Inperium, Inc.Non-Profit

Finding 2024-001 – Review and approval of Federal expenditures Identification of the federal program: Assistance Listing Number 93.558: - Temporary Assistance for Needy Families (TANF) - U.S. Department of Health and Human Services - Federal award identification number – Various (see SEFA) - Federal award year – July 1, 2023 – June 30, 2024 Material Weakness Condition: The TANF program as operated by CHOR Youth & Family Services (CHORYFS) is a fee-for-service program. Billings to grant funders for services rendered by CHORYFS are not independently reviewed and approved prior to submission. Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Cause: For CHORYFS, the Company’s processes and controls established for review and approval of billings for services rendered by CHORYFS related to the TANF program did not allow for independent review and approval of CHORYFS’ service billings. Effect or potential effect: For CHORYFS, there is an increased risk of errors in the billing to grant funders resulting in the incorrect amount being reimbursed. Questioned costs: None. Context: For CHORYFS, the Company was not able to provide evidence of review and approval of expenditures for the CHORYFS portion of the program. Expenditures for this portion of the federal program represent $240,389 of the total $636,345 on the SEFA. Identification as a repeat finding, if applicable: Yes. 2023-006 Recommendation: We recommend management implement processes and controls that will ensure an independent review and approval of service billings submitted for grant funding is performed and documentation to evidence such review and approval is retained. Views of responsible officials and planned corrective actions: Management agrees with the finding. See attached letter.

Finding 2023-002 – Internal controls and compliance attributable to Provider Relief Funds Identification of the federal program: Assistance Listing Number 93.498: - COVID-19 – Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution - U.S. Department of Health and Human Services - Federal award identification number – Not Applicable - Federal award year – January 1, 2020 – June 30, 2023 Material Weakness and Nonmaterial Noncompliance Condition: The Company was not able to provide documentation to evidence the review and approval of certain expenses incurred by its grant recipient entities in connection with the PRF program. Also, supporting documentation for data utilized by management to calculate and report lost revenue for the applicable grant period was not fully accessible for audit. However, management was able to support the amount reported for lost revenues using Option iii with qualifying expenses incurred during the period of availability. In addition, the Company’s reporting in the PRF reporting portal was not submitted within the required timeframe for one Period 5 submission. Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” The Provider Relief Funds were provided under the Coronavirus Aid, Relief, and Economic Security Act (Pub. L. No. 116-136, 134 Stat. 563) and are to be used to prevent, prepare for, and respond to coronavirus. Specific criteria are established by the U.S. Department of Health and Human Services (HHS) with respect to allowable cost and reporting requirements for this program, including: - Funds shall reimburse the recipient only for health care related expenses or lost revenues that are attributable to coronavirus. - Entities may elect to calculate and report lost revenue using one of three options. For entities electing to report lost revenues using Option ii, the difference between budgeted and actual patient care revenues, budgets must be approved before March 27, 2020 and cover each quarter during the period of availability. Entities electing to calculate lost revenues using another reasonable method should report using Option iii. Cause: The Company’s processes and controls established for review and approval of expenses incurred related to the PRF program did not allow for the retention of documentation to evidence such review and approval was completed and did not ensure timely reporting in all cases. Also, the recipient entity experienced a change of control on December 31, 2021, which resulted in limitations on management’s ability to access documentation to support the lost revenue calculation. Effect or potential effect: There is an increased risk of improper use of grant funds and/or errors in reporting requirements. Also, amounts reported in the Health Resources & Services Administration (HRSA) PRF Reporting Portal (the Portal) can no longer be supported by the Company. This resulted in the Company identifying different allowable expenditures to replace the amount of lost revenue that had been indicated as used in the portal reporting. Questioned costs: None. Context: The Company was not able to provide evidence for review and approval of 15 out of 40 non-payroll expenses tested that were charged to the PRF program. The Company did not complete its reporting within the required timeframe for one of 12 reports tested. The sample sizes were based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Also, the recipient entity reported approximately $66,000 of total lost revenues available to be used through December 31, 2022 in its required Phase 4 reporting through the Portal. Total lost revenues available was calculated as the difference between actual revenue by quarter and the corresponding prior year quarter, beginning with the fourth quarter of 2020 and ended with the second quarter of 2023. Identification as a repeat finding, if applicable: No. Recommendation: We recommend management implement processes and controls that will ensure proper review and approval of grant expenditures is performed and documentation to evidence such review and approval is retained and will ensure timely reporting. Also, we recommend management retain all necessary documentation to support its reporting in the Portal for both qualifying health care related expenses and the calculation of lost revenues. Views of responsible officials and planned corrective actions: Management agrees with the finding. See attached letter.

Finding 2023-003 – Preparation and reconciliation of the Schedule of Expenditures of Federal Awards (SEFA) Identification of the federal program: Assistance Listing Number 21.027: - COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (SLFRF) - U.S. Department Treasury - Federal award identification number – Not Applicable/Wake67 - Federal award year – March 3, 2021 – December 31, 2026 Assistance Listing Number 84.010: - Title I Grants to Local Educational Agencies (Title I) - U.S. Department of Education - Federal award identification number – Various (see SEFA) - Federal award year – July 1, 2022 – June 30, 2023 Assistance Listing Number 93.558: - Temporary Assistance for Needy Families (TANF) - U.S. Department of Health and Human Services - Federal award identification number – Various (see SEFA) - Federal award year – July 1, 2022 – June 30, 2023 Assistance Listing Number 93.658: - Foster Care Title IV-E - U.S. Department of Health and Human Services - Federal award identification number – (Various – see SEFA) - Federal award year – July 1, 2022 – June 30, 2023 Material Weakness and Nonmaterial Noncompliance Condition: For the year ended June 30, 2023, adjustments to the SEFA provided by the Company’s management were required for several programs to accurately report Federal expenditures. In addition, it was noted that some expenditure amounts for the TANF and Foster Care Title IV-E programs were determined based on historical information and not current year actual amounts. Criteria: The Code of Federal Regulations (2 CFR 200.510(b)) requires that the auditee prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA is required to include, at a minimum: 1) individual federal programs by federal agency; 2) the name of the passthrough entity and the identifying number assigned by the pass-through entity; 3) the total federal awards expended for each individual federal program; and 4) total amount provided to subrecipients for each federal program. Cause: The Company’s processes and controls established for reporting its expenditures of Federal awards did not allow for the accurate preparation and reporting of its SEFA for the year ended June 30, 2023. Effect or potential effect: The initially-prepared SEFA was overstated by approximately $205,000 for the SLFRF program (ALN 21.027), $371,000 for the Title I program (ALN 84.010), and $257,000 for the TANF program (ALN 93.558). The Company also initially included expenditures of approximately $1,204,000 for a grant that had ended on June 30, 2022, which had to be removed from the SEFA in its entirety. The effect of including amounts based on historical information is not known. Questioned costs: None. Context: Applies to the testing of the expenditure amounts for major programs and additional testing required to obtain appropriate audit evidence over the SEFA. Identification as a repeat finding, if applicable: No. Recommendation: We recommend management implement processes and controls that will ensure the accurate and timely reporting of the Company’s Federal expenditures included on its SEFA. Views of responsible officials and planned corrective actions: Management agrees with the finding. See attached letter. Identification as a repeat finding, if applicable: No. Recommendation: We recommend management implement processes and controls that will ensure proper review and approval of grant expenditures is performed and documentation to evidence such review and approval is retained and will ensure timely reporting. Also, we recommend management retain all necessary documentation to support its reporting in the Portal for both qualifying health care related expenses and the calculation of lost revenues. Views of responsible officials and planned corrective actions: Management agrees with the finding. See attached letter.

Finding 2023-004 – Review and approval of Federal grant reporting Identification of the federal program: Assistance Listing Number 21.027: - COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (SLFRF) - U.S. Department of Treasury - Federal award identification number – Not Applicable/Wake67 - Federal award year – March 3, 2021 – December 31, 2026 Assistance Listing Number 93.498: - COVID-19 – Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution - U.S. Department of Health and Human Services - Federal award identification number – Not Applicable - Federal award year – January 1, 2020 – June 30, 2023 Material Weakness Condition: The Company was not able to provide documentation to evidence the review and approval of the reports submitted in connection with the SLFRF and PRF programs. Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Specific to ALN 21.027, Act 2 of 2022, Article I-J, ARPA Health Care Workforce Supports requires the entity receiving payments from the Pennsylvania Department of Human Services (PA DHS) under this section to use them only for retention or recruitment of the qualified staff and to submit a report to the PA DHS by September 30, 2022 enumerating staff retention payments. Specific to ALN 93.498, per the HRSA reporting guidance, providers who accepted PRF payments agreed to the Terms and Conditions of the program. Providers who received one or more payments totaling greater than $10,000 in the aggregate during a payment received period must report on use of funds in each applicable reporting period. Cause: The Company’s processes and controls established for review and approval of reporting requirements related to the SLFRF and PRF programs did not allow for the retention of documentation to evidence such review and approval was completed. Effect or potential effect: There is an increased risk of noncompliance with the reporting requirements. Questioned costs: None. Context: We noted a lack of evidence of review for two reports for ALN 21.027 and 12 reports for ALN 93.498. Identification as a repeat finding, if applicable: No. Recommendation: We recommend management implement processes and controls that will ensure proper review and approval of grant reporting requirements is performed and documentation to evidence such review and approval is retained. Views of responsible officials and planned corrective actions: Management agrees with the finding. See attached letter.

Finding 2023-005 – Review and approval of Federal expenditures Identification of the federal program: Assistance Listing Number 93.958: - Block Grants for Community Mental Health Services - U.S. Department of Health and Human Services - Federal award identification number – Not Applicable - Federal award year – July 1, 2022 – June 30, 2023 Material Weakness Condition: The Company was not able to provide documentation to evidence the review and approval of expenses incurred by its CHOR Youth & Family Services (CHORYFS) and Community Prevention Partnership of Berks County (CPP) grant recipient entities in connection with the Block Grants for Community Mental Health Services program. Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Cause: The Company’s processes and controls established for review and approval of expenses incurred related to the Block Grants for Community Mental Health Services program did not allow for the retention of documentation to evidence such review and approval was completed. Effect or potential effect: There is an increased risk of improper use of grant funds. Questioned costs: None. Context: The Company was not able to provide evidence of review and approval of non-payroll expenditures for the CHORYFS and CPP portion of the program. Expenditures for this portion of the federal program represent $93,481 of the total $2,561,377 on the SEFA. Identification as a repeat finding, if applicable: No. Recommendation: We recommend management implement processes and controls that will ensure proper review and approval of grant expenditures is performed and documentation to evidence such review and approval is retained. Views of responsible officials and planned corrective actions: Management agrees with the finding. See attached letter.

Finding 2023-006 – Review and approval of Federal expenditures Identification of the federal program: Assistance Listing Number 93.558: - Temporary Assistance for Needy Families (TANF) - U.S. Department of Health and Human Services - Federal award identification number – Various (see SEFA) - Federal award year – July 1, 2022 – June 30, 2023 Material Weakness Condition: The TANF program as operated by CHORYFS is a fee-for-service program. Billings to grant funders for services rendered by CHORYFS are not independently reviewed and approved prior to submission. The TANF program as operated by Crossroads is a cost reimbursable program. The Company was not able to provide documentation to evidence the review and approval of certain expenses incurred by its Crossroads entity in connection with the TANF program. Criteria: The Code of Federal Regulations (2 CFR 200.303(a)) requires that each non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Cause: For CHORYFS, the Company’s processes and controls established for review and approval of billings for services rendered by CHORYFS related to the TANF program did not allow for independent review and approval of CHORYFS’ service billings. For Crossroads, the Company’s payroll system did not provide evidence of the review of timesheets. Effect or potential effect: For CHORYFS, there is an increased risk of errors in the billing to grant funders resulting in the incorrect amount being reimbursed. For Crossroads, there is an increased risk of improper use of grant funds. Questioned costs: None. Context: For CHORYFS, the Company was not able to provide evidence of review and approval of expenditures for the CHORYFS portion of the program. Expenditures for this portion of the federal program represent $509,594 of the total $873,569 on the SEFA. For Crossroads, the Company was not able to provide evidence for review and approval of 20 out of 40 payroll expenses and 27 out of 40 non-payroll expenses tested that were charged to the TANF program. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Identification as a repeat finding, if applicable: No. Recommendation: We recommend management implement processes and controls that will ensure an independent review and approval of service billings and expenditures submitted for grant funding is performed and documentation to evidence such review and approval is retained. Views of responsible officials and planned corrective actions: Management agrees with the finding. See attached letter.

Finding 2023-007 – Late Audit Reporting Identification of the federal program: Assistance Listing Number 21.027: - COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - U.S. Department Treasury - Federal award identification number – Not Applicable/Wake67 - Federal award year – March 3, 2021 – December 31, 2026 Assistance Listing Number 84.010: - Title I Grants to Local Educational Agencies (Title I) - U.S. Department of Education - Federal award identification number – Various (see SEFA) - Federal award year – July 1, 2022 – June 30, 2023 Assistance Listing Number 93.498: - COVID-19 – Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution - U.S. Department of Health and Human Services - Federal award identification number – Not Applicable - Federal award year – January 1, 2020 – June 30, 2023 Assistance Listing Number 93.558: - Temporary Assistance for Needy Families (TANF) - U.S. Department of Health and Human Services - Federal award identification number – Various (see SEFA) - Federal award year – July 1, 2022 – June 30, 2023 Assistance Listing Number 93.658: - Foster Care Title IV-E - U.S. Department of Health and Human Services - Federal award identification number – Various (see SEFA) - Federal award year – July 1, 2022 – June 30, 2023 Assistance Listing Number 93.958: - Block Grants for Community Mental Health Services - U.S. Department of Health and Human Services - Federal award identification number – Not Applicable - Federal award year – July 1, 2022 – June 30, 2023 Significant Deficiency and Nonmaterial Noncompliance Condition: The Company did not complete and submit their Uniform Guidance audit for the year ended June 30, 2023 to the federal clearing house until after the March 31, 2024 deadline. Criteria: Under 45 CFR Part 75.512, the Uniform Guidance requires that audits are submitted by the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Cause: Delays stemming from various findings caused the required audit procedures and ultimate completion date to extend beyond the regulatory deadline. Effect or potential effect: The late filing could potentially impact future funding from government agencies. Questioned costs: None. Context: The June 30, 2023 single audit reporting package was filed late with the Federal Audit Clearinghouse. Identification as a repeat finding, if applicable: No. Recommendation: We recommend management implement processes and controls that will ensure future audits are completed and submitted timely. Views of responsible officials and planned corrective actions: Management agrees with the finding. See attached letter.