ensure the SEFA is completed accurately and timely.

Lincoln Marti Charter Schools has taken immediate corrective action to ensure that all federal expenditures are reflected correctly in the Schedule of Expenditures of Federal Awards. Policies and procedures on grants and contract funding were reevaluated and the staff responsible for preparation of the schedule have received additional instruction on how to accurately prepare and finalize the schedule. Additionally, there will be segregation of duties between the preparer and reviewer of the Schedule of Expenditures of Federal Awards.

Management agrees with the finding and recommendation. Management is working with the accounting team to implement a new process to ensure that an internal SEFA is prepared and reconciled on a quarterly basis, at a minimum. Management will review and approve all reconciliations.

CORRECTIVE ACTION PLAN February 3, 2023 Crossroads Rehabilitation Center, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Greenwalt CPAs 5432 West Vermont Street Indianapolis, IN 46224 Audit Period: Year ending June 30, 2022 The findings from the June 30, 2022, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. MATERIAL WEAKNESS Finding 2022-001 Criteria: According to 2 CFR 200.508(a), the auditee must prepare appropriate financial statements, including the schedule of expenditures of Federal awards (SEFA) in accordance with 2 CFR 200.510. As instructed in the OMB Compliance Supplement, Provider Relief Funds (PRF) should be reported on the SEFA based on upon the PRF report that is required to be submitted to the HRSA reporting portal. For example, PRF funds received in period 2 (July 1, 2020, to December 31, 2020) should be reported on the SEFA for the fiscal year ends of December 31, 2021 through December 31, 2022. Condition: Federal awards totaling $332,841, including Provider Relief Funds received in period 2 of $178,159, were excluded from the SEFA. Cause: Crossroads had significant turnover within the accounting department and the new personnel had not been aware of the PRF funds received in a prior fiscal year. In addition, there was no overlap in the CFO position to provide for a smooth transition. Effect: An audit adjustment was made to report the three awards on the SEFA totaling $332,841. Recommendation: We recommend that Crossroads retain documentation regarding the information used to prepare the SEFA, along with notes for future years to assist with future personnel transitions. Planned Corrective Action: Crossroads will update policies, procedures and document retention plans to ensure that data is easily accessible. Instructions for completion of all audit related reports will be maintained and available to all finance personnel. Finding 2022-002 Criteria: Accounting reconciliations and supporting documentation should agree to the general ledger and be prepared and reviewed timely. Condition: Investment reconciliations, bad debt analysis and contributions receivable reconciliations had not been performed until requested during the audit. In addition, accounts receivable aging reports and depreciation reports did not agree to the general ledger. Cause: There was significant turnover within the accounting department during the year, including the Financial Accounting Manager and CFO positions. In addition, there was no overlap within the CFO position to provide for a smooth transition. This was the first-year end closing for both individuals in those positions. Effect: Audit adjustments were made resulting in a decrease of assets of approximately $4,700,000, a decrease in liabilities of approximately $400,000, and a decrease in net assets of approximately $4,300,000. Recommendation: We recommend that Crossroads create a schedule of all year-end reconciliations that need to be performed to ensure that required reconciliations are performed and reviewed timely. Planned Corrective Action: The lack of documentation and training of the Financial Accounting Manager for year-end closing processes prior to the former CFO?s departure left a significant knowledge gap. This also hindered the ability of the current CFO, who joined the organization 2 months prior to year-end, to be able to provide the required information or perform the necessary reconciliations. Going forward, all processes for month-end and year-end will be documented and followed. Accounts will be reconciled and reviewed on a monthly/quarterly/yearly basis as determined by the materiality of the account. If there are any questions regarding this plan, please contact Techia Brewer, CFO, at tbrewer@eastersealscrossroads.org.

Identifying Number: 2022-012 Finding: SEFA Reporting Corrective Actions Taken or Planned: UCAN agrees with this finding and agrees this was directly due to the turnover in the finance team and staffing challenges. The finance team will undergo additional training in federal grant requirements and SEFA reporting. This is a repeat finding, with the original corrective action plan to be completed before March 31, 2023. We do believe that corrective actions that have been taken have resolved this issue. Contact person is Kimberly Parish, Chief Financial Officer and she can be reached at kim.parish@ucanchicago.org.

Finding 2022-0002 Criteria: According to 2 CFR Subpart F Section 200.Sl0b, the auditee must prepare a Schedule of Expenditures of Federal Awards {SEFA) for the period that includes all amounts spent on federal programs during the reporting period. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was materially understated by $33,592. Cause: This was the School's first single audit and the first time for the School's accountant to prepare the SEFA. The School does not have a process in place for School Administrative personnel who are familiar with the School's grants to review the SEFA for accuracy and completeness. Effect: An audit adjustment was made to increase the reported amount on the SEFA for the Rural Education Grant (84.358A) by $38,256 and reduce the reported amount on the SEFA for the Special Education Grants (84.027) by $8,288. The increase in expenditures resulted in the need to select a second federal award for testing. Recommendation: We recommend that the School's accountant work with administrative personnel to identify all awards from federal sources and implement a process whereby School administrative personnel review the SEFA prepared by the accountant. In addition, we recommend that the accountant reconcile federal award expenditures to the claims that were filed for the year. Action Taken: As of the date of the exit conference, we will institute an in-person quarterly review of each award with the responsible party to ensure costs are appropriately allocated and reimbursements requested. As part of this quarterly review, we will identify the source of the award, year-to-date expenses, grant budget and year-to-date reimbursement claims submitted. The accountant will reconcile federal award expenditures to the claims filed for the year. Furthermore, at year-end, the SEFA will be prepared by the accountant and reviewed by the appropriate administrative personnel for completeness and accuracy.

Finding Number: 2022-002 Condition: The SEFA was not accurate. Planned Corrective Action: Management has accepted the finding. Moving forward, internal conrols will be strengthened with regard to review and recording of revenue and expense recognition. Specifically, as it relates to this instance, review of documentation from the U.S. Department of Education (DOE) as it relates to HEERF grant funding will be more closely reviewed for understanding to include verification of understanding, guidelines and procedures from the DOE and other pertinent agencies for grant funding. Contact person responsible for corrective action: Deborah McKenzie, Director of Grants & Chief Financial Officer Anticipated Competion Date: November 30, 2022

Federal Schedule Audit Comment: County Response Emergency Rental Assistance Program Timely Reporting: The County made every attempt through communications with the Treasury to upload annual reports for ERA 1, without being able to do so by the due date. The County did submit the documents manually by e-mail through dumps of the system. County staff worked with the US Treasury to address these issues. A resolution to the problem did not occur until second quarter of 2023. The Final report for ERA 1 has been submitted through the portal. Cumulative Expenditure/ Obligation Amounts: There was some misinterpretation on the part of County staff on whether the cumulative amounts to be reported was for the quarter or cumulatively for the grant program. It is to be noted that amounts in the County system were properly recorded and no exceptions were noted in the actual expenses/ obligations being for a valid grant purposes. Corrected on Final Report for ERA 1. State/ Local Federal Relief Funds Program Cumulative Expenditures/ Obligations Incorrectly Reported: There was some misinterpretation on the part of County staff on reporting the election of the $10,000,000.00 Revenue Replacement Funds for the SLFRF. It was thought that you could only show the $10,000,000.00 as obligated and expended once the election was made. This resulted in a net overstatement of obligations for any revenue replacements funds that were not yet obligated by resolution by the Board of Mahoning County Commissioners. The County tracked the individual projects by notes in the Treasury system to note the actual obligations. The County?s financial system tracks grants by fund, department and project codes. The funds in the County?s financial system were and are correctly obligated and tracked. The County will make the necessary corrections to the 2023 second quarter report to make sure the report agrees with the County?s financial system. It is to be noted that no exceptions were noted in funds being used for the stated purposes of the grant. Senior management will provide additional oversight to the reports prior to submitting to the US Treasury.

Finding 2022-002: Program: Various, including AL 97.036 ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters); AL 10.923 Emergency Watershed Protection Program; and AL 93.563 ? Child Support Enforcement ? Reporting. Corrective Action Planned: The County will develop a Schedule of Expenditures of Federal Awards (SEFA) chart and designate the County Clerk to coordinate the collection of information from individual county offices on Federal awards expenditures. Anticipated Completion Date: March 30, 2023 Responsible Party: Carl Grotelueschen, County Board Chair

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.

2022-002 Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Auditor Recommendation: We recommend management attend Federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the Federal funds are reported accurately on the SEFA and that programs are reported under the correct assistance listing number. Corrective Action: The year ended August 31, 2022 was the first year in which the Center expended federal awards in excess of the limit that requires a Single Audit. Since receiving the EIDL loan, the Center maintained detailed tracking and documentation of all disbursements associated with the loan and understood such expenditures exceeded the $750,000 threshold for a Singe Audit during the fiscal year ended August 31, 2022. With the clarification of the specific rules surrounding the disclosure of EIDL loans on the SEFA, management will continue to review Federal Award guidance and requirements to ensure compliance with current and future federal awards. Name of Responsible Contacts: Larry Goodpaster, Director of Finance & Operations, and Kelly Martin, Accounting Manager Projected Implementation Date: May 1, 2023 and ongoing

Corrective Action Plan For the Year Ended December 31, 2022 Finding: 2022?001 Inaccurate SEFA reporting Responsible Official: Michelle Maddox, CFO Corrective Action Plan: Management will implement additional controls to ensure the completeness and accuracy of amounts reported for expenditures of the Federal Transit Administration grants in the schedule of federal awards. These additional controls include the annual review of new implementation guides. Anticipated Completion Date: December 31, 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

Finding Number: 2022-007 Condition: For SEFA reporting, expenditures were overstated for one program and understated for another. In addition, an ALN listed for expenditures was inaccurate. Planned Corrective Action: Grant documents will be reviewed upon receipt to determine the proper ALN and the federal portion of funding. All existing grants will also be reviewed. The ALN listed in each grant document will be used when completing the SEFA. A second staff member will verify the accuracy of the SEFA prior to submission. All ALN numbers will be reviewed upon receipt and verified with state analysts when applicable. The organization will ensure that the funding sources are verified to the most appropriate level at the state level to verify funds and funding sources. Contact person responsible for corrective action: Kelly Scott, Deputy CEO Anticipated Completion Date: 4/30/2023

Views of Responsible Officials: Connect Our Kids acknowledges the findings of the audit and will take immediate corrective action. Planned Corrective Action: All accounts will be reconciled in a timely manner for the following fiscal year. The federal grant revenue and expenditure cutoff will be maintained for the end of the fiscal year with any adjustments for accrual purposes no later than January 31st of the following year. Responsible Official: Cara Dobbins, CFO Anticipated Completion Date: 9/30/2023

As requested, the New Mexico Coalition to End Homelessness has completed its corrective action plan for the audit findings in the 2022 fiscal year annual audit report. We have reviewed the findings and have made a corrective action plan to address each of the findings with completion dates. 2022-002?PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Federal Agency: All presented in the Schedule of Expenditures of Federal Awards. Program Name: All presented in the Schedule of Expenditures of Federal Awards. Assistance Listing Nos. and Program Expenditures: All presented in Schedule of Expenditures of Federal Awards. Award Number and Program Award Year: All presented in Schedule of Expenditures of Federal Awards. Compliance Requirement: Other ? Schedule of Expenditures of Federal Awards preparation Type of Finding: E Questioned Costs: None Statement of Condition While conducting the audit, the following was reviewed; the Coalition?s Federal grants report for the fiscal year and identified the federal grants, Assistance Listing # (AL#) and the amounts of the federal expenditures and all of the other items required to properly present the Schedule of Expenditures of Federal Awards (SEFA). The finance staff of the Coalition confirm the correctness of the SEFA. Despite the confirmation of accuracy, additional federal expenditures and grouping of grant expenditures were identified after several reviews of the SEFA. Criteria 2 CFR 200.510 indicates that the auditee must prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200.502 Basis for Determining Federal Awards Expended. Per 2 CFR 200.502 the determination of when a Federal award is expended should be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as expenditure/expense transactions associated with awards. In addition, 2 CFR Part 200.303 requires the program establish and maintain effective internal controls over Federal awards that provides reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of Federal awards. Effect Without an established process governed by effective internal controls, the Coalition may not prevent or detect material misstatements on its SEFA in a timely manner. In addition, the errors could result in improper selections of major program(s) for the single audit and a substandard single audit. Cause Historically, the Coalition has requested the auditor assist in identifying accruals related to federal grant expenditures as the organization has maintained these records on a cash basis. As the organization has taken more responsibility on maintaining its federal grant expenditures on an accrual basis, an incomplete SEFA has been provided. Recommendation It is recommended the Coalition prepare the Schedule of Expenditures of Federal Awards and submit this to the auditor for testing. The SEFA should include the name of the grant, name of grantor, the AL #, the pass-through number if applicable and a reconciliation of the federal revenues and expenditures to the Coalition?s general ledger. The Coalition staff should perform more detailed reviews of the reports to ensure they properly reflect grant receipts and expenditures. This review should be performed by someone other than the preparer and should include documented evidence of agreeing the reported data to the accounting records. We further recommend training for those individuals involved in the preparation and review of the reports to ensure they are fully aware of the requirements. View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2023 Fiscal Year and information will be given to the auditors when requested for the 2023 Audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately. When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by October 31, 2023 (Final copy of the SEFA will not be given to the auditors until requested for the 2023 Audit) Designation Of Employee Position Responsible For Meeting Deadline: Executive Director, Monet Silva will oversee this project and work closely with the auditors to make sure that the information saved and shared is correct. Thank you, Monet Silva Executive Director

This finding relates to the preparation of the SEFA for the disclosure of the loan balances under the Company?s Railroad Rehabilitation & Improvement Financing (RRIF) loan. In the initial version of the SEFA, Amtrak did not reduce the audit period loan balance by the FY21 loan repayment. An updated version of the SEFA corrected the balance presented. The presentation on the SEFA of the balance of the RRIF loan has specific federal regulation requirements. Amtrak will review and update its SEFA Preparation Guide to ensure full compliance with 2 CFR Part 200 specifically for presentation of the RRIF loan balance. Amtrak will also consider providing training to key grants management personnel on an annual basis to keep them up to date with federal regulations. The contact for this item is Lucia Butts, AVP Funding and Grants. The Company anticipates that the updated procedures and training will remediate this finding in the fiscal year ending September 30, 2023 and beyond.

Inaccurate Schedule of Expenditures of Federal Awards (The SEFA) Personnel Responsible for Corrective Action: Roxy Custer, Accounting Manager Anticipated Completion Date: December 31, 2023 Corrective Action Plan Broomfield agrees with the auditors? recommendation to continue working and strengthen internal controls by implementing additional training and oversight of personnel to ensure the Schedule of Expenditures of Federal Awards (SEFA) accurately reflects federal expenditures for the fiscal year. Staff will continue to map the respective Assistance Listing Number (ALN) numbers to align with the corresponding project codes within the financial system. The Accounting division will ensure that employees responsible for preparing and reviewing the SEFA receive additional training and oversight so they understand the reporting requirements outlined in the Uniform Guidance.

Management agrees with this finding and is in the process of developing internal controls to ensure timely and appropriate actions are made on the deficiency noted.