Corrective Action Plans

2024-003: Material Weakness and Noncompliance – Preparation of Schedule of Expenditures of Federal Awards (SEFA) Statement of Condition/Criteria: The Code of Federal Regulations requires a non-federal entity to 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 CFR Section 200.502(a) and must reconcile amounts reported in the SEFA to the amounts reported in the auditee’s financial statements. Planned Corrective Action: County management will develop a closing process to ensure all federal expenditures are identified, recorded, and reconciled on the SEFA.

2024-001 - Material Weakness and Noncompliance, Completeness and Accuracy of Schedule of Expenditures of Federal and State Awards (Repeat Finding 2023-001) Audit Finding: There were several adjustments to the basic financial statements, Schedule of Expenditure of Federal Awards (SEFA) and Schedule of Expenditures of State Awards (SESA) as originally provided by the Town. The SEFA and SESA balances are required to be reconciled to the basic financial statements prepared in accordance with generally accepted accounting principles in the United States (US GAAP). The Town has failed to adequately perform such reconciliation and as a result of procedures performed by RSM a number of adjustments to expenditures reported on the SEFA and SESA as well as to intergovernmental Revenues reported on the basic financial statements had to be performed. Corrective Action Taken: The Town Finance Department has placed an emphasis on educational meetings with the Board of Education within the area of receiving grants. These issues have resulted from the continual problem of employee turnover of personnel working within the areas of responsibility of grants accounting. All positions in the BOE Finance Department have now been filled, and the Director of Finance at the BOE has implemented monthly reconciliation procedures. From the Town side, the reconciliations between the GAAP financial statements and amounts reported on the SEFA and SESA will be overseen by the Town Comptroller. The Deputy Comptroller and BOE Director of Finance meet regularly to discuss updates and issues and will reconcile the June 30, 2025 reports in the first quarter of FY2026. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

The Office of Financial Management and Budget (OFMB) has collaborated with County departments and agencies that administer grants to ensure staff are informed of and participate in relevant training opportunities related to State and Federal grants. In addition, OFMB continues to monitor grant activity through established agenda review and grant reconciliation processes to identify and address potential errors or omissions and will provide guidance as needed.

Re: FY23-24 Federal Single Audit Finding (2024-001) Name(s) of Contact Person(s) Responsible for Corrective Action: Sean Perez, Finance Director; Jeff Gilbreath, Executive Director Hawaiʻi Community Lending (HCL) is diligent and ensures all grant requirements are met for Federal, State, and private funding awards. Due to the transitioning of its Finance Directors upon the start of the FY23-24 audit, the proper procedures to correct the CDFI ERP project account were miscommunicated, and the Schedule of Expenditures for Federal Awards (SEFA) were not reduced to reflect the proper adjustments. The corrective action being taken by HCL leadership is to ensure all loans disbursed and charged to restricted grants are reviewed thoroughly by the Finance Director. The Finance Director will review all eligibility requirements that are met, to include the eligible mapping area, as required and provided by the funder. This thorough review of eligibility will ensure that all loans charged to restricted funding will be properly allocated and charged correctly. In addition to the thorough review mentioned above, HCL will develop procedures to review the SEFA, in detail, which is prepared by a third-party accounting vendor. The procedures will include an extensive review of expenditures by the Finance Director and subsequent review and approval by the Executive Director to ensure all expenses are eligible and allocated properly to our federal grants. Once the SEFA has been fully reviewed and approved by the Finance Director and Executive Director, it will be forwarded to the auditors. Additional staff may be involved in the review and eligibility confirmation process to ensure accuracy. Internal audits of expenditures will also be completed on a quarterly basis. The anticipated completion date of this corrective action plan is June 30, 2025. Mahalo, Jeff Gilbreath Executive Director Hawaiʻi Community Lending

Finding 2024-004 Personnel Responsible for Corrective Action: Director of Sponsored Programs - Eva Kain, Grant Accountant – Charme Benson and Comptroller – Steve Wille Anticipated Completion Date: June 30, 2025 Corrective Action Plan:. The Grant Accountant, in collaboration with the Comptroller and Director of Sponsored Programs, will compile SEFA data on a quarterly basis and reconcile it against CX reports. The Sponsored Programs Director will verify all Assistance Listing Numbers (ALNs), subrecipient amounts, and accruals. Documentation of all federal awards and drawdowns will be maintained in a centralized repository for internal and audit access.

Finding 2024-003: SEFA Preparation – Subrecipient vs. Subcontractor Determinations Name of Responsible Official: Nikolos Oakley, CFAO Anticipated Completion Date: 09/30/2025 Condition: Subcontractor amounts were improperly included in the Amounts Provided to Subrecipients column on the Schedule of Expenditures of Federal Awards (SEFA). Context: Management made improper subrecipient vs. subcontractor determinations, resulting in inaccurate SEFA preparation. This resulted in $2.6 million being removed from the Amounts Provided to Subrecipients column in the original SEFA provided to the auditors by management. Views of Responsible Officials and Planned Corrective Action: IntraHealth acknowledges the finding regarding the improper inclusion of subcontractor amounts in the Amounts Provided to Subrecipients column on the Schedule of Expenditures of Federal Awards (SEFA). We will improve our reporting and review processes to ensure subcontractor amounts are not incorporated under Amounts Provided to Subrecipients column in SEFA. Corrective Action: • Implement a more rigorous review process to ensure that only true subrecipients are included in the Amounts Provided to Subrecipients column of the SEFA. Subcontractor amounts will be reported separately as required. We will also improve training for the finance and grants management teams to ensure they fully understand the regulations. IntraHealth is committed to ensuring the accuracy of future SEFA reports and will complete the corrective actions by 09/30/2025. We will also continue to monitor the effectiveness of these changes to prevent future misclassifications.

2024-003 – Significant Deficiency – Internal Control Significant Deficiency in Internal Control: Management is responsible for preparing an accurate Schedule of Expenditures of Federal Awards (SEFA). Low-Income Home Energy Assistance expenditures were understated by $54,831 as federal LIAP and Assurance 16 funds were not included on the prepared SEFA. Insufficient internal controls over the preparation and review process for the SEFA to ensure all federal funds were included. Recommendation: The Organization should strengthen its review process to ensure that federal award program revenue reported in the statement of activities reconciles to the amounts reported on the SEFA. As part of this review, all required minimum elements should be traced to original source documentation, including award letters, grant reports, and trial balance profit and loss reports. Responsible Person for Corrective Action: Lindsay Mitchell, Director of Fiscal & Facilities Corrective Action to be Taken: The Finance Director has initiated a training process to ensure that all fiscal team members are equipped to review contracts, grants, and Memorandum of Understanding (MOUs). This includes verifying that all applicable Assistance Listing Numbers (ALNs) are properly identified and that related revenue is accurately tracked within the accounting system. Additionally, a new revenue code has been established to separately track Low-Income Home Energy Assistance Program (LIHEAP) funds from other federal revenues. This ensures accurate reporting and proper classification of federal awards on the Schedule of Expenditures of Federal Awards (SEFA). The anticipated completion date for this corrective action is 9/30/2025.

Views of Responsible Officials: Civic Works acknowledges the deficiencies identified in the preparation of the SEFA for the year ended September 30, 2024. We recognize the significance of accurate reporting of federal expenditures and are committed to implementing corrective actions to address these deficiencies effectively. To address the identified issues, the following corrective actions will be implemented:  Review and Reconciliation of SEFA:  Civic Works will conduct a comprehensive review and reconciliation of the SEFA to ensure that all federal programs are accurately reported, expenditures are properly classified under the correct Assistance Listing Numbers, and amounts reported are reconciled to the general ledger and supporting documentation. Implementation of a SEFA Preparation Checklist:  A detailed SEFA preparation checklist will be developed and utilized by accounting staff to verify the completeness and accuracy of federal award information, including verification of all federal program expenditures, identification of new programs, and validation of Assistance Listing Numbers.  Training and Capacity Building:  Targeted training will be provided to accounting personnel responsible for SEFA preparation to ensure a thorough understanding of SEFA reporting requirements under 2 CFR 200.510(b) and 2 CFR 200.516. The training will emphasize accurate classification, reporting, and reconciliation processes.  Establishment of Review and Approval Procedures:  A secondary review process will be implemented wherein the SEFA will be reviewed by the finance committee before submission.

Finding 2024-002 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 10.555 National School Lunch Program cluster Name of Federal Agency: U.S. Department of Agriculture Compliance/Internal Control over Compliance: Auditee Responsibilities Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the total Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger. Cause: The District relied on individuals with insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have sufficient training or monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Expenditures of federal awards and not be detected and corrected. Because the Auditee’s SEFA was completed incorrectly, and not reconciled to the general ledger the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following: • SEFA was originally presented for auditors with incorrect information. • No reconciliation between federal expenditures reported on the GL and the SEFA was presented. • Recording of State vs Federal activities was not posted to the GL correctly, requiring adjustments during the audit. • Not all grants were recorded in separate and identifiable GL accounts. Repeat of a Prior-Year Finding: Yes Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. City’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Planned Implementation Date: October 1, 2025 Responsible Person: Director of Business Services, Myrtle Point School District No. 41

: Borough Finance staff have redesigned the methodology for the fiscal year end reconciliation between the amounts reported to grantors, the amounts recorded in the General Ledger and the amounts reported in the Schedule of Expenditures of Federal Awards (SEFA). Going forward the amounts recorded in the General Ledger will tie to the amounts reported in the SEFA and any reconciling items will be noted on the reconciliation between the General Ledger and the amounts reported to the grantors. Completion Date: June 30, 2025

Views of responsible officials and planned corrective actions: The Clinic will be seeking professional consultation and guidance on a process to support and enforce monthly reconciliations of the amounts submitted for the grant with the amounts booked within the system, using appropriate grant-tracking schedules. Relevant staff will be retrained, and a monthly review will be completed by an appropriate professional and submitted to the Chief Executive Officer (CEO). Personnel responsible for implementation: Deborah Lerner, CEO and Board of Directors Date of implementation: July 1, 2025

Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Auditee’s Corrective Action Plan: The city’s legacy financial system did not collect data required for SEFA. Agencies had to provide most details manually and work between spreadsheets and multiple systems to input and track receipt grant awards and spend on personnel, supplies and services and sub-recipient awards related to grants. The steps to address this legacy finding have been phased and include the technology implementation, staff training and additional oversight. As noted, the City implemented Workday, an Enterprise Resource Planning (ERP) system, across workstreams so that Financial Accounting, Grants, Procurement, Supplier Accounts, Banking, Payroll and Human Resources are all in one system. As with any ERP, an ongoing process of evaluation and updates are needed to continuously align workflow and business processes. This approach has led to continued improvement over the years as the grants management module is fully implemented in Workday. Since implementation, additional enhancements have been adopted and utilized with a robust workflow process for grant approval, grant budget tracking, and invoice scheduling. In addition to the technology adoption, an increase in citywide grants training and oversight has been implemented. The progress is detailed below: • FY 23 represented the first year in the new system. To compile the SEFA, the City used a hybrid approach to leverage Workday and Agency provided data. o There were some data accuracy challenges from data entry errors. To address those data entry challenges the award modification business process was improved post-implementation to add a GMO review and approval step of award modifications. o As of May 2024, all award modifications now require centralized GMO review to verify data accuracy. o Additional process changes in FY 23 included implementation of the requirement as part of the FY 24 budget preparation process that grant worktags must be created and budgeted for during the City’s annual budget process. The grant worktag creation process includes approvals at the agency program and fiscal levels, as well as at the Department of Finance level. • In FY24 further Award Module enhancements were adopted to provide key new data points in Workday. o Each grant award now includes information: Federal Assistance Listing Number (fna CFDA#), Passthrough Agencies & Passthrough Identifier. o Additionally, in FY 24, GMO, in collaboration with BAPS launched the Grants Workstream Training sessions. These monthly citywide virtual live trainings are on a variety of grant management related topics, averaging 60 attendees per session. Attendees are city agency grant managers and city agency fiscal staff. • In FY 24 and FY 25 the topics covered included: o FY 24 Grant Work tag Preparation o FY 24 SEFA Preparation o Grant Accounting Best Practices and Workday Billing o Award Set-up Best Practice & Potential Pitfalls o Extra Features in Workday (including reporting and how to set up award tasks and deadlines) o Subrecipient Monitoring Best Practices o Cost-reimbursable grant invoicing in Workday o FY 25 SEFA preparation o FY 26 Grant Work tag Preparation o Grant Management Roles and Responsibilities o Specific training on the SEFA, including information on understanding the importance of the SEFA, what information is included and how to review SEFA data, was conducted. Citywide training sessions were held in FY 24 and FY 25 to ensure that the reporting is understood by city agencies, with special emphasis on subrecipient payments being reported properly. The training schedule is ongoing and continuous. • To improve SEFA reporting data, in FY 25 there is an emphasis on subrecipient set up and spending to ensure that functionality is refined to improve uniformity in subrecipient set up. GMO, in conjunction with BAPS, the Bureau of Procurement and city agencies will work to refine subrecipient set up, spending and monitoring, including improved reporting. o GMO has hosted three subrecipient monitoring and management–related trainings since December 2024. Additionally, to improve subrecipient managing and monitoring, GMO modified the award setup business process in Workday to include verification of subaward status before final award setup approval. In FY 25, GMO provided training on how to setup subawards accurately in Workday. As discussed above, these trainings will be ongoing. • Additionally, GMO and the BBMR will collaborate on a subaward dashboard to monitor subrecipient spending data in real time. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City Completion Date: FY26 3rd Quarter- • Design and complete a grants management dashboard within Workday • Ongoing and continuous - GMO will continue to conduct trainings on SEFA reporting and subrecipient management and reporting.

Finding 2024-006 Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing No.: 97.036 Federal Grantor: U.S. Department of Homeland Security Passed-through: California Governor's Office of Emergency Services Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the Schedule of Expenditures of Federal Awards. Compliance Requirements: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control Over Compliance Department’s Management Response: Management agrees with the recommendation that the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance. View of Responsible Officials and Corrective Action: To ensure the completeness of Disaster Grant expenditures reported on the SEFA, the Auditor-Controller’s Office will obtain a listing of all projects from the FEMA Grants Portal. This list will be used to verify that all obligated projects have been accurately reported on the SEFA. Name of Responsible Persons: Jason McGuire, Deputy Director, Auditor-Controller Implementation Date: July 2025

Finding 2024-004 Program: Crime Victim Assistance Assistance Listing No.: 16.575 Federal Grantor: U.S. Department of Justice Passed-through: California Governor’s Office of Emergency Services Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the Schedule of Expenditures of Federal Awards. Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control Over Compliance Department’s Management Response: Management agrees with the recommendation to enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance. View of Responsible Officials and Corrective Action: To ensure compliance with §200.510(b) of the Uniform Guidance, the Auditor-Controller’s Office will provide additional detailed instructions when requesting departmental information for the County’s SEFA. In addition, County-wide training will be conducted to assist departments in accurately completing the request. Name of Responsible Persons: Jason McGuire, Deputy Director, Auditor-Controller Implementation Date: August 2025

Finding 2024-009 Program: CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Direct Award and Pass-Through City of San Buenaventura Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807 Year: 2024 Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control over Compliance Department’s Management Response: Management agrees with the recommendation that the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA. View of Responsible Officials and Corrective Action: To ensure compliance with §200.510(b) of the Uniform Guidance, the Auditor-Controller’s Office will provide additional detailed instructions when requesting departmental information for the County’s SEFA including obtaining expenditure details to support costs reported for subrecipients. In addition, a countywide training session will be conducted to assist departments in accurately completing the request. Name of Responsible Persons: Jason McGuire, Deputy Director, Auditor-Controller Implementation Date: August 2025

Almost Home has begun establishing and finalizing a formal SEFA preparation schedule. Almost Home will also be retaining a CPA/Audit Consultant to work with the staff and conduct periodic reviews of the audit process and status.

Views of Responsible Officials and Planned Corrective Action The County has established a document and an internal control structure designed for tracking in the future. Finding resolution timeline: This has been resolved for FY 25 as of 03/20/2025. Designation of employee position responsible for meeting this deadline: Andrea Montoya, Deputy County Manager

The University concurs with the recommendation. The University will review and enhance its procedures and internal controls to ensure the SEFA is complete and accurate

CORRECTIVE ACTION PLAN 3/27/2025 US Department of Health and Human Services CARES of NY, Inc. respectfully submits the following corrective action plan for the year ended April 30, 2024. Name and address of independent public accounting firm: Wojeski & Company CPAs, PC 159 Wolf Road Albany, NY 12205 Audit period: Year ending April 30, 2024 The findings from the April 30, 2024 schedule of findings and questions costs are discussed below. The findings are numbered consistent with the numbers assigned in the schedule. Finding 2024-0001 – Reporting of the Schedule of Expenditure of Federal Awards Recommendation: We recommend that the Organization implement additional processes and procedures to ensure that the SEFA is complete and accurate. Corrective Action plan taken: The corrective action taken was to notify Auditors as soon as the error was realized so that audits could be corrected. There is no need for further corrective action. This incident was isolated and not recurring. The grant for which this finding is associated was a temporary covid grant that has since ended. To prevent future errors for occurring, all new contracts will be reviewed prior to submitting the summary of federal awards to the auditor to ensure that any federally sourced funding is properly identified regardless of grantor. CARES of NY, Inc. will implement a check and balance procedure where the grants director will review the listing prior to audit submission for accuracy. Responsible Person for corrective action plan: Eileen Wiebicke, Chief Financial Officer Anticipated completion date for corrective action plan: 1/24/2025 (date auditors were notified of error) If the US Department of Health and Human Services has questions regarding this plan, please call Eileen Wiebicke at 518-489-4130 x 702.

Recommendation noted. Staff has requested a quote from our QuickBooks advisor, Kemper CPAs.

The District has determined that it is more cost effective to continue to engage the auditor to prepare the schedule of expenditure of federal awards.

The City internally identify improvement opportunities in managing grants. As a part of the City’s grant oversight improvement efforts, the City began implementing various processes and internal controls surrounding grant monitoring, which improves the SEFA drafting process and mitigates risks of future inaccuracies. These efforts began in early 2024 and include the following: • Creation of a grant policy that provides City staff with guidance, information, and expectations surrounding grants. • Creation of a master grants database that lists the general ledger fund, applicable project ledger references, status, grant type, start/end dates, granting agency, pass-through agency, grant name, assistance listing numbers, grant amounts, and the grant manager for each grant. This database is now used to verify the completeness and accuracy of the SEFA (beginning FY24). • Formal quarterly monitoring. Each quarter, the City will formally review the grants database with department contacts and grant managers to verify the completeness and accuracy of the database. The City is formalizing this process and plans to include department signoffs evidencing the review process. If any items are missing, the missing component will be identified and added to the database on a timely basis. The City will also utilize this quarterly process to review the grants policy to ensure grant managers are aware of the requirements related to their grants. • The City is in the process of formalizing the SEFA drafting process utilized during the FY24 SEFA preparation, which includes additional mitigating procedures such as reviewing all next FY federal receipts to ensure none of them relate to the SEFA year federal expenditures. Personnel Responsible for Implementation: Marvin Lopez Position of Responsible Personnel: Deputy Administrative Services Director (Fiscal Services) Expected Date of Implementation: June 30, 2025

The City agrees with the auditor’s finding and recommendation. The City will add additional internal controls surrounding the review of funding sources to ensure correct classification of State and Federal Funding.

Management attempted to contract with multiple accounting consultants for creating the SEFA but they were already at full capacity and were not available to assist with the creation of the report. When the relevant contract or grant award did not include the necessary information, SCEC management and program staff reached out to our contracting agencies to confirm whether federal funds were part of each award and to find out CFDA numbers and other contract information necessary to complete the form. Nevertheless, there were several errors that in the SEFA submitted to our auditors for review. For the two IRP and RMAP lending programs, the prior year balances were carried over into the FY 24 SEFA through a clerical error. The errors in item 11.037 and 11.419 are related to information we received from the contracting agency. In particular, 11.037 was listed under US Economic Development Administration according to the contracting agency and we were given the description of Economic Adjustment Assistance. The description for 11.419 was given to SCEC by the contracting agency as CDS – Congressionally Directed Spending. Finally, we provided two CFDA’s for the STEM Education award with the submission of the SEFA as we were waiting for confirmation from Program Managers about the correct CDFA numbers. The auditors were informed that we were waiting for these numbers when the SEFA was submitted. In FY24, SCEC had 29 different federal funding sources, from 14 different agencies. We are working to improve our capacity to report these awards without error before the review of our auditors.

Management is implementing enhanced controls and formal procedures to ensure that all funding sources, particularly those received through intermediary or passthroughentities, are correctly identified and appropriately classified for reporting. These measures include: - Expanding documentation requests to verify funding sources. - Maintaining ongoing dialogue with pass-through entities to confirm federal assistance classifications.