Corrective Action Plans

Finding 2023-002 – Reporting (Compliance; Internal Control Over Compliance) Condition: The School District did not complete and submit their audit to the Federal Audit Clearinghouse by the due date of March 31, 2023. Recommendation: We recommend the School District become familiar with reporting requirements for each award and implement procedures to begin audit preparation work earlier in the fiscal year to ensure reports are filed within the nine-month reporting deadline set forth by Uniform Guidance. Finding 2023-002 – Reporting (Compliance; Internal Control Over Compliance), continued Views of Responsible Officials: The District hired new Financial Staff as of July 1, 2023. The Financial Consultant did not renew an agreement for assistance for the 2023-24 fiscal year. New Finance Staff did not provide audit information on a timely basis to the audit firm. The Financial Consultant was rehired on May 2024 and has since been working with the audit firm to provide the needed information in a timely fashion. The District is retaining the current audit firm with anticipation of the report for the 2023-24 fiscal year being issued and filed on a timely basis. Rachel Pretty On Top, Chairman of the Board Lodge Grass School District

MIRACLE SQUARE, INC. Sumter, South Carolina CORRECTIVE ACTION PLAN October 29, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Miracle Square, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2023. Bernard Robinson & Company, L.L.P. Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year ended December 31, 2023 The findings from the Schedule of Findings and Questioned Costs for the year ended December 31, 2023 are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2023-001 - U.S. Department of Housing and Urban Development, Supportive Housing for Persons with Disabilities (Section 811), Assistance Listing #14.181 Recommendation: We recommend the board of directors and management ensure that the annual financial reports to HUD are submitted by the required due date. Action Taken: We agree with Finding 2023-001 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the annual financial statements are submitted once the audits are back on track with the scheduled due dates. Finding 2023-002 - U.S. Department of Housing and Urban Development, Supportive Housing for Persons with Disabilities (Section 811), Assistance Listing #14.181 Recommendation: We recommend the board of directors and management ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. Action Taken: We agree with Finding 2023-002 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the data collection forms are submitted electronically to the FAC each fiscal year. If HUD has questions regarding this plan, please call (803) 808-3966. Sincerely yours, Reese Quick, President Southern Development Management Company, Inc.

FINDING 2023-001 NONCOMPLIANCE - REPORT SUBMISSION Program Title/Federal Grantor/ALN: Foster Care Title IV-E U.S. Department of Health and Human Services Assistance Listing Number 93.658 Corrective Action Plan The Organization will file the SF-SAC Single Audit Data Collection Form by the due date or file an extension when needed. Name of the Contact Person Responsible for Corrective Action Brian Gambini, Administrator Anticipated Completion Date September 30, 2025

Management's Response: We concur. View of Responsible Officials and Corrective Action: In 2024, TPREF engaged an independent accounting firm to reconcile all accounts and perform month-end and year-end close activities. Also in 2023-2024, TPREF reviewed and established proper utilization of new accounting software to support timely reporting to align with policies and procedures. To provide greater oversight and supervision, and to ensure timely and accurate charging of expenses, billing, and revenue recognition, the accounting firm assumed responsibility for accounts receivable with reporting to the CEO. In 2025, the accounting firm will be supplemented by an in-house bookkeeper to manage accounts receivables with oversight by the CEO and accounting firm. Anticipated Completion Date: The onboarding to new accounting firm was completed in September 2024 and TPREF has transitioned to regular client services management. By end of the first quarter 2025, TPREF will have hired and onboarded an in-house bookkeeper to supplement the accounting firm.

Finding 2023-001—Reporting BAERI acknowledges the repeated finding related to reporting. The inability to meet the reporting deadline for the 2023 audit stems from the concurrent timing of the 2022 and 2023 audits, which prevented the implementation of the corrective action plan outlined in our 2022 audit response. BAERI has fully implemented the corrective action plan developed in response to Finding 2022-001. These corrective actions include: 1. Policies and procedures to ensure internal documentation required for the annual audit is easily accessible to finance staff and not onerous to compile for auditors. 2. The hiring and training of additional finance staff to support the implementation of these policies and ensure a smooth and timely audit process. Due to the concurrent completion of the 2022 and 2023 audits, these measures were not able to impact the 2023 audit. However, they are now in place and will be reflected in the 2024 audit, which will be completed by June 2025. Additionally, BAERI has transitioned its fiscal year from a calendar year to a federal fiscal year (October 1 to September 30). This change will better align our reporting timelines with federal requirements and further support timely submissions. The 2024 audit report and SF-SAC form will be submitted to the Federal Audit Clearinghouse within nine months after the end of the audit period, demonstrating compliance with 2 CFR 200.512. BAERI remains committed to improving its compliance and ensuring timely reporting in future audits.

Recommendations: We recommend that the Authority strengthen its internal controls and improve oversight of the audit process to ensure timely completion and submission of future reports. Additionally, the recipient should work closely with the audit firm to establish clearer timelines and ensure that any delays are addressed promptly. Authority Response: Leadership recognizes the federal award finding and questioned costs and is already moving forward with a systems change to ensure timeliness of completing the necessary processes with the annual audit.

Name of Auditee: Springfield Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2023 CAP Prepared by: Denise Jordan, Executive Director Phone: (413) 785-4500 (A) Current Findings on the Schedule of Findings and Questioned Costs (3) Finding 2023-003 (a) Comments on the finding and recommendation - The Authority agrees with the findings. However, the root of the issue is related to complications with the software conversion to Yardi. (b) Action taken - The Authority has replaced Yardi with PHA-Web for its accounting software. (c) Planned implementation date of corrective action - Completed on October 31, 2024.

Finding No. 2023-001: Compliance with Single Audit Requirements Description of the Finding: Big Sky Economic Development Corporation, Inc. (BSEDC) did not engage to conduct a single audit for FY23 despite meeting the expenditure threshold, and the required audit report was not submitted within the prescribed due dates. This oversight necessitated the reissuance of the FY23 financial statement audit to complete and issue a single audit. Planned Corrective Actions: BSEDC’s Senior Director of Finance engaged with an independent auditor to complete the single audit for FY23 and re-issue the financial statement audit which was missed during the performance of the FY23 financial statement audit due to the Senior Director of Finance and the parties they engaged to perform the audit not having a clear understanding of the calculation for federal expenditures for the federal revolving loan fund. The Senior Director of Finance now has a clear understanding of the requirements for the calculation and reporting of federal expenditures in the Schedule Expenditures of Federal Awards as it relates to the federal revolving laon fund. Timeline for Completion: BSEDC engaged with an independent auditor to complete the single audit for FY23 and reissue the FY23 financial statement audit in June 2024. Expected completion is November 2024. Responsible Person or Party: BSEDC’s Senior Director of Finance is responsible for implementing the corrective action.

Finding 2023-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended June 30, 2023, management was unable to provide timely year end trial balances in accordance with U.S. GAAP without significant adjusting journal entries required to accurately reflect the underlying accounting transactions. Recommendation We recommend that individuals overseeing the accounting and finance department continue to review the Organization’s current accounting policies and update existing policies or implement new policies, as needed, to ensure that the trial balances are accurately maintained throughout the year, reconciliations are completed and reviewed monthly or quarterly, as appropriate, and the trial balances and related supporting schedules are prepared and reviewed timely after year-end. Management’s Corrective Action Plan There was significant turnover in the finance department, including the CFO and the finance director. These turnovers affected the ability of the organization to produce the information on time for the auditors. The Organization is working with external consultants to improve the timeliness of reconciliations and audit preparation and recruiting vacant positions. We completed accounting policy changes which will correct the issues noted. Management is confident that the issues that have been noted will be rectified in the fiscal year ending June 30, 2024. Contact Person: Cynthia Benton, Chief Financial Officer Anticipated Completion Date: June 30, 2024

We agree with this finding. The Chief Financial Officer in collaboration with the Assistant Director for Finance and the Assistant Director for Financial Compliance will set a calendar at the end of the fiscal year to ensure timely closeout of the books that will allow ample time to engage and complete the audit prior to the deadline for the FAC filing.

Federal Assistance Listing Number: 93.959 Block Grants for Prevention and Treatment of Substance Abuse Condition The Organization’s Data Collection Form submission to the Federal Audit Clearinghouse was not filed on time within nine months of the end of its fiscal year. Views of Responsible Officials and Corrective Action Although a new consulting firm was engaged to complete the June 30, 2023 financial statement audit and ensure filing of the June 30, 2023 Single Audit within nine months of the end of the fiscal year, additional time was needed to complete accurate fiscal records for the year ended June 30, 2023. Monthly closings and fiscal records reconciliations for the year ending June 30, 2024, are being conducted on a timely basis. As a result, we are expecting an on-time filing of the Data Collection form for the year ended June 30, 2024.

Finding Number: 2023-003 Finding Name: Data Collection Form Late Submission Finding Synopsis: The organization did not submit the December 31, 2023 data collection form and reporting package to the Federal Audit Clearinghouse in a timely matter. Action Steps: The late submission was due to switching audit service providers. Systems and procedures are already in place to ensure timely completion of audit and submission of the audit package to the Federal Audit Clearinghouse. Management is now aware that when switching audit firms we will have to allocate more time for the new firm to get familiar with the agency. Contact Person(s): William Chatman, Executive Director/CEO, 815-963-6236 Claudia Seijas, Director of Finance, 815-963-6236 Anticipated Completion Date: Continues

2023-002: Late Audit Submission Auditor's Recommendation: SWCAP should take steps to ensure that its financial records are available in a timely manner to allow the audit to begin sufficiently before the audit due date. SWCAP also should work with their auditing firm to agree upon information that will and will not be prepared by SWCAP so that a proper audit plan can be developed for timely completion. Corrective Action: SWCAP acknowledges the delay in completing the 2023 audit. The unforeseen staffing challenges by our auditing firm in conjunction with our internal turnover significantly impacted our timeline. SWCAP has identified and implemented changes with its personnel and hired an outsourced accounting firm. SWCAP has implemented proactive measures to streamline its audit preparation and submission processes to prevent similar delays in the future. These include enhancing internal review procedures, ensuring clear communication with auditors, and allocating sufficient resources for timely compliance with reporting requirements, federal regulations, and guidelines. Responsible for Corrective Action: Finance Team (Outsourced accounting firm, Operations Manager, Executive Director). Anticipated Completion Date: Completed as of December 2024.

View of Responsible Officials and Corrective Action Plan – The Academies will develop a reliable system that will lead to the timely processing of the financial records by reviewing existing procedures to identify bottlenecks and areas of improvement. Feedback will be gathered from team members involved in the financial record keeping process so that standard procedures can be development and implemented. Furthermore, opportunities to automate processes and use software to assist with data entry, record reconciliation, and reporting can be used. This will significantly decrease manual workload and improve accuracy and timeliness.

The Center intends to identify appropriate resources and implement procedures necessary for timely submission of the Single Audit report in the future.

To address these issues, the newly appointed Director has implemented procedures to ensure the timely closing of accounting recrds, subsidiaries, and reconciliations, following procedures in place including ATI-0001-2025 (Accounting and Finance Operations), ATI -0002-2015 (Period End Procedures), and ATI-0005-2015 (accounts Payable). These efforts include establishing a structured closing schedule, standardizing record maintenance processes, and enhancing reconciliation protocols. Additional measures such as improving the tracking and archival of financial records have also been introduced. Furthermore, a team consisting of both internal staff and external consultants has been assigned to support these inititives and facilitate the timely completion of the Single Audit process.

Management’s Response: Management acknowledges the delay in submission and is taking corrective action to address the issue. Steps include improving internal controls, implementing a detailed timeline for the audit process, etc. Management is committed to ensuring future compliance with reporting deadlines.

2023-001 – Reporting – Submission of the Data Collection Form Individuals Responsible for Corrective Action Plan: J. Neal Bolton, Director of Revenue Management & Budget Shemaine Rose, Controller Anticipated Completion Date: December 2024 Management acknowledges that the reporting package and data collection form for the year ended June 30, 2023, was not filed with the Federal Audit Clearinghouse on or before the deadline of March 31, 2024. Management maintains that appropriate schedules and notes thereto were prepared accurately and timely, and that the delay was due primarily to the unique nature of Provider Relief Funds being reported, which resulted in evolving compliance requirements over the funding and reporting periods. Management will file the reporting package and data collection form immediately upon completion and will continue to monitor and adhere to future Federal compliance updates to prevent such delays in the future.

As of 2017, the Puerto Rico Treasury Deparment decreed that all government agencies are required to submit their financial statement for review before making it official, In order to complete and submit the Single Audit Report, the Authority is also required to included information on retirees, their post-emplymnet benefits and their pension. These new requiremt as mentined above are extremely delay in completion of the reports.

Recommendation: We recommend the organization work closely with the audit firm to ensure that the single audit reporting package is issued by the deadline or within a federally approved extended date along with submitting the required data collection form with the Federal Audit Clearinghouse. Response: The delinquent single audit reporting package and data collection form will be filed in December 2024. Going forward, we will work with the external audit firm to ensure that their required grant testing is completed, and the single audit reports included with the single audit reporting package, as well as the required data collection form is submitted to the Federal Audit Clearinghouse within the required or extended due date each year.

Management Response #2023-004: Due to staffing shortages and turnover, the company lacked sufficient personnel to adequately monitor or document grant activities which led to the delay in timely filing of the audit with the Federal Audit Clearinghouse. Corrective Action Plan: The following actions have been implemented to address the issue: • The finance team redefined and expanded roles to designate specific staff members whose primary responsibility is to monitor and manage all grant activities. • The finance team developed Project Budget Reports for each federal award. These reports include a detailed budget, monthly expenses, and monthly revenue (drawdowns). The reports will be reviewed and reconciled by both the grants administration staff and the finance team on a monthly basis to ensure alignment with allocated costs. This process ensures compliance with grant regulations and supports the timely reconciliation of grants, which is crucial for year-end reporting, preparation of the Federal Financial Reports (FFRs), SEFA, audit preparations, and data collection for the Federal Audit Clearinghouse (FAC). Responsible Party: Tamara Barnes, CFO

2023-008 Reporting Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. The necessary reports will be filed as soon as they are available.

Eastern Carolina Human Services Agency, Inc. Corrective Action Plan For FY Ending June 30, 2023 Section II. Financial Statement Findings. 1. Finding 2023-001 - U.S. Department of Health and Human Services, Community Services Block Grant, Assistance Listing #93.569; U.S. Department of Housing and Urban Development, Housing Voucher Cluster, Assistance Listing #14.871/14.879. Statement of Condition: Internal control processes over financial accounting did not ensure that all transactions were properly recorded. Internal control processes over financial accounting did not ensure that key accounts were reconciled or received on a periodic basis. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director. Action Plan: After review/monitoring of the previous Finance Officers duties and responsibilities, it was determined that the internal control processes of the finance department were not carried out properly to meet the requirements of 2 CFR Part 200 Section 200.302. Therefore, the agency terminated the Finance Officer. The agency immediately began the search for a new Finance Officer via Indeed and other employment hiring agencies. This process took much longer than expected which left an unexperienced Accounting Technician to operate the Finance Department along with limited finance knowledge of the Executive Director. After several advertisements for the vacant position the agency interviewed numerous applicants and was finally able to hire the current Finance Officer. The Finance Officer has worked continuously to insure that the internal control process of the department is implemented by making sure all accounts are reconciled and reviewed with supporting evidence of each review. With this process back in place, management and the Board of Directors will review and sign off on each account's financial statements. Additionally, the agency has approved and scheduled HUD training for the Finance Officer through Nan McCay. Further, financial and accounting training for the Finance Officer/ Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Finding 2023-002 - U. S. Department of Housing and Urban Development Voucher Cluster, Assistance Listing #14.871/14.879 Statement of Condition: For the year ended June 30, 2022, the Organization did not submit their audited financial statements to HUD by the required deadline. For the year ended June 30, 2023, the Origination did not submit their unaudited or audited financial statements to HUD by the required deadline. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director Action Plan: The submittal of the GAAP-based unaudited and audited report for FY ending June 30, 2022, was a management oversight due to the lack of a Finance Officer in place. The agency currently has a Finance Officer in place who will submit timely GAAP-based unaudited and audited financial information electronically to HUD via the Financial Assessment Sub-System (FASS-PH). Additionally, the agency has approved and scheduled HUD training for the Finance Officer through Nan McCay. Further, financial and accounting training for the Finance Officer/ Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Finding 2023-03 - U.S. Department of Health and Human Services Community Services Block Grant, Assistance Listing #93.569; U.S. Department of Housing and Urban Development, Housing Voucher Cluster, Assistance Listing #14.871/14.879. Statement of Condition: The origination did not submit the data collection form and required reporting package to the Federal Audit Clearinghouse (FAC) for the year ended June 30, 2023, by the required due date. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director Action Plan: Management will ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. To further ensure this finding is resolved, training for the Finance Officer/Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Section II - Findings relating to the financial statements which are required to be reported in accordance with generally accepted government auditing standards. 1. Finding 2022-001 Statement of Condition: Controls over the vendor payment process were not properly followed. Action Plan: Submitted previously with Financial Statements and Independent Auditor's Report FY Ended June 30, 2022. Current Status: Corrected The Management Department (Finance Officer and Executive Director), with the supervision of the Board of Directors Finance Officer, will continue to make every effort necessary to meet all HUD submission as required, in order to be in compliance with all HUD rules and regulations. Respectfully submitted, Trudy Murray Executive Director

Finding 2: Delayed Single Audit Delivery Background: The delivery of our single audit has been delayed due to staffing challenges and the need for improved coordination. With our organization’s expansion post-pandemic, increased hiring has required administrative staff to adapt to complex compliance requirements. Corrective Actions: 1. Audit Timeline Adjustment o Action: Begin the audit process no later than April each year to allow sufficient time for completion and submission. o Responsibility: Executive Team and Audit Committee o Timeline: Adjust the audit schedule for the upcoming year immediately. 2. Training for Administrative Staff o Action: Provide targeted compliance and audit process training for administrative staff to improve their proficiency and efficiency. o Responsibility: Administration o Timeline: Start training sessions within 60 days. 3. Regular Check-ins with Auditors o Action: Schedule regular monthly check-ins with auditors to ensure alignment on timelines and address potential issues early. o Responsibility: Finance Department o Timeline: Implement monthly check-ins starting [insert date]. 4. Resource Allocation o Action: Assess and allocate additional resources to support the audit process, ensuring staff have the necessary tools and support. o Responsibility: Administration o Timeline: Complete resource assessment within 60 days. ________________________________________ Conclusion AYUDA, INC. is committed to addressing these findings with urgency and transparency. By implementing the corrective actions outlined above, we aim to strengthen our financial management and compliance processes, ensuring these issues do not recur. We appreciate the auditors' feedback and are eager to demonstrate our improvements in the upcoming audit cycle. Approval: ________________________________________ Miguel Chacon Co-Executive Director 12/11/2024

Management will file the required calendar year 2023 reports immediately upon completion of the audit, in December 2024, and has addressed the underlying cause as noted above at 2023-001. Anticipated Completion Date of Corrective Action: On or before December 31, 2024.