Corrective Action Plans

The Alabama Law Enforcement Agency will strengthen its procedures to ensure expenditures are charged only within the approved period of performance for each federal grant. Grant period dates will be monitored and reviewed by multiple divisions, including the Grants Section, Payroll Section, and Programs Office, to provide additional oversight and verification. Because payroll expenditures are reported and reimbursed on a cash basis and the State payroll expense is in arrears, payroll funding allocations will be reviewed and updated prior to the end of the grant period. Specifically, grant-funded payroll charges will be evaluated at least 30 days before the grant expiration date to ensure that costs incurred after the period of performance are not charged to the grant. These enhanced monitoring and review procedures will help ensure compliance with federal grant requirements and prevent future charges outside the approved grant period.

The Alabama Law Enforcement Agency has corrected the program coding within the State's financial system to ensure that each grant is associated with the appropriate Assistance Listing (CFDA) number. To strengthen internal controls and reduce the risk of similar errors in the future, grant setup and coding information will be subject to review by multiple individuals prior to implementation. Additionally, annual reviews will be conducted to verify that grant information recorded in the financial system is consistent with the applicable Notice of Award and other grant documentation. These measures are intended to enhance the accuracy of federal program reporting and ensure expenditures are properly attributed to the correct funding source.

There is no direct guidance detailing steps to update the FMAP rate in STAARS. Changes are made in the STAARS cost allocation test environment and then implemented in the production environment via STAARS Support. Cost allocation runs quarterly. While we initiate the entering of statistics from work sampling and other sources, we are at the mercy of STAARS Support to actually run cost allocation for DHR.

DHR has added additional steps related to Adult Day Care services entered in FACTS. This will ensure entered services reconcile to the approved invoice prior to approval in FACTS.

However, if this finding is affirmed the corrective action plan will be for the Alabama Military Department to ensure all charges to support federal awards will be charged appropriately in STAARS. Accounting entries in STAARS will be allocable and allowable charges as approved by the Grants Officer.

PAYROLL CONTROLS Criteria: In accordance with the documentation standards of 2 CFR section 200.430(a), costs of compensation for personal services are allowable to the extent the total compensation for individual employees is reasonable for the services rendered, conforms to the established written policy of the recipient or subrecipient and is determined and supported as provided in 2 CFR section 200.430(g), which states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: Payroll testing was completed for a sample of 40 individuals for which time and expenses were charged to R&D grants. Within that selection, we noted instances where payroll controls did not function properly in regard to percentage of time allocated to a grant, proper pay code inclusion, fringe benefit calculation and timely and supervisor level review of time sheets. Context: Management was able to isolate the time allocation error to 20 employees for which the time and costs charges to the grants were in excess of actual time allocation. This resulted in $87,831.53 in excess charged to the grants. Additional control deficiencies did not result in significant improper grant expenditures. Cause: A new payroll system was implemented in fiscal 2025. Grant allocation percentages were not accurately established in the payroll system upon conversion. Effect: Time charged to grant efforts by certain individuals exceeded actual time worked. Recommendation: Review controls should be enhanced to ensure grant expenditures accurately reflect payroll costs. Corrective Actions Taken or Planned: Management identified the issue early following implementation of the new payroll system and performed a detailed review to isolate the impacted population. Corrections were made to payroll allocations for the affected employees, and reimbursement adjustments were processed as appropriate. To prevent recurrence, management has implemented the following control enhancements: - Standardized procedures for establishing and validating grant allocation percentages within the payroll system; - Enhanced supervisory review requirements for time reporting and payroll approvals; - Periodic monitoring and reconciliation of payroll charges to grant budgets; - Additional training for payroll and grant accounting personnel on system configuration and compliance requirements. Responsible Parties: VP of Accounting and Controller and VP of Audit & Compliance. Anticipated Completion Date: Completed in fiscal year 2025; ongoing monitoring procedures are in place.

Finding Number: 2025-003 Finding Title: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting Program: 93.658 Foster Care Title IV-E, 93.778 Grants to States for Medicaid Name of Contact Person Responsible for Corrective Action: Ryan DuMond, Supervisor, Accounting Corrective Action Planned: Staff will conduct thorough reviews of all Quarterly Fiscal Memos and attachments issued by DHS to ensure that reporting requirements are fully understood and applied consistently. The County will also develop and document a comprehensive procedure for preparing the DHS‑2550 and DHS‑2556 reports, including detailed instructions for entering adjustments, processing reversing entries, reporting amortization, properly coding capital purchases, and handling MAXIS‑related costs. A mandatory review process will be implemented before submission of each report to verify accuracy and compliance with DHS guidance. As part of this review, staff will closely examine expense classifications to ensure that capital outlay expenditures are accurately coded and reported, and that all required amortization expenses are correctly included. These actions will help prevent misclassification and report errors in future submissions. Anticipated Completion Date: July 2026

Management Response: Management acknowledges Finding 2025-005 and agrees that the deficiency in accounting for expenses covered under the resource sharing agreement constitutes a material weakness in internal control over financial reporting and compliance. Misclassification of individual expense categories by $70,223 affected the accuracy of category-level reporting and increased the risk of budget overages or noncompliance where federal awards and resource sharing agreements contain line-item spending limitations or require accurate reporting by cost category. Although the error did not necessarily affect total expenditures, incorrect classification can impair oversight, distort budget-to-actual monitoring, and reduce the reliability of information used for internal and external reporting. Management determined that the root causes included insufficiently detailed written guidance for coding transactions under the resource sharing agreement, inconsistent use of account mappings between the general ledger and agreement budget categories, and inadequate review of category-level coding before expenditures were finalized and reported. Existing procedures addressed expense processing generally, but they did not provide enough direction on how shared-service or agreement-covered costs should be classified into the proper expense categories for budget monitoring and reporting. To address this material weakness, management is implementing a corrective action plan focused on improving category-level classification and reporting for expenses covered under the resource sharing agreement. The plan includes four key actions: revising written accounting procedures to define category descriptions, coding rules, and decision standards; creating a standardized crosswalk between general ledger accounts and agreement budget categories; requiring supervisory review of category coding before final reporting; and implementing periodic budget-to-actual monitoring to identify unusual balances, potential overages, and coding trends that may indicate misclassification. Under the revised process, each expense charged under the resource sharing agreement will be recorded using the approved chart-of-accounts mapping and supported by documentation sufficient to identify the nature of the cost, the applicable budget category, and the reason the selected classification is appropriate. If a transaction involves a cost type that does not clearly align to an established category, accounting personnel will be required to elevate the transaction for review before posting or reporting. Any manual reclassification entries affecting agreement categories will require documented justification and supervisory approval. In addition, management will compare recorded expenditures to budgeted amounts by category on a recurring basis so that unusual fluctuations, coding anomalies, or category overages can be investigated and corrected before financial or grant reporting is finalized. Management will also provide targeted training to accounting, finance, and grants personnel responsible for recording or reviewing resource sharing agreement activity. Training will address the relationship between GAAP-based accounting records, agreement-specific budget categories, and federal compliance expectations for accurate, current, and complete financial reporting and comparison of expenditures to budget amounts. Management will supplement this training with periodic reviews of classification trends and exception items so that recurring coding issues can be identified and corrected through additional guidance, process changes, or retraining as needed. Management believes these corrective actions directly address the auditors’ recommendation to review current policies and procedures for compliance with GAAP and federal regulations. Responsibility for implementation will rest primarily with the Finance Director, in coordination with accounting and grants personnel involved in resource sharing agreement reporting. Management expects the enhanced coding guidance, account crosswalk, review controls, and category-level monitoring procedures to improve the accuracy of expense classification, strengthen budget oversight, and reduce the risk of misstatements or noncompliance related to resource sharing agreement expenditures in future periods. Corrective Action Plan Summary Corrective Action Responsible Staff/Role Target Completion Date Evidence of Completion Revise and adopt written accounting procedures for expenses covered under the resource sharing agreement, including category definitions, coding rules, and documentation standards for classification decisions. Finance Director; Accounting Manager June 30, 2026 Approved procedures; updated accounting manual; staff distribution records. Develop and implement a standardized crosswalk between general ledger accounts and resource sharing agreement budget categories, including guidance for common transaction types and reclassification scenarios. Accounting Manager; Finance Director July 15, 2026 Approved account crosswalk; coding reference guide; sample mapped transactions. Require documented supervisory review of category coding for resource sharing agreement transactions before final reporting, including review of manual reclasses and higher-risk expense categories. Finance Director Effective immediately Reviewer signoff on category reports; approved reclassification support; supervisory review documentation. Provide targeted training to accounting, finance, and grants personnel on category-level expense classification, use of the crosswalk, and reporting requirements under the resource sharing agreement Compliance Officer; Finance Director August 31, 2026 Training materials; attendance logs; completed acknowledgements or knowledge checks. and applicable federal regulations. Perform monthly budget-to-actual category reviews for resource sharing agreement expenditures to identify unusual balances, potential overages, and coding anomalies requiring investigation or correction. Accounting Manager; Finance Director Monthly, beginning July 31, 2026 Monthly budget-to-actual reports; exception logs; documented follow-up and corrections. Perform quarterly monitoring of a sample of resource sharing agreement transactions to verify correct category coding, consistency with the approved crosswalk, and compliance with agreement and federal reporting requirements. Compliance Officer; Finance Director Quarterly, beginning September 30, 2026 Quarterly monitoring reports; sample testing documentation; corrective action follow-up records

Management Response: Management acknowledges Finding 2025-003 and agrees that the control deficiency related to allocation of expenses within the WIOA Cluster constitutes a material weakness in internal control over compliance. This finding is distinct from Finding 2025-002 because it concerns the methodology, approval, and monitoring of cost allocations affecting WIOA programs, including restrictions applicable to the Youth program, rather than the allowability of costs based on timing or period of performance. Although the identified costs were corrected, the deficiency increased the risk that shared or allocable costs could be assigned to restricted programs in a manner inconsistent with federal requirements if not detected and prevented in a timely manner. Management determined that the root causes were insufficiently detailed written procedures for allocating shared costs within the WIOA Cluster, lack of explicit documentation addressing the prohibition on transfers to or from the Youth program under 20 CFR 683.130, and inconsistent supervisory review of allocation entries before posting. Existing practices addressed cost charging generally, but they did not provide enough direction on how shared expenditures benefiting multiple WIOA funding streams should be allocated, documented, reviewed, and restricted when Youth funds were involved. To address this material weakness, management is implementing four control improvements. First, it will formalize written cost allocation policies and procedures for the WIOA Cluster that define approved methodologies, documentation standards, proportional benefit requirements, and restrictions applicable to the Youth program. Second, it will require documented supervisory review and approval of all allocation entries affecting WIOA programs before posting to the general ledger. Third, it will provide targeted training to finance, grants, and program management personnel on WIOA-specific allocation requirements, with particular emphasis on Youth program restrictions. Fourth, it will implement periodic monitoring to verify that allocations follow the approved methodology and remain consistent with federal requirements. Under the revised process, each allocation affecting WIOA programs will be supported by contemporaneous documentation identifying the nature of the cost, the programs benefiting from the expenditure, the basis used to distribute the cost, and the calculation of the amounts charged to each program. When a cost benefits multiple programs and proportional benefit can be reasonably determined, the allocation will be based on that proportional benefit. When proportional benefit cannot be determined precisely, the allocation will be supported by a reasonable documented method that is applied consistently. Allocation support must also include a compliance checkpoint confirming that no allocation results in an impermissible transfer to or from the Youth program. No allocation entry affecting WIOA programs will be recorded without documented preparer support and written supervisory review evidencing compliance with internal policy and applicable regulations. Management will also establish recurring monitoring controls to test allocations recorded during the year. On at least a quarterly basis, the Finance Director or designee will review a sample of WIOA allocation entries to confirm that the approved methodology was followed, supporting documentation was retained, supervisory approval was completed, and Youth program restrictions were observed. Exceptions identified through this monitoring process will be documented, investigated, and corrected promptly, with any necessary retraining or policy revisions implemented to prevent recurrence. Results of the monitoring process will be communicated to senior management as part of ongoing oversight of federal awards compliance. Management believes these corrective actions directly address the auditors’ recommendations and strengthen controls over allocation of expenses within the WIOA Cluster without duplicating the corrective actions described in Finding 2025-002. Responsibility for implementation will rest primarily with the Finance Director, in coordination with grants and program leadership. Management expects the enhanced policy framework, approval requirements, training, and monitoring activities to reduce the risk of noncompliant allocations, improve documentation of shared cost methodologies, and support sustained compliance with 2 CFR 200.405 and 20 CFR 683.130. Corrective Action Plan Summary Corrective Action Responsible Staff/Role Target Completion Date Evidence of Completion Revise and adopt written WIOA cost allocation policies and procedures that define approved allocation methodologies, documentation requirements, proportional benefit standards, and explicit restrictions applicable to the Youth program. Finance Director; Grants Manager June 30, 2026 Approved policy and procedure document; distribution to applicable staff; retained version history. Implement a standardized allocation worksheet and review checklist for all shared costs charged to WIOA programs, including a compliance checkpoint for Youth program restrictions. Accounting Manager; Finance Director July 15, 2026 Standard allocation template; completed review checklist; sample completed allocation packages. Require documented supervisory review and approval of all allocation entries affecting WIOA programs before posting to the general ledger. Finance Director Effective immediately Signed allocation entries; reviewer signoff; journal entry support retained with monthly close documentation. Provide targeted training to finance, grants, and program personnel on 2 CFR 200.405, WIOA allocation principles, and the prohibition on transfers to or Finance Director; Compliance Officer August 31, 2026 Training materials; attendance logs; completed acknowledgements or assessments. from the Youth program under 20 CFR 683.130. Perform quarterly monitoring of a sample of WIOA allocation entries to verify adherence to the approved methodology, adequacy of support, supervisory approval, and compliance with Youth program restrictions. Finance Director; Compliance Officer Quarterly, beginning September 30, 2026 Quarterly monitoring reports; exception logs; documented corrective follow-up. Evaluate the effectiveness of the revised allocation controls and update policies, training, or monitoring procedures if deficiencies or exceptions are identified. Finance Director; Executive Leadership Semi-annually during fiscal year 2027 Management review memoranda; updated procedures; remediation tracking documentation.

Finding: 2025-002 Reportable finding considered a material weakness-Expenses incurred outside of the period of performance Effect: The organization claimed and was reimbursed for unallowable costs under 2 CFR 200.458. Failure to maintain effective controls over cost allowability increases the risk of noncompliance questioned costs, and potential repayment of federal funds. Questioned costs: Known questioned costs of $403,805 were identified by reviewing each transaction prior to the date and for the month after the award began to ensure there are no likely questioned costs. Recommendation for the organization from the auditor: • Formalize and implement written policies and procedures governing identification, approval, and accounting for pre-award costs. • Require documented written approval from the federal awarding agency prior to charging any pre-award costs to federal awards. • Provide training to program and finance personnel on Uniform Guidance cost allowability requirements, including 2 CFR 200.458 and 2 CFR 200.403. • Implement supervisory review controls to ensure costs charged to federal awards are incurred within the approval period of performance or have documented prior approval. Corrective Action Plan for Pre-award costs Management acknowledges the audit finding that pre-award costs were charged to multiple federal awards for expenses incurred before the approved period of performance beginning October 1, 2024. The costs were incurred without the required written prior approval from the Maryland Department of Labor (MD DOL), the pass-through entity. As a result, unallowable costs were reimbursed and later removed from the Schedule of Expenditures of Federal Awards (SEFA). Management determined that the issue resulted from insufficient internal controls, the absence of formal written procedures for pre-award costs, and gaps in staff understanding of Uniform Guidance requirements. To address these root causes, the organization adopted a formal written policy governing the identification, approval, documentation, and accounting of pre-award costs. The policy requires written prior approval from MD DOL before any pre-award costs may be incurred or charged to a federal award and establishes documentation, retention, and accounting standards to support compliance with 2 CFR 200.458 and 2 CFR 200.403. Third, the organization also implemented a mandatory written approval workflow requiring program and grants staff to prepare and submit a formal request to MD DOL whenever pre-award costs are anticipated. No costs may be incurred until written approval is received. Approval documentation must be retained in both the official grant file and the accounting system. This workflow is now part of the grant start-up process for all federal awards. Fourth, the organization strengthened supervisory review controls to ensure that all costs charged to federal awards fall within the approved period of performance or have documented prior approval. These controls include a pre-posting cost allowability checklist, supervisory review and approval of all federal charges, and accounting system alerts that flag costs incurred outside the period of performance. Additionally, the Compliance Officer will conduct quarterly internal compliance reviews to verify adherence to federal requirements and internal policies. Finally, the organization implemented preventive measures to ensure long-term compliance. These include maintaining a centralized grant calendar with period-of-performance dates, requiring dual review of costs charged during the first 90 days of new awards, and conducting semi-annual internal audits of federal expenditures. Any discrepancies identified will be reported to senior leadership within five business days. Management is committed to ensuring full compliance with Uniform Guidance and MD DOL requirements. All corrective actions described above have been implemented or will be fully implemented by July 31, 2026. The organization believes these actions sufficiently address the audit findings and significantly strengthen internal controls over federal award management. Corrective Action Plan Summary Corrective Action Responsible Staff/Role Target Completion Date Evidence of Completion Develop and implement formal Pre-award Cost Policy Finance Director June 1, 2026 Final approved policy; distribution email; policy posted to shared drive Establish mandatory written prior approval workflow Finance Director June 30, 2026 Completed approval request template; sample approval documentation; updated grant file checklist Conduct Uniform Guidance training Compliance Officer July 31, 2026 Training materials; attendance logs; post-training assessments Implement supervisory review controls Finance Director June 30, 2026 Completed checklists; system screenshots; supervisor sign-offs Perform quarterly internal compliance reviews Compliance Officer Quarterly, ongoing Quarterly review reports; corrective action memos (if applicable) Maintain centralized grant calendar Director of Performance and Compliance June 30, 2026 Updated grant calendar; access logs or distribution email Conduct semi-annual internal audits Compliance Officer Semi-annual, ongoing Internal audit reports; follow-up documentation Dual review of early-period charges Finance Director; Grants Manager July 1, 2026 Dual-review sign-off forms; documented approvals

Management Response: Management acknowledges Finding 2025-004 and agrees that weaknesses in the review and approval of expenses represent a material weakness in internal control over compliance. The reimbursement of personal credit card expenses and the charging of those transactions to federal awards resulted in unallowable costs and demonstrated a breakdown in the review process for employee reimbursements and supporting documentation. Although the known questioned costs total only $46, the broader risk is that additional unallowable, unsupported, or improperly coded expenses could be charged to federal awards if review controls are not strengthened. Management determined that the root causes included insufficiently detailed procedures for reviewing employee reimbursement requests, inconsistent verification of business purpose and allowability before reimbursement, and inadequate supervisory review of expense documentation before costs were posted to federal awards. Existing controls were not precise enough to identify personal or otherwise unallowable charges embedded within reimbursement activity, particularly when descriptions were incomplete or reviewers did not independently confirm that the expense was necessary, reasonable, properly documented, and allowable under Uniform Guidance. To address this material weakness, management is implementing a corrective action plan focused on strengthening pre-payment and pre-posting review of employee reimbursements and other expense transactions charged to federal awards. The plan includes four key actions: revising reimbursement and accounts payable procedures to require detailed support for every request; requiring documented secondary review by supervisory or finance personnel independent of the submitter; implementing exception-based review procedures for higher-risk transactions; and performing periodic post-payment monitoring to confirm that review procedures are operating effectively and that unallowable costs are promptly identified and corrected. Under the revised process, no employee reimbursement or expense charged to a federal award will be approved unless the request includes sufficient supporting documentation to allow the reviewer to determine that the cost is necessary, reasonable, allocable as applicable, consistently treated, and adequately documented in accordance with Uniform Guidance cost principles. Reviewers will be required to confirm the business purpose of the transaction, assess whether the type of cost is allowable under the terms of the award and applicable federal regulations, and verify that no personal items, duplicate charges, sales tax errors, or unsupported amounts are included. If documentation is incomplete or a charge appears questionable, the transaction will be held pending clarification, recoded to a non-federal source, or denied reimbursement as appropriate. Any unallowable expense identified after reimbursement will be promptly removed from the applicable federal award and reported through management’s corrective follow-up procedures. Management will also reinforce accountability through targeted training and oversight. Employees who prepare, review, approve, or process reimbursements and expense reports affecting federal awards will receive training on allowable cost principles, documentation expectations, and the importance of careful review under 2 CFR Part 200, including the requirement that costs be adequately documented and necessary and reasonable for the performance of the federal award. In addition, Finance will generate periodic exception reports highlighting reimbursement activity charged to federal awards, personal credit card reimbursements, and other transactions meeting defined risk criteria. These reports will be reviewed by management to identify trends, address control failures, and implement additional corrective measures when needed. Management believes these corrective actions directly address the auditors’ recommendations and strengthen controls over the review and approval of expenses charged to federal awards without repeating the corrective actions already established for pre-award costs, allocation methodology, or broader financial close procedures. Responsibility for implementation will rest primarily with the Finance Director, in coordination with accounts payable, grants, and program leadership. Management expects enhanced documentation standards, independent review requirements, exception-based oversight, and monitoring activities to reduce the risk of personal or otherwise unallowable expenses being reimbursed and charged to federal awards in future periods. Corrective Action Plan Summary Corrective Action Responsible Staff/Role Target Completion Date Evidence of Completion Revise and adopt written expense reimbursement and accounts payable review procedures requiring itemized receipts, documented business purpose, funding source identification, and explicit confirmation that requested costs are not personal in nature. Finance Director; Accounts Payable Supervisor June 30, 2026 Approved procedures; updated reimbursement forms; staff distribution records. Implement a standardized reimbursement review checklist requiring reviewer validation of allowability, Accounts Payable Supervisor; July 15, 2026 Completed checklist template; sample reviewed reimbursement business purpose, receipt support, coding accuracy, and identification of any personal or unsupported charges before reimbursement or posting to a federal award. Finance Director packages; approval signoff documentation. Require independent supervisory review and approval for all employee reimbursements and any expense transaction charged in whole or in part to a federal award, including personal credit card reimbursement requests. Finance Director Effective immediately Supervisor approval records; signed reimbursement packages; workflow evidence showing independent review. Provide targeted training for employees, supervisors, accounts payable, and grants personnel on allowable cost principles, documentation standards, and reviewer responsibilities for expenses affecting federal awards. Compliance Officer; Finance Director August 31, 2026 Training materials; attendance logs; completed acknowledgements or knowledge checks. Create periodic exception reports for reimbursement activity charged to federal awards, missing receipt transactions, unusual merchants, and other higher-risk expense patterns, and require documented management review of the results. Accounting Manager; Finance Director September 30, 2026 Exception report format; monthly or quarterly review logs; documented follow-up on exceptions. Perform quarterly post-payment monitoring of a sample of reimbursed expenses charged to federal awards to verify compliance with documentation, Compliance Officer; Finance Director Quarterly, beginning September 30, 2026 Quarterly monitoring reports; exception logs; evidence of recoding, recovery, or corrective follow-up. approval, and allowability requirements and to ensure prompt correction of any identified exceptions.

The District will implement proper control over program expenditures. Expenditures for other programs will be paid directly from those program funds, if possible.

The Division is in the process of designing and implementing a precise control to ensure that the amount of food distributed is properly reviewed and that the Division maintains such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Michael Zielinski, Major, Divisional Commander.

MANAGEMENT VIEWS AND CORRECTIVE ACTION PLAN REPORT ON FEDERAL AWARDS IN ACCORDANCE WITH THE OMB UNIFORM GUIDANCE SEPTEMBER 30, 2025 Finding 2025-001 Procurement- Lack of Cost or Price Analysis Cluster: Research and Development, and also applies to Expanded Food and Nutrition Education Programs, which is not a cluster Sponsoring Agency: National Aeronautics and Space Administration and Department of Agriculture Award Names: NASA 90NSSC24K0999 and NI22eFNEPXXXG004-0003 Award Numbers: 208905 and 385076 Assistance Listing Title: Mission Support and Expanded Food and Nutrition Education Program Assistance Listing Number: 43.009 and 10.514 Award Year: 2024 – 2025 Management notes 2025-001 is a repeat finding of 2024-001, but given the timing of the finding last year, our 2024 CAP was anticipated to be completed as of October 1, 2025. To ensure Auburn University is in compliance with 2CFR 200.324, Auburn University has implemented the following corrective action plan: In addition to our current policies that required three quotes for purchases between $15,000-$75,000 and a formal competitive bid for purchases greater than $75,000, Auburn University revised our policies to require a cost or price analysis for items greater than $250,000, documenting that the purchase is reasonable. For items greater than $250,000, we will include a certification on the Professional Services Contracts and the Sole Source request forms indicating an analysis of cost or price has occurred and that the purchase is reasonable. As part of the cost or price analysis, we will utilize available data points. In addition to our analysis, we will ensure that our reviews have been appropriately documented and included in our files. Prior to the implementation date noted below, we will review any purchases greater than $250,000 in fiscal year 2026 and ensure proper cost or price analysis is completed and documented. The corrective actions noted herein have been implemented as of October 1, 2025. Contact: Missty Kennedy Chief Procurement Officer and Executive Director Procurement and Payment Services Amy Douglas Associate VP Financial Services/Controller Completed Date: October 1, 2025

Item 2025.001 - Activities Allowed or Unallowed Recommendation We recommend that the Organization consistently enforce its internal controls over payroll to ensure that the allocations are reviewed and approved by the appropriate supervisor. Repeat Finding Not a repeat finding. Action Taken The Health Center converted the payroll system from Paycom to Paylocity which has capacity for grant hours tracking. We should have compliance in three months after implementation. The first pay date using Paylocity will be 7/2/2026 covering the pay period from 6/14/2026 to 6/27/2026. In addition, The Health Center's new GL system, Sage lntacct, also has grant accounting capability. With these two systems conversions, we should be able to track time and effort compliance.

Insufficient Cash and Deficit of Unrestricted Net Position Corrective Action The Authority will analyze and evaluate charges and allocations to the Section 8 Housing Choice Voucher Program and budget administrative and applicable operating expenses of the Program within HUD’s administrative funding limits. Additionally, the Authority will abstain from advancing Public Housing Program assets to the Section 8 Housing Choice Voucher Program. Jebidiah Jackson, Executive Director, has assumed the responsibility of executing this corrective action as of August 1, 2026.

Audit Finding Reference: 2025-003 Improve Controls over Period of Performance Planned Corrective Action: The District has strengthened its grant management and closeout procedures to ensure that all expenditures charged to federal awards are incurred, processed, and paid within the applicable period of performance. Specifically, the District will: 1. Implement a formal grant closeout checklist that includes a review of all open purchase orders, encumbrances, unpaid invoices, and outstanding obligations prior to submission of final expenditure reports. 2. Require reconciliation of grant expenditures between the Grants Office, Special Education Department, and Business Office before final grant reports are submitted. 3. Establish periodic reviews of open encumbrances throughout the year to identify outstanding obligations and ensure timely processing of invoices. 4. Designate backup personnel and document grant management procedures to ensure continuity during staffing transitions or vacancies. 5. Require supervisory review and approval of all grant closeout documentation to verify that all allowable expenditures have been recorded and reported appropriately. 6. Provide training to personnel responsible for grant administration and financial reporting regarding federal period-of-performance requirements and grant closeout procedures. Planned Implementation Date of Corrective Action: The revised grant monitoring and closeout procedures have been implemented for all active federal grants and will be fully incoiporated into the District's grant management process beginning with the current fiscal year. Person Responsible for Corrective Action: Grants Manager Signature Derek Pinto, Assistant Superintendent of Finance

Audit Finding Reference: 2025-001 Maintain Employee's Time and Effort Records Planned Corrective Action: The District will implement and enforce a formal time and effort reporting process for all employees whose salaries are charged to federal programs. The process will include: 1. Identification of all employees whose compensation is funded, in whole or in part, by federal awards. 2. C.ompletion of required semi-annual certifications or periodic personnel activity reports, as applicable, in accordance with Uniform Guidance requirements. 3. Review and approval of certifications bysupervisory personnel to ensure accuracy and completeness. 4. C.entralized maintenance of all certifications by the Grants Office to ensure records are readily available for audit and monitoring purposes. 5. Development of a compliance calendar with established due dates and reminder notifications for required certifications. 6. Quarterly monitoring bythe Business Office to verifythat all required certifications have been completed, reviewed, and retained. Planned Implementation Date of Corrective Action: The District has begun implementing these procedures and will have the revised process fully operational by 6/30/2026. All required certifications for the current fiscal year will be collected and maintained going forward. Person Responsible for Corrective Action: Grants Manager, Funds Analyst, Deputy Chief Financial Officer Signature Derek Pinto, Assistant Superintendent of Finance

Audit Finding Reference: 2025-002 Improve Procurement Procedures Planned Corrective Action: The District will strengthen its procurement procedures for federally funded purchases to ensure compliance with Uniform Guidance requirements. Specifically, the District will: 1. Revise procurement procedures to clearly identify when federal procurement requirements apply in addition to state and local procurement regulations. 2. Develop and implement a federal procurement checklist that must be completed prior to the award of any contract funded in whole or in part with federal grant funds. 3. Work with the Law Department to establish standardized contract templates containing all required federal contract provisions, including the Byrd Anti-Lobbying Amendment when applicable. 4. Require a secondary review bythe Business Office or Grants Management personnel before contract execution to verify compliance with Uniform Guidance procurement standards and required contract clauses. 5. Provide annual training to Business Office staff, grant managers, and other personnel involved in procurement activities regarding federal procurement requirements and contract provisions. 6. Conduct periodic internal reviews of federally funded procurement transactions to ensure ongoing compliance. Planned Implementation Date of Corrective Action: The revised procedures, procurement checklist, and standardized contract templates will be implemented by7 /1/2026. Training will be completed for applicable staff during the current fiscal year and prior to the initiation of future federally funded procurements. Person Responsible for Corrective Action: Assistant Superintendent of Finance Derek Pinto, Assistant Superintendent of Finance

Audit Finding Reference: 2025-004 Maintain Approved Rate Support for Employee Pay Rates and Time and Effort Support Planned Corrective Action: The District will strengthen internal controls over payroll costs charged to federal programs by implementing the following corrective measures: 1. Identify all employees whose salaries and wages are charged, in whole or in part, to the Child Nutrition Cluster and other federal awards. 2. Implement a formal process requiring completion of appropriate time and effort certifications in accordance with Uniform Guidance requirements and District policy. 3. Establish procedures to ensure certifications are completed in a timely manner, signed by employees and/or supervisors as required, and maintained in a centralized location. 4. Develop a compliance tracking system to monitor the collection and retention of required documentation throughout the year. 5. Conduct periodic reviews of payroll allocations to verify that payroll charges are supported by appropriate documentation and accurately reflect the work performed. 6. Provide annual training to Child Nutrition, Payroll, Human Resources, and Business Office personnel regarding federal time and effort documentation requirements and record retention responsibilities. Planned Implementation Date of Corrective Action: The District has implemented procedures to identify all federally funded employees and will require completion and retention of all applicable time and effort documentation beginning immediately and for all future reporting periods. Person Responsible for Corrective Action: HR Generalist for Cafeteria Derek Pinto, Assistant Superintendent of Finance

Corrective Actions to Be Implemented: The organization is moving from MIP Fund Accounting to QuickBooks online Advanced which will remove the multi-step data entry process currently used for time capture and payroll processing. Simultaneously, we are implementing Hourtimesheet, a Defense Contract Audit Agency (DCAA) compliant time tracking system which does not allow time entries outside of each employee assigned grant allocations. It has a native integration with Quickbooks and is the gold standard for government contract compliance. • QuickBooks Online Advanced anticipated completion: June 1, 2026 • Hourtimesheet anticipated completion: September 1, 2026 Responsible Parties: Brandi Senters, Finance Director, will be responsible for implementation, with oversight from the Executive Director, Erin Broussard.

Corrective Action Plan: Misuse of Funds – Vehicle: Pact updated its Global Vehicle Policy effective November 1, 2025. The updated Global Vehicle Policy reinforces Pact’s zero-tolerance policy. No new reports of vehicle misuse have been received since November 2025, and all the reported cases of misuse occurred prior to November 1. Pact’s updated policy complies with all applicable laws and regulations, including the organization’s internal Code of Conduct, while aligning with the objectives and scope of work for the project. Pact’s guidelines specify roles and responsibilities and role assignments; identify authorized places to obtain fuel; where to store vehicle keys; where to park vehicles; and require individuals to enter detailed records regarding the use of the vehicle into a log. Misuse of Funds – Payroll: In alignment with Pact’s core principle of continuous quality improvement, and following substantiation of the misuse in one country office, Pact developed and implemented a corrective action plan. This plan included a comprehensive quality review of existing controls to identify and address any procedural gaps in the timesheet systems to ensure the timesheet systems have a functional auditable approval trail. We have reinforced, including in Senior Management Team meetings with staff, and other trainings supervisors’ responsibility to review and verify hours worked for their staff.

Finding 2025-001 Condition: Time and effort certifications were not maintained for grant employees. Corrective Action Planned: Southbridge Public Schools will be creating and implementing procedures for time and effort certifications. The procedure will include use of the form distributed by the Massachusetts Department of Elementary and Secondary Education for employees who are paid by a grant and require a time and effort certification. Anticipated Completion Date: July 31, 2026 Contact: Matthew Robidoux – Business Manager

Condition Holyoke Gas & Electric (HG&E) calculated indirect costs using an incorrect total direct cost base rather than the modified total direct costs required by the grant agreement and 2 C.F.R. §200.414(f). Indirect cost was calculated based on total cost, including construction and material. Corrective Action Plan Corrective Action Planned: By December 25, 2026, HG&E will implement a formal grant administration policy that clearly defines roles and responsibilities and establishes a comprehensive framework for effective grant management. In addition, HG&E will ensure that all questions related to indirect costs and other compliance requirements are confirmed in writing. HG&E believes this approach will significantly reduce the risk of future reporting errors. Names of Contact Persons Responsible for Corrective Action: Brooke McMahon – 413-536-9318 Bill Sullivan - 413-536-9523 99 Suffolk Street Holyoke, MA 01040 Anticipated Completion Date: The Corrective Action Plan will be implemented by December 31, 2026

Expenditures submitted for the Alabama Medicaid Administrative Claiming Program included expenditures supported by federal funds. Contact Person: Dr. Brock Nolin, Superintendent Corrective Action: Claims will be adjusted to correct the duplication of federal funds. Policies and procedures will be implemented according to the recommendations found in the Schedule of Findings and Questioned Costs. Proposed Completion Date: Prior to the submission of the July-September 2026 claim.