Corrective Action Plans

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.

From: Eric Caldwell, Vice President, Finance Subject: Single Audit Corrective Action Plans for Year Ended December 31, 2022 Date: March 3, 2025 Prior Year Findings and Corrective Actions: Finding 2020-001 Preparation of the Schedule Expenditures of Federal Awards – Material Weakness in Internal Control Over Compliance Finding Summary: The Health System did not have sufficient controls to ensure the SEFA included all expenditures that qualified as an expenditure of a federal award during the period. Effect: The SEFA was revised to include $1,019,828 of expenditures related to ALN #93.461, HRSA COVID-19 Uninsured Program, which resulted in an additional major program and the reissuance of the 2020 reporting package. Corrective Action Plan: 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 2020 Schedule of Expenditures of Federal Awards. Responsible Individual: 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, is responsible for this corrective action that has been put into operation as of 1/1/2025.

Program: Highway Planning & Construction (ALN 20.205) Finding: 2020-001 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: The Harbor Department will ensure that federal expenditures are accurately and completely reported on the SEFA. The expected completion date for implementation of these planned actions will be completed Fiscal Year 2024.

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

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

Finding 2019‐001 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.

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