Corrective Action Plans

2022-01 Single Audit Data Collection Forms Not Filed By Due Date Recommendation: We recommend Levi Towers, Inc. develop specific procedures to ensure that the audit report is received prior to the June 30 reporting deadline. Action Taken: Levi Towers, Inc. will develop procedures to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future. Name of responsible person responsible for corrective action: David Wilson Anticipated completion date for the corrective action: February 9, 2024

The Logan County Commission will endeavor to ensure that financial statements are complete and that the audit is scheduled prior to the single audit deadline. We have employed an outside accounting firm to assist with the financial statements

Although management acknowledges that the City’s annual financial statement and single audits have not been completed timely, we also note that it was the only issue identified in the federal single audit. The City has invested significant time and resources to bring its accounting and reporting current. Management anticipates this issue being fully corrected by September 2024 with the timely filing of the 2023 audit. Dr. Brian Martinez, Commissioner of Finance, is responsible for ensuring that this corrective action is completed.

Finding 2022-008: Deadline for Federal Single Audit – Significant Deficiency. Response: 1. Audits will be performed on time beginning in 2024. 2. We will ensure that the Data Collection Form is completed online at h

Finding 2022-001- Federal Audit Clearinghouse (FAC)- 20 N. Murray Street Springfield, Ohio 45503 93 7.325.8715 thes hfb.org The Organization recognizes its lapse in filing the F AC on time. Amidst changes in accounting personnel and the Executive Director role throughout 2022 and early 2023, the Organization has now appointed a Finance Director and filled the Executive Director position. Faith Schiffer, the new Finance Director, will oversee the timely completion of the financial statement audit and ensure the F AC filing meets its deadline.

Management’s Corrective Action Plan For the Year Ended December 31, 2022 Finding Number 2022-001 Contact Person(s): Chanya Swartz, Director of Finance and Controller Corrective Action Planned: Over the last few years, we had significant turn-over of personnel within the finance and accounting department and had an ERP implementation to upgrade our accounting system in 2023. They impacted our processes and things getting done in a timely manner. However, we believe that we have now turned the corner and the personnel situation and processes are now under control. This should ensure that all processes including the submission of “Single Audit Reports” will get back on track and we do not anticipate any more delays moving forward. Anticipated Completion Date: Date completed September 30, 2024

1.) Finding 2022-001 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

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: 3/1/23 Staff: Don Reynolds, contracted CFO Mike Michelon, Interim Executive

The Enterprise Center and Affiliates Corrective Action Plan Year Ended June 30, 2022 Finding 2022-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended June 30, 2022, 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 The Organization is working with external consultants to improve the timeliness of reconciliations and audit preparation. We are continually making accounting policy changes which will correct some of the issues noted. Management is confident that the issues that have been noted will be rectified in the fiscal year ending June 30, 2023. Contact Person: Della Clark, Chief Executive Officer Anticipated Completion Date: June 30, 2023

Views of Responsible Officials and Planned Corrective Action

The Department understands the importance of complying with the Uniform Guidance with respect to the timely submission of single audit reports and the Data Collection Form, and have established policies and procedures to ensure compliance. The late submission in the prior year was primarily due to unforeseen circumstances delaying the completion of the 2021 audit engagement.

As evidenced by previous audit findings, COSA has never experienced a delay in year-end closing. And as previously discussed, due to staff changes and other unforeseen events, the organization was not prepared to commence the audit in a timely manner. COSA has already corrected steps to prevent these issues in the future.

Finding 2022-003 - Single Audit Reporting Package Submission (Repeat Finding) Responsible Person, Title: Vanessa Keppner, Board SecretaryITreasurer Anticipated Completion Date: Completed 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.

Finding 2022-003 - Single Audit Reporting Package Submission (Repeat Finding) Responsible Person, Title: Vanessa Keppner, Board SecretarylTreasurer Anticipated Completion Date: Completed 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.

Finding 2022-003 - Single Audit Reporting Package Submission (Repeat Finding) Responsible Person, Title: Vanessa Keppner, Board Secretaryrrreasurer Anticipated Completion Date: Completed 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.

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