Corrective Action Plans

Management agrees that due to turnover in staff during 2022 and 2023, there were gaps in communication leading to the single audit not being completed and submitted to the Federal Audit Clearinghouse be the due date. As of the audit report date, the Council has engaged an outside accounting firm to provide financial oversight. Action: Develop procedures to ensure required single audits are completed and submitted to the Federal Audit Clearinghouse by the 9-month due date. Due Date: 8/1/24 Staff: Don Reynolds, contracted CFO Carrie Castillo, Executive Director, is the official responsible for implementing each corrective action plan.

The Town will implement internal controls to ensure the filing deadline is met. Jason Vieira of the Towns Finance Department is responsible for the corrective action plan.

Comments on the Finding and Each Recommendation Statement of condition #2023-001: The Corporation did not submit the Data Collection Form (SF-SAC) for the year ended December 31, 2022 to the Office of Management and Budget (OMB) in a timely manner as required by Uniform Guidance section 2 CFR 200.512. Recommendation: The Corporation should submit all future Data Collection Forms in the required time frame. Action(s) taken or planned on the finding: Management concurs with the finding and the auditor's recommendation. On August 29, 2023, the Data Collection Form was submitted to OMB. No further action is required and the finding is resolved.

REPORTABLE NONCOMPLIANCE WITH FEDERAL REPORTING REQUIREMENTS – ALL FEDERAL PROGRAMS AWARDED UNDER THE UNIFORM GUIDANCE 2023-004 Federal Reporting Deadline Finding Summary 2 CFR Part 200, Subpart F, § 200.512(a)(1) requires the School’s audited SEFA and federal reporting package to be submitted to the federal audit clearinghouse within the earlier of 30 calendar days after the receipt of the auditor’s report(s), or 9 months after the end of the audit period. The School’s audited SEFA and federal reporting package for the fiscal year ended June 30, 2023, were not submitted to the federal audit clearinghouse within 9 months after the end of the audit period. Corrective Action Plan Actions Planned – The audit of the School’s SEFA for the year ended June 30, 2023, was not completed within the 9-month reporting period. The completion of the School’s audited annual financial statements for the year ended June 30, 2023, which is a required component of the federal reporting package, was delayed beyond the 9-month deadline pending sufficient audit evidence. School management will ensure that all information required to comply with federal reporting requirements will be completed and submitted in a timely manner going forward. Official Responsible – The School’s Executive Director, Matthew Cisewski. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The School agrees with this finding. Plan to Monitor – The School’s Executive Director, Matthew Cisewski, will monitor the year-end financial closing and reporting process to ensure all federal and state reporting requirements are complied with in the future.

2023-003 – Late Audit Report Corrective Action: CBNHC will implement the following corrective actions: • CBNHC will continue in its recruiting and will hire the various accounting positions as defined in the corrective action plan for finding 2023-001. • CBNHC will implement the corrective actions described in the corrective action plan for finding 2023-001 to assure compliance with its regulatory requirement for completing its timely audits. • In the event that the CBNHC experiences changes in its staffing levels again, it will actively seek interim support through an accounting consultant in order to maintain its accounting records. Person Responsible: The following individuals will be responsible for the above corrective action plan: • Human Resource Director (Christina Chavez) – Will complete positions descriptions and will participate by actively recruiting for CBNHC’s vacant positions within the hiring requirements defined by the Navajo Nation. • Interim Finance Director/Chief Operations Officer (Volelle Zamora) – Is responsible for ensuring the timely completion of CBNHC’s annual financial audits in accordance with the requirements defined by the Single Audit Act (2 CFR Part 200.512). • Chief Executive Officer (Derrick Watchman) – Is responsible for ensuring compliance with CBNHC’s Annual Funding Agreement (AFA) with the Indian Health Service (IHS). Completion Date: September 30, 2024. CBNHC will be back in compliance with its financial requirements and expects to have its audit report completed on time for fiscal year 2024.

Finding No. 2023-005 – Biweekly and quarterly reporting and finding No. 2023–006 – Audit requirements for auditees – report submission Conditions 1) For finding No. 2023-005: During our audit procedures regarding the compliance requirement related to reporting, we noted that, during the fiscal year ended June 30, 2023: • For ALN 21.027 - Coronavirus State and Local Fiscal Recovery Fund - ARP Act ✓ The Corporation was not able to provide audit evidence for the submission of four (4) biweekly reports, out of a sample of eight (8) reporting dates. ✓ One (1) monthly report, out of a sample of eight (8) reporting dates, was submitted later than its due date as follows: • For ALN 97.036 - Disaster Grants – Public Assistance (Presidentially Declared Disasters) Program The Corporation was required to submit four (4) quarterly reports during the year ended June 30, 2023. The Corporation provided incomplete reports for quarters 3 and 4. The report of quarter 3 does not include the correct amounts already expensed by the Corporation, while the report of quarter 4 was not completed and signed by the preparer. 2) For finding No. 2023-006: The data collection form and the reporting package for the year ended on June 30, 2023 was not submitted to the Federal Audit Clearinghouse within the timeframe prescribed by the Uniform Guidance. Corporation response The Corporation agrees with the findings Corrective Action Plan Upon receipt of the audit findings, we initiated an immediate review of our monthly reporting procedures. We have identified specific areas that require attention and are implementing immediate corrective actions to address the identified deficiencies. • Policies and Procedures Review - Simultaneously, we are reviewing our existing policies and procedures related to monthly reporting. This includes a reassessing reporting timeline, data validation processes, and the overall framework for ensuring accuracy and completeness in our monthly reports. • Staff Training and Development - Recognizing the critical role of our personnel in the reporting process, we are providing additional training to the individuals involved. This training will emphasize the importance of adherence to reporting guidelines, accurate data entry, and the significance of meeting established deadlines. • Communication Protocol Enhancement - We recognize the importance of effective communication regarding reporting processes. To address this, we are enhancing us communication protocols to ensure that all relevant stakeholders are informed of reporting requirements, timelines, and any changes to procedures. • Finance Team - The Corporation has changed its management staff structure in the finance and budget department, with the mission of improving the monitoring process and compliance with federal and local regulations. A new Finance and Budget Director and the Associate Director of Finance and Budget have been appointed. Name of the contact person responsible for corrective action plan Jesús A. Rodríguez Avilés – Financial Planning and Analysis Director Anticipated Completion date June 30, 2025

Contact Person - Sharon Millner, Executive Director Corrective Action Plan - The Agency will work to submit financial statements to the Federal Audit Clearinghouse within nine months of year-end. NWCA entered into a contract with Creative Planning for the Fiscal Director and supportive fiscal services in November of 2023. The fiscal department is now utilizing accounting software more efficiently and will be able to provide information needed for the audit in a timely fashion so that the audit can be completed before the auditing firm's busy tax season. Completion Date - 8/31/2024

On July 31, 2024, the Authority issued the audited financial statements for the fiscal year 2023 and Single Audit reporting package corresponding to year ended June 30, 2023 will be submitted on or before August 31, 2024. Currently, the audit for the fiscal year 2024 is in process and the Authority expects to issue and submit the 2024 financial statements and Single Audit reporting package within the established due date.

Finding No. 2023-002 Late Filing of Audit Package and Data Collection Form Description of Finding: The audit package and data collection form were not filed with the FAC within the required timeframe for the year ended June 30, 2023. Statement of Concurrence: Hampden County Career Center, Inc. concurs with the audit finding. Corrective Action: Hampden County Career Center, Inc. has replaced the finance director who left during the audit that resulted in the delay. Name of Contact Person: David Gadaire, President and CEO, DGadaire@masshireholyoke.org Projected Completion Date: Immediate – the position of the finance director has since been filed and the Organization does not expect any such delays in the future.

Finding 2023-002 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Thelma Nicholia Corrective Action Plan: The City will engage with an independent audit firm in advance of the 9-month deadline for the June 30, 2024 audit to ensure that the audit is completed within the required timeframe. Proposed Completion Date: June 30, 2024

2023-005: Reporting Type of Finding: Noncompliance, Material Weakness Condition: The School did submit their audit for the fiscal year ending June 30, 2023 timely. The audit was submitted August 16, 2024, which was 138 days past the March 31, 2024 deadline. Action planned in response to finding: Management will implement procedures to ensure that all audit documentation, is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Repeat Finding: Similar to prior year finding 2022-004. Planned completion date for corrective action plan: June 30, 2024 Name of the contact person responsible for corrective action: Dolores Silva, Chief Financial Officer

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: R.J. Barrett Manor Housing Development Fund Company, Inc. agrees with the auditor’s recommendations and will implement procedures to ensure timely filing in the future. For questions regarding this corrective action plan, please contact Kyle Lyskawa, Chief Financial Officer, at (315) 424-1821.

Finding 2023-005: Late Submission of June 30, 2023, Audit Report Federal Programs ALN: 93.575, 93.596, 93.558 Criteria: The Organization is required to file its audit report each year to the Federal Audit Clearinghouse within nine months after the end of fiscal year in accordance with 34 CFR 200.512. Condition: The Organization did not file its fiscal 2023 report to the Federal Audit Clearinghouse within nine months after the end of fiscal year Cause: The Organization experienced employee turnover in key managerial and accounting roles causing delays in close out and completion of the audit. Effect: The Organization did not meet the submission requirements as set forth by 34 CFR 200.512. Recommendation: We recommend the Organization closely monitors this important submission requirement to avoid missing the deadline. Corrective Action Plan: Management has taken corrective action to ensure timely submission of the annual audit report to Federal Audit Clearinghouse in compliance with submission requirements. Responsible Party: Jenny Longo, CFO Anticipated Completion Date: March 2025

Identifying Number: 2023-001 – Late Audit Reporting Finding: The audit, data collection form and reporting package for the Organization for the year ended June 30, 2023, should have been submitted to the Federal Audit Clearinghouse by March 31, 2024. Corrective Actions Planned or Taken: The Organization will schedule and complete future external audits in a manner that will allow timely reporting. Responsible Official: Rebecca Leininger, Executive Director Anticipated Completion Date: March 31, 2025

Finding 2023-002 – Material Weakness Program: Federal Highway Works Administration - Highway Planning and Construction Cluster The delays in the commencement and completion of the audit, as well as the material misstatements and excessive year-end closing journal entries, were primarily due to significant turnover in our finance department during the fiscal year and the financial closing process. Effect of Condition: We acknowledge that these issues led to material adjustments identified through the audit procedures, which significantly delayed the audit process Corrective Action Plan: 1. Enhanced Accounting Processes: o StanCOG is in the process of reviewing and strengthening internal controls to ensure that all assets, liabilities, revenues, and expenses are properly recorded and reported in a timely manner. o StanCOG is implementing a more robust financial closing process, ensuring proper application of accounting principles to all financial closing accounts and processes. 2. Staffing and Training: o StanCOG has brought in new staff with an education and background in accounting principles. o StanCOG has begun the recruitment process to fill the vacancies in the finance department with qualified personnel. o StanCOG has retained experts in Financial Metropolitan Planning that will assist with cross-training staff. o StanCOG will continue to provide finance team members with training, tools, and resources to continue to educate the finance team to help mitigate material weaknesses in the department going forward. 3. Internal Review and Monitoring: o StanCOG will institute a monthly internal review process to identify and correct any discrepancies promptly. o StanCOG will monitor the financial closing process closely to ensure timely and accurate completion. o StanCOG will review and revise existing accounting policies and procedures to reflect updates as necessary. Timeline for Implementation: • Recruitment and onboarding of new finance staff: By in-progress - Ongoing • Completion of cross-training programs: By August 2024 - Ongoing • Full implementation of enhanced accounting processes: By October 31, 2024

Finding Number: 2023-005 Reporting - Compliance and Internal Control Summary of Finding: CFR Section 200.303, Internal Controls, Section (a) states the Organization must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations, and terms and conditions of the federal award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its reporting process. 2 CFR section 200.512(a) states that the data collection form and reporting package must be submitted the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). If the due date falls on a Saturday, Sunday, or federal holiday, the reporting package is due the next business day. The Uniform Guidance does not have a provision addressing whether the cognizant or oversight agencies may extend due dates. During the fiscal year, we noted that the Organization failed to submit the data collection form and reporting package to FAC on a timely basis. Response to finding: We agree with the finding. Corrective Action: The retaining of a new audit firm for the FY2023 audit, the departure of key staff and reorganizational issues, winding down of Heartland Alliance and spin-off of entities into their own companies all have prevented the timely filing this year. Each new spin-off company will now be responsible for their own Financial Audit and Heartland Alliance is winding down and will not require any further audits. Individual(s) Responsible for Corrective Action Plan: o Name: Robin Armour o Title: Interim Chairman of the Board o Email address: robin@amdcapital.com o Anticipated Completion Date: March 31, 2025

Finding 2023-001 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Anita Fuller, Finance Director Corrective Action Plan: FY23 Audit onsite work has been completed and is still pending review. FY24 Audit has been scheduled in two part. Testwork is scheduled for the week of September 30, 2024. With the final review in November. Upper-level staffing positions have been filled which will allow for work to be fulfilled in-house. Proposed Completion Date: Immediately

Finding 2023-003 (Repeat finding, prior year finding 2022-004) The organization did not issue its single audit reporting package until August 2024. Management's view: Management acknowledges its responsibility for meeting critical reporting deadlines and agrees with recommendations for improving its compliance with reporting deadlines. In reviewing the obstacles that led to not complying with such deadlines multiple protocols have been implemented to prevent such a delya. Proposed Correction Action: to address matters proactively, Management has implemented the following protocols to ensure reporting deadlines are properly adhered to: Management has hired consultants specialized in the non-profit sector to provide oversight and ensure the organization complies with all reporting requirements on a timely basis.Management will continue to strehgthen and formalize its monthly closing process so that end-of-year reporting is less burdensome. Accounting staff with experience in record retention and electronic filing have been retained and all participate in ongoing cross-training so that each is capable of covering the various duties carried out within the accounting department. Accounting Staff have begun utilizing a scan=and-attach feature of the accounting software package. Saving electronic copes of documents will make the record retention process more efficient. Physical filing of documentation will continue to serve as a backup system. Attaching each scanned document to a specific transaction within the accounting software system should make the documentation more accessible. Anticipated Correction Date: The measures have been initiated and are expected to be completed by November 1, 2024. Management anticipates the fiscal year 2024 audit will be completed ahead of the required deadline.

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Bessie Riordan Addition Apartments agrees with the auditor’s recommendations and will implement procedures to ensure timely filing in the future. For questions regarding this corrective action plan, please contact Kyle Lyskawa, Chief Financial Officer, at (315) 424-1821.

Finding #2023-001 Prior Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Carpenter Apartments agrees with the auditor’s recommendations and will implement procedures to ensure timely filing in the future. For questions regarding this corrective action plan, please contact Kyle Lyskawa, Chief Financial Officer, at (315) 424-1821.

VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: Management will begin the single audit process as soon as possible when the books close. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The Organization will implement the recommendation. Officials Responsible for Ensuring CAP: The Organization’s appointed staff member is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date for the CAP is June 30, 2024. Plan to Monitor Completion of CAP: The Board of Directors will be monitoring this corrective action plan.

In November 2023, a Controller, Hannah Pawlowski, was hired and in July 2024 a Chief Financial Officer, Veronica Koller, was hired to bring the needed staff on hand to ensure that the financial statement and single audits for the period of June 30, 2024, are completed in time necessary to submit the data collection form within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period.

REPORTABLE NONCOMPLIANCE WITH FEDERAL REPORTING REQUIREMENTS – ALL FEDERAL PROGRAMS AWARDED UNDER THE UNIFORM GUIDANCE 2023-006 Federal Reporting Deadline Finding Summary 2 CFR Part 200, Subpart F, § 200.512(a)(1) requires the Academy’s audited SEFA and federal reporting package to be submitted to the federal audit clearinghouse within the earlier of 30 calendar days after the receipt of the auditor’s report(s), or 9 months after the end of the audit period. The Academy’s audited SEFA and federal reporting package for the fiscal year ended June 30, 2023, were not submitted to the federal audit clearinghouse within 9 months after the end of the audit period. Corrective Action Plan Actions Planned – The audit of the Academy’s SEFA for the year ended June 30, 2023 was not completed within the nine-month reporting period. The completion of the Academy’s audited annual financial statements for the year ended June 30, 2023, which is a required component of the federal reporting package, was delayed beyond the 9 month deadline pending obtaining sufficient audit evidence. Academy management will ensure that all information required to comply with federal reporting requirements will be completed and submitted in a timely manner going forward. Official Responsible – The Academy’s Executive Director, Farhiya Einte. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The Academy agrees with this finding. Plan to Monitor – The Academy’s Executive Director, Farhiya Einte, will monitor the year-end financial closing and reporting process to ensure all federal and state reporting requirements are complied with in the future.

In connection with those identified in 2023-001 and 2023-002, Management has established a rigorous procedure for reviewing and implementing controls to ensure that all contracts from the consolidated organizations are reviewed by designated personnel, guaranteeing full compliance with reporting requirements.

CSS management will improve staffing and internal controls to ensure compliance with the timely reporting requirements stated in 2 CFR §200.512.