Corrective Action Plans

Description of Finding: The school did not adequately track its expenditures of federal awards and did not prepare a complete SEFA as of the year end. Statement of Concurrence or Nonconcurrence: The school agrees with the audit finding as presented. Corrective Action: While the school’s chart of accounts includes specific accounts for grants and Title I funds, the chart of accounts did not explicitly list all federal revenue (Title I, ESSER Grant, USDA, and Federal Facility Grant). The school has already updated the chart of accounts to account for all federal funds with appropriate identification of revenue sources. This will allow the school to accurately account for monthly revenue and expenditures relating to federal funding sources, along with accurate monthly financial reporting of federal fund usage and expenses. Name of Contact Person: Chaz Patterson-Ellis, Chief Financial Officer, 678-466-7300, chaz.patterson@chatthillscharter.org. Projected Completion Date: Sept 30, 2023. Chaz Patterson-Ellis, Chief Financial Officer.

Finding 2022-004 - Material Weakness a. Inadequate Segregation of Federal and Non-Federal Expenditures b. Plan of Action - As this is an audit from four years ago, we acknowledge the deficiency at that time. i. Establish policies and procedures to ensure that all Federal awards are identified and reported accurately on the general ledger, utilizing separate general ledger accounts, cost centers, or project codes for Federal awards. A reconciliation of each applicable general ledger account and grant will be created and maintained, external to the general ledger, for all future grants, beginning in fiscal year 2026, but also retroactively as each year is prepared for audit. ii. Establish procedures to track expenditures by funding source throughout the project lifecycle. The City will establish written procedures for grant expenses during the FY27 fiscal year. iii. Internal Controls should be designed to perform periodic reconciliations of the SEFA information to the general ledger accounts throughout the fiscal year. See item i. and ii above. Provide appropriate training to staff who are assigned to prepare and review the SEF A. The outside consulting firm began in July 2023, with additional support added in June 2026, with the departure of the City Manager, who was also the prior Finance Director. c. Timeframe for implementation - We will strengthen our grant reconciliation procedures and documentation of support to be able to timely provide support to the auditor. We expect to have adequate reconciliation procedures during the FY23 audit preparation, with full implementation during the FY27 fiscal year.

Management agrees with the finding and is in the process of revising internal controls to address SEFA preparation.

Judge Lucas Response: This was an oversight on our part. Steps have been taken to fully comply with all SEFA reporting in the future.

This was a simple mistake in reporting the SEFA revenue instead of the expenditures. Since discovering expenditures are required this will not be an issue going forward.

The Schedule of Expenditures of Federal Awards (SEFA) provided to the audit firm was incomplete due to two primary factors: (1) insufficient understanding by staff regarding the requirement to include federally funded capital expenditures, and (2) improper recording of property acquisitions. Management acknowledges this oversight, which occurred during the implementation of a new program and at a time when staff were not fully aware that such expenditures must be reflected on the SEFA. Furthermore, certain capital expenditures paid directly through escrow were not recorded in the organization's accounting records. To remediate these issues, management has taken the following corrective actions: - Delivered targeted training to staff on the proper treatment and reporting of federally funded capital expenditures; - Updated internal closing and reporting procedures to incorporate a formal review of balance sheet activity; and - Updated internal closing and reporting procedures to incorporate a reconciliation to settlement statements when recording new property acquisitions; and - Strengthened internal controls to ensure all federally funded capital items are accurately captured in future SEFA submissions. Management is committed to maintaining compliance with federal reporting requirements and ensuring the completeness and accuracy of future SEFA filings.

Finding: During the audit of the auditee's SEFA for the year ended December 31, 2022, we noted discrepancies related to incorrect identification of Assistance Listing Numbers for certain grants, as well as difficulty providing initial supporting detail for balances of expenditures for certain Federal programs. The auditee lacks sufficient internal controls over the preparation and review of the SEFA. Specifically, there is no established process to reconcile federal expenditures reported on the SEFA to the auditee's underlying accounting records. A formal review process involving an individual independent of the preparation was not conducted to ensure the SEFA was complete and accurate before submission to the auditors. Views of responsible officials and planned corrective actions: Management agrees with the recommendation to establish and document a formal, multilevel review process for the preparation of the SEFA. Baltimore Medical System recently hired a new grant accountant who will be responsible for the preparation of the SEFA. • The Controller will perform a detailed reconciliation of the SEFA’s data to the general ledger and supporting grant documents. • The Grant Accountant will develop a central repository that includes all grant contracts/awards and a summary document which contains the grant name, grantee, award amount and period, Assistance Listing Numbers, pass-through entity and subrecipient information. • Train relevant staff on the SEFA requirements governed by the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for the Federal Awards (2 CFR Part 200, 200.510(b)). Anticipated date of completion: December 31, 2025 Contact person responsible – Tammy Grinnan, Controller and Margaret Boemmel, CFO

Finding 2022 – 003: Reporting: Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Response: For the audit period and subsequent audit periods the employee responsible for the SEFA did not prepare the SEFA for the audit. For future audit periods the SEFA will be prepared by the Financial Consultant.

During the grant agreement review and signature process, the source of funding is identified and confirmed with the funder. As a result, when the Schedule of Expenditures of Federal Awards (SEFA) is developed, the source of funds has already been correctly identified.

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

2022 – 006: Reporting - Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Condition: During fiscal year 2022, the Organization did not have adequate controls in place to ensure the SEFA accurately reflected each award's federal agency and assistance listing number. There were differences between the SEFA and the grant agreements/compliance supplements, requiring adjustments to the SEFA. Corrective Action Plan: As of October 1, 2024, the start of FY25 QuickBooks has been the only software used, and Revenue and Disbursements are being classed by Fund. General ledgers are now reconciled monthly. Each grant will have its own folder and required information to assure an accurate SEFA can be completed will be included.

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.

Management concurs with the finding and will implement a proper expenditure reporting process, reconciled monthly, to avoid recurrence during future audits.

The City will review the process for identifying federal awards to minimize the likelihood of errors in preparing the schedule of expenditures of federal awards to minimize the likelihood of errors in preparing the schedule of expenditures of federal awards. This will include inquiries of the Engineer’s Office.

Management’s Planned Corrective Action: Disagree: We have established a cost center or “Department” for each federal program that clearly identifies federal expenditures. Our funders request monthly copies of receipts and payment issued to verify expenses. Responsible Party: Beaulieu Accountancy Corporation, Accountant Completion Date: 9/25/2024

Finding no.: 2022-003 Contact person(s) responsible: Kymberly Horner, Executive Director Corrective action planned: The SEFA was assigned to be prepared internally, but unfortunately was not submitted due to staff turnover during the course of the audit. This oversight will be corrected by improving procedures around internal task assign-ments when employee turnover is experienced in the Fiscal department during the course of the audit. Anticipated completion date: December 2023

PREPARATION OF SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS - SIGNIFICANT DEFICIENCY Federal Program Community Development Block Grant/Entitlement Grant ALN 14.218; passed through the County of Berks HOME Investment Partnership Program ALN 14.239; passed through the County of Berks Emergency Rental Assistance ALN 21.023; passed through the County of Berks Condition/Cause The Authority provided information relating to the federal programs including grant agreements and other supporting documentation. However, the information prepared by the auditee required material adjustments as a result of audit procedures. Certain account reconciliations were not performed prior to the audit, which impacted amounts reported on the SEFA. Recommendation In order to meet Uniform Guidance requirements, the Authority should prepare the SEFA from the grant award documentation and any other relevant information including the assistance listing numbers, grant award amounts, grant amounts received, grant amounts expended, and grant revenue recorded. The amounts reported in the SEFA should reconcile to the general ledger. Management Response The Authority researched the method to prepare a SEFA and will be preparing the SEFA starting with the 2023 audit.

Consortium’s Fiscal Agent will ensure that supporting documentation will be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. In addition, Fiscal Agent will complete corrective action for 2022-005 & 2022-006

Condition: The schedule of expenditures of federal awards (SEFA) was not accurate. Planned Corrective Action: The City will review its process for identifying and communicating Federal Grant expenditures to its auditors. Contact person responsible for corrective action: Robert McMahon, City Administrator Anticipated Completion Date: 09/30/2025

2022 - 008: Reporting: Preparation of the Schedule of Expenditures and Federal Awards (SEFA) (Repeat Finding:2019-007 and 2020-007 and 2021-006) Condition: During fiscal year 2022, the Governmental Department did not have sufficient controls to ensure the SEFA accurately reflected each award’s federal expenditures. There were differences noted in reconciling expenditures from the original SEFA to the trial balance, and it was discovered that certain adjustments for grants receivable, unearned revenues and grant revenue had not been made in order to properly report total federal expenditures. These errors were corrected through adjustments proposed as part of the audit, and the final version of the SEFA reconciles to the Governmental Department’s general ledger. Corrective Action Plan: Management of the Tribe realizes the importance of the SEFA and will be sure that the SEFA matches the general ledger and accurately reflect each awards federal expenses. The internal task list to be developed will include reconciliations from the trial balance to the SEFA on a least a quarterly basis

Responsible Parties: Chief Executive Officer (Rose Turner), Interim Chief Financial Officer (Dan Miles), Finance Director (Kelly Glover) Gateway’s Management will utilize the implemented Matrix duties and responsibilities Grid to help monitor the documentation of required procedures and Standard Operating Procedures approved by the Board of Directors. The health center will use the approved Financial Policies and Procedures Manual as its Standard Operating Procedures. The Health Center’s Management employs key management staff that reflects the size and composition of a health center. Ongoing evaluations will be used to monitor the qualifications of the staff. This Audit is a late submission, however with the submission a qualified Chief Financial Officer is in place and has the qualifications needed to assess and train staff accordingly and provide recommended changes to the department. This new Chief Financial Officer will serve as a technical resource to assist with the implementation of all the resolutions to the findings of the 2022 and 2023 audits

Finding Number: 2022-003 Condition: Controls in place were not adequate to ensure the schedule of federal expenditures was complete and accurate. Planned Corrective Action: The federal funding was not received until fiscal year 2023 while some expenditures were incurred in fiscal year 2022. The timing of events contributed to the oversight on the 2022 SEFA. WakeMed has reeducated staff on the preparation of the SEFA in order to prevent this error from reoccurring.Contact person responsible for corrective action: Lynn Bailey Anticipated Completion Date: 12/5/2024

Action Taken: Management is in the process of instituting additional procedures to ensure all awards are assessed not only to identify whether sources of funds are Federal, requiring inclusion on the SEFA, but also to identify continuing compliance period when applicable. Management has also conducted internal training relative to applicable 2 CFR 200 regulations and requirements and will continue to provide periodic staff training to ensure continued compliance. Anticipated Completion Date: Management estimates that additional processes will be in place by December 31, 2024.

The Township Fiscal Officer will prepare the SEFA or contract with a CPA firm to have the SEFA prepared going forward.

Management accepts this finding. A detailed set of procedures was documented immediately after the discovery of this error in preparing the Schedule. Included in these procedures, a query is run of research projects. This query is sent to Sponsored Research Services (SRS) to review to verify the reporting status and AL numbers, and other items are correct and complete. Once SRS has verified the data in the query is complete and accurate, then the Controller’s office will proceed with preparing the Schedule as well as reconciling it to the Statement of Activities (SOA) In the procedures, we have added that SRS and the Controller, and/or Chief Financial Officer review the Schedule prior to initiation of the audit review process.