Corrective Action Plans

This incident is an anomaly due to the unanticipated loss of an employee in a small department. The root cause is lack of human capital in the department responsible for the submission of the audit to the Federal Audit Clearinghouse. We acknowledge the importance of adhering to regulatory deadlines and ensuring the timely submission of these documents. In response to your recommendation, we have already implemented measures to streamline our reporting processes and enhance our internal communication channels to facilitate the timely completion and submission of the required documents. This has involved establishing clear timelines, assigning responsibilities to designated personnel, and implementing monitoring mechanisms to assure that we meet the submission deadlines. The Chief Financial Officer (CFO) was responsible for the submission of the single audit on or before the March 31, 2024 deadline. This will be completed on or before March 31, 2024. The CEO will request board of directors' approval to hire an Executive Finance Officer (EFO) in an effort to increase the depth of the finance department. This will provide coverage during unexpected absenses in an effort to avoid future delays. The board of directors' approved the posting of a new EFO position on September 15, 2023. Position is posted and will remain posted until the position is filled. As soon as the EFO is hired, the CFO and EFO will cross train all duties related to the timely completion of documents to assure the timely submission of the single audit and assure that the Federal Audit Clearinghouse deadline is met. This is pending the hiring of the EFO. The position is currently posted. By October of each year, the CFO or EFO will conduct random sample internal audits or reviews before the single audit submission deadline to ensure documents are accurate and in compliance with federal regulations. Implement plans of correction for any areas identified out of compliance. This process is on-going.

1.) Finding 2023-001 Data Collection Form Submission Delay a. Program Information: N/A b. Criteria: Per 2 CFR 200.512(a)(1), the audit package and the data collection form shall be submitted 30 days after receipt of the auditor's report(s), or 9 months after the end of the fiscal year whichever comes first. c. Condition: For the year ended June 30, 2021, the audit package and data collection form was not submitted within the required timeline. Response: Explanation: The delay in submitting our annual audited financial statements was due to significant transitions within the MHAAO finance team. In the first half of FY23, we faced the departure of our contract accountant and then Finance Director, leaving substantial parts of the audit work incomplete. With only one staff accountant, we faced challenges in making progress on audit deliverables. After my appointment as the new Finance Director in February 2023, we encountered further delays due to our previous audit partner's scheduling difficulties. This led us to engage with Aldrich Advisors, who committed to completing the FY22 audit for us within the calendar year 2023. Corrective Action: To address the lack of capacity on the MHAAO finance team, we successfully hired three new positions by the beginning of FY24: a Payroll Specialist, Accounts Payable Specialist, and an experienced Accounting Manager. We also recently promoted our Staff Accountant to a Senior Financial Analyst role, in charge of grants, contracts and compliance. We now have a strong and capable team to strengthen our internal financial processes and implement best practices in nonprofit financial management. To address this finding comprehensively, we have also implemented a new policy with two key components: - A centralized tracking system for reporting deadlines, maintained by myself, our Accounting Manager, and our Senior Financial Analyst. - Enhanced communication protocols for required submissions, including immediate communication with our audit team and funding partners in case of potential delays. Future Measures: Integration of these measures into our internal financial management policies and procedures, ensuring consistent application and preventing future delays. Contact person responsible for corrective action: John Domingo, Finance & IT Director Completion date: 10/17/2023

Name of Contact Person: Greg Frehner, Superintendent. Recommendation: We recommend that all required filings be submitted timely according to the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations Guidelines. Corrective Action: The auditors discussed the issue with the District. A new checklist will be used with audit completion to ensure timely submission for the 2023 fiscal year. Proposed Completion Date: Immediately.

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: Stryker Homes 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 2022-001 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

Contact Person David Drapeaux Corrective Action Plan The district will complete the fiscal year 2023 audit requirement on or before the March 31, 2024 deadline. Going forward the audits will be completed on time and this finding will be resolved. Corrective Action Plan March 31, 2024 Completion Date On-going

Name of Contact Person: Ronald Ferrell, Superintendent. Recommendation: We recommend that all required filings be submitted timely according to the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations guidelines. Corrective Action: The auditors discussed the issue with the District, and the auditors will ensure timely submission for the 2023 fiscal year. Proposed Completion Date: Immediately.

PDA: PDA will be hiring a complement position to develop and maintain an audit tracking report to ensure that all single audits are properly logged and processed. In addition, this position will review the financial information in each audit report to determine if all pass-through funding is properly included and subject to audit. This position will coordinate with the bureaus within PDA to ensure all required follow-up is completed in a timely manner. Anticipated Completion Date: 06/30/2024 Contact Name: Tracee Gotwalt, Audit Coordinator PDOA: The PDOA is looking to improve management decision communications in addition to more thorough evaluations as a new Comprehensive Monitoring Process pilot is starting in April 2024 to address the noncompliance of subrecipient monitoring. This has resulted in management designing control activities to achieve timely submissions in the future by initiating the following: 1. An audit tracking log has been established to track report submissions, document when they were received, initiated, findings requiring follow-up, and subsequent steps to finalize the audit. 2. A separate tracking mechanism is in place to ensure the monitoring of subrecipient activities for compliance with federal statutes, regulations, and the terms and conditions of the Agreement for the 52 Area Agency on Aging subrecipients. 3. PDOA is looking to fill a vacant position with a focus of tracking subrecipient expenditures in the aggregate and tracks Single Audit submissions on a Commonwealth wide basis since the Aging Cluster is material and has material sub-granted expenditures. 4. Since receiving the finding, PDOA has reached out to the resource account where Subrecipient Single Audit reports are received by the Federal Audit Clearinghouse (FAC) to verify all outstanding audit items for PDOA, as action is required within six months of receipt. 5. It is PDOAs impression that having increased oversight of the Schedule of Expenditures of Federal Awards (SEFA) will allow for timely dissemination of Management Decision Letters (MDL) in the six-month timeframe for making a management decision for federal award findings. 6. Additionally, PDOA will confirm a closure letter was sent to the Philadelphia Corporation for Aging documenting PDOA’s management decision regarding federal award findings, as included in their FYE 06/30/2021 Single Audit report. 7. Follow-Up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Preliminary procedures will be directed to the agency’s audit review committee for resolution of completeness. 8. In the event the audit review committee determines additional steps beyond the monitoring efforts outlined above are insufficient, additional efforts will be communicated to the AAA network. Anticipated Completion Date: 06/30/2024 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison DOH: DOH’s subrecipient single audit tracking report now includes a mechanism to monitor management decision deadlines related to each entity’s FAC submission date. The process for tracking subrecipient audit reports with findings has been updated to include and highlight subrecipients’ audit reports where DOH is the lead agency for finding resolution or the report contains findings that relate to the Department. Anticipated Completion Date: 03/31/2024 Contact Name: Steven Marsden, Chief, Audit Resolution Section PDE: PDE has implemented weekly, monthly and quarterly checks to ensure that all single audits are properly logged and processed. The clerk typist will conduct a weekly review and provide confirmation to the audit coordinator by signature. Bi-weekly, the clerk typist will follow up on any single audits that remain open. Anticipated Completion Date: Completed Contact Names: Clayton Carroll, Audit Coordinator, Bureau of Budget & Fiscal Management; Jessica Sites, Director, Bureau of Budget & Fiscal Management

Contact Person: Lane Estes, VP for Administration and Interim VP for Finance Corrective Action: The College acknowledges the Uniform Guidance Audit for the year ended May 31, 2022 was not submitted timely to the Federal Audit Clearinghouse. The College’s Uniform Guidance Audit for the year ended May 31, 2022, was delayed as the College was negotiating with the State of Alabama a funding arrangement that did not materialize as the legislative approval outlined. The Uniform Guidance Audit for the year ended May 31, 2022 has now been completed and submitted. The Uniform Guidance for the year ended May 31, 2023 was due on February 29, 2024 and the College requested an extension. The Uniform Guidance Audit for the year ended May 31, 2023, is scheduled to be completed by March 31, 2024 and will be submitted promptly to the Federal Audit Clearinghouse. Anticipated Completion Date: March 31, 2024

Finding: Late Issuance of the 2023 Single Audit Reporting Package The City’s fiscal year 2023 Single Audit package was not submitted to the Federal Audit Clearinghouse within the required time period. The Single Audit package for the City’s fiscal year ended April 30, 2023 should have been submitted to the Federal Audit Clearinghouse by January 31, 2024. Corrective Action Taken or Planned: City will schedule and complete future external audits in a manner that will allow timely reporting of the Single Audit. Anticipated Completion Date: June 2024 Responsible Person(s): Cynthia Smith, Assistant Finance Director

Due to turnover of the Organization's Finance and Administration manager, the Organization was unable to have the annual audit completed within the required timeframe, and subsequently were also late in submission of the FAC report. The Organization has internally hired a Staff Accountant and an Accounts Payable to assist with audit preparation. The Organization has externally contracted an accounting firm that has provide the Organization with a CPA to conduct audit preparation and other financial services, as requested. We can confirm that this is not a repeat finding but an isolated instance. The Organization will work on getting financial information timelier (i.e. submit the reporting package with the guidelines of Uniform Guidance).

View of Organization - Harrington Family Health Center concurs with this finding. Planned Corrective Action - The Center will purchase new software and implement regular reconciliation procedures for accounts receivable to insure the audit will not be delayed. Anticipated Completion Date - April 1, 2024. Responsible Contact Person - Jessica Ackley, Chief Financial Office (207) 483-4502

The Kanawha County Regional Development Authority of Charleston - Kanawha County will ensure that the data collection form will be submitted to the federal audit clearing house within 30 days of the aduit being issues.

The filing of the Data Collection Form will be submitted by the required due date. In the prior year, the audit report was submitted after the Federal Audit Clearinghouse deadline. The current audit will be submitted with sufficient time to meet the Federal Audit Clearinghouse submission date requirement. Responsible party(ies) for corrective action(s): Chief Financial Officer Corrective action(s) timeline: March 15, 2024

Finding Number: 2023-001 Planned Corrective Action: Management has taken corrective action to ensure timely submission of the annual audit report to Federal Audit Clearinghouse in compliance with submission requirements. Anticipated Completion Date: March 2024 Responsible Contact Person: Laura Gambino, Chief Executive 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: Bessie Riordan Senior 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: Mercy 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: Hawley-Winton 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: St. David’s Court 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.

Simpson management hired additional staff to allow management the additional time necessary to prepare and review internal financial statements in a timely and efficient manner so that the audit can begin and be completed in a timely and efficient manner. Management believes their processes are properly designed to ensure timely filing of the Single Audit Reporting Package in future years.

The Organization continues to work with the contract financial team who plans to have the books closed in a timely manner going forward. The Organization is also actively working with their auditor to improve communication during the audit so a future break-down in communication does not occur. We expect the issue will be mitigated for the 2023 audit.

Corrective Action Plan: The Brevard Housing Authority procured the auditor in year of 2019 for a three (3) year term. The engagement letter was signed for the FY 2023 audit on October 4, 2023. The auditors started the audit on October 13, 2023 by requesting Cash Disbursement testing selections. Management provided all information and responded to all questions timely and notified the team of office closures for holidays in November and December. Management will procure a new audit firm to ensure the due date is met in the future. Name of Responsible Person: Tara Irby, Executive Director Projected Completion Date: December 31, 2024

Recommendation: We recommend management ensure that the data collection forms are submitted electronically to the FAC within the required due dates each fiscal year going forward. Action Taken: We agree with Finding 2023-002 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will provide additional oversight to ensure the data collection forms are submitted electronically to the FAC each fiscal year going forward within required due dates. The data collection form for the year ending June 30, 2022 was submitted to the FAC on June 12, 2023.

Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Pitcher Hill 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.

Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: Onondaga Apartments 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.