Corrective Action Plans

2025-001 - Miscalculation of Reconnect Scholarship Awards. Auditor Description of Condition and Effect. For 3 out of 12 students tested, the incorrect amounts of Michigan Reconnect scholarships were calculated and awarded to students. As a result, the College had a total of 16 students whereby the Michigan Reconnect scholarships awarded during the fiscal year were miscalculated, resulting in $16,101 in under-awarded scholarships and $288 in over-awarded scholarships to students. The College corrected under-awarded scholarships by adjusting student accounts to reflect accurate award amounts and issued refunds to students as applicable on March 18, 2026. The college corrected over-awarded scholarships by adjusting the student accounts and updating the Michigan Student Scholarships Grants ("MiSSG") reporting system to refund MiLEAP on August 6, 2025. Auditor Recommendation. We recommend that the College implement a formal review process for Michigan Reconnect scholarship award calculations, ensuring that each calculation receives a second, independent review to verify its accuracy. Corrective Action. The College recalculated the awards for the students impacted, adjusted their student accounts, notified the students of these corrections and returned $288 in over-awarded scholarships to MiLEAP by updating the MiSSG reporting system. Additionally, the College plans to conduct additional training of stafff on the Michigan Reconnect Expansion program, including the last-dollar calculation methodology, and will implement a review of the calculations by a second individual of all disbursements. Responsible person. Maryann DeCaire, Director of Financial Aid. Anticipated Completion Date. March 31, 2026.

Condition: Expenditures for the Child and Adult Care Food Program were incorrectly reported as expenditures to other nutrition programs. Recommendation: The auditors recommend that the School properly identify and report nutrition program expenditures by program. Contact Name: Anastacia Europa Ruiz, Chief Operating Officer Corrective Action Planned: The School Management will identify nutrition program expenditures by each separately funded program and report such expenditures by each separately funded program. Anticipated Completion Date: June 30, 2026

Condition: For FAL 10.185, all 40 vendor disbursements tested lacked evidence of supervisory approval, as the payment request forms were not signed by the designated approver prior to payment. For FAL 10.558, 27 of thirty-two vendor disbursements tested lacked documented supervisory approval prior to payment. Finally for FAL 84.010A, two of the ten vendor disbursements tested lacked documented supervisory approval prior to payment. In each noted instance, payments were processed without evidence that the School performed and documented a review in accordance with established internal control procedures. Recommendation: The auditors recommend that the School enforce existing policies requiring documented supervisory approval prior to processing payments and implement monitoring procedures to ensure approval documentation is completed and retained. In addition, the School should strengthen pre-payment review procedures to ensure expenditures are evaluated for allowability, necessity, reasonableness, and proper allocation in accordance with 2 CFR Part 200 and applicable program requirements. Training should be provided to personnel responsible for processing and approving federal program expenditures to reinforce compliance responsibilities. Contact Name: Anastacia Europa Ruiz, Chief Operating Officer Corrective Action Planned: The School Management will require documented supervisory approval, including signature and date, on all payment request forms prior to processing vendor disbursements charged to federal programs. Accounts payable staff will not release payments without evidence of required authorization. Written disbursement procedures will be reviewed and the applicable staff will be retrained within 90 days. The School will perform monthly oversight of disbursement activity and quarterly sample reviews to ensure ongoing compliance. Anticipated Completion Date: June 30, 2026

Recommendation We recommend implementing a Program Improvement Plan between the Title IV-E team and Fostering Connections to ensure that adoption cases potentially eligible for extended subsidies are processed promptly upon consideration, with the necessary agreements executed in a timely manner, i.e., before the children in question turn 18. Management Response Corrective Action The Office of Performance and Accountability Director will work with the Adoption and Kinship Unit Supervisor to establish a biannual review of payments to adoptive parents to verify if cases need to be closed. Due Date of Completion: June 30, 2026 Responsible Person(s) Office of Performance and Accountability Director

Recommendation We recommend a Program Improvement Plan with documentation retention and file checklist, training, implementation, and monitoring process. There should be accountability for non compliance with these requirements. Management Response Corrective Action Missing Documentation The CYFD Adoption Subsidy unit will continue to organize its filing system. The Eligibility Manager and Office of Performance and Accountability Director will work with the Adoption and Kinship Unit Supervisor to review and ensure appropriate checklists, training, and processes are in place. In addition, the Eligibility Manager, OPA Director, and Adoption and Kinship Unit will conduct an additional case review to ensure required documentation is present and establish a biannual cadence of self-assessment checks to ensure no missing documentation. Criminal Records Mitigation The agency continues to ensure that workers, supervisors, and managers follow proper procedures for mitigating criminal records checks. The agency addresses this by creating a supervisor checklist to ensure licensure documentation is complete and accurate. The supervisor will conduct an initial placement review; the checklist will include verification by the supervisor of the completed level of care documentation. Supervisors and Managers will address work performance with employees through corrective actions or employment evaluation. Due Date of Completion: June 30, 2026 Responsible Person(s) Office of Performance and Accountability Director

Recommendation The Department should strengthen controls over the retention and documentation of foster care records to ensure compliance with all applicable regulations. This includes ensuring all required documentation are properly collected, stored, and accessible for audits. Regular internal audits of foster care case files should be implemented to confirm compliance with internal controls and regulations. A system to track and follow up on outstanding documents will ensure timely collection of all required records. We also recommend that the files are stored electronically in one location, with appropriate access given to individuals. The Department should also review licensing processes for providers with disqualifying criminal histories and take corrective actions when necessary. Additionally, staff training on proper documentation and adherence to internal controls should be enhanced. Management Response Issue Missing and incomplete supporting documentation for Children placed in Children placed in Congregate Care Settings. Root Cause Lack of clear instruction or process. Direction and agreement on how to work with HCA and MCO to obtain needed documentation when a child is placed in a congregate setting. Corrective Action Create a supervisor checklist to ensure licensure documentation is complete and accurate. Supervisor will perform review at initial placement; checklist will include supervisor verification of complete and accurate placements agreements. Supervisors and Managers will address work performance with employees through corrective actions or employment evaluation. Work with CYFD Behavioral Health and NM Health Care Authority (HCA) to ensure CYFD has proper documentation for Medicaid licensed and approved congregate care facilities, to include certification of staff CRCs, licensure, and placement agreements. Issue a directive to CYFD licensing and placement staff that outlines the process for determining level of care, payment, placement agreements, and how this is documented for children in custody placed in all congregate care settings. The CYFD Office of Performance and Accountability in partnership with CYFD Protective Services Licensing and Support will incorporate annual Regional Placement Reviews into its annual case review schedule Issue Missing and incomplete placement agreements for children placed with foster families. Root Cause Lack of clear instruction or process. Need for more robust supervisory oversight. Corrective Action Create a supervisor checklist to ensure placement agreement documentation is complete and accurate. Supervisor will perform review at initial placement; checklist will include supervisor verification of complete and accurate placements agreements. Supervisors and Managers will address work performance with employees through corrective actions or employment evaluation. Provide FACTS Entry and Documentation Refresher training for all Licensing and Support Staff. The CYFD Office of Performance and Accountability in partnership with CYFD Protective Services Licensing and Support will incorporate annual Regional Placement Reviews into its annual case review schedule. Issue No documentation of Level of Care in hard file or entered into FACTS per agency procedures Root Cause Lack of clear instruction or process. Need for more robust supervisory oversight. Corrective Action Create a supervisor checklist to ensure level of care documentation is complete and accurate. Supervisor will perform review at initial placement; checklist will include supervisor verification of completed level of care documentation. Supervisors and Managers will address work performance with employees through corrective actions or employment evaluation. Provide FACTS Entry and Documentation Refresher training for all Placement and Licensing Staff. The CYFD Office of Performance and Accountability in partnership with CYFD Protective Services Licensing and Support will incorporate annual Regional Placement Reviews into its annual case review schedule. Issue Missing criminal records checks and no mitigation measures found. Root Cause Lack of clear instruction or process. Need for more robust supervisory oversight. Corrective Action Create a supervisor checklist to ensure criminal record check (CRC) documentation is complete and accurate. Supervisor will perform review at initial placement; checklist will include supervisor verification of completed CRC documentation. Supervisors and Managers will address work performance with employees through corrective actions or employment evaluation. Provide "cheat sheet" that outlines level of documentation needed to verify CRC’s have been completed for family foster homes, TFC homes, and congregate care settings. Provide guidance on when and how to mitigate criminal record checks histories, and how this is documented. Provide FACTS Entry and documentation refresher training for all Placement and Licensing Staff. The CYFD Office of Performance and Accountability in partnership with CYFD Protective Services Licensing and Support will incorporate annual Regional Placement Reviews into its annual case review schedule. Issue Missing Abuse and Neglect Checks Corrective Action Create a supervisor checklist to ensure abuse and neglect check documentation is complete and accurate. Supervisor will perform review at initial placement; checklist will include supervisor verification of completed Abuse and Neglect Check documentation. Supervisors and Managers will address work performance with employees through corrective actions or employment evaluation. Provide guidance on conducting abuse and neglect checks and documents that show checks are completed before a child is placed and in accordance with agency policy and procedure. Provide FACTS Entry and documentation refresher training for all Placement and Licensing Staff. The CYFD Office of Performance and Accountability in partnership with CYFD Protective Services Licensing and Support will incorporate annual Regional Placement Reviews into its annual case review schedule. Issue Missing Foster Care Licensure Corrective Action: Create a supervisor checklist to ensure licensure documentation is complete and accurate. Supervisor will perform review at initial placement; checklist will include supervisor verification of completed licensure documentation. The CYFD Office of Performance and Accountability New Mexico Children, Youth, and Families Department Reporting 30 in partnership with CYFD Protective Services Licensing and Support will incorporate annual Regional Placement Reviews into its annual case review schedule. Issue Missing Abuse and Neglect Petition and Ex-Parte Custody Orders Root Cause Need for more robust supervisory oversight in the Title IVE determination process. Corrective Action The Title IVE/Medicaid Manager will work with CYFD Children's Court Attorneys to ensure that Abuse and Neglect Petitions and Ex-parte Custody Orders are present when conducting initial and ongoing Title IVE determination. The CYFD Office of Performance and Accountability in partnership with CYFD Protective Services Licensing and Support will incorporate annual Regional Placement Reviews into its annual case review schedule. Due Date of Completion: June 30, 2026 Responsible Person(s) Protective Services Division Director, Behavioral Health Division Director, Director of Performance and Accountability, Policy Director

FINDING 2025-010 Name of Responsible Individual: Lisa Simon, CPA, CFO Corrective Action: The University acknowledges that the internal controls surrounding the allowable costs during fiscal year 2025 were lacking and needed to be reinforced for future fiscal years. With the hire of the new CFO and HR leader post June 30, 2025 – these enhanced controls and processes have been put in place, and all payroll and other expenses are detailed, supported, and filed appropriately. Anticipated Completion Date: Completed Fall 2025 and Ongoing

Starting in May 2024, the Alliance adapted its monthly Time and Effort Report that is reviewed by Kim Atkins, Executive Director, to be used for allocation of expenses other than payroll. This ensures a consistent, reviewed and authorized report is being used for expense allocation. This report is shared monthly with the Alliance’s funding agencies along with the submission of monthly vouchers for processing. During the year ended June 30, 2025, the Alliance has ensured that allocations were signed off on by Kim and has significantly reduced the amount of finance staff time required to process the allocation of administrative costs. The data from this monthly report is entered into NetSuite for allocation of administrative costs but subsequent review of the allocation program in NetSuite determined that the proper adjustment for adding new grants had not been built into the program. The Accounting Manager, Sarah Burgess, is currently working with NetSuite to fix this problem going forward. As of July 1, 2025 the Alliance is modifying all of its grants to adopt the 15% de minimis cost rate for all expenses other than personnel, direct program, and space costs.

2025-001: Other Matter – Allowable Costs/Cost principles Compliance (Department of Transportation Federal Assistance Listing No. 20.513 Enhanced Mobility of Seniors and Individuals with Disabilities program) Recommendation: Implement stronger internal controls over cost allocation and grant expense reviews, including: • Periodic reconciliation of depreciation schedules against federal funding sources. • Staff training on 2 CFR §200.436 requirements. • Pre-approval process for expenses charged to federal grants. Action Taken: The Organization agrees with the finding and have implemented procedures to ensure that the Organization’s is following allowable costs/cost principles compliance federal requirements.

Finding Number: 2025-001 Anticipated Completion Date: March 14, 2025 Responsible Contact Person: Stephen Thomas, CEO Planned Corrective Action: TASC of Southeast Ohio has reviewed all personnel files to ensure that all approved rates are included in the files. Internal controls surrounding the documentation of approvals of timesheets and pay raises have been implemented.

Contact Person: Business Manager and Human Resource Manager Planned Corrective Action: The District currently does have processes and controls in place to ensure grant expenditures have been approved. Specific to this audit finding of missing documentation in support of an employee’s approved hourly rate, the Business Manager will meet with the Human Resource Manager to review the current control and approval processes for employee contracts and salary authorization forms and make changes as appropriate. Planned Completion Date: Current and ongoing

2025-005 – Allowable Costs/Cost Principles: Lack of Time and Effort Report Certification and Lack of Timesheets Cluster: Not applicable Sponsoring Agency: United States Agency for International Development (USAID) Award Name: USAID Foreign Assistance for Programs Overseas Award Number: 7200AA19CA00018 Assistance Listing Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: ALN 98.001 Award Year: 2024-2025 Pass-through entity: Not applicable Compliance Requirement: Allowable Costs/Cost Principle The current process of annual effort certification is based on the federal fiscal year, with reports created in November and certification due on January 28. During testing, one out of forty reports was not certified. Monitoring of uncertified reports is performed year-round, monthly during the year and weekly during the certification period (mid-November through January). To address this, the campus will implement system and process improvements through the transition to a new effort reporting platform. The campus is currently in the process of changing effort reporting platforms, which will enhance monitoring and certification controls. The updated system will allow for more regular oversight from the PI as they will have access to a dashboard providing a year-round view of payroll expenditures on their projects, which is expected to improve oversight and timely certification. Implementation of the new effort reporting platform is expected to go live in September 2026. During field testing 14 hourly employee timesheets selected were not available. Timesheets are held at the department level, and due to the termination of USAID funding, administrative positions responsible for retrieving these timesheets were no longer available. Due to the unique circumstances surrounding the termination of the USAID awards, the central office was unable to retrieve reports as a result of the loss of departmental administrative staff. To address this, effective immediately the central office will request the archiving and accessibility of documents upon receiving termination notices. All other archiving will follow the University’s record retention policies as outlined in University policy. For inquiries regarding this finding, please contact Mario Reina-Guerra at mreinaguerra@ucdavis.edu.

Department: Health and Human Services Title: Internal control over Medicaid drug rebates needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. Drug Rebate pre-invoicing and post-invoicing is completed quarterly. As demonstrated during walkthroughs and during our meetings Maine completes specific tasks to ensure accuracy of the invoicing process. The pre-invoicing and post-invoicing procedures are documented in the Pharmacy Rebate Information Management System (PRIMS) Desk Level Procedure (DLP). The pre-invoicing work is performed by the State that compares drug utilization data to the number of dispensed units invoiced. Upon the completion of the pre-invoicing review approval is provided to the vendor allowing them to continue with the invoicing process. There is no requirement regarding how we select our sample of invoices to review. Based on OSA noting no exceptions to the drug rebate amounts, our system in place to review invoiced drug rebates is functioning as intended. Completion Date: N/A Agency Contact: Michelle Probert, Director, Office of MaineCare Services, DHHS, 207-287-2093

Department: Health and Human Services Title: Internal control over the Adoption Assistance eligibility and benefit determination process needs improvement Questioned Costs: Known: $1,645 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Office of Child and Family Services made changes to the Katahdin System in August 2025 to stop duplicate payments. The Office of Child and Family Services will develop training information regarding children in adoption assistance agreements who are no longer receiving support from the adoptive parents. The Office of Child and Family Services will develop a training and train the appropriate staff. Completion Date: August 1, 2025, May 1, 2026, and December 31, 2026, respectively Agency Contact: Denise Merrill, Manager of Child Welfare Statewide Programs, DHHS, 207-822-2255

Department: Health and Human Services Title: Internal control over the Foster Care and Adoption Assistance eligibility and benefit determination process needs improvement Questioned Costs: Known: Known: ALN 93.658 $51,247 ALN 93.659 $42,689 Likely: undeterminable Status: Corrective action complete Corrective Action: The Department made changes to the OCFS licensing policy. The Department updated the Katahdin system (User story 3002158) to avoid overlapping payments for childcare in both Foster Care and Adoption. Completion Date: July 31, 2056, and August 3, 2025 Agency Contact: Robert Blanchard, Associate Director, OCFS, DHHS, 207-624-7955

Department: Health and Human Services Administrative and Financial Services Judicial Branch Title: Internal control over Child Support Services expenditures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS and the Maine Judicial Branch will update the Cooperative Agreement to strengthen policies, procedures, and oversight in order to ensure that expenditures are based on actual costs. Completion Date: March 31, 2026 Agency Contact: Jerry Joy, Director, Division of Support Enforcement and Recovery, DHHS, 207- 624-6985

Department: Health and Human Services Title: Internal control over TANF work verification plan procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review and update ACF199/209 system processes within OFI and the ASPIRE Contractor to enhance existing procedures to ensure that information reported on the ACF-199/209 is accurate and complete prior to submission to the Federal government. This will include modifying existing SOP as necessary. The Department will enhance existing procedures and follow-up processes of the ACRT reviews to ensure that the reviews include information regarding the date the review was conducted and the dates on which any outstanding issues are resolved. The Department will review the Work Verification Plan to identify opportunities to improve the processes created to accurately record and report on work participation data. Completion Date: June 30, 2026 Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207-592-1481

Department: Health and Human Services Title: Internal control over TANF client payments needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review and update standard operating procedures to ensure that support payments made to and on behalf of TANF clients are accurate, allowable and adequately documented. Completion Date: June 30, 2026 Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207-592-1481

Department: Health and Human Services Education Title: Internal control over PDG subrecipient monitoring procedures needs improvement Questioned Costs: Known: $128,333 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The OCFS procurement staff and DHHS DCM will ensure that all contracts issued by OCFS include the Federal award identification number or the grant award number, as applicable. The DOE procurement staff will ensure that all contracts issued by DO include the Federal award identification number, the Federal award date, the assistance listing title and number, the indirect cost rate for the Federal award, name of Federal agency, assistance listing title and number, identification of whether the Federal award is for research and development, and the indirect cost rate for the federal award. Completion Date: March 31, 2026 Agency Contact: Tara Williams, Associate Director of Early Care & Education, DHHS, 207-557-2342

Department: Health and Human Services Title: Internal control over Health Disparities program payments to subrecipients needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The conditions noted do not support that costs were unallowable. Furthermore, the Department demonstrated that the funds had been used in accordance with the terms and conditions of the award. The Department’s processes provide reasonable assurance that payments are appropriate. Completion Date: N/A Agency Contact: Eden Hale, Associate Director, Division of Population Health Equity, Maine CDC, 207-441-1090

Department: Defense, Veterans and Emergency Management Administrative and Financial Services Title: Internal control over National Guard payroll costs needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: Defense, Veterans and Emergency Management (DVEM): The Department identified "agency heads" for the positions identified in the audit. The Department communicated to "agency heads" regarding the requirement to sign forms. Department of Administrative and Financial Services (DAFS): The Department will update the PMF guidance as part of ongoing modernization efforts. The Department will educate HR Staff in reviewing completed PMFs to ensure they are fully completed before processing. Completion Date: DVEM: March 2026 DAFS: August 1, 2026, and October 1, 2026, respectively Agency Contact: DVEM: Michelle Lenihan, Deputy Commissioner, DVEM, 207- 430-5997 DAFS: Michael J. Dunn, Esq., Acting State Human Resources Officer, BHR, 207- 215-2951

Department: Health and Human Services Title: Internal control over Summer EBT eligibility needs improvement Questioned Costs: Known; $1,680 Likely: Undeterminable Status: Corrective action complete Corrective Action: Documentation and Records Retention: The Department replaced manual notification with automation through the statewide database. Database generated letters are both retained appropriately and easily retrievable for individual clients. Inaccurate certifications through database errors: Database cleanup and streamline certification logic updates were necessary to resolve inaccurate certifications. This process was completed prior to issuance for summer of 2025. Completion Date: May 1, 2025 Agency Contact: Evan Denno, Program Manager – SNAP, DHHS, 207-446-3201

Department: Education Title: Internal control over CNC subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review and monitor the tracking spreadsheet monthly. The Department will hold monthly meetings to ensure CNP web questions and tools are completed, and documents are saved in the appropriate location. The Department will conduct training with NSLP reviewers on expectations for saving documentation Conduct training with NSLP reviewers on how to answer SFSP procurement questions for schools. The Department will update the Special Provision 2 base year review and validation procedure to include where to save documents and show the completion in CNP web. The Special Provision 2 base year reviews will be included in Step 2, starting SFY 2027. Completion Date: May 1, 2026 (first to third items), June 15, 2026 (fourth item), June 30, 2026 (fifth item), and October 30, 2026 (sixth item) Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: Known: ALN 10.559 $61,336 ALN 10.582 $12,215 Likely: ALN 10.559 undeterminable ALN 10.582 undeterminable Status: Corrective action in progress Corrective Action: The Department will create a business requirements document for the SFSP site sheet and claims camp/closed enrolled eligibility edit checks. The non-congregate application now requires sponsors’ to have a written procedure to address site proximity, this is captured in an offline form in the checklist document. The Department submitted a ticket to update the FNS report so it will collect the data needed. For the FFVP, a tracking procedure is in place for SFY 2026 to stay within the $50-75/student rate. A spreadsheet is being used to track this information and has been implemented. Completion Date: March 4, 2026 (first item), June 30, 2025 (second and fourth items), and March 19, 2025 (third item) Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC eligibility needs improvement Questioned Costs: Known: ALN 10.555 $73,683 ALN 10.559 $226,773 Likely: ALN 10.555 undeterminable ALN 10.559 undeterminable Status: Corrective action in progress Corrective Action: The Department will create a business requirements document for the SFSP site sheet and claims camp/closed enrolled eligibility edit checks. The Department will create a user guide to approve the site info sheet and apps to address oversite errors with the approval process. A financial eligibility edit check in the software will be implemented for program year 2026. A policy statement for non-congregate was a required document with an edit check in program year 2025. Completion Date: March 2, 2026, April 30, 2026, April 15, 2026, and May 1, 2025, respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880