Corrective Action Plans

Finding 2022-002: Special Education Cluster (IDEA), CFDA 84.027 and 84.173 U.S. Department of Education Passed through the Colorado Department of Education Compliance Requirements: Reporting Grant No.: 4027, 6027, 4173, and 6173 Type of finding: Internal Control (material weakness) and noncompliance (material noncompliance) Material Weakness: The material weakness at Finding 2022-001 also applies to this grant. Action Taken: The SLV BOCES will continue to evaluate duties and responsibilities of staff responsible for financial close and grant reconciliation. As of September 2022, Special Education Coordinators have been given grant oversight responsibilities and will monitor grants closely to assure that expenditures are made in a timely manner. Although the BOCES does not currently have a Budget Manager, we are working closely with an accounting agency to perform budgeting and accounting tasks with the assistance of the SLV BOCES HR/Payroll Manager. If the U.S. Department of Education have questions regarding this plan, please call the responsible party listed below. Sincerely yours, Stacy Holland Interim Executive Director San Luis Valley Board of Cooperative Educational Services Cindy Squires Human Resources/Payroll Manager San Luis Valley Board of Cooperative Educational Services

CORRECTIVE ACTION PLAN - FINDING 2022-002 We have prepared the accompanying corrective action plan as required by the standards applicable to financial audit contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Federal Assistance # 84.041, 84.425, 84.027 Program Titles Impact Aid, Covid-19 Education Stabilization Fund, Special Education ? Grants to States Federal Agency U.S. Department of Education Condition The District did not submit their audit for the fiscal year ending June 30, 2022 timely. The audit was submitted April 24, 2023, which was 24 days past the March 31, 2023 deadline. Corrective Action Plan The District will coordinate with the audit firm under contract to ensure that the audit report for the fiscal year ending June 30, 2023 will be submitted in a timely manner. District Contact Arlene Laughter, Business Manager Completion Date June 30, 2023

Corrective Action Plan for Current Year Finding Tulsa Educare, Inc. submits the following corrective action plans for the identified finding for the audit period July 1, 2021, through June 30, 2022. Finding 2022-001: Submission of Data Collection Form Corrective Action: Tulsa Educare has added a task to its financial audit checklist of ensuring the data collection form and reporting package is submitted to the Federal Audit Clearinghouse within the required timeframe. Person Responsible: Brad Weber, Director of Finance Timing for Implementation: Immediate

Finding 2022-001: The Corporation did not submit the Data Collection Form (SF-SAC) for the year ended September 30, 2021 to the Office of Management and Budget ("OMB") in a timely manner as required by Uniform Guidance section 2 CFR 200.512. Comments on the Finding and Each Recommendation: The Corporation should submit all future Data Collection Forms in the required time frame. Action(s) taken or planned on the finding: Management concurs with the finding and recommendations and submitted the Data Collection Form on September 27, 2022.

DATA COLLECTION FORM COMPLIANCE Department of Health and Human Services 93.788 The State Opioid Response Transportation Project Manager will complete and submit all future annual Single Audits to the Federal Audit Clearinghouse prior to the required deadline to ensure all compliance requirements are met beginning with the Single Audit Reporting Package for fiscal year ending June 30, 2023 prior to the March 31, 2024 deadline.

Identifying Number: Finding 2022-001 Late Data Collection Form Filing Finding: The District?s fiscal year 2021 Single Audit package was not submitted to the Federal Clearinghouse within the required time period. School District 54 Corrective Action Plan: Uniform Guidance 2 CFR 200.512(a) requires that each organization?s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor?s report or nine months after the end of the audit period. The Single Audit package for the District's year ended June 30, 2021 and audit report was issued on December 27, 2021, as such data collection form should have been submitted to the Federal Audit Clearinghouse by January 27, 2022. The audit was not completed until December 27, 2021, which put a lot of strain on internal resources and the District could not independently track the submission of the data collection form. The District will make sure that the data collection form is filed timely after the audit is complete. Contact Person Responsible for Corrective Action Plan: Ric King, Assistant Superintendent of Business Operations (847-357-5039) Anticipated Completion Date: Fiscal Year 2023

CORRECTIVE ACTION PLAN July 14, 2023 U.S. Department of Health and Human Services Crisis and Counseling Centers, Inc. respectfully submits the following corrective action plan of the year ended June 30, 2022. Name and address of independent public accounting firm: One River CPAs 46 FirstPark Drive, Oakland, ME 04963 FINDING ? FINANCIAL STATEMENT AUDIT None FINDING ? FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Health and Human Services 2022-001 Noncompliance and Material Weakness in Internal Control over Compliance: Requests required to complete the audit were not submitted within sufficient time to allow for audit and reporting prior to the deadline. The following errors and missing required elements were noted and corrected as a result of auditing procedures on the SEFA: ? Expenditures under agreement MHC-22-322B under CFDA 93.665 were not included. ? Expenditures under agreement CBH-22-1003A under CFDA 93.958 were not included. ? Expenditures under Period 4 of Provider Relief Funds (PRF) were included in error. ? There were two instances of COVID-19 programs that did not include the appropriate prefix. ? Subtotals were not included for the following CFDA numbers 93.958; 93.104; and 93.243. ? Expenditures under agreement CDM-21-4462A under CFDA 93.243 were shown included under CFDA 93.959 in error. Recommendations: Management should seek additional training for the fiscal department on preparation of the SEFA standards. In addition, review processes over the SEFA should be strengthened. Both the preparer and reviewer should have a clear understanding of the required minimum elements. As part of the review, all required minimum elements should be vouched to original source documents including copies of awards, reporting, and the trial balance. Any inconsistencies should be resolved before beginning the audit. The compliance supplement should be reviewed for reporting guidance on new Federal programs. Responsible Person for Corrective Action: Timothy D. Floyd, Chief Financial Officer Management will seek additional training in preparation of the SEFA and the applicable standards. The anticipated completion date for this corrective action is December 31, 2023. If the U.S. Department of Health and Human Services has questions regarding this plan, please contact Timothy D. Floyd, Chief Financial Officer at 207-626-3448 or tfloyd@crisisandcounseling.org. Sincerely, Timothy D. Floyd, Chief Financial Officer

Audit Finding: Pursuant to 2 CFR 200.512 Report submission, Army West Point Athletic Association Inc. (?AWPAA?) did not submit its FY2022 data collection form and reporting package by the earlier of 30 calendar days after receipt of the auditor' report(s), or nine months after the end of the audit period. Root Cause Analysis: In July 2021, the Business Office experienced turnover as staff members departed for new employment opportunities. These departures were higher compensation, more favorable work environment (hybrid/full remote arrangements), as well as for profit and nonprofit opportunities outside of college athletics. The COVID-19 global pandemic also contributed to these departures as the organization had to reduce head count and execute voluntary salary furloughs over the course of four months. Even though the AWPAA COVID-19 countermeasures were temporary, the entire Business Office staff departed over a thirty--day period. In July 2022, the Business Office was fully staffed. Unfortunately, the FY2021 data collection form and reporting package were not completed and submitted until January 2023 or seven months after the end of FY2022. The cumulative effect of submitting the FY2021 data collection form and reporting package late caused a delay in AWPAA?s ability to complete FY2022?s submission by the required deadline. Corrective Action Plan: To complete the FY2022 financial statement audit on/by June 30, 2023. Furthermore, the Business Office will accelerate its financial statement and single audit preparations and engagements to submit its future data collection form and reporting package in a timely manner. Estimated Completion Date: Submit FY2022 data collection form and reporting package by June 30, 2023. Submit FY2023 data collection form and reporting package by November 30, 2023. Point of Contact: Wen-Kang Chang, Chief Financial Officer

The University will develop adequate policies and procedures for the reporting requirements of the Federal Awards and the management monitors and oversee the compliance requirements. Bethesda University was not aware of the submission of the audit because several transitions in all key personnel and insufficient oversight have led to untimely reporting. The University will ensure that the management of the University reviews the reporting requirements of the Federal Awards and determines the level of an organization?s adherence to regulatory guidelines. The management acknowledged that the audit must be completed and the reporting required within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the fiscal period end date which would be March 31. The University will monitor and oversee the compliance requirement and make sure it is properly performed and submitted in timely manner. Person Responsible for Corrective Action Plan: Sheng Wang, Chief Financial Officer Anticipated Date of Completion: June 30, 2023

2022-007: Internal Control over Compliance with Reporting Requirements Management agrees with the finding and takes responsibility to comply with reporting requirements. Management plans to adhere to documented policies and procedures and documented instructions for reporting requirements contained within grant agreements to ensure that the required reports are properly submitted to the federal government on a timely basis. Management will implement a policy of formally tracking all required reports and submission deadlines to address the delayed submission of the data collection form and reporting package and will submit the earlier of 30 calendar days after receipt of the auditor?s reports or nine months after the end of the audit period to the Federal Audit Clearinghouse (FAC). Individual(s) Responsible for Corrective Action Plans: Marcelo Presser Interim Chief Financial Officer mpresser@heartlandalliance.org Anticipated Completion Date: 12/2023

Fiscal Year Ended June 30, 2022 Section III ? Federal Awards Findings and Questioned Costs Item 2022-001 Federal Assistance Listing Number: 93.044 American Rescue Plan for Supportive Services under Title III-B of the Older Americans Act6 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 Necessary staffing changes were made to ensure that future filings are completed within nine months of the end of the fiscal year. Person responsible for the corrective action plan: Kevin Heslop, Vice President of Finance

#2022-003 Untimely Data Collection Form and Single Audit Reporting Submission U.S. Department of Education Title I Grants to Local Educational Agencies #84.010 U.S. Department of Education Education Stabilization Fund (ESF) #84.425 Recommendation: We recommend that Management of the Board of Education take the necessary steps to ensure that the year-end financial statements are supported by accurate reconciliations and documentation in a timely manner so that the reporting package and data collection form can be submitted as required. Action Taken: Management of the Board of Education will properly plan and take the necessary steps to ensure that year-end financial statements are supported by accurate reconciliations and other documentation so that the reporting package and data collection form can be submitted as required by the Uniform Guidance. Joseph Campinelli III, Treasurer/Chief School Business Official is responsible for implementing these procedures by March 31, 2024.

PDE: Audits retrieved from the Federal Audit Clearinghouse are now reviewed after entry into PDE?s SharePoint website, to ensure PDE remains compliant with federal guidelines to respond to any and all findings pertaining to federal dollars it passes to subrecipients. Likewise, PDE Audit Section continues to improve upon its processes for timely determinations of those single audits with findings by multiple means, including periodic SharePoint enhancements designed to aid in timely review of single audit packages, working closely with PDE program areas to assist in timely responses and quickly addressing SharePoint access issues as they arise. Anticipated Completion Date: 06/30/2023 Contact Person and Title: Clayton P. Carroll, II, Audit Coordinator; Jessica Sites, Director, Bur. of Budget and Fiscal Mgmt DEP: BAFM now provides agencies with single audit reporting packages that have findings each week that have been accepted by the Federal Audit Clearinghouse (FAC). This allows for us to start our management decision process in a timelier manner and meet the six-month deadline for issuing our decision. This information first appeared in our notifications starting April 30, 2021. In addition, the DEP program that had been previously identifying agreements as contracts rather than subrecipient agreements has corrected this issue and all subrecipients have been notified in writing of this correction and provided the information for submitting their single audits (if necessary). The letters were sent to subrecipients on approximately May 31, 2022. DEP Fiscal Management staff will continue to monitor the BAFM SharePoint site and FAC for additional filings to attempt to avoid this issue in the future. DEP is also hiring additional staff for the oversight and monitoring of the subrecipient single audits to ensure compliance with all requirements. These positions are currently in the filing process, and we are hopeful that they will be filled, and staff trained by September 30, 2023. Anticipated Completion Date: 09/30/2023 Contact Person and Title: Jennifer L. Brandt, Senior Fiscal Management Specialist, Federal Grants and Audits DOH: NORTH Inc.?s Single Audit report for the period ending 9/30/2020 was officially submitted and showing on the FAC on 2/9/2023. Bureau of WIC staff reached out to the Director and CFO of NORTH Inc. by phone and email. Emails were sent with instructions on how to submit the report as well as the importance of submitting the report timely per their grant agreement. Each follow-up phone call included discussion on the importance of submitting their single audit as soon as possible. Moving forward the Bureau of WIC will implement the following procedure: 1 .Three months after the end of the audit period (Federal Fiscal Year), Project Officers will send an email that outlines the process for submitting a single audit reporting package to the FAC to their respective WIC local agencies. This email will provide a date that the single audit is due to be submitted to the FAC in order to stay in compliance with their current WIC grant agreement. 2. Six months after the end of the audit period (three months from the due date of the single audit reporting package) an official letter from the Bureau Director will go out to the WIC local agencies that are due to submit a single audit. The letters will include instructions on how to submit the single audit in FAC and the Audit Requirements link referenced in their grant agreement. 3. If the WIC local agency notifies the Bureau of WIC that their auditor will not be able to submit their agency?s single audit by the due date, then the Project Officer will work with the local agency to get a projected date of completion and a timeline on when the local agency?s auditor is able to finalize the audit and submit it to the FAC. The Bureau of WIC will then notify DOH?s Audit Coordinator and OB-BAFM of this information, so they are able to track it. 4. If the WIC local agency does not submit the report by the due date and fails to notify their project officer; a notice to cure letter will be sent to the agency. Concerning NORTH Inc.?s Single Audit report for the period ending September 30, 2021: 1. The Bureau of WIC will contact NORTH Inc. and request a meeting with their auditor. 2. Following the meeting with NORTH Inc.?s auditor, the Bureau Director will send an official letter to NORTH Inc. The letter will include the instructions on how to submit the single audit in the FAC and the Audit Requirements link referenced in their grant agreement. They will also be made aware of the actions that could result from them not submitting this audit by the agreed upon date. 3. If the single audit is not received by the agreed upon date, then the Bureau of WIC will send a notice to cure letter. Anticipated Completion Date: 03/24/2023 Contact Person and Title: Sally Zubairu-Cofield, Director, Bureau of WIC DHS: Regarding the timeliness of finding resolution and procedures related to the SEFA reviews, the Audit Resolution Section (ARS) hired an additional staff member in August 2021 and hired two additional staff members in February 2022, and an additional staff member in January 2023. Finally, the ARS worked with Office of the Budget, Bureau of Accounting and Financial Management to develop a risk-based approach for single audit reviews, which will greatly streamline the process of single audit reviews to gain substantial efficiencies. Regarding late audit report submissions, we will continue to follow the requirements of 2 CFR ?200.339 and Commonwealth Management Directive 325.8. We will continue to work with counties and their independent auditors to obtain any late Single Audit reports. Anticipated Completion Date: 06/30/2023 Contact Person and Title: David Bryan, Manager, ARS; Alexander Matolyak, Director, Division of Audit & Review

The Organization started its remediation of its accounting closing processes during 2021. As a part of the Organization?s remediation they hired an external consultant to provide chief financial officer/controller level services over the Organization?s accounting and financial processes. Timely and accurate accounting records will ensure the timely completion of future reporting requirements for the Organization.

Oversight Agency: U.S. Department of Housing and Urban Development Northwest Compass, Inc. respectfully submits the following corrective action plans for the year ended June 30, 2022. Auditor: Dugan & Lopatka, CPA?s 4320 Winfield Road Suite 450 Warrenville, IL 60555 Audit Period: For the year ended June 30, 2022 The findings from the schedule of finding and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-002 Youth Homelessness Demonstration Program, CFDA #14.276 Auditor?s Recommendation: We recommend that upon receiving the final reporting package, the Organization completes all requirements with the Federal Audit Clearinghouse. Northwest Compass has adopted this policy for FY2022. If the funding agency has questions regarding this plan, please call me at (847) 392-2344.

Management?s Corrective Action Plan Bells City School respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: ATA CPAs + Advisors PLLC 185 North Church Street Dyersburg, TN 38024 Responsible official for corrective action: Mark Wallace, Director of Schools, Bells City School Board of Education Audit period: June 30, 2022 The findings from the June 30, 2022, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. 2022-003 Data Collection Form Not Filed by Deadline - compliance - other Corrective Action Taken/Planned: The School has and will continue to provide data to the audit firm in a timely manner. The audit firm will ensure that the audit report and data collection form are filed timely in the future. Anticipated Completion Date: March 31, 2024.

Corrective Action Plan: In response to the finding labeled 2022-002, the College has begun to improve improved its processes to close year-end books in a timely manner and produce financial statements in a manner that accommodates a single audit filing within published timeframes. The College has also found an individual with appropriate financial reporting skills, knowledge, and experience to sit on the board of directors. The remediation of this finding should be completed before March 30, 2024, the College?s 2023 audit period single audit submission deadline

Finding 2022-001 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Nickie Crowe, Finance Director Corrective Action Plan: The City of Nome will communicate with Nome Joint Utility System (NJUS) by July 1 of each year requesting their confirmation on the schedule for the completion of NJUS? audited financial statements not later than November 30. The City of Nome and NJUS will communicate monthly on the status of the NJUS Audited Financials until the target date of November 30 of each year is met. If NJUS fails to communicate, the Nome Common Council will be notified immediately so that new action can be taken to ensure the City of Nome is compliant on future audits. Proposed Completion Date: November 30, 2023

Audit Finding #2022-003 Reporting Name of Contact Person: Maryland Hutchinson, Fiscal Manager. Corrective Action: UCAP has implemented measures to ensure that there is no delay in financial reporting in the future. UCAP works directly with the grantors and contract administrators in order to ensure timely payment of all reimbursable grants and has implemented steps in order to ensure that costs won?t have to be recategorized in the future. Proposed Completion Date: This will be complete by 6/30/2023 and will be reflected in the upcoming year-end.

2022-004. 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.

FINDINGS ? FEDERAL AWARD FINDINGS 2022-001 Single Audit Data Collection Form Not Filed By Due Date Recommendation: We recommend that Area Agency on Aging of Northwest Arkansas, Inc. & Subsidiaries develop specific procedures to ensure that the audit report is received prior to the March 31 reporting deadline. Action taken: Area Agency on Aging of Northwest Arkansas, Inc. and Subsidiaries 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 contact person responsible for corrective action: Brad Bailey Anticipated completion date for the corrective action: September 8, 2023

2022-002 (2021-004) LATE FILING OF THE SINGLE AUDIT REPORTING PACKAGE WITH THE FEDERAL AUDIT CLEARINGHOUSE - REPEATED (Significant Deficiency, Non-compliance) Recommendation: We recommend that management enhance its internal control structure, including financial close and reporting, to ensure timely filing of future Single Audit reporting packages. Management Response Corrective Action: NMACD management will enhance its internal control structure, including final close and reporting to ensure timely filing of future Single Audit reporting packages. We plan to start our FY23 audit in November, which should correct this finding. Due Date of Completion: No later than the due date of the Data Collection Form, which is March 31, 2024. Responsible Party(ies): Executive Director working together with Contracted Accountant

2022-014 ? Late Submission of Annual Federal Reporting Package Corrective Action: NTU has developed a comprehensive year-end financial close and annual federal reporting plan with the assistance of our consultants, Harshwal & Company, LLC in September 2022. This plan was not implemented until after the end of fiscal year 2022. As part of this plan, NTU will ensure that financial accounting books and records are reconciled and closed in a timely manner prior to providing the final trial balance to the auditor. Person Responsible: Cheryl Thompson, Finance Director and Harshwal & Company LLC Estimated Completion Date: July 31, 2023

Corrective Action Plan: The District will implement procedures to ensure that all audit documentation is available for auditing in a timely manner and the audit report is submitted within the appropriate timeframe.

1. Develop and implement a schedule. Audit Commencement should be initiated by mid-september following the close of FY. 2. Conduct a weekly follow-up meeting to ensure that all internal and external documents are being produced and supplied to appropriate parties 3. Ensure that all internal personnel are given the knowledge and resources to mitigate the disruption that may come from any employee transition or turnover. 4. Conclude the audit by the end of December of the following end of the FY.