Corrective Action Plans

Corrective action the auditee plans to take in response to the finding: Wellpinit School District acknowledges the audit finding regarding the absence of a written methodology for allocating state and local funding and staffing to the high school grade span in compliance with Title I, Part A supplement not supplant requirements. At the time of the audit, the District operated under a partial exemption and believed it was appropriately following guidance from the Office of Superintendent of Public Instruction (OSPI). However, the District did not fully understand that a written methodology was still required for the non-exempt high school grade span. While allocation decisions were made using consistent practices, they were not formally documented in a manner that demonstrates compliance with federal requirements. To address this finding, the District is implementing the following corrective actions: 1. Development and Adoption of a Written Methodology The District is developing a formal, written methodology for allocating state and local funds and staffing to its high school grade span. The methodology will: • Allocate resources based on objective, neutral criteria such as student enrollment, program offerings, and staffing ratios • Ensure each high school receives the state and local resources it would otherwise receive if it were not receiving Title I, Part A funds • Clearly document that Title I status is not considered in the allocation process This methodology will be formally adopted and applied beginning with the next annual budget development cycle. 2. Strengthening Internal Controls The District is establishing internal control procedures to ensure compliance with supplement not supplant requirements, including: • Annual documentation of allocation formulas and staffing decisions • Review and approval of allocations by the Business Manager prior to budget adoption • Maintenance of supporting documentation demonstrating consistent application of the methodology 3. Training and Capacity Building District leadership and business office staff will participate in training on Title I, Part A fiscal requirements, including supplement not supplant provisions and documentation standards, utilizing guidance provided by OSPI and federal program resources. 4. Ongoing Monitoring and Oversight The Business Manager will be responsible for monitoring implementation and ensuring compliance by: • Conducting annual reviews of allocation practices • Verifying that documentation is complete and audit-ready • Updating the methodology as needed to reflect changes in enrollment, programming, or regulatory guidance 5. Implementation Timeline The written methodology and internal control procedures will be finalized prior to the development of the upcoming fiscal year budget and fully implemented for that cycle. Documentation supporting compliance will be retained annually.

Identifying Number: 2025-006: Special Tests—Gramm-Leach-Bliley Act Noncompliance Finding: - The Institute does not have a written information security program that addresses the seven required elements under the Gramm-Leach-Bliley Act. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with the Gramm-Leach-Bliley Act and Department of Education requirements: 1. Comprehensive Review and Revision of the Written Information Security Program (WISP) • The Institute will conduct a comprehensive review of its existing Written Information Security Program (WISP) to ensure that all required elements of the GLBA Safeguards Rule are incorporated. The revised program will be approved by senior management and maintained as a formal institutional policy. 2. Formal Risk Assessment Process • The Institute will develop and implement a documented risk assessment process to identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of student information. Risk assessments will be performed periodically and updated as significant operational, or technology changes occur. 3. Implementation of Required Security Safeguards • Management will document and implement administrative, technical, and physical safeguards designed to mitigate identified risks and protect student information. Safeguards will be reviewed periodically to ensure continued effectiveness. 4. Ongoing Monitoring and Testing of Controls • The Institute will establish procedures for ongoing monitoring of information security controls, including periodic evaluations of the effectiveness of safeguards, review of security incidents, vulnerability assessments, and corrective action tracking. Results will be documented and retained for review. 5. Vendor and Service Provider Oversight • The Institute will strengthen oversight procedures for third-party service providers that have access to protected student information. Contracts and vendor management procedures will be reviewed to ensure appropriate security expectations and monitoring requirements are established. 6. Security Awareness Training • Annual information security and data privacy training will be provided to employees with access to student information. Training will address GLBA requirements, cybersecurity risks, data protection responsibilities, incident reporting procedures, and institutional security policies. 7. Designation of Responsible Personnel • Management will formally designate individual(s) responsible for coordinating and overseeing the Information Security Program, including risk assessment activities, monitoring efforts, policy updates, and compliance reporting. 8. Periodic Reporting to Senior Management and the Board • The Information Security Program Coordinator will provide periodic reports to senior management and the Board or appropriate governing committee regarding information security risks, monitoring activities, cybersecurity incidents, and the status of GLBA compliance efforts. 9. Annual Review of the Information Security Program • The Institute will conduct an annual review of its Information Security Program to ensure continued alignment with GLBA requirements, Department of Education guidance, emerging cybersecurity risks, and institutional operations. Identifying Number: 2025-006: Special Tests—Gramm-Leach-Bliley Act Noncompliance (Continued) Responsible Officials: • Executive Vice President – Ariane Sweeney • Chief Information Officer - Dean Lane • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Director of Financial Aid – Dr Thelbert Snowden Anticipated completion date: The revised Written Information Security Program, formal risk assessment process, monitoring procedures, and training program will be fully implemented by December 31, 2026. Ongoing monitoring, risk assessments, and annual reviews will continue thereafter.

Identifying Number: 2025-005: Special Tests—Credit Balances Noncompliance Finding: - During our testing of the Student Financial Assistance Cluster, we identified an instance in which the Institute did not refund a Title IV credit balance within the required 14-day time frame. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with Title IV credit balance requirements: 1. Development of Written Policies and Procedures • The Institute will develop and maintain formal written policies and procedures governing the identification, tracking, review, approval, and refunding of Title IV credit balances. Procedures will clearly define responsible personnel, required timelines, supervisory review requirements, and documentation retention standards. 2. Implementation of Credit Balance Tracking Process • Management will implement a standardized tracking process to identify Title IV credit balances immediately upon creation and monitor outstanding balances through refund issuance. The tracking log will include the student name, credit balance amount, date created, refund due date, refund date, and reviewer approval. 3. Monitoring of 14-Day Compliance Requirement • The Institute will establish controls to monitor compliance with the 14-day refund requirement, including periodic review of open credit balances and automated or manual reminders for approaching refund deadlines. Any overdue items will be escalated to management for immediate resolution. 4. Documentation of Review and Approval • Evidence of review and approval will be maintained for all Title IV credit balance refunds. Documentation will include supporting reports, refund calculations, processing dates, and supervisory approval demonstrating that refunds were processed accurately and timely. 5.Monthly Management Review • Management will perform monthly reviews of all Title IV credit balances and refund activity to verify compliance with Department of Education requirements. Review procedures will include verification that all refunds were issued within required timeframes and that supporting documentation has been retained. 7. Staff Training • Financial Aid, Student Accounts, and Finance personnel involved in processing Title IV funds will receive training on federal credit balance requirements, documentation standards, and internal control responsibilities. Training will emphasize the importance of timely refund processing and compliance monitoring. 8. Ongoing Compliance Monitoring • The Institute will periodically review credit balance activity and related controls to ensure procedures are operating effectively. Any exceptions identified will be documented, investigated, and corrected timely, with results reported to senior management. Responsible Officials: • Director of Financial Aid – Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Executive Vice President – Ariane Sweeney Anticipated completion date: The Institute will fully implement credit balance tracking procedures, documentation requirements, management review controls, and staff training by December 31, 2026. Ongoing monitoring and periodic compliance reviews will continue thereafter.

Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records Finding: - During our testing of the Student Financial Assistance Cluster, we noted that the Institute did not perform monthly reconciliations between its internal records and COD system data. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen controls over COD reporting and reconciliation activities. 1. Implementation of Monthly Reconciliation Procedures • The Institute will establish formal monthly reconciliation procedures requiring comparison of: o COD system data to internal financial aid records; o Student financial aid records to the student information system; and o COD activity to the general ledger and related financial reporting records. • The reconciliation process will be designed to verify that all aid originated, disbursed, adjusted, and reported to the Department of Education is complete and accurate. 2. Development of Written Policies and Procedures • Management will develop and maintain formal written policies and procedures governing COD reconciliation activities. These procedures will identify responsible personnel, reconciliation timelines, required documentation, review expectations, and procedures for investigating and resolving discrepancies. 3. Timely Investigation and Resolution of Differences • Any discrepancies identified during the reconciliation process will be reviewed, documented, and resolved timely. Management will maintain documentation explaining the nature of reconciling items, corrective actions taken, and the date of resolution. 4. Documentation and Retention Requirements • The Institute will maintain completed reconciliation workpapers each month, including supporting reports, reconciliations performed, explanations of variances, and documentation of corrective actions taken. Reconciliation records will be retained in accordance with federal record retention requirements. 5. Management Review and Approval • Completed reconciliations will be reviewed by supervisory personnel independent of the preparation process. Evidence of review will be documented through signed and dated approvals, electronic workflow approvals, or other documentation demonstrating that reconciliations were reviewed for completeness and accuracy. 6. Staff Training • Financial Aid and Finance personnel responsible for COD reporting and reconciliation activities will receive training regarding Department of Education requirements, reconciliation procedures, documentation standards, and internal control responsibilities. 7. Ongoing Monitoring and Compliance Oversight • Management will perform periodic monitoring of reconciliation activities to ensure procedures are operating effectively and reconciliations are completed on a timely basis. Compliance results and any significant reconciliation issues will be communicated to senior management and tracked through resolution. Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records (Continued) Responsible Officials: • Director of Financial Aid 0 Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Executive Vice President – Ariane Sweeney Anticipated completion date: Formal reconciliation procedures, documentation standards, and management review controls will be fully implemented by December 31, 2026. Monthly reconciliations will be performed and documented on an ongoing basis thereafter.

Identifying Number: 2025-003: Special Test-National Student Loan Data System (NSLDS) Enrollment Reporting Noncompliance. Finding - Instances of noncompliance have been identified where student enrollment changes were not reported to the NSLDS within the 60-day requirement. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions: 1. Development of Formal Written Procedures • The Institute will develop and maintain formal written policies and procedures governing NSLDS enrollment reporting. These procedures will clearly define reporting requirements, timelines, responsible personnel, supervisory review responsibilities, and documentation retention requirements to ensure compliance with Department of Education regulations. 2. Establishment of Reporting Calendars and Tracking Controls • Management will implement a formal reporting calendar and tracking mechanism to monitor NSLDS reporting deadlines. The tracking process will identify enrollment status changes requiring reporting and ensure all submissions occur within the required 60-day timeframe. 3. Enhanced Monitoring and Reconciliation Procedures • The Institute will perform periodic reconciliations between student enrollment records and NSLDS submissions to verify that all enrollment status changes have been reported accurately and timely. Any discrepancies identified during reconciliation will be investigated and corrected promptly. 4. Documented Review and Approval Process • Management will require documented evidence of supervisory review for each NSLDS submission. Review documentation will include dated approvals, electronic workflow approvals, or other evidence demonstrating that submissions were reviewed for completeness, accuracy, and timeliness prior to certification. 5. Staff Training and Cross-Training • Financial Aid personnel responsible for enrollment reporting will receive training on NSLDS reporting requirements and internal control procedures. Cross training will be implemented to ensure coverage during staff absences and reduce the risk of reporting delays due to personnel changes. 6. Ongoing Compliance Monitoring • Management will conduct periodic reviews of NSLDS reporting performance and maintain monitoring documentation to verify ongoing compliance with federal requirements. Any exceptions identified will be addressed through corrective action and management follow-up. 7. Oversight and Accountability • The Director of Financial Aid and senior administration will review compliance monitoring results periodically and track remediation efforts until the finding has been fully resolved. Management will maintain documentation supporting the operation of controls and timely reporting activities. Responsible Officials • Director of Financial Aid – Dr Thelbert Snowden • Executive Vice President – Ariane Sweeney • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Registrar (as applicable) – Adele Hartswick Anticipated completion date: The Institute will implement formal policies, reporting calendars, monitoring controls, reconciliation procedures, and review documentation requirements by December 31, 2026. Ongoing compliance monitoring and periodic review activities will continue thereafter.

We will strengthen our controls around reporting of expenses on consolidated SEFA report for our subsidiary and related organizations. We will exclude expenses that exceed the total budget and recommend posting adjustments in the books so that these are not included in grant expenses.

Corrective Action Planned: Management agrees with the auditor’s findings. The Director of Litigation, Lisa Hollingsworth, will meet with the Regional Leaders and ensure that they remind their staff about the necessity of obtaining a written statement of facts from clients in each relevant case. Name(s) of Contact Person(s) Responsible for Corrective Action: Director of Litigation – Lisa Hollingsworth Southeast Regional Leader – Brian Lipford Southwest Regional Leader – Peter Hemberger Anticipated Completion Date: On or before December 31, 2026

The organization will develop a procedure for the review and approval of adjusting journal entries, and attaching supporting documentation ensuring entries are being charged to the correct funding sources. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date: October 31, 2026

The organization will develop a process of checks and balances to ensure that supporting documentation is provided and attached to justify the draw down requests. A reconciliation of expenditures recorded on the books and submitted request for reimbursement. All excess funds will be returned to the funding source. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date:

The auditor compares being a beneficiary to being a sub-recipient instead of is the secondary institution a contractor or a sub-recipient. The organization agrees that policies and procedures should be put in place in the event that funds are going to be passed-through. In addition, the organization feels that it was able to show the funds that were passed-through to the contractor. Responsible Individual: Chief Financial Officer– Scott Korba Estimated Completion Date

While the organization has a written leave policy it does not address specific leave benefits for the CEO. The CEO has drafted a CEO Compensation and Benefits Policy to be reviewed by the Board and revised or approved at the October 21, 2026 Board of Directors meeting. Responsible Individual: Chief Executive Officer – Wilma Torres Estimated Completion Date: October 21, 2026

2025-004 – Lack of Written Policies and Procedures Auditor Description of Condition and Effect. Although the Organization has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Organization. As a result of this condition, the Organization did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Organization review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Organization has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Board of Directors before the end of fiscal year 2026. Responsible Person. Rob Rafson, Executive Director Anticipated Completion Date: December 2026

2025-005 – Lack of Documentation for SAM.gov Exclusion Checks Auditor Description of Condition and Effect. Although the Organization has processes in place to cover these areas, and completes SAM.gov exclusion checks, the Organization did not retain documentation to support that the exclusion checks were performed for vendors. As a result, there is no evidence that the Organization verified whether these parties were suspended or debarred prior to entering covered transactions. Auditor Recommendation. We recommend that the Organization retain evidence that SAM.gov exclusion checks are being completed for vendors to document that vendors are not suspended or debarred prior to entering covered transactions. Corrective Action. The Organization will begin retaining documentation for its SAM.gov exclusion checks that it completes for vendors to verify whether these parties were suspended or debarred prior to entering covered transactions. Responsible Person. Rob Rafson, Executive Director Anticipated Completion Date: December 2026

The Town of Highgate has endured a significant amount of turnover in the Town Administrator's role. This reporting was a task of the Town Administrator. The Town Treasurer was unaware that the SF-425 reports for the Town's active grant awards were not being filed in a timely fashion. The newly appointed Town Administrator has been made aware we are required to file the SF-425 when a grant award mandates the submission. Corrective action has began, the Town Administrator and Treasurer have been working together to get in compliance with our required reporting across all State and Federal Agencies that have awarded the Town grant funds. Trainings have taken place and the newly hired Administrator is aware of the required reporting and is able to perform this task on time when required.

SAMARITAS AND SUBSIDIARIES Management’s Corrective Action Plan For the Year Ended December 31, 2025 Finding 2025-001 Contact Person(s): Bridgette Zappacosta, Chief Financial Officer Corrective Action Planned: Management concurs with the finding. During the period under review, the Finance Department was transitioning to a new accounting system. The identified exceptions occurred prior to the implementation of the new system and related processes. As part of the transition to Blackbaud Financial Edge NXT, Samaritas has implemented controls designed to prevent expenditures from being charged outside of a federal award's period of performance. Grant records within the system now include defined start and end dates that prevent expenditures from being applied to awards outside the authorized grant period. In addition, Samaritas enhanced its invoice approval process by adding a required custom field to identify the service period associated with each invoice. This information is reviewed during the monthly close process to identify invoices received before or after a grant period and to ensure expenditures are recorded in the appropriate award period. The Finance Department completed training on these revised procedures in July 2026. Management will continue to monitor compliance with these controls as part of its monthly grant and financial review processes. Anticipated Completion Date: Implemented July 2026; ongoing monitoring procedures are in place.

CORRECTIVE ACTION PLAN — Finding 2025-003 Grant Accounting Reconciliation and Compliance over Allowable Costs / Reporting — Compliance Finding (Allowable Costs / Cost Principles, Reporting) and Material Weakness in Internal Control over Compliance and Financial Reporting Programs: Weatherization Assistance for Low-Income Persons (ALN 81.042); Low-Income Home Energy Assistance Program – LIHEAP (ALN 93.568), and related state and federal funds administered through the Weatherization program | Cognizant / Pass-Through Agencies: U.S. Department of Energy; U.S. Department of Health and Human Services; State of Vermont Department for Children and Families | Entity: Southeastern Vermont Community Action, Inc. (SEVCA) | CAP Contact: Joshua Davis, Executive Director, JDavis@sevca.org 1. Summary of Finding Finding 2025-003 identified that Weatherization work-in-progress (WIP), grant revenue, and deferred revenue balances did not reconcile to the supporting documentation required under the related grants, resulting in significant audit adjustments; those balances were adjusted to agree with program reporting only at grant-year and fiscal-year close rather than on an ongoing basis. The finding also identified that expenditures recorded in the general ledger could not be reconciled to expenditures reported in the state reporting system (Hancock) for both the LIHEAP and Weatherization programs, and that subcontract labor and subcontract material costs were overstated and billed to both programs, requiring repayment of $133,144.05 to the State of Vermont. 2. Management’s Response Management concurs with the finding, and the $133,144.05 has been repaid. Both conditions share a common root cause: Weatherization and Finance operate on separate systems — Hancock for program job-costing, the general ledger for financial reporting — without a recurring, independently reviewed monthly reconciliation between the two. Program staff prepare both the Hancock job-closing data and the resulting Monthly Expenditure Reports (MERs), and Finance’s role has been limited to sign-off on the cash draw request and MER rather than independent verification of the underlying data. This allowed a set of jobs that were closed, reported, then inadvertently reopened, re-closed, and billed a second time to go undetected until identified by the independent audit. 3. Root Cause Gap A – Balance reconciliation (drives the WIP, revenue, and deferred revenue condition): No recurring monthly reconciliation exists between Hancock’s reported WIP activity by grant and the general ledger’s WIP asset, revenue, and deferred revenue balances. Alignment has relied on a semi-annual adjusting entry that forces the general ledger to agree with year-end or grant-end program reporting, without documenting the variance being corrected. Gap B – Source data review (drives the expenditure reporting and overbilling condition): Finance’s review of the MER and cash draw request has not included independent verification that the population of jobs and costs reported as newly closed for the month is accurate and non-duplicative, which allowed reopened-and-reclosed jobs to be billed twice without detection. Gap C – Subcontract cost validation: Subcontractor invoices and purchase orders are reviewed and approved at the point of payment. Weatherization’s existing job-closeout procedure for verifying subcontract labor and material costs on a closed job has not been reviewed for consistency with grant requirements, and is not currently integrated with Finance’s review of cash draw requests and MERs. 4. Corrective Actions The actions below establish monthly, documented, independently reviewed controls for closing Gaps A, B and C scoped to what can be reliably implemented and sustained in the near term. 1. Develop and implement a written Monthly Grant Reconciliation Procedure requiring Hancock’s month-end WIP, revenue, and deferred revenue activity by grant to be reconciled to the corresponding general ledger balances every month, rather than only at grant-year and fiscal-year close — Finance Director; within 60 days (by early October 2026). 2. Replace the semi-annual WIP adjusting entry with a monthly adjusting entry supported by a documented reconciliation identifying the variance between Hancock-reported and general-ledger balances. During the initial implementation period, Finance will develop and refine the reconciliation methodology; each variance identified will be documented, researched, and corrected once its cause is determined. A specific materiality threshold and escalation protocol for unresolved variances will be documented and adopted by January 2027, based on the pattern observed in the initial reconciliation cycles. The reconciliation and any correcting entries are subject to documented Finance Director review and sign-off, and independent review and sign-off by the Executive Director, retained for audit testing — Finance Director / Staff Accountant / Executive Director; first full month applied July 2026, ongoing thereafter; materiality threshold and escalation protocol adopted by January 2027. 3. Develop and implement a written MER Review Procedure requiring that, prior to submission, Finance compare the current month’s Hancock closed-job listing against the prior month’s listing for each grant to identify jobs appearing more than once, including jobs closed, reopened, and re-closed — Finance Director / Staff Accountant; within 60 days (by early October 2026). 4. Formalize the existing Finance review and sign-off of the MER and cash draw request to explicitly include and document this closed-job comparison, subject to independent review and sign-off by the Executive Director prior to submission, — Finance Director / Executive Director; effective with the September 2026 submission cycle. 5. Require Weatherization to flag, at the point of submission, any job reopened after an initial closing, so Finance’s review has a defined starting point — Weatherization Administration Staff; effective with the October 2026 submission cycle. 6. Train Weatherization and Finance staff on the updated procedures, including the integrated job-closeout review (Item 7), and on 2 CFR 200 Subpart E (allowable, allocable, and properly supported costs), and retain completed reconciliations and MER review documentation, including job-closeout review documentation, to support future audit testing — Finance Director / Accounting Staff; training by early November 2026, retention ongoing. 7. Review Weatherization’s current job-closeout procedure, in coordination with Weatherization Administration Staff, to confirm that subcontract labor and material costs attributed to a closed job are verified as complete, accurate, not previously billed, and correctly classified. Correct or strengthen the procedure as needed to bring it into compliance, document it, and integrate it with Finance’s review of the MER and cash draw request (Items 3–4) — Finance Director / Weatherization Administration Staff; review completed by mid-September 2026, procedure documented, corrected as needed, and integrated with Finance’s review by mid-November 2026. 8. After the monthly WIP/general ledger reconciliation (Item 2) and MER closed-job comparison (Items 3–4) have been operating for at least one full quarter, apply the same closed-job comparison methodology retrospectively to Hancock data for FY24 and FY25 to identify any additional jobs closed, reopened, and re-closed and billed more than once. Document the results, including any additional amounts potentially due to the State of Vermont or U.S. Department of Energy, and report findings to the Finance Committee and, if additional overbilling is identified, to the State of Vermont Department for Children and Families and the U.S. Department of Energy — Finance Director; lookback completed by April 2027, following at least one full quarter of the new procedures operating. 9. Establish a semiannual internal compliance review across all major federal award programs (Head Start, CSBG, LIHEAP, HWAP, and CDBG), phased in to match available capacity. The first cycle will verify that expenditures recorded in the general ledger reconcile to amounts reported to each funder; a sample-based test of cost allowability will be incorporated beginning with the second cycle. The review is performed by the Finance Director and independently reviewed by the Executive Director, with results reported to the Finance Committee — Finance Director / Executive Director; first review by June 2027, semiannual thereafter, cost-allowability testing added beginning with the review in December 2027. 5. Anticipated Completion Date Both procedures will be documented, approved, and in effect no later than October 2026, with the first full reconciliation and MER review cycle completed at October month-end close. The Weatherization job-closeout review (Item 7) will be completed, corrected as needed, and integrated with Finance’s review by mid-November 2026. Staff training will be completed by early November 2026. The materiality threshold and escalation protocol for reconciliation variances (Item 2) will be adopted by January 2027. The FY24–FY25 historical lookback (Item 8) will be completed by April 2027. The program-wide semiannual internal compliance review (Item 9) will begin no later than June 2027, with cost-allowability testing phased in by December 2027. 6. Broader Process Review – Weatherization / Finance Integration These near-term actions reduce but do not fully resolve a systemic issue: Weatherization and Finance rely on separate systems and staff, connected only by manual, summary-level data transfer. Fully closing that gap — including possible transaction-level reconciliation between Hancock and the general ledger — requires broader cross-departmental review, which management has begun, led by the Executive Director and Finance Director in consultation with Weatherization Administration Staff. The review will incorporate the results of the Weatherization job-closeout procedure review (Item 7) and will evaluate the feasibility of transaction-level reconciliation, staffing needs, and interim manual controls, and is targeted for completion by November 2026. A detailed scope, timeline, and set of deliverables is maintained as a supplementary document, available to the Finance Committee and auditors on request; a summary of findings and any resulting recommendations will be incorporated into next year’s corrective action reporting. 7. Monitoring The Finance Director will review completed monthly reconciliations and MER review documentation, and the integrated Weatherization job-closeout review (Item 7), as part of each monthly close and submission cycle; the Executive Director will independently review and sign off on this documentation on the same cycle. Unresolved reconciliation variances will be handled per the protocol adopted under Item 2. Reconciliation status and any unresolved variances will be reported to the Finance Committee monthly, together with progress on the broader Weatherization / Finance process review until that work concludes. The semiannual program-wide internal compliance review (Item 9) will be reported to the Finance Committee upon completion of each cycle. 8. Evidence of Completion Items 1–2 (Monthly WIP/GL reconciliation): Reconciliation workpapers, variance research notes, Finance Director and Executive Director sign-off, and escalation records where applicable. Items 3–4 (MER closed-job comparison): Closed-job comparison reports, and the MER and draw request with Finance Director and Executive Director sign-off. Item 5 (Weatherization reopened-job flag): Flagged job listing submitted with each MER cycle. Item 6 (Training): Training materials and sign-in sheets or completion certificates. Item 7 (Weatherization job-closeout review): Documentation of the procedure review, any corrections made, and sign-off integrating it into the MER/draw review. Item 8 (Historical lookback): Lookback workpapers, a summary of results, and related Finance Committee and funder correspondence. Item 9 (Semiannual compliance review): Review workpapers, sample testing documentation, and the Finance Committee report. All records will be retained in accordance with SEVCA’s record retention policy and 2 CFR 200.334.

Management's Response Management will review the provided State Conservation Commission and Department of Environmental Protection grant awards with the percentage breakdown of Federal and State money grant sources from the contract allocations and spending balance of the federal monies verses state monies within the grant allocation.

The County has implemented procedures to ensure all future foster care maintenance for which reimbursement is sought is allowable.

Finding 2025-004 See response to finding 2025-001.

1. Explanation of Disagreement with Audit Finding: There is no disagreement with the finding. 2. Actions Planned in Response to Finding: Corrective actions are underway, including clarified expectations, additional training, and improved monitoring to prevent recurrence. Also, site-level recording and reporting templates have been implemented for the 2025-2026 school year and are in place at each recipient program. 3. Official Responsible for Ensuring CAP: The District’s Principal on Special Assignment who oversees the Title I program and the Business Services Director are the school officials responsible for carrying out the corrective action plan. 4. Planned Completion Date for CAP: The planned completion date for the CAP is June 30, 2026. 5. Plan to Monitor Completion of CAP: The Board of Education and administration will be monitoring this corrective action plan.

CORRECTIVE ACTION PLAN Name and Number of the Project: Alamo Area Mutual Housing Association, Inc. Audit Firm: M Group, LLP Audit Period: The year ended December 31, 2025 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING 2025-003: The Company does not have effective internal controls or consistently follow the written policies and procedures over federal awards. CORRECTIVE ACTION: Effective January 1, 2026, Prospera has control over ACG and plans to improve the internal control procedures and monitor the federal awards.

BPTC will ensure that all future operating grant purchases are allowable costs/activities per the grant agreements. BPTC will return the funds improperly reimbursed through Pay.gov.

Management acknowledges that owner certified financial data is required to be submitted through the Federal Audit Clearinghouse online system by March 31st of each year for the preceding fiscal year. To ensure that this deadline is adhered to each year going forward the CFO or designee will create an aggressive closing schedule so that accurate financial information is available on a timely basis to adhere to future filing requirements. In addition, RAIN is in the process of implementing NetSuite, a new accounting software system, which will help automate and accelerate the monthly and year-end close process, further supporting timely completion of the audit and future Federal Audit Clearinghouse submissions. Anticipated Completion Date: 12/31/2026 Contact Person: Kendell Burroughs, CFO

Management agrees with the finding that payroll costs charged to HUD-funded programs were based on estimated allocations and did not consistently reflect actual time and effort in accordance with 2 CFR §200.430 (Compensation—Personal Services) and applicable HUD program requirements. Management acknowledges the requirement that personnel costs charged to HUD awards (e.g., CDBG, HOME, CoC) must be supported by records that accurately reflect work performed on eligible program activities.

Management has updated its policies and procedures to require a formal annual review and update of the cost allocation plan. This review will occur in conjunction with the finalization and Board approval of the organization’s annual operating budget, ensuring that the CAP aligns with the most current program structure, funding sources, and cost allocation methodologies.