Corrective Action Plans

Finding No.: 2024-032 Activities Allowed or Unallowed: Allowable Costs/Cost Principles Responding Agency: Guam Environmental Protection Agency (GEPA) Responsible Personnel: Michelle Lastimoza, Director Request to DOA will require immediate collaboration between Guam EPA and DOA to gather, reconcile, and provide all documentation supporting compliance of allowable costs incurred during the federal award period of performance as specified in the terms and conditions of the federal award or in the approved extension.

Finding No.: 2024-025 Activities Allowed or Unallowed: Allowable Costs/Cost Principles Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency disagrees with this finding. Please refer to a letter dated March 31, 2026, regarding Reports on Compliance September 30, 2024.

Finding No.: 2024-021 Activities Allowed or Unallowed: Allowable Costs/Cost Principles Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency disagrees with this finding. Please refer to a letter dated March 31, 2026, regarding Reports on Compliance September 30, 2024.

Finding No.: 2024-018 Eligibility Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency is reviewing the management of Federal Grants to ensure robust handover and succession plans are in place for future programs. The sudden passing of the ERA Program Coordinator directly impacted overall management of the program.

Finding No.: 2024-013 Allowable Costs/Cost Principles: Procurement, Suspension, and Debarment Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director Agency disagrees with 2 out of the 3 findings. • Condition 1 regarding the Authorization To Proceed (ATP), as per the Grant and Cooperative Agreement and the Grant Terms and Conditions, it did not state that an ATP is required to begin work on the grant for D20AP00048 and D21AP10145.The Government complies with ATP requirements for grants which mandate such compliance. If the grant is silent, no ATP is required.. • Condition 2 GSA will continue to verify vendor eligibility through SAM.gov prior to contract award. Documentation of the verification will be retained in the procurement file for each transaction. • Condition 3 The necessary controls will be strengthened when the updated Federal Grant module is fully implemented.

Finding No.: 2024-011 Period of Performance Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director (DPHSS) The DPHSS WIC Program disagrees with the findings. All supporting documents related to the findings were provided promptly on March 3,2026 when request was received on February 26,2026. In accordance with WIC FY 2024 Closeout Guidance and the requirements under 2 CFR 200.344, the WIC Program is allowed 90 days after the end of the period of performance to submit all final financial reports, as well as 90 days to liquidate all obligations incurred during the period of performance. For FY 2024, the closeout timeline required that all obligations be liquidated no later than January 31, 2025. The program adhered to these federal requirements. All obligations were liquidated prior to the close of the fiscal year grant, and obligations were reported in the fiscal year in which they occurred, consistent with 7 CFR 246.17. Furthermore, the final closeout report was submitted within 120 days after the end of the fiscal year, fully complying with WIC closeout procedures. Based on the timely submission of all supporting documentation and adherence to federal closeout regulations, the DPHSS WIC Program maintains that the questioned costs were appropriately obligated, liquidated, and reported.

93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) 2024-023 Strengthen Controls to Ensure Compliance with Provider Eligibility Requirements of CHIP and the Medical Assistance Program DOM Response: Two instances of no documentation that required fee were collected. DOM Partially Concurs. After a review of the 2 files, DOM has found in one instance an application fee was collected and sent to DOM for processing; however, the receipt of the application fee was not indicated by comments in the system. DOM will work with Gainwell to ensure remedial training is conducted to reduce errors in the future. One (1) instance correlates to an application received before DOM began requiring the fee on October I, 2022. Thirty-eight instances of no documentation that provider's medical license was current and free of limitations. DOM Partially Concurs. After a review of the 38 files, DOM has found in thirty-one (31) instances the license from the board was attached and the checklist completed after the license was not verified by LexisNexis . Two (2) instances were applications approved prior to the Gainwell implementation; however, the licenses remain valid in SFY 2024 and reflect correct effective dates in the system. One (1) instance is a group and does not require license. Four (4) instances the license from the board was manually verified and attached after the license was not verified by LexisNexis; however, there were typographical errors or omissions in the license fields in the system. DOM will ensure Gainwell conducts remedial training to mitigate these errors in the future. Thirty-one instances of no documentation of review prior to approval of provider's application. DOM Does Not Concur. After a review of the 31 files, DOM has verified all applications identified within this finding as being approved by DOM without review have documented comments in the system of record to show a review of each application was conducted prior to approval. This would include Fifteen (15) instances with review notes, requests for missing information (if applicable), etc. entered by reviewers since the Gainwell Go-Live. Sixteen (16) instances with review notes, requests for missing information (if applicable), etc. entered by reviewers prior to the Gainwell Go-Live. Ten instances of no documentation of verified identity and exclusion status of providers using required federal databases prior to application approval. DOM Partially Concurs. After a review of the 10 files, DOM has found in five (5) instances the LexisNexis report indicated the NPI was verified. One (I) instance of the NPI not verified by LexisNexis, but the Gainwell Analyst performed a manual search in NPPES and attached the verification results on 11/14/24. Four (4) instances before Gainwell began processing applications. The provider was sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Agency began revalidation in 2017 by stratifying all providers; however, due to PHE all revalidations were paused. As a result, not all revalidations have been completed. At this time, revalidation dates have been assigned in alignment with CMS guidance and will be completed within CMS required timelines, i.e. 44 months from end of the PHE. One (I) instance has a note indicating revalidation occurred in 2017, but no documentation can be located in the system, which potentially could be attributed to data conversion from the legacy system to the new system. Four instances of no documentation of OIG exclusion checks prior to application approval. DOM Concurs. After a review of the 4 files, DOM has found in three (3) instances contain a comment within EDMS that verifies the providers were sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Please note: Agency began revalidation in 2017 by stratifying all providers, however due to PHE all revalidations were paused. As a result, not all revalidations have been completed. At this time, revalidation dates have been assigned in alignment with CMS guidance and will be completed within CMS required timelines, i.e., 44 months from end of the PHE. One (1) instance has a note indicating revalidation occurred in 2017, but no documentation can be located in the system, which potentially could be attributed to data conversion from the legacy system to the new system. Two instances of no documentation of collection of the provider's NPI. DOM Concurs. After a review of the 2 files, DOM has found all instances contain a comment within the system which verifies the provider was sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Eight instances of missing or incomplete documentation of required disclosure details. DOM Partially Concurs. After a review of the 8 files, DOM has found in two (2) instances where the individual provider's date of birth is in the system. Two (2) instances where the individual provider's date of birth is not available as it was not a required element at the time of application. DOM will ensure the date of birth is obtained from the provider and added to the system. Three (3) instances where the organizational provider has all required elements. One (1) instance where the organizational provider's address is not available as it was not a required element at the time of application. The missing data is now required and will be collected at the next revalidation. Four instances of no documentation required screening procedures in accordance with provider's designated risk level. DOM Partially Concurs. After a review of the 4 files, DOM has found in three (3) instances where the individual provider's file contains a comment within EDMS verifies provider was sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Please note: Agency began revalidation in 2017 by stratifying all providers, however due to PHE all revalidations were paused. As a result, not all revalidations have been completed. At this time, revalidation dates have been assigned in alignment with CMS guidance and will be completed within CMS required timelines, i.e., 44 months from end of the PHE. One ( l) instance the individual provider was screened, and a site visit was conducted (as this provider type was deemed moderate risk at that time) and the documentation is available in the system. DOM Corrective Action Plan: a. In response to the audit findings, the Division of Medicaid (DOM) will collaborate with its Fiscal Agent, Gainwell Technologies, to review all identified issues and implement corrective measures. As part of this effort, mandatory refresher and remedial training will be conducted for Gainwell Provider Enrollment staff. This training will emphasize the requirement for comprehensive and accurate documentation within provider files, including clear, detailed, and supportive comments that fully reflect all actions taken during the enrollment and maintenance processes. Additionally, DOM will implement enhanced oversight and quality assurance monitoring to ensure sustained compliance with documentation standards. DOM notes that certain discrepancies identified in the audit may predate the implementation of the MESA system and the transition to Gainwell Technologies as the Fiscal Agent. Due to system conversion constraints, data limitations, and the absence of complete historical documentation within the current system, DOM's ability to retrospectively validate or remediate these pre-implementation discrepancies is limited. As such, corrective actions will be applied prospectively, with a focus on ensuring accuracy, completeness, and compliance within the current MESA environment moving forward. b. Bill Hardin c. March 31, 2026

Rndlng 2024-017: Spedal Tests and Provisions Significant Defldency In Internal Control over Compliance Crit eria: Per 45 CFR 1356.2l (ml(l ), in meeting the requirements of section 47l(a)(ll) of the Act, the tilie IV·E agency must review at reasonable, specifi c, tim e-limi tedperiods, to be established by the agency, the amount of the payments made for foster care maint enance to assure their continued appropriateness , and that the amount made to a licensed or approved relative or kinship foster famil y home is the same as th e amount that would have been made if the child was placed in a licensed or appr oved non-relative foster family home. Based on the Olicia Y. Lawsuit' s Mi ssissippi Sett.lem ent Agreement and Reform Plan, MOCPS is requ ired to review and publi sh u pdated! foster boardpayment rates every two years. Per 45 CFR 75.303(a), non-Federal entities expending HHS awards must establish and maintain effective internal contro ls over comp liance with Federal states, regulations, and the terms and conditions of the Federal award. Condit ion: Our audit procedures over foster care board payments disclosed that the approved payment board rates were unattai nable . The rates had not been updated from the rate approved in 2019 and no documentation could be provided for the required biannual review. Furt her, therate applied for children aged 0- 8 were not the most recent approved rates resulting in underpayments to foster families. Perspective: Below are the exceptions noted in our testing of foster care board payments for proper allocation of the rates and their approval. The samples were not statistically valid. • One of tenrate categories did not have the proper rateappliedbased on provided board rates resulting in twenty-six of forty sample payment Items being underpaid. • MDCPS did not maintain adequate documentation for the required rate review. Personnel Responsible for Corrective Action: Name: A/asha King Title: Grants Accounting Team Lead Email: Aiasha.King@mdcps.ms.gov Phone Number: 601-359-4016 Co rr ective Acti on Plan: Prior to lhe Single Audit, MDCPS im plemented the Foster Board Payment Review Standard Operating Proce dure (2.15.9.1) to ensure payment rates are verified and approved prior to issuan ce. Annual reviews of board payment rates will be conducted to ensure alignment with approved rates. Antldpatecl Completion Date: Completed as of March 19, 2026.

Finding 2024- 015: Allowable Costs/ Cost Principle Signifi cant Deficiency In Internal Contro l Over Compliance Criteria: Per 45 CFR 1355.57(d), a title N·E agency must allocate project costs in accordance with applicab le HHS regulations and other guidance. Per 45 CFR 75.303(a), non-Federal entities expending HHS awards must establish and maintain effective internal con trols over compliance with Federal sta tes, regu lations, and the terms and conditionsof the Federal award. Condition: Our audit procedures over administrative services disclosed that MDCPS lacked proper policies and procedures over data editing or modification of the cost allocation system. Perspe ctive: Per discussion with management, it was determined that no formal policies and procedures were established for data editing or modifications. Personnel Responsible for Corrective Action : Name: Christopher Roy Title : Deputy Director to the CFO Email: Christopher.Roy@mdcps.ms.gov Phone Number: 601-359-4043 Corrective Action Plan: MDCPS Is strengthening segregation of duties within the Cap Plus system by limiting administrative privileges and ensuring supervisory approval is documented for all cost allocation changes. AntJdpated Completion Date: Permissions were corrected and completed as of March 31, 2026. Documented process and policy anticipated completed May 30, 2026.

Finding 2024 - 014: Allowable Costs/ Cost Prlnclple Significant Defldency In Internal Control Over Compliance Criteria: Per 45 CFR 1355.57(d), a title IV-E agency must allocate project costs in accordance with applicable HHS regulati ons and other guidance. Per 45 CFR 75.303(a), non-Federal entities expending HHS awards must establish and maintain effective internal controls over compliance with Federal states, regulations, and the terms and conditions of the Federal award. Condition: Our audit procedures over administrative services disclosed that MDCPS lacked proper controls over employee training costs expended through a specific vendor. Perspective: Below are the exceptions noted in our testing of administrat ive services for appropriate review over cost allocation . The samples were not stat ist ically valid. One hundred percent of the costs charged for employeetraining using a specific vendor (four transactions) were te.ste d, and four out of four transactions lacked appro priate review. Personnel Responsible for Corrective Action: Name: Christopher Ray Title : Depuly to 1he Chief Financial Officer Email: christoher.Roy@mdcps.ms.gov Phone Number: 601-359-4043 Corrective Action Plan: MDCPS will enforce our policy requiring approval of the grant management's team's review of appropriate detailed documentation provided by vendor payments. Antldpated Completion Date: Completed as of March 31, 2026.

Finding 2024- 013: Terminated User Access Not Removed Timely Significant Deficiency In Internal Control Over Financial Reporting Criteria: Per 45 CFR 75.303(a), non-Federal entitles expendingHHS awards must establish and maintain effective internal controls over compliance with Federal states, regulati ons, and the terms and conditions of the Federal award. Management must mainta in effective user access controls over financia l reporting systems. This Includes promptly removing or disabling access for terminated users and periodically reviewing user access to confirm it aligns with current employment status and job responsibilities. Condition: Testing of IT general controls identifiedinstances where terminated employees' user accounts or financial application access remained active beyond the termination date. MDCPS did not disable terminated user access or remove related application rights in a timely manner. Perspective: During our review of general IT controls, the auditor received a list of terminated employees. Of the 11 employees presented, 6 maintainedaccess to MACWIS after termination.Further, during the performance of a process walkthrough,it was noted that the former chief financial officer was still active in CapPlus and SPHARS. Personnel Responsiblefor Corrective Action: Nome: Shannon Rushton (Employee Seporotlon SOP) Title : Deputy Commissionerof Human Capitol Email: Shannon.Rushton@mdcps.ms.gov Phone Number: 601-359-2696 Name: Christopher Ray (CapPlus User Termination) Title: Deputy Director to the CFO Email: Christopher.Roy@mdcps.ms.gov Phone Number: 601-359-4043 Corrective Action Plan: MDCPS has reinforcedthe EmployeeSeparation St andard Operating Procedure(2.19.2.2) to ensure all system access is removed promptly upon employee separation. Human Resources will notify system administrators immedai tely upon employeetermination, and system administrators will disable all associated application access no later than th e employee's final day of employment. Human Resources will conduct periodic user access reviews to ensure procedures are properly Imp lemented. The Finance Division will ensure the cap Plus software's access and penn1ss1ons are monitored and maintained by the agency with assistance from Interactive Voice Application (IVA). Upon a Cap Plus user's termination , they will be removed from the Cap Plu s software upon their last day of employment or the removal of th eir dutie.s by the agency. These permissions do not require IT or Human Resource control as Cap Plus i s independent of all accounting, payroll, and HR software. Antldpated Completion Date: Empl oyee Separation SOP effectiveas of July 22, 2025. CapP lus user's termination procedures effective as of March 31, 2026.

The Department should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Department of Health should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Response: The Department concurs with the finding and the need for a proper method of time recording for accurate time and effort reporting. Prior to the conclusion of the audit, the agency created an internal review group to assess the need for an efficient time keeping system to be utilized throughout the agency to allow for uniformity and accuracy. Corrective Action: The Department will continue to move forward with the implementation of the new time keeping system which allows for proper time and leave collection for documentation and allocation of employee time. In the system, the employee time will be recorded and approved by supervisory personnel for accuracy prior to submission payroll processing. The system will allow documentation to be assessed when needed. Name of contact person responsible for the corrective action: Lucreta Tribune Anticipated date for completion of corrective action: July 1, 2026

The Department should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Department of Health should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Response: The Department concurs with the finding and the need for a proper method of time recording for accurate time and effort reporting. Prior to the conclusion of the audit, the agency created an internal review group to assess the need for an efficient time keeping system to be utilized throughout the agency to allow for uniformity and accuracy. Corrective Action: The Department will continue to move forward with the implementation of the new acquired time keeping system which allows for proper time and leave collection for documentation and allocation of employee time. In the system, the employee time will be recorded and approved by supervisory personnel for accuracy prior to submission payroll processing. The system will allow documentation to be assessed when needed. Name of contact person for the corrective action: Lucreta Tribune Anticipated date for completion of corrective action: July 1, 2026.

The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Response: The Department concurs with the finding and the need to enhance procedures and strengthen controls over processing expenditures to ensure compliance with the awards’ period of performance. Corrective Action: The program will enhance procedures and strengthen controls to ensure expenditures presented for payment are allowable and within the awards’ period of performance. Program leadership will develop and document an internal expenditure review process to ensure a complete review of presented expenditures for payment is completed prior to submission to the agency’s Accounts Payable Department for processing. Name of contact person responsible for the corrective action: Jameshyia Ballard Anticipated date for completion of corrective action: September 30, 2026

The Department should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Department of Health should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Response: The Department concurs with the finding and the need for an effective method of time recording for accurate time and effort reporting. Prior to the conclusion of the audit, the agency created an internal review group to assess the need for an efficient time keeping system to be utilized throughout the agency to allow for uniformity and accuracy. Corrective Action: The Department will continue to move forward with the implementation of the new time keeping system which allows for proper time and leave collection for documentation and allocation of employee time. In the system, the employee time will be recorded and approved by supervisory personnel for accuracy prior to submission payroll processing. The system will allow documentation to be assessed when needed. Name of contact person responsible for the corrective action: Lucreta Tribune

Finding No. 2024-002 Loan Originations Involving Fraudulent Documentation Federal Agency: U.S. Department of Commerce Economic Development Administration Program Titles and ALN Numbers: EDA Revolving Loan Fund Program Capital Allocation - New York Contractor Loans (a non major program) (11.307) Federal Grant Numbers: Award #01-79-15074 Compliance Requirements: Activities Allowed and Unallowed and Allowable Costs Contact Person: James H. Bason, President and Chief Executive Officer, TruFund Financial Services, Inc., 9 East 40th, NY 10016 Corrective Action: (1) Federal agency notification: Management has notified the U.S. Department of Commerce Economic Development Administration of this finding and the questioned cost, and will cooperate fully with any federal review or recovery process. (2) Federal corrective action plan: Management has provided EDA with a corrective action plan addressing the specific internal control deficiencies applicable to federally funded loan programs. (3) Enhanced internal controls over federally funded programs: All corrective actions implemented under Finding 2024-001 apply equally to all federally funded loan programs, including enhanced verification, segregation of duties, and suspicious activity monitoring. (4) Replenishment of EDA Revolving Loan Fund: Subsequent to year-end and prior to the issuance of this report, TruFund replenished $410,000 in non-federal, unencumbered funds to the EDA Revolving Loan Fund, in response to EDA's request to restore the fund balance. Anticipated Completion Date: April 30, 2026

The District uses an outside party to oversee grant management. District management will review work performed by outside parties to ensure completeness and accuracy.

Corrective Action Plan Management will prepare the schedule of expenditures of federal awards as part of the year end closing process each year to determine their audit requirements under the Uniform Guidance and provide the schedule to the audit firm during the financial audit process.

See the University response section at the end of this report for the corrective action plan for finding 2024-118.

Assistance listing numbers and program names 97.024 Emergency Management Performance Grants Agency: Department of Emergency and Military Affairs (DEMA) Name of contact person and title: Keith Tagaban, Audit Supervisor Anticipated completion date: September 18, 2026 Agency’s Response: Concur The Department of Emergency and Military Affairs will maintain required documentation to support payroll costs charged to the federal program and ensure compliance with award requirements. Internal Audit will review FY2024 payroll charges for allowability and adequate support in coordination with the State Finance Office, the Emergency Management Grants Administration Office, and State Human Resources Office. Unallowable costs, if identified, will be resolved through reimbursement adjustments or repayment, as appropriate. Payroll documentation policies will be updated, and training will be provided to ensure required records are retained for the prescribed retention period.

Assistance listing numbers and program names: 93.575 Child Care and Development Block Grant 93.575 COVID-19 - Child Care and Development Block Grant 93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund 93.596 COVID-19 - Child Care Mandatory and Matching Funds of the Child Care and Development Fund Agency: Department of Economic Security (DES) Name of contact person and titles Lacie Butler, Administrative Services Officer Anticipated completion date: May 30, 2026 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: The Department is revising its procedures to ensure that it receives and retains documentation to support its provider’s expenditures, including Payment Disbursed Quickly (PDQ) submitted billings. Specifically, due to PDQ system limitations the Department is implementing additional validation procedures for these payments, and restricting the use of this system to limited providers to ensure future compliance. The Department is conducting an internal audit to validate that all required PDQ submissions are on file for Fiscal Year 2025; instances of non-compliance will be resolved in the same manner as an overpayment. The Department will continue to retain all records related to a federal award for a period of 3 years from the final expenditure report submission date.

Assistance listing numbers and program names: 21.023 COVID-19 Emergency Rental Assistance Program 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Agency: Department of Economic Security (DES) Name of contact person and title: Molly Bright, Community Services Division Assistant Director Anticipated completion date: June 30, 2026 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: 1. Ensure benefit payments are for allowable costs paid to or on behalf of eligible program applicants. The Division will review and confirm that benefits payments paid to or on behalf of eligible program applicants are allowable expenditures of the federal funding being disbursed. 2. Update existing policies and procedures to include a post-review of the benefits subsystem’s automated review of eligibility requirements, such as verifying the income thresholds and geographic location aligned with the Division’s written policies and procedures, and supported by required documentation. The Division should correct any inaccurate eligibility determinations identified during the post-review. Emergency Rental Assistance Program policies and procedures require validation of eligibility based upon substantiating applicant documentation, including household income and geographic location. The Division will update Division policy to include a post-review process to identify and correct any errors or discrepancies. 3. Allocate sufficient staffing resources to perform a thorough evaluation of program benefits applications and provide training on eligibility requirements and allowable benefit payments. The Division will allocate sufficient staffing resources to evaluate program benefits applications and provide training on eligibility requirements and allowable benefit payments. 4. Work with the federal agencies to resolve the $64,131 in program funds that were spent in violation of federal regulations, policies and procedures, and may need to be returned to the federal agencies. The Department of Economic Security will address the audit recommendations as follows: 1. Ensure benefit payments are for allowable costs paid to or on behalf of eligible program applicants. The Division will review and confirm that benefits payments paid to or on behalf of eligible program applicants are allowable expenditures of the federal funding being disbursed. 2. Update existing policies and procedures to include a post-review of the benefits subsystem’s automated review of eligibility requirements, such as verifying the income thresholds and geographic location aligned with the Division’s written policies and procedures, and supported by required documentation. The Division should correct any inaccurate eligibility determinations identified during the post-review. Emergency Rental Assistance Program policies and procedures require validation of eligibility based upon substantiating applicant documentation, including household income and geographic location. The Division will update Division policy to include a post-review process to identify and correct any errors or discrepancies. 3. Allocate sufficient staffing resources to perform a thorough evaluation of program benefits applications and provide training on eligibility requirements and allowable benefit payments. The Division will allocate sufficient staffing resources to evaluate program benefits applications and provide training on eligibility requirements and allowable benefit payments. 4. Work with the federal agencies to resolve the $64,131 in program funds that were spent in violation of federal regulations, policies and procedures, and may need to be returned to the federal agencies. The Division will coordinate with applicable federal agencies to resolve these unallowable costs.

Assistance listing number and program name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Agency: Department of Economic Security (DES) Office of Economic Opportunity (OEO) Name of contact persons and titles: David Almaraz, DES DERS Business Administrator Stephen Sifuentes, OEO Finance Administrator Senior Anticipated completion date: See below Agency’s Response: Concur DES Anticipated completion date: December 31, 2026 The Department will address the audit recommendations by amending its ISA subaward with the Arizona Office of Economic Opportunity. The Department will also adjust its subrecipient monitoring schedule, procedures and offer training and assistance on conference-related requirements to the Arizona Office of Economic Opportunity. OEO Anticipated completion date: June 30, 2027 The Office of Economic Opportunity (OEO) acknowledges the finding regarding the use of WIOA Dislocated Worker Formula Grant funds for conference meals and promotional items. To address these concerns, OEO has undertaken proactive measures to strengthen internal controls, enhance oversight, and improve compliance with federal cost principles. As such, OEO will utilize these findings to strengthen its existing system, address any identified deficiencies, and continue to enhance fiscal management. Through these corrective actions, the OEO is committed to full compliance and the effective stewardship of federal funds. 1. Ensure Summit costs charged to the WIOA federal program are appropriate, necessary, and managed to minimize charges to the federal award. The OEO acknowledges the auditors’ findings regarding the management of Summit costs charged to the Workforce Innovation and Opportunity Act (WIOA) federal program. OEO is committed to ensuring that all expenditures are appropriate, necessary, and managed with the highest level of fiscal responsibility to ensure charges are necessary and allowable to the federal award. To address this finding, OEO will collaborate closely with the Arizona Department of Economic Security (ADES) to develop and implement comprehensive formal policies and procedures governing the State Workforce Development Board and WIOA funded events including Summit expenditures. Our joint efforts will focus on implementing a documented review and approval process to ensure costs charged to the federal award are supported by documentation and evaluated in accordance with 2 CFR §§ 200.403. As part of this corrective action, the process will integrate cost-containment measures into the planning and approval of the events budget planning phase. This will include requiring staff to assess whether proposed costs are necessary, reasonable, allocable and limited to helping the workforce development system achieve the purpose of the Workforce Innovation and Opportunity Act (WIOA). OEO and ADES will conduct working sessions to develop, implement, and monitor these protocols, with the goal of finalizing a standardized procedure for all WIOA-funded event expenditures. This approach ensures consistency across agencies and establishes clear oversight to prevent recurrence. 2. Develop and implement written procedures, including a standardized review process, to ensure that costs charged to the WIOA federal program are allowable prior to requesting reimbursement from DES. The OEO recognizes the importance of verifying the allowability of expenditures prior to the reimbursement phase. We concur that a standardized documented review process is necessary to maintain fiscal integrity and compliance of WIOA federal program funding and federal regulations. OEO, in partnership with the ADES, will develop and formalize written internal control procedures designed to vet all costs before they are submitted to ADES for reimbursement. The proposed standardized review process will align with existing practices for monitoring and expending federal funds as described under WIOA for the State Workforce Development Board and will include: ● Pre-submission verification: Implementation of an internal review checklist based on 2 CFR 200 Subpart E Cost Principles and applicable State policy. This will ensure that every line item is: ○ Allowable under both WIOA statutory requirements and federal cost principles. ○ Allocable to the specific federal award in proportion to the benefits received. ○ Compliant with the State of Arizona Accounting Manual ○ Documented with sufficient supporting evidence (pictures, invoices, receipts, and justifications) to withstand audit scrutiny. ● Standardized approval workflow: Establishment of a clear designated approval framework. ● Policy Integration: These procedures will be codified into an OEO Fiscal Manual, providing staff with a clear roadmap for processing WIOA-related expenditures. OEO will coordinate with ADES technical assistance teams to ensure our internal review templates align with ADES’s appropriate reimbursement systems. This collaborative design phase will ensure that once a request reaches ADES, it has already undergone a vetting process, thereby reducing errors. 3. Work with federal grantor and/or DES to resolve the $90,015 of questioned costs associated with the 2024 Summit and any subsequently held Summits. OEO will collaborate with the ADES, the primary grant recipient, to establish the most appropriate course of action for resolving any unallowable expenditures. Initially, OEO will work with ADES to precisely define the actual allowable amount based on programmatic cost allowability, which may require consultation with the original federal grantor, for final clarification on disputed cost. Subsequent steps for resolution will be guided by ADES’s direction and the requirements of the federal grantor.

Finding Reference: 2024-007 Finding Title: Timecard Approval Controls – Payroll Charge to Federal Grant, Significant Deficiency CAP Contact Persons: • John Morris, Chief Financial Officer, Financial Affairs, (312) 322-6420 • Scott Dolude, Director of Payroll, Financial Affairs, (312) 322-6526 Planned Corrective Actions: 1. Timecard Approval Requirements for Federal Grants: Management will reinforce payroll control procedures to require that all employee timecards charged to Federal grants are reviewed and approved by designated supervisors in a timely manner and in accordance with established payroll deadlines. Specifically, that all required approvals must be completed prior to payroll processing and fiscal period close to ensure the allowability, accuracy, and proper allocation of costs charged to Federal awards. By June 30, 2026, management will send an email to all impact supervisory and management personnel responsible for time review and approval processes. 2. Documentation Standards and Audit Trail: Management will establish formal documentation standards to ensure that evidence of supervisory review and approval, including approval dates, is consistently retained in a secure, centralized system. These standards will support a clear and retrievable audit trail demonstrating compliance with the payroll documentation and allowability requirements of 2 CFR §200.430(i). 3. Monitoring and Compliance Oversight: Management will implement periodic monitoring procedures to assess compliance with timecard review and approval requirements. These procedures will include exception reporting, timely follow-up on identified deficiencies, and management review of monitoring results. Corrective actions will be implemented, as necessary, to address recurring or systemic issues related to untimely, incomplete, or undocumented approvals. Based on the results of monitoring processes, Director of Payroll and Timekeeping will conduct organizational, departmental, or team-based follow-up to address non-compliance or other issues. Anticipated Completion Date: 06/30/2026

Finding Reference: 2024-006 Finding Title: Indirect Cost Rate Pool, Noncompliance and Significant Deficiency CAP Contact Persons: • John Morris, Chief Financial Officer, Financial Affairs, (312) 322-6420 • Alan Ochab, Senior Director, Budget Management & Analysis, (312) 322-1519 Planned Corrective Actions: 1. Correction Adjustment: Management has communicated to its consultant, Maximus, its expectation that the final 2026 indirect cost rate report will incorporate an adjustment to remove the disallowed expense related to the unallowable tax penalty for all affected 2026 rates. Metra will not authorize submission of the final report to the Federal Transit Administration (FTA) until the Finance team confirms that the adjustment has been appropriately reflected and its impact fully evaluated. The adjustment, including relevant background information and its general impact on the rates, will be disclosed in the transmittal letter submitted to the FTA with the final report. 2. Independent Review Controls: Management will strengthen internal review controls by implementing a secondary review of the indirect cost rate data, including consulting with Internal Audit to improve review procedures. This review will verify that costs included in the indirect cost pool are allowable, reasonable, and adequately supported in accordance with 2 CFR Part 200, prior to submission to the Federal Transit Administration (FTA). Anticipated Completion Date: 09/30/2026