Corrective Action Plans

Federal Program Child Nutrition Cluster - Passed through the Pennsylvania Department of Education and Pennsylvania Department of Agriculture ALNs 10.555 and 10.553 Education Stabilization Fund - Passed through the Pennsylvania Department of Education ALN 84.425 Criteria Per the Uniform Guidance 2 CFR 200.510, the auditee is required to prepare a schedule of expenditures of federal awards (SEFA). Condition The District prepared a SEFA and provided information relating to the federal programs including grant agreements and other supporting documentation. However, the SEFA prepared by the auditee required material adjustments as a result of audit procedures. Cause Certain account reconciliations were not performed prior to the audit, which impacted amounts reported on the SEFA. Effect Amounts reported on the SEFA provided by the auditee were not accurate. The SEFA was subsequently updated through audit procedures, including inquiry and review of grant documentation of awards received and amounts expended. Questioned Costs None. Context A SEFA was prepared by management; however, several adjustments were required in order for the schedule to accurately reflect the current year activity. Repeat Finding Yes. See finding 2022-003. Recommendation In order to meet Uniform Guidance requirements, the District 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 new Assistant Business Manager has been trained in Uniform Guidance requirements as well as Federal program guidelines. This should not happen in the future.

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.

The Village Treasurer will start preparing the Schedule of Expenditures of Federal Awards each year or contract with a CPA firm for assistance in preparing the Schedule of Expenditures of Federal Awards each year.

A grant manager and grant-financial coordinator have been hired to work with the finance team to communicate the whole gamut of applicable elements of ASC 606. Also, we are purchasing a grant management system—not a manual Excel sheet- that can scan grants and identify conditions and restrictions.

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

Finding 2023-004 - Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Management (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education 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: Errors in recording and reporting of revenues and expenditures of federal awards may not be detected and/or corrected. Because the Auditee’s SEFA that was presented for audit 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. • Inadequate reconciliation between federal expenditures reported on the GL and the SEFA was presented. Repeat of a Prior-Year Finding: No 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. District’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: November 1, 2024 Responsible Person: District Business Manager

All future federal expenditures will be reconciled to the disbursement ledger.

The Organization experienced substantial growth of programmatic activities which required the department to focus on ongoing maintenance and tracking. The Organization completed a significant components of year end close in the fall of 2023 and final review and adjustments to the SEFA were conducted in January 2025. The department is finalizing the year end close for the next year end close and will focus on the completeness and accuracy of the SEFA.

I was a newly elected official in 2023 with no prior training in the County Clerk’s office. I had no knowledge of how SEFA monies were to be reported. After this finding was brought to my attention, internal controls were implemented. A process/procedure was put into place where all grants received are tracked, as are the expenditures for each grant. The clerk and deputy clerk are now involved in the grant tracking procedure as well as reviewing the SEFA report for accuracy after it is prepared. In January 2025 a Grant Policy was adopted by the Caldwell County Commission to make all county employees aware of the process for reporting and tracking grants received. The Grant Expenditures and Reimbursements Tracking Procedures were also revised. The procedure now involves not only the county clerk and deputy clerk, but also the grant applicant, accounts payable clerk, and the county Collector/Treasurer. The SEFA report will be reviewed by all involved to help ensure accuracy. Anticipated Completion Date: It is anticipated that the 2025 SEFA grant reporting will be much more accurate than in previous years. However, considering the new Grant Policy and the revised Grant Expenditures and Reimbursement Tracking Procedures were not in place until January 2025, it is anticipated that the date of completion will be January 2026.

County’s Response: The County Clerk will implement a procedure to keep more detailed records that accurately states the expenditures of federal awards of the County.

Finding 2023-004- Lack of Effective Controls Over Preparation of Schedule of Expenditures of Federal Awards Grantor: U.S. Department of the Treasury Assisstance Listing#: 21.027 Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Year: Fiscal year 2023 9/1/22-8/31/23 Award Number: Not Listed Management understands the importance of effective internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA). At the time of preparing the 2023 SEFA, $2 Million was improperly excluded causing the reported to be restated. Corrective Action Plan and Anticipated Completion Date: The total expenditures reported in error for the 2023 SEFA will be restated and the consolidated Financial and Compliance Report in Accordance with the Uniform Guidance will be re-sibmitted to the appropriate federal and state agencies. On a go forward basis, management's review will include a reconciliation of all grant expenses reported on the current SEFA to the grant awards listed on the State of Illinois Department of Public Health (IDPH) grant portal (EGrMS) to ensure all federal awards are reported.

Management understands that all Federal programs (even as a sub-awardee) need to be part of the SEFA schedule. Going forward Financial Administrator will ensure to include all programs associated with Federal Award (direct or indirect) on the SEFA schedule. Carefully review all contracts to ensure that all contracts that are included, if any questions arise, a third-party consultant will be contacted. Anticipated Completion Date: June 30, 2024. Responsible Contact Party: Olga Batkhan, Financial Administrator.

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

CONDITION: The Regional Office of Education No. 39 did not have sufficient internal controls over the preparation of the SEFA to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. PLAN: The ROE will implement controls over financial statements for both the internal Business Office Manager and the contracted accounting firm to prepare and review the financial statements including the schedule of expenditures of federal awards, to ensure program titles, assistance listing numbers and other pertinent information is accurate for financial statement presentation ANTICIPATED DATE OF COMPLETION: The anticipated date of completion is December 2024. CONTACT PERSON: Jill Reedy, Regional Superintendent

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.

I was a newly elected official in 2023 with no prior training in the County Clerk’s office. After this finding was brought to my attention, I created a process where all grants received are tracked as are the expenditures for each grant so they can accurately be reported.

I was not the clerk in 2023, so I don’t feel as I can respond, however, I will work to see this is resolved. We are implementing new software to better track all financials.

Material Weakness and Noncompliance – Preparation of Schedule of Expenditures of Federal Awards (SEFA) Statement of Condition/Criteria: The Code of Federal Regulations requires a nonfederal 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. Contact person responsible for corrective action: Ashleigh Young, County Controller/Administrator Anticipated Completion Date: March 2025

The Board of Directors hired Gorman Management Company (GMC) on March 1, 2024, to operate the property, Ardmore Village. GMC has extensive experience in the on-site and financial management of properties like Ardmore Village. Specifically, GMC has procedures in place to maintain compliance with the regulations applicable to the Section 8/202 program and the FHA Section 223f program. GMC is well versed with CFR §200.512 (single audit data collection form), HUD Handbooks 4350.3, 4370.2 and 4381.5. GMC manages over 40 properties that have similar reporting and auditing requirements. All of the issues related to these findings will cure through GM C's policies and procedures.

Finding No. 2023-006: Inaccurate Reporting on the Supplementary Schedule of Expenditures of Federal Awards ALN and Program Expenditures: 97.036 ($5,258,177) Program Name: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Corrective Action: Process Improvements: - The University will establish a Supplementary Schedule of Expenditures of Federal Awards (SEFA) controls narrative to formalize preparation and reconciliation processes of SEFA data. - The central University Research Administration team (URA), in coordination with Finance and Administration, will review SEFA preparation and data collection processes and establish a formalized reconciliation process. - Biannually, URA will conduct third party searches to verify funding received at each entity. Expected Implementation: August 2024 – December 2024 Contact: Jennifer A. Ponting (Associate Vice President, Research Administration)

Due to no fault of Southern Workforce Board, Inc., and circumstances beyond the previous CAP's control, the audit report for the period ending 6/30/2023 was not completed as required. Upon notification of prior audit firm closing, Southern Workforce Board, Inc. performed an immediate procurement by soliciting a Request for Proposal to 13 audit firms. Upon completion of the procurement, Michael Green, CPA was selected to perform the 6/30/2023 audit as soon as their schedule would allow. Upon successful completions of 6/30/2023 audit report, the audit process for the period ending 6/30/2024 will proceed on time. Southern Workforce Board, Inc. will ensure in the future that the audit firm selected will be able to perform the planned audits in a timely manner in the future.

Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes Auditee’s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is “live” as of August 2022, the City is currently working to refine the software and fully utilize functionality. The Workday grants modules requires the grant funding source be defined prior to grant approval and fields are available for the AL titles and numbers and sub-recipients’ information. The implementation of the Workday grants modules centralizes much of the grant management function by requiring the agencies to upload the grant documents into Workday. The City has: • Held weekly meetings for two years with agency grant representatives to design and configure the Workday grant module. • Uploaded the grant award, sponsor information and grant budget data into a Workday. • Implemented a “new grant” request which uses a Workday business process. • In the process of reviewing and correcting recoverable costs per grant award so it is properly recorded. • Within Workday we are able to track grant performance period, CFDA, manage and capture grant related expenditures and calculate automated billing to sponsors on recoverable costs Business processes have been developed and implemented in Workday’s grant management module to include: Definition of the grant funding source by creating a system-generated grant work tag (identifier) upon receipt of the Sponsor’s Notice of Award; populated fields in Workday with passthrough award data with Prime Sponsor and Bill to sponsor Billing data, and modification of the create award process to add the Grants Management Office to final approval. In FY 24 the City implemented a citywide Grants Management Committee coordinated by the Mayor's Office of Performance and Innovation. Through feedback from this workgroup we identified an expanded scope of responsibility for the Grants Management Office; including oversight and compliance, technology, training and budget monitoring. In the short term a new Grants Director position was created and onboarding is to occur in the first quarter of FY25. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City. Completion Date: June 2024

Condition: The Authority did not identify that they were subject to an audit under the Uniform Guidance (U.G.) and a schedule of expenditures of federal awards (SEFA) was not prepared by management. Recommendation: The Authority should review federal, state, and local grants to determine if they are federally funded and, if federally funded, utilize the account number outlined in the State of Michigan chart of accounts to track federal funding. Planned Corrective Action: A schedule of federal awards will be created to track total costs covered by federal awards beginning in FY24. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024

The Treasurer will review the Schedule of Expenditures of Federal Awards to ensure all federal awards are being reported and the expenditures are properly reported.

Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Finding: 2023-011 Contact Person: Sarah Castillo Grants Accounting Officer Emergency Operations Center (EOC) Finance Division Phone: (562) 570-5479 Email: Sarah.Castillo@longbeach.gov Planned Actions: The Emergency Operations Center (EOC) Finance division acknowledges there has been deficiencies in the manner we report expenditures related to a declared disaster on the SEFA, which will be addressed by issuing a Financial Management Disaster Procedure Manual that will include a narrative on this specific matter. The manual will be published on our City Intranet and utilized for all City Staff as a resource for all future disasters that occur. Revisions to the Procedure Manual will be made as needed to ensure we are up to date with the latest compliance changes. Expected Completion Date: 12/31/2024