Corrective Action Plans

Resolved. Reporting package submitted.

CONDITION: The Regional Office of Education No. 39 was required to submit its June 30, 2022, data collection form and related reporting package to the Federal Audit Clearinghouse by March 31, 2023; however, it was not submitted until January 3, 2024, resulting in a delay of 278 days. PLAN: The new ROE Business Office Manager will work closely with their contracted accounting firm to ensure that the office gets back on schedule with the yearly audit deadlines. Because the audit for FY22 was not completed until January 2024 the Federal Audit Clearinghouse could not be submitted until that time. The FY24 financial statements are scheduled to be provided in January 2025 so that the office can get back on schedule for the FY25 audit deadline of August 31, 2025 and therefore the March 31, 2026 Federal Audit Clearinghouse deadline. ANTICIPATED DATE OF COMPLETION: The anticipated date of completion is December 2025. CONTACT PERSON: Jill Reedy, Regional Superintendent

FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2023-001: Section 811 Capital Advance Program and Project Rental Assistance Contract ALN# 14.181 Recommendation: Implement procedures and controls to ensure that future audits are completed and submitted in a timely manner. Action Taken: Management agrees with the auditor’s finding and recommendation. The new Deputy Director of Finance will play a key role in ensuring adherence to audit timelines and enhancing overall reporting efficiency. If the United States Department of Housing and Urban Development has questions regarding this plan, please email Laura Jaworski at laura@thehouseofhopecdc.org.

Finding 2022-08 Late Issuance of 2023 Single Audit Reporting Package Condition: The Organization is required to submit the reporting package by the deadline required by Uniform Guidance, which was September 30, 2024, for the year ended December 31, 2023. The Organization failed to file their report by this deadline. Corrective Actions Taken or Planned: - VOICES has engaged a licensed CPA firm with expertise in Single Audit reporting and federal compliance. The CPA firm will work proactively with VOICES to ensure that all financial statements, schedules, and compliance documents are completed, reviewed, and filed well in advance of the reporting deadline. - VOICES’ executive team and the CPA firm will perform quarterly reviews to detect and resolve issues early, reducing delays during the annual audit process. - Assign internal staff responsibilities to ensure all documents are prepared and reviewed ahead of the audit.

Actions Planned: The Organization has contracted with a healthcare consulting firm and has outsourced the financial reporting function in its entirety. They are responsible for general ledger reconciliations to the appropriate subsidiary ledgers and/or supporting documentation. They will also be responsible for all internal and external financial reporting.

2023-001 – Reporting Requirements (previously 2022-004) Noncompliance. Federal Programs: AL 21.023 – Emergency Rental Assistance Program. AL 14.231 – Emergency Solutions Grant. Auditors Notes: As required by 2 CFR 200.512, the single audit report must be submitted to the federal audit clearinghouse within the earlier of 30 calendar days after the receipt of the auditor's report, or nine months after the end of the audit period. The Organization experienced delays in the completion of the financial statement audit, and therefore the single audit was delayed until after the required submission date. The Organization is relatively new to the single audit process and requirements, there were various versions of guidance received and unclear identification of responsibilities until later into the program year that resulted in delays. The effect was a delay in the finalization of the single audit and inappropriate reporting to the related granting agencies. We recommend that the Organization develop a process to track and ensure that reporting deadlines are met. Management’s Response: Inland Southern California United Way and Subsidiaries are currently catching up on both financial audits and single audits for the Organization, therefore deadlines that have already passed could not have been met. However, the Accounting Manager and Executive Director of Finance will be responsible for ensuring that any future deadlines, effective FY24, for program reporting requirements as well as both financial audits and single audits are completed and submitted in a timely manner.

SUBRECIPIENT MONITORING ALN Number 93.558 Temporary Assistance for Needy Families (TANF) 93.489, 93.575, 93.596 Child Care Development Fund (CCDF) 93.568 Low Income Household Energy Ass istance Program (LIHEAP) 2023-018 Strengthen Controls over Subrecipient to Ensure Compliance with Uniform Guidance Auditing Requirements. Response: MOHS concurs that it needs to strengthen controls over subrecipient monitoring for the Child Care Development Fund (CCDF) and Temporary Assistance for Needy f amilies (TANF) programs to conform with Uniform Guidance. Corrective Action Plan: I . Strengthen cont rol over the subrecipient to ensure compliance with Uniform Guidance Requirements: A. The Office of Compliance, Division of Monitoring has made significant strides in strengthening controls over the subrecipient monitoring process. The Division continues to review and update the processes and procedures as necessary to ensure processes are adequate and effective. Staff are constantly notified/trained on updates to policies, procedures. and regulations to ensure continued compliance with monitoring the agency's subgrant agreements. Additionally, the Division is in the process of implementing a case management system to assist with this process. 8. Responsible Parties: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Anticipated Completion Date: This corrective action has been implemented and is ongoing.

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.