Corrective Action Plans

Condition: The schedule of expenditures of federal awards (SEFA) was not complete. Planned Corrective Action: The School District will develop a checklist, or a report downloaded from the General Ledger, of all federally funded grants, and will compare the grants listed on this report with the grants listed on the Schedule of Expenditures of Federal Awards (SEFA) to ensure that all grants are reflected on both documents. Additionally, the Assistant Superintendent will review, date and sign a copy of the SEFA document prior to its submission, and the Business Office will retain this signed paper copy in its audit file annually. Contact person responsible for corrective action: Michael Zopf Anticipated Completion Date: June 30, 2024

Contact: Reginald Gregory Title: Executive Director/Controller Phone Number: 202-772-4300 Estimated completion date: June 30, 2024 Corrective Action: Management will continue to stress the importance of following the detailed procedures for preparation and review of the SEFA. Responsibility for compiling the SEFA was assigned to a Senior Program Accounting Manager who is tasked with assuring the SEFA and all support reconciliation are complete and accurate. Both the Director of Program Accounting and the Executive Director of Finance/Controller will review the SEFA for completeness, accuracy, and compliance with CFR Section §200.510(b).

Views of Responsible Officials and Planned Corrective Action: The School agrees with this finding. Lisa Hendricks, the Director of Finance, and the 3rd party accountant will work closely to develop a grant tracking system that determines the source of the grant funds prior to expending any of the funds.

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

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

Recommendation: We recommend that Minnesota Land Trust review its internal controls to ensure the SEFA captures all federal awards expended at the correct amounts in accordance with 2 CFR 200.510(b) Schedule of expenditures of Federal awards and CFR 200.502, Basis for determining Federal awards expended. Actions to be Taken: The Minnesota Land Trust will add additional internal controls to ensure a complete listing of federal expenditures is easy to provide and that the listing is reviewed by the Finance Department prior to audit fieldwork. Timeline for Completion: A complete listing of federal expenditures to be available from our accounting software (i.e., automatically) by October 31, 2023. Contact person responsible for corrective action: Claire Colliander

Response to Finding 2023-003 - Schedule of Expenditures of Federal Awards (SEFA) Preparation The district will strive for monthly requests for reimbursement for all applicable federal funds, thus creating awareness of the funds and potential issues before they arise. The District Director of Finance will be responsible for overseeing the implementation of these responses and anticipates corrective dates to be immediate. Person(s) responsible for action: Lanell Farmer/Director of Finance

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.

Inaccurate Grant Reporting (Material Weakness) Person Responsible for Implementing the Correction Plan: Autumn Stewart, City Recorder Anticipated Completion Date: June 30, 2026 Repeat Finding: No Planned Corrective Action: The City will strengthen internal controls over SEFA identification and preparation to ensure compliance with Uniform Guidance single-audit requirements. The City will also implement enhanced review and communication procedures with external auditors, as the condition was significantly impacted by deficiencies in the auditors’ evaluation and classification of major programs during the audit process.

In response to the finding of a misstatement of the 2022 Schedule of Federal Awards document submitted to Frost, PLLC, the County has established a cycle of training for new and existing staff within the Grants department as well as created a multi-step review process in order to identify and correct errors prior to beginning the auditing process. This process includes coordinating with other County departments, such as the Treasurer's Office, to make sure all activities are recorded in the proper periods on the Schedule of Federal Awards.

Finding Reference Number 2022: Preparation of SEFA Description of Finding: The initial Schedule of Expenditures of Federal Awards (SEFA) contained material errors and omissions, including omitted amounts passed through to subrecipients, inaccurate federal expenditure amounts, and other incomplete information, and required significant auditor assistance and multiple revisions before it was materially accurate. Statement of Concurrence or Nonconcurrence: Threshold CoC concurs with the finding. Corrective Action: Management will implement formal procedures for preparation and review of the SEFA. The process will include reconciling federal expenditures to the general ledger and supporting grant records; verifying that all federal programs, Assistance Listing Numbers, and pass-through information are complete and accurate; identifying and reporting all amounts provided to subrecipients; and documenting an independent supervisory review of the completed SEFA before it is provided for audit. Name of Contact Person: Jason Feldhaus, Executive Director, jason@thresholdcoc.org Projected Completion Date: December 31, 2026

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