Corrective Action Plans

Finding 2021‐001 Federal Agency: United States Department of Housing and Urban Development (HUD) Planned Corrective Actions: Responsible Official – Darryl Johnson, Deputy CFO Anticipated completion date – October 2025 Management will review its controls and update standard work documentation to ensure that all loans and expenditures related to the Housing Trust Fund are appropriately accumulated and reported in the schedule of expenditures of federal awards (SEFA) for the period covered by the New York State Housing Finance Agency’s financial statements in accordance with Uniform Guidance 2 CFR section 200.502. All staff working on SEFA preparation and review, will receive additional education in reporting for federal programs.

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.

Management feels that the SEFA wasprepared in accordance with guidance that was available at the time. We will continue to evaluate all federal programs’ expenditures and include on the SEFA as necessary. All federal expenditures will continue to be reconciled to College ledgers.

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 20201-0001 Responsible Official: Richard E Rico Views of Responsible Officials: With the volume of new COVID-19 federal programs, it was more challenging to completely prepare the SEFA. Processes will be put into place to compile the SEFA, reconcile to support and perform a related review prior to audit. In addition, any funds with unusual reporting requirements will be reviewed in detail to ensure reporting is complete and accurate. This has been implemented as of January 2025.

Finding: In accordance with 2 CFR 200 200.510(b), the auditee must prepare a Schedule of Expenditures of Federal Awards 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. The Corporation’s Schedule of Expenditures of Federal Awards for the year ended June 30, 2021 was initially prepared without federal expenditures totaling $1,222,859 for the HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund, Assistance Listing number 93.461. Corrective Actions Taken or Planned: In July 2023, the Corporation has provided education and training to the staff regarding how to identify programs and costs that need to be reported on the annual SEFA. This includes a process to enhance internal controls around the timely identification of federal awards and the reconciliation of the SEFA to ensure that it is accurate and complete. Name of contact person responsible for corrective action: Rose Rosario, Director of Patient Financial Services.

Confluence Health has made significant changes to its internal controls to ensure federal funds are accounted for properly in the Schedule of Expenditures of Federal Awards. Confluence Health developed a Grants Committee that approves all Federal and State Grants. This Committee reviews all grant applications and after approval, contacts finance and executive leaders of the approved grants by the committee. In addition to the control implemented above, Confluence Health meets internally monthly with all parts of the organization that receive cash payments from grant programs and incur federal expenditures to confirm if federal grant funds have or have not been received and spent. Our Revenue Cycle department that received the funds related to this program has provided education to their team, and leadership is aware of the risk and importance of reporting federal funding of grants and monitoring compliance. The COVID-19 HRSA Uninsured Program has been reported appropriately on Confluence Health’s restated 2021 Schedule of Expenditures of Federal Awards. This process has been put in place and continues monthly during our month-end close meetings to ensure federal grant funds are being reported correctly. The Vice President of Finance, Eric Caldwell, will be the individual responsible for the corrective action plan.

Program: Transportation Infrastructure Finance & Innovation Action (TIFIA) Program (ALN 20.223) Finding: 2021-002 Contact Person: Wei Chi Director of Finance City of Long Beach Harbor Department Phone: (562) 283-7594 Email: wei.chi@polb.com Corrective Action Plan: Going forward, the Harbor Department will ensure that federal loans are reported on the SEFA. The expected completion date for implementation of these planned actions is no later than June 30, 2025.

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

Public Health’s Accounting Office will generate the FI$Cal Year End Close report (KK_12 expenditure) and collaborate with the ELC program to ensure that all expenditures captured are complete and accurate, ensuring timely reporting of the SEFA data for FY 2023-24 and beyond. Additionally, we will update the procedures to document the SEFA reporting for the ELC program.

EDD agrees with this finding. The deferred transition to FI$Cal and the difficulties experienced thereafter have continued to cause EDD to be late with submitting year-end financials and its ability to submit timely the cash basis expenditures into the Single Audit Expenditures Reporting Database (Database). In addition, the onset of the COVID-19 pandemic created additional issues which ultimately impacted the EDD’s ability to submit timely year-end financials. However, the EDD is making progress and continues to gain ground in the department’s efforts to follow the State’s deadlines for submitting year-end financials and entering the cash basis expenditures into the Database. By the end of fiscal year 2021-22 and into fiscal year 2022-23, the EDD did a restructuring within the accounting area which realigned workload amongst the units and provided additional resources in critical areas. These changes will have a lasting effect and help the department to be better positioned going forward in processing the accounting workload and ultimately be able to catch up and submit year-end financials and enter the cash basis expenditures into the Database by the State’s deadlines. In addition, the EDD took lessons learned from the fiscal year 2019-20 financial audit to update processes and procedures and applied that knowledge going forward. Also, staff have been participating in various trainings offered by Finance and the Department of FISCal and staff continue to work with the control agencies when issues arise that would impact our accounting functions. While the EDD is still behind, the department is making great progress on catching up. The EDD submitted the last of its fiscal year 2020-21 financials in July 2022 and is targeting to submit the last of its fiscal year 2021-22 financials by the end of March 2023. The EDD’s goal is to submit fiscal year 2022-23 financials by the end of December 2023. Similar to the 2019-20 financial audit, the EDD will take the knowledge learned during the 2020-21 audit season, continue to engage with the control agencies, and continue to train and develop staff in order to keep progressing towards the department’s goal of becoming timely with the submission of the year-end financials and entering of the cash basis expenditures into the Database.

Finding 2021-002 Responsible Official: Donnie Gosnell, Controller Views of Responsible Officials: With the volume of new COVID-19 federal programs, it was more challenging to completely prepare the SEFA. Processes will be put in place to compile the SEFA, reconcile to support and perform a related review prior to audit. In addition, grant agreements will be required to go through the contract approval process. This will allow all grants to be identified and tracked, ensuring completeness. This has been implemented as of March 2024

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

In collaboration with the audit team, we will correct the procedures used to develop the Schedule of Expenditures of Federal Awards to ensure that it is completed correctly and accurately .Anticipated Completion Date April 30,2024.Responsible Contact Person-Kathleen Boyce, CFAO

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.

Controls Over Financial Statement Preparation and Reconciliation Procedures Should be Improved. Corrective action: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards. Person responsible: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration Anticipated Completion Date: June 30, 2024

Finding Number: 2021-002 Condition: Controls in place were not sufficient to ensure the accuracy and completeness of the SEFA. Planned Corrective Action: In order to assure the accurate classification of federal grant expenditures, the Federation staff implemented the following controls as part of their accounting review process: 1) The Senior Accountant responsible for grant accounting and the Senior Director of Finance will perform a complete review of all grant agreements, to determine whether the grants are funded with federal or state funds. 2) The quarterly workpapers will include a copy of the signed grant agreement, a current SEFA schedule, and a general ledger that correctly corresponds to the totals included on the included SEFA. 3) The staff will perform a quarterly review of the State of Michigan website (Michigan.gov/MDHHS) to confirm the funding sources of all existing grants. Contact person responsible for corrective action: Rebecca Stasch, Senior Director of Finance Anticipated Completion Date: 05/31/2023

The BOCC will work to design and implement internal controls to ensure accurate reporting of federal expenditures on the Schedule of Federal Awards (SEFA) and ensure compliance with federal requirements.

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

Our office will collect all documentation of awards and enter each award into the budget. We will establish a separate folder for each grant award and retain copies of the grant award documents, vendor quotes, invoices, and payments in the office of the county clerk. We will obtain receipts of revenues.

Management Response to Audit Comment # 2021-004 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PERPARATION, PROPER APPROVAL OF DISBURSEMENTS, GRANT CLOSE-OUT PROCEDURES AND REQUIRED REGULATORY REPORTING. POLICIES AND PROCEDURES SHOULD BE IMPROVED LOW INCOME HOME ENERGY ASSISTANCE PROGRAM HEAD START AND EARLY HEAD START PROGRAMS Federal Assistance Listing: 93.568 and 93.600 Responsible Person: G. Keith Williams Anticipated Completion Date: December 31, 2023 / On-Going Corrective Action: The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and fully agrees with the need for improved internal controls over financial statement preparation. Management believes that the proper approval of disbursements was adhered to during the reporting period with minimal deviation and continues to ensure proper policies are followed. Federal reports (SF425’s, LIHEAP) were filed during this period and may not have been properly reviewed during the course of this audit. For example, the LIHEAP reports were reconciled with the assistance of the State Program Specialist to ensure proper return of funds as requested by the funding agency. Management reserves the right to discuss this further as needed for the purpose of this finding. Adequate fiscal personnel staff has continued to be a challenge for the agency as management has done an exhaustive search for additional fiscal personnel and made job offers to qualified individuals only to have them decline the offer at the last moment. We have just offered the position of General Ledger Accountant to an individual and they are expected to start in two weeks. This will assist the CFO in the area of financial controls and reporting. It should also be noted that all bank reconciliations are current and being completed in a timely manner as dictated by our policies and procedures. Management continues to ensure all federal, state, and local and local regulatory reports and completed and submitted in a timely manner. As stated previously, the CFO worked directly with the State LIHEAP Program Staff to ensure proper reporting and reconciliation before returning unused funds.

Finding 2020‐001 Federal Agency: United States Department of Housing and Urban Development (HUD) Planned Corrective Actions: Responsible Official – Darryl Johnson, Deputy CFO Anticipated completion date – October 2025 Management will review its controls and update standard work documentation to ensure that all loans and expenditures related to the Housing Trust Fund are appropriately accumulated and reported in the schedule of expenditures of federal awards (SEFA) for the period covered by the New York State Housing Finance Agency’s financial statements in accordance with Uniform Guidance 2 CFR section 200.502. All staff working on SEFA preparation and review, will receive additional education in reporting for federal programs.

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.