Corrective Action Plans

Finding 2022-003 - Single Audit Reporting Package Submission (Repeat Finding) Responsible Person, Title: Vanessa Keppner, Board Secretary/Treasurer Anticipated Completion Date: Response: We concur with this finding. The board has approved use of a new auditing firm which has improved the timeliness of the audit. The FY21 audit will be planned to be completed and submitted in the correct time frame. Vanessa Keppner Secretary/Treasurer

We agree with the finding. The current year audit will be certified and submitted within the required timeframe.

Wabanaki Public Health and Wellness received our FY21 audit in April 2023, which did not allow for the changes to be made in time for FY22. The corrective action plan from FY21 continues to be our course of action and will be fully implementing the following to ensure compliance in FY23. Wabanaki Public Health & Wellness is committed to having our Single audits completed in time for submission to the clearing house within the appropriate time frame. WPHW has obtained WIPFLI for the next five years and will schedule our audit as early in the season as possible. Wabanaki Public Health & Wellness will be prepared to provide all information that is requested prior to the auditors being within our offices by the designated date in which the items are requested. During the period in which the auditors are within house and the weeks following the Director of Finance and the Financial Quality and Compliance Manager will be available to answer any questions, provide documentation, and details for all requirements for WIPFLI to complete the audit for submission to the clearing house. Person(s) Responsible: Beth McLean Timing for Implementation: Summer 2023

2022-002. Finding: Compliance Findings ? Reporting Response: The Business Manager is the contact person at this entity responsible for the corrective action plan for this comment. The COVID pandemic has caused problems for our School District. Due at approximately the same time were the extended audit for June 30, 2022, the annual report for June 30, 2023, and the proposed budget for the 2023-2024 school year. The late filing was caused by multiple financial processes being completed simultaneously.

Finding 2022-004: Financial Reporting Timelines (Uniform Guidance Compliance) The Accounting Officer will coordinate in advance of the audit to make sure we have had our processes reviewed and confirmed to be in compliance with the Uniform Guidance Compliance, as well as, have ledgers, bank reconciliations, invoices and receipt properly organized. We will engage the Auditor early as well to make sure we are on a path to submit documentation to the Federal Audit Clearing House before March 31, 2023. To address these findings and ensure compliance with Title 2 requirements, Habitat for Humanity Yuba/Sutter will implement the following corrective action plan: 1. Operationalize the Grants Management Standards ? Habitat for Humanity Yuba/Sutter will conduct a comprehensive review of its current grants management policies and procedures to identify any gaps or deficiencies in compliance with Title 2 requirements. ? The organization will update its grants management policies and procedures to align with Title 2 regulations, including documentation requirements, financial management, reporting, and record keeping. ? Habitat for Humanity Yuba/Sutter will provide training and resources to its staff involved in grants management to ensure they are knowledgeable about the updated policies and procedures. ? The organization will establish a system for ongoing monitoring and internal audits to ensure compliance with grants management standards, and make necessary adjustments as needed. 2. Establish a Robust Marketplace of Modern Solutions ? Habitat for Humanity Yuba/Sutter will conduct a thorough review of its current marketplace of solutions, including vendors, software, and technologies used in its operations. ? The organization will identify opportunities to modernize its systems and processes to enhance efficiency, streamline operations, and ensure compliance with Title 2 requirements. ? Habitat for Humanity Yuba/Sutter will develop a plan to implement modern solutions, including budgeting, procurement, and implementation timelines. ? The organization will establish a process for ongoing evaluation and monitoring of the effectiveness of the modern solutions implemented, and make necessary adjustments as needed. 3. Manage Risk ? Habitat for Humanity Yuba/Sutter will conduct a comprehensive risk assessment to identify potential risks associated with grants management and compliance with Title 2 requirements. ? The organization will develop and implement risk mitigation strategies, including internal controls, monitoring mechanisms, and contingency plans. ? Habitat for Humanity Yuba/Sutter will establish a system for ongoing risk management, including regular risk assessments and reviews, and updates to risk mitigation strategies as needed. ? The organization will ensure that all staff involved in grants management are aware of the risk mitigation strategies and trained on how to implement them effectively. 4. Achieve Program Goals and Objectives ? Habitat for Humanity Yuba/Sutter will review and align its program goals and objectives with the requirements of Title 2. ? The organization will develop a comprehensive plan to ensure that its programs are designed, implemented, and evaluated in accordance with Title 2 guidelines, including outcome measurement, data collection, and reporting. ? Habitat for Humanity Yuba/Sutter will establish regular monitoring and reporting mechanisms to track progress towards program goals and ensure compliance with Title 2 requirements. ? The organization will provide training and resources to its staff involved in program management to ensure they are knowledgeable about the updated program goals and objectives and the requirements of Title 2.

Finding No. 2022-001 Audit Requirements for Auditees ? Report Submission Condition found The data collection form and the reporting package for the year ended on June 30, 2022 was not submitted to the Federal Audit Clearinghouse within the timeframe prescribed by the Uniform Guidance. Views of Responsible Officials and Corrective Action PlanPuerto Rico Department of Health (DOH), Puerto Rico Infrastructure Financing Authority (PRIFA), Puerto Rico Aqueduct and Sewer Authority (PRASA), entered on December 30, 2016, into a Memorandum of Understanding (MOU), subsequently amended on September 17, 2018, to include the Fiscal Agency and Financial Advisory Authority (FAFAA). Under the MOU, as amended, each party has agreed to assume specific responsibilities in connection with the operations of the Revolving Fund pursuant to the Operating Agreement entered between the EPA and the DOH on September 28, 2018. Pursuant to the MOU, as amended, DOH will remain as the administrator for the Revolving Fund, PRIFA will act as the operating agent to provide assistance with the financial and accounting activities, and FAFAA will conduct the financial capabilities analysis of any eligible assistance recipient of funds, provide the necessary information to the DOH and PRIFA to the extent as possible for the development of the different programs compliance reports reviews, provide assistance as fiscal agent, financial advisor and information agent of the Commonwealth to ensure that the monies are safeguarded in a trust structure and to assist the DOH as deemed necessary with the administration of the program. The data collection form and the reporting package were not file on time due to lack and availability of funds to cover expenses related to the audit process and other expenses related to the administrative responsibilities assigned in the MOU, as amended, to PRIFA. Management is requiring DOH to formalize a Subaward, as established in the MOU, as amended, to facilitate and respond to the lack of funding to cover all the related expenses for the administrative responsibilities assigned to PRIFA. EPA has been informed and communication will be maintained until the Subaward is finally signed. Management plans are to file the data collection form for the fiscal year ended on June 30, 2022 on or before June 30, 2023, and the data collection form for the fiscal year ending on June 30, 2023 on or before December 31, 2023, which will result in elimination of the finding. Name (s) of the Contact Person (s) Responsible for Corrective Action Francisco Pares, Secretary of the Treasury Department, Eduardo Rivera Cruz, Executive Director Puerto Rico Infrastructure Financing Authority and Dr. Carlos Mellado, Secretary Puerto Rico Department of Health Anticipated Completion Date June 2023

Identifying Number: 2022-003 Finding: Late Issuance of the 2022 Single Audit Reporting Package The City?s fiscal year 2022 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, 2022 should have been submitted to the Federal Audit Clearinghouse by January 31, 2023. 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, 2023 Responsible Person(s): Cynthia Smith, Assistant Finance Director

2022-001 - INTERNAL CONTROL OVER COMPLIANCE - SIGNIFICANT DEFICIENCY CONDITION: DLS submitted the 2021 data collection package to the Audit Clearinghouse after the required due date. CAUSE: The Judicial Council of California did not process the reimbursement requests timely. DLS was unable to determine actual revenue and contract receivable until resolution. CRITERIA: Uniform Guidance 2 CFR 200.512(a) requires that 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. EFFECT: DLS was not in compliance with Uniform Guidance 2 CFR 200.512(a). QUESTIONED COSTS: n/a RECOMMENDATION: DLS should ensure timely compliance as part of year end audit process. Management Response: DLS will schedule its annual audit to occur in August, at the latest. This will ensure that the annual audit is completed in time to meet the Sept. 30th filing deadline with the Audit Clearinghouse. In the event that the Judicial Council is unable to process reimbursements timely, DLS' management will estimate revenue and receivable balances based on reasonable and probable amounts so that the audit will still be completed on time. Date: 9.13.23 __________________________________ John P. Passalacqua, Executive Director

Two Rivers Head Start Agency respectfully submits the following corrective action plans for the year ended August 31, 2022. Auditor: Audit Period: Dugan & Lopatka, CPA's 4320 Winfield Road Suite 450 Warrenville, IL 60555 For the year ended August 31, 2022 The findings from the schedule of findings and questioned costs is discussed below. The findings are numbered consistently with the number assigned in the schedule. Findings - Financial Statements 2022-01: Auditor's Recommendation: We recommendthe Agency implement procedures to ensure timely reconciliation of general ledger accounts. Action Taken: The Agency experienced significant employee turnover in the Accounting Department. New staff have been hired. The Fiscal Officer will reconcile the general ledger balances no later than 30 days after the end of the previous month. The Executive Director will review and sign the reconciliations. 2022-02: Auditor's Recommendation: We recommend that the timesheets be reviewed by the accounting department to verify all timesheets have a supervisor approval before processing payroll. If the approval is missing, the accounting department should e-mail the timesheets to the supervisor and ask for a reply verifying that the hours are correct. We also recommend that the Agency implement fully electronic timesheets that provide the ability for the supervisor to approve a timesheets remotely. Action Taken: The Agency experienced significant employee turnover in the centers. All Supervisors will receive an email reminder, with their direct reports listed, to review and approve timesheets prior to payroll being processed. The Accounting Department will review a Timecard Approval Report prior to payroll being processed. Supervisors will be notified of any missing timecards or approvals. Payroll will not be processed until the report shows all timecards have been completed and approved. Finding - Single Audit Statement 2022-03: Auditor's Recommendation: We recommend that when there is a significant vacancy in the accounting department, the Agency finds some temporary help to keep the accounting records accurate and up to date. This will enable the Agency to have adequate and complete accounting records to meet reporting requirements. Action Taken: Due to significant employee turnover in the Accounting Departmentt SF-425 and SF- 429 reports were not submitted in a timely manner or with information matching the general ledger. The new accounting team is in place and is in the process of correcting and resubmitting or submitting the reports. The accounting team will submit accurate SF-425 and SF-429 reports in a timely manner moving forward. If the funding agency has questions regarding this plan, please call me at 630-264-1444, Ext. 234.

Finding 2022-02: Late Submission of Financial Statements to FAC and REAC (Significant Deficiency) Corrective Action Plan: DuPage Housing Authority (DHA) has existing controls in place, however, DHA had to seek an emergency authorization for a 60-day waiver extension for 2 CFR ? 200.512(a)(1) Report Submission and the Financial Reporting Requirements per 24 CFR ? 902.33(b) for the FY2022 audit. Regulatory waivers provide relief from HUD requirements upon a finding of good cause, subject to statutory limitations, per 24 CFR 5.110. The DHA IL101 general audit submission date is March 31, 2023. DHA expected to have the financial audit submitted by April 30, 2023, as a result of the following reasons: ? Due to the abrupt quitting of the previously procured audit service provider, on February 7, 2023. DHA had to enter into an emergency Intergovernmental Agreement authorizing DuPage Housing Authority (DHA) to share the RFP process for independent audit service provider, Rubino and Company on February 27, 2023. The DHA IL101 HUD audit report submission per 2 CFR ? 200.512(a)(1) audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. The current DHA IL101 audit report submission was due March 31, 2023. ? The 60-Day Waiver extension was submitted to HUD for 2 CFR ? 200.512(a)(1) Report Submission and the Financial Reporting Requirements per 24 CFR ? 902.33(b) for the FY2022 audit will allow DHA an opportunity to avoid adverse effects including but not limited to: o Noncompliance of the audited financial data to HUD on an annual basis o Noncompliance of the annual audit being prepared in accordance with Generally Accepted Accounting Principles (GAAP), as further defined by HUD in supplementary guidance. o Noncompliance of the audited financial data being submitted electronically in the format prescribed by HUD using the Financial Data Schedule (FDS). ? HUD?s National Headquarters went through a recent organizational change; thus, delaying the approval process for the 60-dayextension waiver for 2 CFR ? 200.512(a)(1) Report Submission and the Financial Reporting Requirements per 24 CFR ? 902.33(b) for the FY2022 audit. ? DHA received official verbal approval from HUD?s Waiver Team on May 2, 2023, but the 60- day waiver extension for 2 CFR ? 200.512(a)(1) Report Submission and the Financial Reporting Requirements per 24 CFR ? 902.33(b) for the FY2022 audit is still awaiting final signature from the new HUD Deputy Assistant Secretary. Name of Responsible Person: Cheron Corbett, Executive Director Projected Completion Date: December 31, 2023

YWCA Billings will continue to work with the auditor to meet the required deadlines to ensure the audited financial statements are submitted on a timely basis to the federal audit clearinghouse.

Corrective Action Plan for Fiscal Year Ended June 30, 2022 Finding 2022-001 Condition The District did not meet the deadline for submission of its data collection form and reporting package to the Federal Audit Clearinghouse for the fiscal year ended June 30, 2021. The data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors? report or nine months after the end of the audit period. Therefore, the deadline for submission of the required information for the fiscal year ended June 30, 2021, was December 22, 2021. The data collection form and reporting package was not submitted by that date. Corrective Action Plan Corrective Action Planned: Establish procedures to verify that the data collection form and reporting package have been properly submitted on a timely basis. Name of Contact Person Responsible for Corrective Action: Matthew Moore, CPA, Chief Financial Officer Anticipated Completion Date: December 16, 2022

Finding 2022-002: Filing of Single Audit Report Finding: The Organization did not timely submit the Single Audit Reporting Package for the fiscal year ended September 30, 2021 within nine months after the end of the audit period. Response: Agree Explanation/Corrective Action: The fiscal year end September 30, 2021, audit was delayed as it was unclear if a single audit was required. The Organization will file the Single Audit Reporting related to the fiscal year end September 30, 2021 and does not expect delays to continue for fiscal year ended September 30, 2022.

Finding Type: Noncompliance with Federal Programs. Name of Contact Person: Mr. Matt Winters, City Manager, (573) 686-8620. 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: We have hired a new Accounting Manager and will ensure the Data Collection Form is filed timely going forward. Proposed Completion Date: Immediately

We are looking at options to increase the finance teams so that we have capacity to finish the audits on time in future years Anticipated Completion Date: September 1, 2023 Responsible Contact Person: David Maloney, Shelter House Controller

Finding 2022-002 Reporting ? Significant Deficiency in Internal Control Condition and Effect: The single audit of the Philadelphia Corporation for Aging (the Corporation) federal awards for the year ended June 30, 2022 was not completed within the nine months following the period-end and as a result, the Corporation did not submit its single audit reporting package within the required timeframe. As such, the Corporation did not comply with the aforementioned regulatory requirements. This is a recurring finding from the prior year. View of Responsible Officials and Planned Corrective Action: The Corporation will review all government programs and related activities subject to the Uniform Guidance process to identify where automation can be better utilized to increase timing of information gathering. Cross training of all federal statutes, regulations, terms, and conditions of federal awards will be instituted to enable knowledge sharing amongst management team members. Our newly promoted accounting manager (Effective January 2023) will work to gain familiarity of federal award compliance rules and regulations and document as part of PCA Policy manual.

Proposed Corrective Action: To address matters proactively, Management has implemented several protocols to ensure proper supporting documentation along with a standard filing system has been implemented. Management has also hired consultants to provide oversight to make sure the manner in which financial accountability complies with awards. ?Additional staff members have been hired in order to assist current employee to review all case files on clients submitted by caseworkers prior to submission for approval of payments on client?s behalf are issued. ?Additional staff has been hired to assist in solely processing check issued payments to insure all are processed on a timely basis along with sufficiently reviewing proper coding is used for all payments issued. ?To better organize all documents a standard filing system has been implanted in order to ensure all documents can be easily located. ?Consultants have been hired to assist with the oversight of financials in order to make sure financial reports are provided on a timely basis. ?A tool currently in the accounting system used to manage financials will be used to create projects related to individual grants. This tool will be used to assist with tracking the individual grant activity.

Finding 2022-002; Finding: The single audit package for the year ended June 30, 2021 was not submitted to the Federal Audit Clearinghouse (FAC) within the required time period.; Corrective Actions Taken or Planned: In hindsight, following the completion of the FY21 audit, our auditor advised there appeared to be an issued with the Federal Clearinghouse (FAC) system upload. The auditor could see Wyandot's audit report in the completed section of the FAC website and the archive version however when they viewed the area of the website to find audit information and search for submitted DCFs/audits for Wyandot, the list retrieved didn't show an audit for 6/30/21. Going forward, the Chief Financial Officer, Deb Maiwald, will partner with the audit firm to monitor and confirm that the entire series of confirmation emails are received from the FAC. The anticipated completion date is 3/31/23.

Cluster: All represented on the Schedule of Expenditures of Federal Awards (?SEFA?) Sponsoring Agency: All federal agencies represented on the SEFA Award Names: All awards on the SEFA Award Numbers: All awards on the SEFA Assistance Listing Title: All awards on the SEFA Assistance Listing Number: All awards on the SEFA Award Year: All awards on the SEFA Pass-through entity: All identified on the SEFA Management agrees with this finding related to the late submission of the UG Audit Report. The current year audit process was not indicative of the typical audit process for D-HH. Management has subsequently hired additional staff and will file the audit timely moving forward. Leadership Responsible: Barbara A. Vance, PhD, CRA, Vice President, Research Operations Anticipated Completion Date: 3/31/2024

Identifying Number: 2022-013 Finding: Data Collection Form Filing Corrective Actions Taken or Planned: UCAN agrees with this finding and agrees this was directly due to the turnover in the finance team and staffing challenges. The finance team will undergo additional training in federal grant requirements and SEFA reporting. Implementation will be planned for completion before March 31, 2024. Contact person is Kimberly Parish, Chief Financial Officer and she can be reached at kim.parish@ucanchicago.org.

Action planned in response to finding: Management will implement procedures to ensure that all audit documentation, including documentation from third-party service providers, is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe.

Finding 2022-001 Condition: The School did not meet the deadline for submission of its data collection form and reporting Package to the Federal Audit Clearing house for the fiscal year ended June 30, 2021. The data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors? report or nine months after the end of the fiscal year ended June 30, 2021, was December 5, 2021. Corrective Action Plan Corrective Action Planned: Establish procedures to verify that the data collection form and reporting package have been properly submitted on a timely basis. Name of Contact Person Responsible for Corrective Action: Jessica Mullen, Director of Finance and Operations Anticipated Completion Date: December 16, 2022

2022-001- Noncompliance with Single Audit Submission Requirements Condition: Organization did not submit their Single Audit reporting package and data collection form to the Federal Audit Clearinghouse (FAC) for FY 2021. Corrective Action Planned: Organization has been in communication with predecessor auditor to submit fiscal year 2021 single audit. Additionally, the Organization will implement a new control procedure to ensure Single Audit reporting package and data collection form are submitted timely to FAC. Person(s) responsible for corrective action: Rex Snyder, Chief Accounting Officer Telephone: (205) 639-5125 Anticipated Completion Date: Organization has been in communication with predecessor auditor to submit fiscal year 2021 before fiscal year 2022 is submitted. Management company to implement new control procedure before end of fiscal year 2023.

2022-001- Noncompliance with Single Audit Submission Requirements Condition: Organization did not submit their Single Audit reporting package and data collection form to the Federal Audit Clearinghouse (FAC) for FY 2021. Corrective Action Planned: Organization has been in communication with predecessor auditor to submit fiscal year 2021 single audit. Additionally, the Organization will implement a new control procedure to ensure Single Audit reporting package and data collection form are submitted timely to FAC. Person(s) responsible for corrective action: Rex Snyder, Chief Accounting Officer Telephone: (205) 639-5125 Anticipated Completion Date: Organization has been in communication with predecessor auditor to submit fiscal year 2021 before fiscal year 2022 is submitted. Management company to implement new control procedure before end of fiscal year 2023.

2022-001- Noncompliance with Single Audit Submission Requirements Condition: Organization did not submit their Single Audit reporting package and data collection form to the Federal Audit Clearinghouse (FAC) for FY 2021. Corrective Action Planned: Organization has been in communication with predecessor auditor to submit fiscal year 2021 single audit. Additionally, the Organization will implement a new control procedure to ensure Single Audit reporting package and data collection form are submitted timely to FAC. Person(s) responsible for corrective action: Rex Snyder, Chief Accounting Officer Telephone: (205) 639-5125 Anticipated Completion Date: Organization has been in communication with predecessor auditor to submit fiscal year 2021 before fiscal year 2022 is submitted. Management company to implement new control procedure before end of fiscal year 2023.