Corrective Action Plans

Coronavirus State and Local Fiscal Recovery – Assistance Listing No. 21.029 Cause: Controls over SEFA preparation and federal award identification were not sufficient to ensure all pass-through federal awards (including ARPA CPF) were captured with required identifiers (federal agency, ALN 21.029, pass-through name/number) before year-end reporting. Effect: An initially incomplete SEFA increases the risk that major programs are not properly identified for testing, which could result in modification of opinion due to incomplete SEFA, which ultimately could result in a delayed audit. Recommendation: We recommend CCAC implement and document SEFA preparation controls to ensure completeness and accuracy over maintaining a central grant repository containing award documents with federal agency, performing year-end SEFA reconciliation, and obtaining written ALN/FAIN confirmations from pass-through entities for any awards lacking federal identifiers and retaining those confirmations in the grant file. Views of Responsible Officials: There is no disagreement with the audit finding. See below for actions taken to remedy the finding. Management Response: Christina Cultural Center experienced a SEFA completeness finding during a year with bookkeeping turnover, which affected the initial compilation of federal award activity. In response, management worked closely with the audit team to confirm the complete listing of awards, validate pass-through entity details, and support accurate SEFA presentation. The organization has also identified cross-training as a key next step to strengthen continuity and reduce key-person dependency going forward.

Corrective Action Plan - Audit Finding 2024-001: Inaccurate and Incomplete SEFA and Delay in Reporting 1. Documentation Procedures • All federal pass-through funding received will be supported by written documentation (e.g., subaward agreements, grant award letters). • A centralized repository for federal award documentation will be maintained and made accessible to the finance team. 2. SEFA Preparation Controls • A SEFA preparation checklist will be developed and implemented to ensure all federal programs are accurately identified, classified, and reported. • Verification of Assistance Listing Numbers (ALNs) and funding sources for all awards included in the SEFA will be required. 3. Designation of Responsibility • The SEFA Compliance Lead will be assigned responsibility for verifying the federal nature of all awards and ensuring accurate SEFA reporting. • Ongoing training will be provided to finance staff on SEFA requirements and Uniform Guidance compliance. 4. Review and Approval • A formal review and approval process for the SEFA will be instituted prior to submission, including review by the Finance Director and Executive Director. 5. Monitoring and Follow-Up • The Finance Director will monitor ongoing compliance and report quarterly to the Board of Directors on SEFA preparation and submission status. • An annual internal review of SEFA procedures will be conducted to ensure continued compliance. Implementation Timeline All corrective actions will be implemented by March 31, 2026. Responsible Personnel • SEFA Compliance Lead: Mimi Lim, Sr. Finance and Operations Manager • Finance Director: Christine Kuo • Executive Director: Monique Brown This Corrective Action Plan is designed to address the auditor’s recommendations and prevent recurrence of similar issues, in accordance with 2 CFR 200.511(c) and best practices for federal grant compliance.

It should be noted that distribution of funds under this program terminated on December 31, 2024; no new loans will be originated. The Foundation will implement the recommended actions as appropriate in future programs that may be similar to this one.

Finding summary: an internal control deficiency affecting the accuracy of the Schedule of Expenditures of Federal Awards (SEFA) Responsible department: Finance and PPACG Contact person: Finance Corrective action plan: As of 2025 SEFA internally will be prepared by Grant coordinator and review by Finance. Envida will ensure that all appropriate ALNs and Federal identifications and amounts are included on the contracts. Envida will implement a process for all appropriate department directors, including CEO to sign off on each grant received. Timeline for completion: Dec 31 2025 Monitoring plan: Monthly Review with Grant coordinator Anticipated outcome: SEFA will reflect accurate federal expenditures.

Executive Director will work with all program areas to ensure that all federal awards and subawards are identified as such to ensure we track properly • ED will ensure we have written documentation for all federal pass-through funding with correct ALN numbers and communicate the information to the third party accountants • ED will verify the federal nature of all awards and stay current on SEFA and Uniform Guidance

COO will work with all program areas to ensure that all federal awards and subawards are identified as such to ensure we track properly COO will ensure we have written documentation for all federal pass-through funding We have added an experienced grants accountant supervised by the CFO to verify the federal nature of all awards and stay current on SEFA and Uniform Guidance

Management agrees with the finding and has reached out to contacts at HRSA regarding the preferred treatment of the MHS PRF funds but have not received a response. Kevin Gessler, Vice President at MHS, is the contact person at the System. The expected completion date to receive a response and resolve is September 30, 2024.

Views of Responsible Officials and Planned Corrective Action—Management agrees with the finding and has reached out to contacts at HRSA regarding the preferred treatment of the MHS PRF funds but have not received a response. Kevin Gessler, Vice President at MHS, is the contact person at the System. The expected completion date to receive a response and resolve is September 30, 2024.

Finding Number: 2022-001 Condition: The original SEFA prepared for audit purposes did not include all federal expenditures that should have been reported under ALN 66.443. Planned Corrective Action: All programs that have both Federal and State/Local funding will be examined to ensure correct expenditure by funding source is properly recorded. Contact person responsible for corrective action: Curt A. Reppuhn, CPA Deputy Comptroller Anticipated Completion Date: Fiscal Year Ended June 30, 2023