Corrective Action Plans

Finding No. 2025-002: Procurement- Compliance Finding and Significant Deficiency in Internal Control over Compliance EPIC acknowledges that documentation confirming vendor suspension or debarment was not present in various vendor files for FY25. Corrective Action Plan: EPIC has updated its vendor onboarding process to include confirmation of all new vendors prior to being awarded contracts. In addition, all current vendors will be confirmed eligible to receive federal funds during the RFP process for each subsequent project award. Contact Person Responsible for Corrective Action: Thomas Sperti, Chief Financial Officer

FINDING 2025-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Cost, and Period of Performance Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number and Email Address: 317-392-6310; aglackman@co.shelby.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor’s Office will supply the Council with copies of invoices for approval and complete a check off list for the steps needed to complete this procedure . Anticipated Completion Date: December 31, 2026

An untimely reporting package and DCF are result of various factors to include the City’s astringent calendar in completing conversion of finance module in Munis (ERP) in concert with gaps in external accounting support. This annual requirement, per 2 CFR Section 200.12(2), was not met; however, the City is committed to submitting this package to the Federal Audit Clearinghouse within nine months after fiscal year end.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2025-008: Activities Allowed or Unallowed / Allowable Costs - Lack of Segregation of Duties in Expenditure Determination and Approval (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Management will reassign roles to ensure clear separation between allowability determinations and expenditure approvals. If staffing constraints prevent full segregation, management will ensure that the Finance Manager performs secondary reviews. Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: Management will conduct periodic internal monitoring with documented review of approvals.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2025-007: Cash Management - Inadequate Authorization and Supporting Documentation for Reimbursement Requests (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: A standardized reimbursement packet and formal approval workflow will be created. All reimbursement requests will be routed for required approvals. Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Finance Department will conduct monthly reconciliations and reviews of reimbursement submissions.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2025-006: Activities Allowed or Unallowed / Allowable Costs - Insufficient Budget-to Actual Reviews (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: A monthly review checklist and variance analysis template will be adopted. Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The internal audit function will conduct semiannual reviews to confirm adherence to established review procedures.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2025-005: Activities Allowed or Unallowed / Allowable Costs - Inadequate Chart of Accounts Segregation for Unallowable Costs (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Management will implement a comprehensive redesign of the chart of accounts, including the creation of new account codes and subaccounts to clearly identify unallowable costs. In addition, management will ensure that staff receive training on the revised coding structure. Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Finance Department will conduct quarterly internal reviews to ensure the proper use of the revised account codes and to verify the accuracy of cost classifications.

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Wyoming Federal Emergency Management Assistance Listing Number: 97.036 Program Name: Disaster Grants – Public Assistance Finding Summary: Materials were charged out of inventory in the general ledger at a later date than when the items were actually pulled from inventory for the work order. Management did not detect or correct the differences in average cost. Corrective Action Plan: Since that time, we have implemented an improved barcoding process that allows line crews to charge materials directly as they are pulled for use in the field. Crews can access the system using their iPads, phones, or computers, allowing material transactions to be recorded and transmitted directly to our financial software at the time the materials are issued. This process provides more timely and accurate recording of material usage and reduces the need for manual entry. During the reconciliation of the work orders established to track costs associated with the natural disaster, we identified several materials that had been charged incorrectly and made the necessary corrections. Because inventory is maintained using an average-cost method, the average cost of certain materials had changed by the time the corrections were processed. Although adjustments were made to account for these cost differences, we subsequently determined that not all amounts were fully adjusted. The items identified through the reconciliation process have since been reviewed and corrected. Responsible Individuals: Ryan Gross, VP of Accounting and Finance, and Karri Blasi, Controller Anticipated Completion Date: January 2026 (Barcoding was fully implemented)

DEPARTMENT OF AGRICULTURE 2025-006 Technical Assistance and Training Grant – Assistance Listing No. 10.761 Recommendation: We recommend management evaluate the circumstances surrounding the duplicate reimbursement and assess whether enhancements to existing reimbursement review procedures are necessary to identify and prevent duplicate reimbursement requests from being processed and charged to federal awards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Existing reimbursement review procedures have been reinforced, and additional verification steps will be incorporated into the approval process to help prevent duplicate reimbursements from being charged to federal awards in the future. Name(s) of the contact person(s) responsible for corrective action: Jeff Fournier, Finance Director Planned completion date for corrective action plan: June 30, 2026 If the Department of Housing and Urban Development or Department of Agriculture have questions regarding this plan, please call Jeff Fournier at (413) 665-1271.

Finding 2025-004 – Education Stabilization Fund – ESSER III AL No. 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: The Period of Performance for the Education Stabilization Fund – ESSER III was October 4, 2021 through September 30, 2024. Condition: During our test of controls over compliance it was noted that there was an expenditure charged to the Education Stabilization Fund – ESSER III for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Context: During our test of expenditures and review of the general ledger against the Education Stabilization Fund – ESSER III grant as it is related to compliance it was noted that the School paid in full a four year lease from 3/1/23 to 2/28/27 and charged 10/1/23 to 2/28/27 to the Education Stabilization Fund – ESSER III grant in the amount of $190,869 and thus the period from 10/1/24 to 2/28/27 would be outside the period of performance and thus would not be an allowable cost. Unallowable costs for this period was $52,426. Effect: Assabet Valley Regional Technical High School was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education. Questioned Costs: Questioned cost charged to the Education Stabilization Fund – ESSER III grant whose service period was beyond the grant end date of September 30, 2024 was in the amount of $52,426. Cause: Director of Business Operations in FY23 entered into a lease agreement that extended beyond the grant period. Identification as a Repeat Finding: 2024-007 Recommendation: We recommend the Assabet Valley Regional Technical High School follow procedures to ensure that expenditures charged to the grant is within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Responsible for Corrective Plan: Director of Business Operations Estimated Completion Date: Changes in processes are effective immediately Action Taken: On July 1, 2025, the district reclassified the expense to the non-member tuition revolving fund. Grant purchases will be reviewed and approved by the Director of Business Operations. The district will ensure all grant spending is limited to eligible expenses during the eligible time period for the grant. All grant funded purchases will now be checked for time period compliance.

Finding 2025-003 – Special Education Cluster – AL No. 84.027 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Costs charged to the major programs should meet the requirements as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Condition: During our test of controls over compliance it was noted that there are expenditures charged to the Special Education Cluster for expenses that are unallowable costs. Context: During our test of expenditures and review of the general ledger against the Special Education Cluster as it is related to compliance it was noted that the FY 23 Special Education IEP grant had an invoice charged to the grant for promotional clothing to the budget line as classroom supplies. The FY 2024 Special Education IEP grant had an expense that was not part of the approved grant agreement with the pass through entity. The FY 2025 Special Education IEP grant had 2 expenses that were not part of the approved grant agreement with the pass through entity. The FY 2025 Special Education Grants to States grant had five instances where the invoice charged to the grant was not in agreement with the pass through entity’s grant agreement. FY 2025 Special Education Grants to States grant had two expenses whose supporting documentation was a quote as the invoice was not received. Effect: Assabet Valley Regional Technical High School was not in compliance with the allowable costs/ cost principals requirement as set forth by the Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Questioned Costs: Total questioned costs for the FY 23 Special Education IEP $296.28, FY 2024 Special Education IEP $300.00, FY 2025 Special Education IEP $2,544.00, and FY 2025 Special Education Grants to States $5,862.14. Questioned costs were calculated based on actual invoice costs. Cause: Staff did not properly follow the grant agreement. Staff did not properly review payables to ensure that they were paying for an invoice rather than a quote.. Identification as a Repeat Finding: 2024-005 Recommendation: We recommend the Assabet Valley Regional Technical High School follow procedures to ensure that expenditures charged to the grants are allowable costs as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles) Responsible for Corrective Plan: Director of Business Operations Estimated Completion Date: Changes are to go into effect immediately. Action Taken: Grant managers and Business Office staff will review purchases for grants to ensure only allowable expenses are paid. The Business Manager will review all warrants for accuracy ensuring invoices and not quotes are paid.

Finding 2025-002 – Special Education Cluster – AL No. 84.027 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the School is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over expenses. Specifically, a sample of journal entries charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing the journal entries charged to the program, it was noted that expenses where outside the period of performance. Cause: The grant’s effective date was later than it has been historically. The payroll office should have coded the employees’ salaries to the budget, rather than the grant for that first pay period. Context: During our review of journal entries posted to the major program it was noted that a journal entry posted to the FY 2025 Special Education Grants to States grant included an expense that was outside the period of performance as it was for expenses as of 8/28/24 and that grant start date was 9/9/24. The FY 2023 Special Education Grants to States grant included an expense that was outside the period of performance as it was for an expense whose service period was 1/1/25 – 12/31/25 and grant end date was 9/30/24. Effect or Potential Effect: Due to the noncompliance and material weakness in internal controls noted above, there is a risk of unallowable expenditures being charged to the federal grant. Identification as a Repeat Finding: 2024-004 Questioned Costs: Total questioned costs for the expenses charged to the grant that were outside the period of performance was for FY 2025 Special Education Grants to States was $2,499.10 and FY 2023 Special Education Grants to States was $3,612.98. Recommendation: The Assabet Valley Regional Technical High School should improve the internal controls over Allowable Costs by ensuring employee’s payroll charged to the federal grant is within the period of performance and supported with Time and Effort certifications. Responsible for Corrective Plan: Director of Business Operations Estimated Completion Date: Business Office staff have started changing codes for affected accounts. Action Taken: Proper coding procedures were reviewed with Payroll and Business Office staff. They have been instructed to not charge any salaries to a grant until after the start date.

FA 2025-002 Improve Controls over Expenditures Compliance Requirements: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Numbers and Titles: Federal Award Number: Questioned Costs: Description: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Significant Deficiency Nonmaterial Noncompliance U.S. Department of Agricu lture Georgia Department of Education 10.553 - School Breakfast Program; 10.555 - National School Lunch Program 255GA324N1199 (Year: 2025) $40,701 A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were appropriately reviewed, approved, and documented. Corrective Action Plans: Procedures have been reviewed with program and department leaders to ensure that all expenditures have proper approval before submitting for payment. Expenditures without proper approval will be returned to the responsible department. Board Policy DJED has been reviewed with all department heads to ensure understanding of policy and requirements for obtaining mult iple quotes for certain thresholds. Guidelines have been reviewed with the program manager and school nutrition bookkeeper to ensure all expenditures are recorded in the correct fiscal years. Estimated Completion Date: August 31, 2026 Contact Person: Stephanie Clark, Chief Financial Officer Telephone: 912-876-4854 Email: sclark@liberty.k12.ga.us

The City concurs with this finding and will strengthen controls over federal award reporting by reviewing previously reported ARPA expenditures against the City’s accounting records and supporting documentation and submitting corrections, as necessary; implementing a documented quarterly reconciliation and independent review process requiring reports to be reviewed by an individual other than the preparer prior to submission; maintaining supporting documentation for expenditure allocations and classifications; establishing written procedures for federal award reporting; and providing additional training to staff responsible for grant reporting to help ensure compliance with federal reporting requirements.

Continuum of Care -Assistance Listing No. 14.267 Recommendation: Share & Care should strengthen document retention and disbursement review procedures by implementing a centralized filing system for invoices, lease agreements, and supporting documentation. Management should require all supporting documents to be electronically maintained and attached to each disbursement batch prior to approval. In addition, periodic reviews should be performed to ensure documentation is complete, properly organized, and readily accessible for compliance and audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Share & Care House has strengthened its document retention and disbursement review procedures by implementing comprehensive policies and procedures governing the retention of invoices, lease agreements, client files, and all supporting documentation. Following approval, all supporting documentation is electronically scanned and retained in a secure server location. This location is a restricted administrative location with limited access to protect records from accidental deletion or unauthorized modification and to ensure long-term retention. Original paper documentation is maintained with each program's client files, master lease files, or invoice packets in accordance with the organization's record retention policy. Management conducts periodic reviews to verify that documentation has been properly retained, is complete, and is readily accessible for monitoring, compliance, and audit purposes. These procedures strengthen internal controls over document retention, improve the accessibility of supporting documentation, and ensure compliance with HUD record retention requirements. These corrective actions establish a centralized document retention process, strengthen internal controls over disbursements, and ensure supporting documentation is maintained in compliance with HUD record retention requirements. The Co-Executive Directors will conduct periodic reviews of disbursement packets and electronic files to verify that supporting documentation is complete, properly retained, and available for compliance reviews and future audits. Name(s) of the contact person(s) responsible for corrective action: Sheera Smith Planned completion date for corrective action plan: September 2026

FEMA Public Assistance Advances and Completed Reimbursement Management position. Management accepts the need to address the reported documentation and control deficiency. The original $666,000 and subsequent advances have been fully reimbursed to the Municipality’s FEMA fund; completed reimbursement is distinct from resolution of the historical finding. Management response. The original $666,000 was reimbursed in full to the Municipality’s FEMA fund bank account before the issuance of the Single Audit Report for the fiscal year ended June 30, 2025. The Municipality provided the supporting evidence of these reimbursements to the independent auditors for their review and examination before issuance of their report. The reimbursement occurred after June 30, 2025 and is reported as subsequent corrective action. No principal remains outstanding on these municipal interfund advances. The reimbursement evidence is available, upon request, for review and examination by the cognizant agency for audit, if designated, or the applicable oversight agency for audit; FEMA; COR3; and any other pertinent regulatory or oversight entity and its authorized representatives. Héctor Rubén Caraballo Díaz, Director of Finance, will coordinate timely access to the supporting records and municipal personnel under 2 CFR 200.337. The Municipality will protect sensitive information in public filings while providing authorized reviewers the records needed for their examination. The supporting package includes the municipal advance chronology, COR3 reimbursement and credit documentation, and the May 11, 2026 bank confirmation for a cash transfer to the FEMA account. Management’s full-repayment representation reflects the combined settlement of the advances and related credits. Management confirms that no principal remains outstanding for the original $666,000. Management’s representation of full reimbursement is not a representation that FEMA or COR3 has issued a final allowability or closeout determination. The transfer confirmation records approval and transmission; the resolution file will also retain evidence of the receiving-account posting and the reconciliation supporting the application of credits. These records substantiate completed repayment and preserve the distinction between settlement of principal and compliance with the original award conditions. Finding 2025-008 retains $666,000 in questioned costs for insufficient documentation of the final use and disposition of the original advance. Management’s reimbursement disclosure supplements that finding and does not depend on a change to its wording. Reimbursement does not retrospectively authorize the original use of restricted cash or automatically eliminate the historical finding. The responsible agency or pass-through entity will determine the disposition of questioned costs and any required remedy under 2 CFR 200.521. Management requests full consideration of the reimbursement evidence and appropriate credit for amounts already restored. Restoration to the municipal FEMA fund is not, by itself, repayment to the grantor or formal agency resolution. Corrective Action 1. Completed: reimburse the original $666,000, and provide the supporting evidence to the independent auditors for review and examination before report issuance. Preserve the evidence, dated transmittal, recipients, and index of documents provided. Delivery for examination is not represented as auditor agreement with management’s conclusions. 2. Complete the reviewed reconciliation of advances, COR3 credits, and the May reimbursement to bank and interfund records, and retain the separate tracing of the original use. Document credit eligibility, the source of legally available repayment funds, any excess, and the fiscal year 2026 entries. This reconciliation documents completed interfund settlement and the amounts for which management requests credit in agency resolution. 3. Preserve the posting of the May transfer in the receiving FEMA bank account, the reciprocal municipal ledger entries, and the dated delivery of the evidence to the auditors. For each COR3 credit applied, document the project, underlying eligible expenditure, original municipal funding, entitlement to reimbursement, and absence of duplicate recovery. A COR3 receipt by itself does not demonstrate repayment of an interfund advance. 4. Prohibit advances of FEMA cash for unrelated municipal operations. Permit an interfund reimbursement only after review establishes the specific award, eligible cost previously paid, lawful purpose, available support, and absence of duplicate reimbursement. 5. Retain a transaction-level account of the original $666,000 advance and its ultimate use, distinct from the later restoration. Identify the affected disaster and award, disbursements, eligible-cost support, and any unsupported use. Present the original questioned amount, amounts restored, any amount the agency sustains, and additional remedies separately; repayment will not be netted against the historical finding to imply that no reportable condition occurred. 6. Maintain monthly FEMA bank, project, interfund, and reimbursement reconciliations, with separate preparer and reviewer approval. Resolve exceptions promptly and retain the evidence supporting each release of funds. 7. Provide the reconciled resolution file to COR3 and request written disposition of Finding 2025-008 and its $666,000 questioned cost. Evaluate and address substantiated interest, grant repayment, accounting adjustments, or other remedies required by applicable rules or a written agency determination, preserving available review or appeal rights. Obtain instructions identifying the required recipient, award, amount, and credit for the completed restoration; do not assume that an interfund reimbursement extinguishes a separate grant repayment obligation. 8. Assess Federal cash balances, disbursement timing, and any applicable interest or excess-cash return requirement under the governing award and payment rules. Document the period and legal basis of any amount due rather than estimating interest without authority. The restoration will not be used to support duplicate Federal reimbursement or an unsupported new draw. 9. Keep the reimbursement evidence available for regulatory examination now. Submit the evidence already available to COR3 by September 30, 2026, identify supplemental reconciliation work due October 31, 2026, and complete the resolution submission by November 30, 2026 or any earlier agency deadline. Preserve the distinction between documents already delivered to the auditors and later supplements; do not describe subsequent workpapers as having been provided before report issuance. Implementation Milestones Required Action Owner Completion Evidence Target Date Reimburse original and subsequent advances to the FEMA fund. Finance Director Advance chronology, COR3 credits, May 11 transfer evidence Completed May 11, 2026 Provide reimbursement evidence to the independent auditors. Finance Director Evidence for review and examination; dated preissuance transmittal; regulatory access Completed before report issuance Approve transfer controls and reconcile the completed settlement. Finance Director Approved procedure, signed reconciliation, ledger support Sep. 30, 2026 controls; Oct. 31, 2026 reconciliation and tracing Provide available reimbursement evidence to COR3; complete resolution file and request written disposition. Finance and FEMA Program Staff / Resolution file, transmittal, agency correspondence Sep. 30, 2026 initial evidence; Nov. 30, 2026 complete file; decision external Demonstrate monthly preventive controls. Finance and FEMA Program Staff / Three consecutive reviewed monthly reconciliations Dec. 31, 2026 Responsible official. Héctor Rubén Caraballo Díaz, Director of Finance Anticipated completion. Principal reimbursement completed May 11, 2026; evidence delivered to the auditors before issuance. Documented preventive controls and three monthly reviews by December 31, 2026. Formal resolution of any retained questioned costs remains subject to COR3 or FEMA under 2 CFR 200.521. Evidence of completion. Retain evidence of full settlement of the original $666,000 and subsequent advances, the application of credits, reconciliation to the FEMA fund and municipal ledgers, and preissuance delivery to the auditors. Demonstrate preventive controls for three monthly cycles. Track any retained questioned cost and additional remedy until the responsible agency documents its disposition, with appropriate recognition of restored amounts. Auditor revision of the finding is not a closure condition.

The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that the County receives to ensure that proper internal controls are implemented.

We will work to implement a Risk Assessment plan over federal grants. We will implement controls to make sure we comply with grant requirements and that federal funds are expended in accordance with grant agreements and in a timely manner. We will ensure employees have the current and correct compliance supplement to work from.

The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that the County receives to ensure that proper internal controls are implemented.

We will work to implement a Risk Assessment plan over federal grants. We will implement controls to make sure we comply with grant requirements and that federal funds are expended in accordance with grant agreements and in a timely manner. We will ensure employees have the current and correct compliance supplement to work from.

Management Response: Management has reviewed Finding 2025-001 and concurs with the auditor’s observations. Management recognizes that the exceptions resulted from incomplete procurement documentation and inconsistent use of the required Federal contract provisions and procurement file checklists. Context and corrective actions: • The omission of the Federal contract provisions required by Appendix II to 2 CFR Part 200 was identified through monitoring performed by the grant administrator on behalf of the pass-through entity. Management initiated remediation during the audit period and has amended the affected contracts to include the applicable provisions. Management will also complete a review of active federally funded contracts by September 30, 2026, to confirm that required provisions are included. • One contract lacked documentation demonstrating that the procurement was conducted in a manner providing full and open competition. The vendor relationship predated the grant award; however, management acknowledges that the existing relationship did not, by itself, demonstrate compliance with the applicable procurement documentation requirements. For future federally funded procurements, including procurements involving existing vendors, management will retain documentation of the procurement method, competition performed, and supporting rationale. • For future procurements, the procurement file must include documented evidence of the required price or cost analysis and suspension and debarment verification before contract award or renewal. These requirements will be incorporated into a standardized Federal procurement checklist, as outlined below, with documented review and approval by the Director of Finance and COO. • Management will provide procurement compliance training to relevant personnel by September 10, 2026 and will perform periodic monitoring of federally funded procurement files. Monitoring results will be reported to Board of Directors, and identified exceptions will be tracked through resolution. • The seven exceptions involved four contracts valued below $50,000, two contracts valued between $50,000 and $100,000, and one contract valued above $100,000. These amounts provide context regarding the potential dollar magnitude of the exceptions but do not change management’s obligation to maintain complete procurement documentation and comply with applicable Federal requirements. • Based on the auditor’s procedures, no questioned costs resulted from this finding, and the costs tested were allowable under the grant and otherwise properly supported. Management nevertheless recognizes the importance of addressing the procurement documentation gaps and believes the corrective actions described above will strengthen compliance, improve oversight, and reduce the risk of recurrence. • Management will Develop and Implement Comprehensive Federal Procurement Compliance Checklist. o The Organization has developed a single, comprehensive Federal Procurement Compliance Checklist to be completed for all covered procurements. This checklist ensures compliance with 2 CFR Part 200 (Uniform Guidance) across all identified deficiency areas. The checklist includes: o Federal Contracts Provisions Section (including all contract provisions required by Appendix II to 2 CFR Part 200) o Full and Open Competition Section (including threshold determination, type of procurement method, evidence of public posting, responses, and evaluation of vendors, or a documented Sole Source procurement approval) o Price/Cost Analysis Section (including analysis method, documentation analysis was performed, and evaluation that proposed cost is reasonable). o Suspension and Debarment Verification Section: documented SAM.gov database search, and documentation of escalation if a vendor is found to be on the exclusion list. o The checklist will be integrated into standard procurement workflows to ensure automatic compliance. o Completed checklist must be signed off by the Director of Finance and COO. All documentation referenced in the checklist (competition records, cost analysis, debarment verification) must be retained with the procurement file. o Organization finalized the comprehensive checklist by August 31, 2026 and provided training to all procurement staff by September 10, 2026. The checklist will be required for all new procurements effective September 1, 2026. For all contracts entered into prior to September 1, 2026 that did not comply with the provisions in Appendix II to 2 CFR Part 200, the organization will complete retroactive documentation to the extent possible and execute amendments to incorporate missing Federal provisions by September 30, 2026. Anticipated Completion Date: August 31, 2026 (checklist development); September 30, 2026 (retroactive compliance and amendments) Responsible Party: Daniel Wilmot, Director of Finance

Condition The data collection form and reporting package for the year ended June 30, 2025, were not submitted to the Federal Audit Clearinghouse within the timeframe required by the Uniform Guidance. Corporation response The Corporation agrees with the findings. Corrective Action Plan The Corporation will take the following corrective actions: • Financial Close Acceleration – The Corporation is aligning its accounting closing expectations for the issuance of its financial statements according to the Secretary of the Department of Treasury deadlines. Therefore, the accounting close processes are being improved to be completed by September of each fiscal year and to issue the Single Audit on or before March 31 of the following fiscal year, nine months after each year end. • Compliance Calendar Implementation – Develop a formal compliance calendar to close the accounting books by September 30 and issue the financial statements by March 31. Name of the contact person responsible for corrective action plan Jesús A. Rodríguez Avilés – Financial Planning and Analysis Director Anticipated completion date March 31, 2027

Audit Finding Reference: 2025-003 Special Education Planned Corrective Action: For all special education procurements, a formal sole source justification statement will be documented and retained with the purchase records. Planned Implementation Date of Corrective Action: School year 2026-2027 Persons Responsible for Corrective Action: Ronnie Kessler, Director of Student Services Director Kirsteen Patterson, Director of Finance and Operations

Audit Finding Reference: 2025-002 Planned Corrective Action: The Town of Wayland Purchasing Office will update the Policy and Procedures Guide For Federal Grants to include the Audit Finding 2025-002. Planned Implementation Date of Corrective Action: The Corrective Action will be implemented prior to December 31, 2026 as the Town is currently in the process of hiring the vacancy. Person Responsible for Corrective Action: Town Managers Office- Assistant Town Manager, Town Manager-Michael McCall __Brian Keveny- Finance Director__

Panthera continued strengthening its internal controls through 2025 and early 2026 by expanding its use of Rippling to support more consistent HR workflows, documentation, and approval tracking. We also transitioned portions of our international workforce from DEEL to Safeguard, which offers stronger compliance monitoring and country‑specific employment controls. This shift enhances our ability to maintain complete personnel files, ensure accurate payroll processing, and meet federal requirements for allowability of labor costs. In addition, the new timesheet module implemented across 2024–2025 continues to improve documentation of personnel activity and verification of payroll‑related charges. The organization also experienced a leadership transition with the departure of our CAO in late 2025 and the onboarding of a new Chief People Officer in early 2026. This change has brought renewed focus to HR governance, process standardization, and long‑term workforce planning, further reinforcing Panthera’s commitment to strong internal controls over federal expenditures.