Corrective Action Plans

Corrective Action Plan Finding Number: 2025-002 – Return of Title IV Funds Controls Finding: There is no evidence of a control in place by the College to review Return of Title IV Fund calculations. Corrective Action Planned Given the size of the Financial Aid Office, the College will implement compensating internal controls to ensure R2T4 calculations are accurate, timely, and compliant with federal regulations. Effective immediately, the College will implement the following controls: 1. Standardized R2T4 Processing All R2T4 calculations will be performed using the Department of Education Common Origination & Disbursement (COD) system to ensure consistent application of federal formulas. Official withdrawal dates will be confirmed using Registrar records prior to calculation. 2. Independent Post-Calculation Review Each R2T4 calculation will be reviewed by an individual other than the preparer, where feasible, or through supervisory review when staffing is limited. The review will confirm the accuracy of withdrawal dates, days attended, calculation inputs, and Title IV funds included. 3. Coordination and Reconciliation The Office of Financial Aid will coordinate with Student Accounts to ensure R2T4 results are applied correctly to the student account and that returned funds are processed within required timelines. 4. Documentation and Retention Evidence of review, including reviewer initials and date, will be retained for each R2T4 calculation. A simple R2T4 review checklist or log will be maintained. 5. Ongoing Oversight The Director of Financial Aid will conduct periodic spot checks to ensure R2T4 calculations and reviews are completed accurately and timely. Responsible Official: De Rodrick Jonkins, Director of Financial Aid Anticipated Completion Date: Implemented effective August 1, 2025 Additional Context The Director of Financial Aid assumed the role effective April 1, 2025, after prior corrective actions had been identified. While formal independent review controls were not documented during the audit period, there were no identified R2T4 compliance issues, late returns, or calculation errors. The corrective actions above are intended to formalize review processes and further reduce compliance risk.

Corrective Action Plan Finding Number: 2025-001 – Enrollment Reporting Controls – Student Financial Aid Special Test Finding: There is no control in place by the College to review information submitted to NSLDS for student enrollment status changes. Corrective Actions Planned Given the size of the Financial Aid Office, the College will implement compensating internal controls to ensure accurate and timely enrollment reporting while maintaining operational efficiency. Effective immediately, the College will implement the following controls: 1. Continued Use of the National Student Clearinghouse (NSC) The College will continue to rely on the National Student Clearinghouse as its third-party servicer for enrollment status reporting to NSLDS. 2. Independent Post-Submission Review On a monthly basis, the Office of Financial Aid will review NSC enrollment reporting confirmation files to verify that enrollment status changes were submitted to NSLDS accurately and within the required 60-day timeframe. This review will be performed by an individual other than the primary preparer, where feasible, or through supervisory review when staffing is limited. 3. Documentation and Retention Evidence of review, including reviewer initials and date, will be retained. A simple enrollment reporting review log will be maintained to document compliance. 4. Ongoing Oversight The Director of Financial Aid will conduct periodic spot checks to confirm controls are operating as intended. Responsible Official: De Rodrick Jonkins, Director of Financial Aid Anticipated Completion Date: February 1, 2026 Additional Context The Director of Financial Aid assumed the role effective April 1, 2025, after prior corrective actions had been initiated. While formal independent review controls were not documented during the audit period, there were no identified instances of late enrollment reporting or inaccurate enrollment status submissions to NSLDS. The corrective actions above are intended to formalize controls and ensure sustained compliance with federal requirements.

Monitoring over federal awards – The District has corrected the reporting error for ESSER fund expenditures and is increasing its monitoring responsibilities to meet the needs of federal programs in the future. The District will be developing controls over reporting of federal funds to ensure these funds reconcile to the general ledger going forward.

Reporting - Federal Awards and Expenditures - ESSER – The District has corrected the reporting error for ESSER fund expenditures and is increasing its monitoring responsibilities to meet the needs of federal programs in the future. The District will be developing controls over reporting of federal funds to ensure these funds reconcile to the general ledger going forward.

Contact Person David Drapeaux Corrective Action Plan This finding was resolved in FY2025 through a joint agreement between the District and NDDPI. The questioned costs of $86,171, that were discovered during a separate NDDPI monitoring process, were all returned to the state before the beginning of the 2025 audit. This issue is resolved. Completion Date 05/08/25

Auditor Description of Condition and Effect: During our audit procedures over the District’s payroll process, we noted that an employee’s wages were allocated to the food service function based on a straight percentage instead actual work performed. As a result of this condition, the District does not have proper controls in place over its procedures for allocation of wages. Auditor Recommendation: The District should utilize timecards to support the allocation of wages to federal functions. Corrective Action: The District will. Responsible Person: Jamie Johncock, Business Manager Anticipated Completion Date: June 30, 2025

The purpose of the Goods Receipt (GR) is to record receipt of goods or services as soon as they are delivered and verified to be in acceptable condition. A Goods receipt must be posted in SAP for all items actually received. Vendors submit invoice(s) referencing the purchase order (PO) directly to Accounts Payable after delivery, indicating that the goods or services have been provided and requesting payment. Accounts Payable then reviews the vendor invoice, purchase order, and goods receipt in SAP to perform the required three-way match (PO, GR, and vendor invoice) before processing payment. 1. The Accounts Payable team will collaborate with the Procurement Services Division to establish and implement a process that ensures the timely review and reconciliation of Goods Receipt (GR) entries. This will include the development of clear guidance / training materials for schools and offices to periodically review their GR balances. Training will be conducted via Virtual Office Hours on a quarterly basis for sites to make necessary adjustments when the goods or services received differ from the original Purchase Order (PO) or the corresponding invoice. 2. The Accounts Payable team will collaborate with the Procurement Services Division to develop supplemental documentation and guidance regarding proof of delivery for goods and services received. 3. Accounts Payable staff will receive ongoing training throughout the year on documentation and reconciliation requirements, particularly when new internal controls, procedures, and processes are created. Training will be incorporated into regular team meetings, procedural updates, and onboarding for new team members to maintain alignment and accuracy across the department. The implementation target date for the above corrective action plan is June 30, 2026. Name: Rocio Saucedo Title: Director of Accounts Payable Contact Information: Rocio.Saucedo@lausd.net

Payroll Administration concurs with the recommendation pertaining to the preparation, review, and approval of employee timesheets to ensure the accuracy and completeness of payroll records. Employee timesheets and payroll records are originated, reviewed, and retained at the respective work locations. Therefore, Payroll Administration does not have direct access to these site-level records. To strengthen compliance, Payroll Administration will continue to provide targeted training and guidance to time reporters and time approvers on the timely review and approval of timesheets, the required time and effort certification, as well as the reconciliation of timesheet data with SAP entries. These topics will be reinforced during the monthly Time Reporter and Time Approver Virtual Office Hours. Furthermore, Payroll Administration will continue to issue periodic communications and disseminate the Best Practices Worksheet, which outlines key payroll compliance requirements, including adherence to payroll cut-off deadlines and reconciliation of timesheets and time entry in SAP. Payroll Administration remains committed to supporting District departments and school sites in maintaining full compliance with established payroll policies and procedures. Name: Araceli Pineda Title: Director, Payroll Administration Contact Information: araceli.pineda@lausd.net

Condition: Nine (9) employee payroll expenditures were claimed at an hourly rate greater than that approved by ISBE. Corrective Action Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. In addition, budgets will be monitored and amended accordingly within the period performance of the grant. Responsible Person: Janiesa Owens, Chief School Business Official Anticipated Completion Date: June 30, 2026

Condition: Three (3) monthly claims for reimbursement reported meal counts in excess of those supported by records of the District. Corrective Action Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. In addition, underlying claim support will undergo review before claims are submitted to the ISBE. Responsible Person: Janiesa Owens, Chief School Business Official Anticipated Completion Date: June 30, 2026

U.S. Department of Agriculture Passed Through the North Dakota Department of Public Instruction and the Minnesota Department of Human Services Federal Financial Assistance Listing # 10.565 All Awards Federal Financial Assistance Listing # 10.568 All Awards Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, multiple payroll allocation errors to programs were identified. Responsible Individuals: Kate Molbert, COO David Stachon, CFO Corrective Action Plan: This issue was fixed in FY25. The finding still exists due to July and August payrolls that occurred prior to the fix. After this was brought to our attention in the prior audit, it has been fixed going forward. We discussed this issue with our outsourced payroll provider, PRO Resources. We’ve opted into their upgraded online portal and now have access to better view, change and review allocations ourselves. Anticipated Completion Date: Completed

Beginning with the next semi-annual certification period, the Special Education Director will prepare a comprehensive listing of all staff whose salaries and/or benefits are charged in whole or in part to the Special Educaiton program. This listing will be reconciled to payroll records prior to certification. Once certifications are completed and signed by the Special Education Director, they will be forwarded to the Superintendent's office (or designee) for independent review and approval to verify that every applicable employee has a completed certification on file. Additionally, the District will establish calander reminders and due dates for each semi-annual period to ensure timely completion and submission of certifications. Staff involved in this process will receive refresher training on federal time and effort documentation requirements.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – ALN NOS. 84.027 AND 84.173 2025-001 Internal Control Over Compliance With Federal Allowable Costs Requirements Finding Summary 2 CFR § 200.302(b)(3) requires Independent School District No. 911 (the District) to maintain records that adequately identify the source and application of funds for federally funded activities in accordance with 2 CFR 200 Subpart E – Cost Principles. The District did not have sufficient controls to assure adequate and timely documentation of time and effort was created and retained to support salary costs charged to federal programs and ensure compliance with this requirement. Corrective Action Plan Actions Planned – The District will review policies and procedures for maintaining time and effort documentation for its employees in its federal programs to ensure compliance with the Uniform Guidance in the future. Official Responsible – Director of Finance and Operations, Christopher Kampa. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Director of Finance and Operations, Christopher Kampa, will assure appropriate internal controls and procedures are updated and in place to ensure adequate time and effort documentation is maintained to support all employee salaries charged to federal programs in the future.

Corrective Action Plan: The Finance Department Grants Reporting team will train departments on the process for timesheet monitoring and documentation as outlined in the City’s grant manual. The Grants Reporting team will conduct internal reviews/visits to the applicable departments to ensure time reporting and documentation procedures are followed and documentation retained meets the requirements listed in the grants manual. Persons(s) Responsible for Implementation: Cristen Huntz, Financial Analyst, Finance Department, (816) 513-1148, Email: cristen.huntz@kcmo.org, and Robin Flaherty, Financial Manager, Finance Department, (816) 513-1202, Email: robin.flaherty@kcmo.org. Implementation Date: The anticipated implementation date is April 30, 2026.

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 Identifying Number: Finding 2025-001 Identification of federal program: Federal Award Agency: Substance Abuse and Mental Health Services Administration Program Name and Federal Assistance Listing No.: Certified Community Behavioral Health Clinic Expansion Grants – 93.696 Pass-Through Entity: not applicable, direct funding Pass-Through Award Numbers: not applicable, direct funding Criteria or specific requirement: Section 200.308 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) governs the revision of program plans. A recipient must request prior written approval from the federal agency entity when there is a disengagement from a project for more than three months, or a 25% reduction in time and effort devoted to the federal award. The terms and conditions of this award require that an evaluator be assigned to the program maintaining a 50% level of effort. Any changes to key personnel including level of effort involving separation from the project for any continuous period of three months or longer, or a reduction in time dedicated to the project of 25% or more requires prior approval and must be submitted as a postaward amendment in eRA Commons. Condition: The Certified Community Behavioral Health Clinic Expansion Grants require that a project evaluator devote 50% level of effort requirement to the program. During the fiscal year ended June 30, 2025, due to program personnel turnover, OhioGuidestone was not able to ensure that the required level of effort be maintained and did not obtain the required approvals maintained by the terms and conditions of the grant agreement. Cause: Due to program personnel turnover, OhioGuidestone was not able to ensure that the required level of effort was maintained for the fiscal year ended June 30, 2025. Effect or potential effect: A failure to comply with the terms and conditions of the grant agreement could result in material noncompliance. Questioned cost: None.Context: Due to staff turnover, the project evaluator position for the Four County grant was vacant during February and March 2025. To maintain continuity, the Organization temporarily assigned the project evaluator from the Cuyahoga County contract to cover these months because of her familiarity with the program. However, prior written approval for this change was not obtained as required by the grant agreement. A new project evaluator was hired for April through June 2025, but onboarding delays prevented full engagement until after year-end. As a result, the level-of-effort requirement was not met for February through June 2025. Recommendation: We recommend that the Organization review existing policies and procedures and make enhancements where appropriate to monitor compliance with level-of-effort requirements on a periodic basis and to ensure that the required approvals are obtained. Corrective Actions Taken or Planned: OhioGuidestone acknowledges and agrees with this finding. In addition to tracking the LOE on the shared monthly budget tracking report, we will include a copy of the NOA Special Terms for Key Personnel in the report. If the LOE falls below the required level, the Grant Manager will inform Program Leadership using the comments section of the shared workbook. The staff assigned to the comment will respond with reasoning and expected timeframe to have the position back up to the required LOE. We will evaluate the situation including timeframe and determine if prior approval and a post award amendment is necessary. In the case of staff termination, we will initiate the post award amendment, notify SAMHSA of the separation, and seek approval to deviate from the required LOE during the recruiting period. Upon hiring for the position, another post award amendment will be submitted notifying SAMHSA of the new staff. Grant Manager will host a meeting with all staff involved detailing the new process. Name of contact person responsible for corrective action: Joseph Ziegler, Chief Financial Officer Anticipated completion date: December 31, 2025

Management’s Response – Management is currently in the process of re-evaluating existing policies and procedures within the accounting department, including those related to payroll processes. Effective immediately, payroll journals related to performance payments will be provided to the individual(s) responsible for program oversight of the program so they can be reviewed at the time payments are made. Errors or omissions, if any are identified, can then be corrected immediately. Management will continue to evaluate processes and implement improvements as opportunities to do so are identified.

The Accounting Manager and Executive Director for the year ended June 30, 2025 were terminated in October 2025, and the former Executive Director has returned to assist in implementing necessary controls and processes and train property level staff.

This finding was identified and addressed during the prior fiscal year audit and the current year findings are instances identified from prior to the identification of the finding in the prior year. Going forward the Organization will document the review and approval of the payroll allocated and charged to the federal award. of the payroll allocated and charged to the federal award.

Corrective Action Plan December 18, 2025 Massachusetts Department of Elementary and Secondary Education Office of Charter Schools and School Redesign 135 Santilli Highway Everett, MA 02149 Lawrence Family Development Charter School respectfully submits the following corrective action plan for the year ended June 30, 2025: AAF CPAS 50 Washington Street Westborough, MA 01581 Audit period: July 1, 2024 to June 30, 2025 (Fiscal Year 2025) The findings from the December 22nd schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - FINANCIAL STATEMENT AUDIT FINDINGS SIGNIFICANT DEFICIENCY 2025-01 Massachusetts Teachers' Retirement Board (MTRB) Remittances Regulations outlined in DESE's Charter School Audit Guide require Massachusetts Teachers' Retirement System (MTRS) payroll withholdings to be remitted to the MTRB within ten days of the following month. During our compliance testing, we noted nine instances, out of twelve months tested, for which the MTRS payroll withholdings were not remitted to the MTRB within ten days of the following month. Recommendation: In order to comply with Commonwealth of Massachusetts' MTRB regulations and charter school compliance requirements established by DESE, management should ensure that controls are in place to ensure all MTRS payroll withholdings are remitted timely. Action Taken: We concur with the recommendation, and LFDCS has implemented a policy requiring all MTRS payments to be completed within the first ten calendar days of each month. Effective Date: December 1, 2025 SIGNIFICANT DEFICIENCY 2025-02 Payroll Records The Federal government requires Form I-9's be maintained for all eligible employees. Out of the twenty-five selections tested, we noted one 1-9 form which was not properly completed by the School. We also noted four additional selections where the 1-9 form was unable to be located. We also noted there was no supporting documentation maintained for two W-4 forms. The School experienced turnover in the accounting and finance department during fiscal year 2025. Review of required document was not performed on a timely basis. Because of the failure to maintain required forms, ineligible employees may be added to payroll. Recommendation: Procedures should be implemented requiring the completion of required forms and the formal review and approval should be performed prior to adding employees to payroll. Action Taken: We concur with the recommendation, and LFDCS has implemented procedures to review personnel files for completeness and accuracy before new employees begin working at the school. Effective Date: December 1, 2025 2025-03 General Ledger Maintenance During fiscal year 2025, several general ledger accounts were not properly reconciled to their respective subsidiary ledgers, journals, or supporting schedules. In certain instances, reconciliations were prepared; however, variances were not clearly identified, investigated, or resolved. In other cases, reconciliations were performed in an untimely manner. The accounts affected included revenue and the related Federal expenditures, cash, accounts receivable, accounts payable, and due from Lawrence Prospera (the Fund). Unreconciled variances were also noted in various expense and accrued expense balances. Recommendation: Management should implement policies and procedures to ensure that all general ledger accounts are reconciled to the respective subsidiary ledgers, journals, or supporting schedules on a timely basis. Any variances identified during the reconciliation process should be promptly investigated and resolved to maintain the accuracy and reliability of the financial statements and ensure compliance with Federal grant reporting requirements. Implementing these procedures will strengthen internal controls, help prevent potential misstatements in the financial statements, and facilitate a smoother and more efficient audit process. Action In-Process: We concur with the auditor's recommendation. The LFDCS is in the process of implementing an accounting system while also developing accounting policies that set comprehensive standards and procedures to ensure the integrity and accuracy of the General Ledger (GL). The completed policy will include internal controls to safeguard financial data, prevent errors, and reduce the risk of fraud. It will also require segregation of duties by defining distinct roles for authorization, data entry, and review so that no individual is responsible for both recording transactions and reconciling accounts. These measures will provide accurate verification of assets and liabilities through monthly balance sheet account reconciliations and will enable timely and reliable financial reporting and budget-to-actual variation analysis. Anticipated Effective Date: March 1, 2026 2025-04 Bank Reconciliations During the fiscal year 2025 audit, we noted that the School's operating bank account reconciliations had not been prepared for several months after month end and did not agree to the reconciled bank balance. As a result, a large year-end adjustment was required before the audit to record previously unrecorded transactions in the general ledger. When bank reconciliations are not performed consistently and in a timely manner, there is an increased risk of unauthorized transactions or bank errors going undetected. Management should prepare bank reconciliations immediately upon receipt of the monthly bank statement, further, any outstanding checks which have not cleared within a reasonable time should be investigated upon completion of the monthly reconciliation. Recommendation: There is a lack of segregation of duties as it relates to the bank reconciliation process. The same employee who prepares the bank reconciliations also records the related journal entries in the general ledger. In addition, we did not observe evidence of management review or approval of the bank reconciliations prior to recording activity in the accounting records. This lack of segregation of duties increases the risk of errors or potentially resulting in misstatements of cash balances or unauthorized transactions. Action In-Process: We concur with the auditor's recommendation. Once the accounting system implementation is complete, LFDCS will adopt a reconciliation policy that ensures all cash transactions are properly recorded, complete, and any differences are resolved within ten days of the bank statement closing date. High-volume accounts will be reconciled weekly or more frequently as needed. To maintain sufficient segregation of duties, the Finance Team will prepare the reconciliations while the Director of Finance or another designated approver review and approve them. Under no circumstances will the same person prepare and approve the reconciliation. Additionally, the School will set up an integration between its bank and QuickBooks Online so that bank-cleared transactions are automatically downloaded, reducing manual data entry and increasing the efficiency and accuracy of the reconciliation process. Any discrepancies identified during the process will be investigated and corrected within ten days of month-end, and all reconciliations will be securely saved and readily available. Anticipated Effective Date: March 1, 2026 MATERIAL INSTANCE OF NONCOMPLIANCE 2025-05 Certified Procurement Officer Regulations outlined in the Massachusetts Department of Elementary and Secondary Education's (DESE) Charter School Audit Guide require a charter school administrator who serves as procurement officer to have a valid Massachusetts Certified Public Purchasing Official (MCPPO) designation. During fiscal year 2025, we noted that the School does not have any administrator who has MCPPO designation. Recommendation: In order to comply with DESE's procurement requirements, management should ensure that proper controls are in place and operating effectively to ensure that a designated individual has enrolled and receives a valid MCPPO designation. Management should also develop a checklist that tracks expiration date for MCPPO eligible employees to ensure timely renewal. Action In-Process: We concur with the auditor's recommendation. LFDCS acknowledges the requirement outlined in the Massachusetts Department of Elementary and Secondary Education's (DESE) Charter School Audit Guide that a charter school administrator serving as the procurement officer must hold a valid Massachusetts Certified Public Purchasing Official (MCPPO) designation. To comply with this requirement, the directors of facilities and finance in addition to the grant accountant will enroll in the MCPPO certification program offered by the Massachusetts Office of the Inspector General and ensure they complete the training if not certification process. LFDCS will also implement internal controls to track MCPPO certification status and expiration dates to ensure compliance and timely renewal. The Finance Director completed the initial course, Public Contracting Overview, on December 17th, 2025. Anticipated Effective Date: May 1, 2026 If the Department of Education and Secondary Education has questions regarding LFDCS's plans, please call Mark Ventre, Director of Finance, at 978.216.0461, extension 185. Sincerely yours, Signature : Mark Ventre Email: mventre@lfdcs.org Mark Ventre Director of Finance Lawrence Family Development Charter School

12/7/2026 Cognizant or Oversight Agency for Audit, Codman Academy Charter Public School and Affiliate (the School) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm : AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: July I, 2024 - June 30, 2025 The finding from the June 20, 2025 Schedule of Findings and Questioned Costs is discussed below. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2025-001 Required Payroll Forms Recommendation: AAFCPAs recommends the School implement a standardized checklist and conduct periodic internal reviews of onboarding documentation to ensure all required forms are properly completed and retained in accordance with Federal regulations. Action Taken: As of January, 2026 the staff member responsible for staff on boarding and payroll processing is no longer employed at the School. Codman, with a new staff person in charge of these tasks has instituted a standardized checklist for on boarding, has performed a backward looking audit of employee files and will conduct internal periodic reviews for completeness and accuracy. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please tell Derrick Cielsa, Executive Direct as 617-287-0770 Sincerely yours, Derrick Ciesla Excutive Director

12/7/2026 Cognizant or Oversight Agency for Audit, Codman Academy Charter Public School and Affiliate (the School) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm : AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: July I, 2024 - June 30, 2025 The finding from the June 20, 2025 Schedule of Findings and Questioned Costs is discussed below. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2025-001 Required Payroll Forms Recommendation: AAFCPAs recommends the School implement a standardized checklist and conduct periodic internal reviews of onboarding documentation to ensure all required forms are properly completed and retained in accordance with Federal regulations. Action Taken: As of January, 2026 the staff member responsible for staff on boarding and payroll processing is no longer employed at the School. Codman, with a new staff person in charge of these tasks has instituted a standardized checklist for on boarding, has performed a backward looking audit of employee files and will conduct internal periodic reviews for completeness and accuracy. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please tell Derrick Cielsa, Executive Direct as 617-287-0770 Sincerely yours, Derrick Ciesla Excutive Director

Name of Contact Person: Tonya Vannasdall, Director. Recommendation: We recommend that the Council perform a file review on all recipients to ensure that documentation of eligibility is retained. Secondarily, we recommend that Council strengthen its procedures to ensure that all required eligibility documentation is obtained and retained prior to authorizing program participation and charging costs to the federal award. Corrective Action: The Executive Director will implement a file review process and a process to ensure each file contains documentation of eligibility. Proposed Completion Date: Immediately.

Name of Contact Person: Tonya Vannasdall, Director. Recommendation: It is recommended that the client implement and document formal procedures to ensure all required subrecipient monitoring activities are performed in accordance with Uniform Guidance, including obtaining and reviewing subrecipient audit reports and following up on any identified deficiencies. Corrective Action: The Executive Director will implement the recommendation. Proposed Completion Date: Immediately.

County staff will receive annual daysheet training. The County will conduct training on the time sheet process. The County will continue random monthly reviews of Daysheets and timesheets initiated for May 2025. For those staff identified by the random monthly review with discrepancies, supervisors will provide refresher training on Daysheet and timesheet procedures. Additional targeted reviews will be completed monthly until the deficiencies are corrected.

The PHA has updated the Administrative Plan. Verification requirements are now explicitly stated, including what documentation is acceptable and what is not acceptable as verification. In addition, as the PHA selects applicants from the legacy waiting list, staff confirm the applicant still qualifies for the claimed preference at the time of selection.