Corrective Action Plans

Completion Date: September 30, 2026

Sincerely, Tony Bersano, Controller, Marshall Municipal Utilities

Finding 2025-002: Significant Deficiency in Internal Control over Compliance – Allowable Costs Corrective Action Plan: With the implementation of the new UKG Payroll system in January 2026, the timesheet process now systematically reflects the ability for individuals to track time spent on individual grants when completing their timesheet. Name of Person Responsible for the Corrective Action Plan: Francene LaPoint, Chief Financial Officer and Brandon Wheatly, University Controller Anticipated Completion Date: January 30, 2026

Grant Funds Spent After Award Ended The Division will complete the following corrective actions: •Continue cross-divisional meetings to strengthen grant oversight and fiscal monitoring. •Complete targeted training to support consistent application of requirements. •Update policies and procedures to reinforce verification that expenditures are incurred within the approved grant period and are supported by appropriate documentation prior to approval and payment. Anticipated Completion Date: June 30, 2026.

Congressionally Directed Spending – 93.493 Recommendation: We recommend that the University reviews its procedures around review and approval of expenditures to ensure that only valid expenditures are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The identified expenditures were removed from the award and appropriately reclassified in September 2025. In response to this finding, the University of Maine at Augusta (UMA) has increased the frequency of general ledger review for its federal awards from monthly to twice monthly. This review process includes a direct cross-reference between transactions and the approved award budget. This enhanced oversight allows for timely identification and correction of discrepancies. The UMA Finance Department has several initiatives underway which will mitigate the risk of similar mispostings in the future, including the implementation of a formal training program for staff as a preventative control. A monthly reconciliation and transaction level review process which will be completed with principal investigators is also being developed. These additional procedures are expected to be in place by May 2026 and will support a consistent and strong awareness of federal compliance requirements, award administration and University of Maine System policies and procedures. Name(s) of the contact person(s) responsible for corrective action: Mark Mantey, Assistant Director of Finance, University of Maine at Augusta Planned completion date for corrective action plan: May 2026 If the United States Department of Education or other agency has questions regarding this plan, please call Darla Reynolds at 207-262-7743 or darlab@maine.edu.

Findings 2025-001 Condition: The School’s procurement files did not contain documentation regarding competitive procurement procedures for four contracts. Corrective Action Planned: ● Create/Revise manuals for procurement Policies, Procedures, and Internal Controls. ● Train procurement staff of the District including, but not limited to, the entire business office, the Grant Administrator, and all Grant Managers of the District’s created/revised Policies, Procedures, and Internal Controls manuals. ● Review current FY26 procurement on federal grants and ensure compliance. ● Transfer expenses off of the federal grants that were not compliant with federal procurement regulations. Amend the grants where appropriate. ● Continuously train staff on procedures and maintain internal controls. Anticipated Completion Date: June 1, 2026 Contact: Christopher R. Schweitzer Assistant Superintendent of Finance and Operations cschweitzer@arlington.k12.ma.us 781-879-9069

Corrective Action Plan: The Department agrees with the finding and already has a plan underway to resolve the issues. ODM has been working with the Ohio Medicaid Enterprise System Fiscal Intermediary (FI) vendor to document the Third Party Liability (TPL) process and identify needed system updates, including importing electronic historical evidence into the FI module and creating new system panels that make TPL information easier for staff to view and work with. Thirteen TPL-related system updates have been identified; eight are already in progress and nearly complete. Once these updates are finished, TPL data including archived historical information will be accessible directly in FI in a familiar format. The Centers for Medicare and Medicaid Services requires states to use commercial off-the-shelf (COTS) products and rely on default tools whenever possible. The FI system initially lacked a data structure that could store all historical TPL information in an accessible way. Because the COTS system does not use the same tracking fields as the prior system, some historical evidence such as Document Control Numbers (DCNs) or supporting insurance documentation could not be viewed in FI during the audit period. ODM is adding new panels and data fields so this historical information can be accessed more easily going forward. TPL is complex, and due to the FI system limitations, monitoring is currently a manual process. The ODM TPL Unit Manager continues to review a sample of verifications to ensure insurance information is accurate and correctly captured in FI. The manager maintains a spreadsheet documenting TPL activity, with all relevant recipient information except the DCN (which is not available in FI). The TPL Unit manually removes or end dates TPL coverage in FI and sends a file to the vendor each week to add TPL information to the Other External Enrollment panel. The Department will take necessary steps to ensure all relevant data elements and documentation are maintained and accessible when major system upgrades or replacements occur, including appropriate retention of historical data. Anticipated Completion Date for Corrective Action: July 2026 Contact Person Responsible for Corrective Action: Name: Megan Powell Title: Audit Remediation Manager Address: 50 West Town Street, Suite 400, Columbus, Ohio 43215 Phone Number: 614-752-3844 E-Mail Address: megan.powell@medicaid.ohio.gov

Corrective Action Plan: Medicaid and CHIP Eligibility The Ohio Department of Medicaid (ODM) agrees that accurate and timely eligibility determinations are essential to the integrity of the Medicaid program. Medicaid eligibility rules are complex. During the audit, AOS Auditors submit questions about sampled cases to county departments (CDJFS) and to ODM for review. For future audits, the Department and the Auditor have agreed to meet before the audit concludes to review potential eligibility issues and ensure both teams understand the actions taken on each case. The Department does not agree with the finding that one of the sampled Medicaid recipients was improperly enrolled. In this case, the county agency did not receive reliable information about the individual’s income until October 2024—after the date the services were provided. The CDJFS discontinued services promptly once the information was reported. Under 42 CFR § 435.919, agencies must redetermine eligibility when they receive reliable information that may affect eligibility. Therefore, the individual was validly enrolled at the time services were received. The Department also disagrees with one CHIP-related finding where a child was placed in an incorrect aid category. The child was enrolled in the CHIP 1 category, while Auditors found the child was eligible for CHIP 2. Both categories provide the same federal match rate and the same benefits. The child remained eligible for Ohio’s CHIP program regardless of category. The administrative issues noted above are technical inaccuracies that require correction; however, they do not mean the individuals were ineligible for Medicaid. For example, if a CDJFS fails to upload employment documents into Ohio Benefits, this is a procedural error. If the person’s income still meets the program requirements, they remain eligible. It is important to emphasize that errors in documentation or processing do not necessarily mean ineligible individuals received benefits. Dates of Death and Ohio Medicaid The Department agrees with the Auditor’s concern about services being billed after an individual’s date of death. However, a portion of the 13,159 payments cited—totaling $2.5 million and covering 2,165 deceased individuals—were either allowable under policy or have already been recouped. For example, monthly rental charges for durable medical equipment (DME) may be billed after the date of death if the equipment was delivered earlier. Under OAC 5160-10-01(C)(16)(e), a monthly rental payment covers the entire month. If the Auditor’s sample reflects the larger population, roughly two-thirds of the payments identified were appropriate. Presenting the full $2.5 million without this context may be misleading to readers unfamiliar with common billing practices and applicable rules. The Department has been actively addressing the issues that lead to improper payments after the date of death throughout SFY 2025. The Department updated its use of death certificate data from the Ohio Department of Health (ODH), which required a revised data-use agreement and new automation. The updated interagency agreement took effect May 6, 2025, and a bot was deployed on July 25, 2025 to automatically verify dates of death and discontinue Medicaid coverage. This change shifts work away from county caseworkers, reduces system alerts, and prevents additional payments. The average delay between date of death and this automated update is now 57 days, compared to an average 142-day delay when relying on the federal master death file. This new approach both reduces workload and speeds up eligibility updates. The Department is also testing a process to automatically identify and recover fee-for-service (FFS) claims paid after the verified date of death. Providers will be notified of these claims so they can be reprocessed or recouped. While automation is being developed, ODM is also implementing a manual process to ensure recovery moves forward. Managed care capitation payments are already automatically recouped and are not part of this process. During the SFY 2025 audit, the Auditor did not identify any managed care capitation payments made for months after an individual's death, indicating that the corrective actions implemented are effective. For point-of-sale pharmacy claims, the Single Pharmacy Benefit Manager (SPBM) has implemented a review process to identify claims paid more than one day after a member's date of death. As of July 1, 2025, these claims are being reversed and recouped. Many such claims were the result of automatic prescription refills. To address this, ODM and the SPBM issued a memo to all Medicaid pharmacy providers on March 24, 2025, reminding them that automatic refills are not permitted for Ohio Medicaid members. Refills must be initiated by a prescriber, member, or authorized agent. Claims found to be automatic refills may be subject to recoupment. The Department will continue to verify recipient eligibility, ensure information in Ohio Benefits is accurate, and confirm that eligibility decisions are fully supported and completed on time. The Department’s Medicaid Eligibility Quality Control (MEQC) team conducts ongoing reviews of approved, denied, and discontinued cases to ensure accuracy. When the MEQC team identifies an error or technical issue, the responsible party must provide a root-cause analysis and corrective action plan. MEQC also partners with the Department’s County Technical Assistance and County Engagement teams to ensure training addresses recurring issues. The Department agrees with the Auditor’s recommendation to continue working with state and county agencies to strengthen processes, procedures, and system programming related to eligibility, including improvements to the Ohio Benefits system. The department meets with the Department of Job and Family Services and the Department of Children and Youth regularly to discuss policy changes, assess impacts, and identify alignment opportunities. All agencies also participate in system meetings to review issues, plan enhancements, and ensure updates do not negatively affect other programs. The Department will pursue full reimbursement of all claims improperly paid for services after an individual’s date of death. FFS claims have been referred to the Bureau of Program Integrity’s Surveillance Utilization Review Section (SURS) for review and recoupment. SPBM pharmacy claims will be reviewed and recouped through the established SPBM process. Anticipated Completion Date for Corrective Action: December 2026 Contact Person Responsible for Corrective Action: Name: Megan Powell Title: Audit Remediation Manager Address: 50 West Town Street, Suite 400, Columbus, Ohio 43215 Phone Number: 614-752-3844 E-Mail Address: megan.powell@medicaid.ohio.gov

Corrective Action Plan: The Department will evaluate its current policies and procedures relating to the processing of expenditure transactions and update them, as necessary, to reasonably ensure compliance with period of performance requirements. Anticipated Completion Date for Corrective Action: June 2026 Contact Person Responsible for Corrective Action: Name: Daniel Schreiber Title: Deputy Chief, Budget Address: 77 South High Street, 27th Fl, Columbus, Ohio 43215 Phone Number: 614-466-2209 E-Mail Address: daniel.schreiber@development.ohio.gov

Corrective Action Plan: Ohio EPA respectfully disagrees with the finding because as of May 2025, internal policies were followed as intended and appropriate controls were in place. Internal testing shows that over 80% of all disbursement vouchers received in 2025 were reviewed within 45 days. Moving forward, Ohio EPA will evaluate the payment review and monitoring procedure to ensure documentation clearly demonstrates compliance with review requirements. As appropriate, procedures will be updated to align written guidance with current operational practices. Anticipated Completion Date for Corrective Action: March 2026 Contact Person Responsible for Corrective Action: Name: Craig Rethman Title: Chief Financial Officer Address: 50 W. Town Street, Suite 700, Columbus, Ohio 43215 Phone Number: 614-644-2892 E-Mail Address: craig.rethman@epa.ohio.gov

Corrective Action Plan: For Benefits Adjudication: Standard procedures for verifying claimant eligibility for unemployment benefits remain in place. Adjudication staff have been reminded to double-check start dates and eligibility documentation to prevent the recurrence of similar errors. For Benefit Payment Control (BPC): The Department remains committed to strengthening accountability and proactively identifying any potential training gaps within the team. To support this effort, the Department has recently implemented monthly random case reviews conducted by supervisors, followed by individualized email feedback to staff to reinforce expectations and provide timely coaching. Additionally, supervisors are now required to track all audits and document follow up actions to ensure consistent monitoring and early identification of any emerging trends. These measures are intended to enhance quality assurance, support staff development, and maintain the high standards expected within the Department. Anticipated Completion Date for Corrective Action: Completed February 2026 Contact Person Responsible for Corrective Action: For Benefits Adjudication: Name: Traci A. Brown Title: Assistant Deputy Director - Benefits Adjudication Address: 30 East Board Street, Columbus, Ohio 43215 Phone Number: 614-387-3647 E-Mail Address: Traci.Brown@jfs.ohio.gov For Benefit Payment Control (BPC): Name: BJ Knutson-Cruset Title: Bureau Chief Address: 6680 Poe Ave, Dayton, Ohio 45414 Phone Number: 937-264-5742 E-Mail Address: bj.knutson-cruset@jfs.ohio.gov

CSLRF Reporting - Revenue Replacement Recommendation: We recommend that the Town enhance its internal controls over CSLRF reporting to ensure that amounts reported as revenue replacement are accurately identified, supported, and reconciled to the underlying accounting records prior to submission of required federal reports. This should include implementing a formal reconciliation 9rocess between the general ledger and CSLRF reporting schedules, along with documented review and approval procedures to ensure accuracy and proper classification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding and will strengthen internal controls over CSLRF reporting related to revenue replacement. The Town will implement a formal reconciliation process between the general ledger and CSLRF reporting schedules prior to submission of required federal reports. This process will include documented review and approval procedures to ensure that expenditures designated as revenue replacement are accurately identified, properly classified, allowable, and supported by underlying accounting records. Management will also perform periodic monitoring to ensure that these controls are consistently applied and operating as designed. Name of the contact person responsible for corrective action: Tyler Home. Director of Finance. Planned completion date for corrective action plan: March 3 I . 2026

Corrective Action Plan Organization: Challenger Leaning Center of Maine Federal Program: Congressionally Directed Program ALN: 43.014 Fiscal Year End: 06/30/2025 Finding Reference: 2025-001 The Challenger Learning Center of Maine Board of Directors acknowledges the finding related to the absence of written policies and procedures specific to federal awards as required by 2 CFR 200, Subparts D and E. While no noncompliance or questioned costs were identified in connection with this finding, Challenger recognizes that the lack of formal written policies and procedures increases the risk of future noncompliance. To address this finding, Challenger will develop, formalize, and implement comprehensive written policies and procedures governing the administration of federal awards. These policies will align with applicable requirements under 2 CFR 200 and will include, but not be limited to, the following areas: procurement process and standards of conduct and conflict-of-interest provisions. Challenger will obtain the approval of the Board and will communicate the policies and procedures to the relevant personnel. Documentation of training attendance and materials will be maintained. Challenger will also establish a process for ongoing monitoring and periodic review of compliance with the policies and procedures. Policies will be reviewed at least annually and updated as needed. The Executive Director will be responsible for overseeing the development, implementation, and ongoing monitoring of this corrective action. Responsible Official: Kirsten Hibbard, Executive Director, khibbard@astronaut.org, 207-990-2900 Date of anticipated completion of corrective action plan: June 30, 2026

March 25, 2026 Finding Number: 2025-002 Finding: (Significant Deficiency) AL#84.048: Career and Technical Education Basis Grants to States, U.S. Department of Education, Award No. V048A240016, Passed through the Kansas State Board of Education Contact Person: Taben Azad, Director, Budgeting Planned Corrective Action: The District acknowledges the finding. The Budget Department will implement a training process for all internal budget analysts as well as Career and Technical Education (CTE) program managers and business office staff on the requirements of 2 CFR 200.308 and 200.309, focusing on the “Period of Performance” and allowable cost principles. Additionally, the Budget Department will establish both a quarterly and year-end reconciliation process where the CTE assigned budget analyst will compare all expenditures against the authorized period of performance dates listed in the Perkins V Local Grant Handbook and specific grant award terms. Anticipated Completion Date: These processes will be implemented immediately.

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Ann Higgins and Dr. Amy K. Sivley Contact Phone Number and Email Address: 2 260-563-8871, higginsa@msdwc.k12.in.us; 60-563- 2151, sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: The following procedure has been put into practice effective March 1, 2024: 1. A proportionate Share Working Spreadsheet was developed and is distributed annually to service providers working with non-pub students. 2. Service providers document the following information for each corporation: Student name, Date of service, Time of Service, Number of hours, Type of Service, and any other required information. 3. Documentation is reviewed monthly. 4. Reimbursement for non-pub services is requested when reimbursement amounts reach $1,000.00 or annually, whichever comes first. Superintendent/CFO will attend monthly co-op meeting and request documentation that corrective action plan is being followed. Anticipated Completion Date: Upon approval, this corrective action plan item is completed.

Finding #2025-002 - Wage Allocations Criteria: Wages should be allocated to federal and state programs on the basis of time spent in each program. Condition: 1 out of 40 payroll transactions reviewed had differences between the wages that were charged to the grant and the wages that should have been charged to the grant based on the number of hours worked. Questioned Costs: $1,540. Cause: Payroll software coded manager time as admin time instead of the specific grant funding code. Effect: Wages could be charged to the wrong federal awards and not detected and corrected. Recommendation: We recommend that management review payroll software inputs and outputs for accuracy prior to completing grant claims. Response: HALO's management concurs with this finding. HALO's processes will include a review of payroll software inputs and outputs to ensure hours and wages are accurately allocated. Contact Person: Yvonne MacDonald Hames Anticipated Completion: June 30, 2026

Finding 2025-003, Timesheet - Timekeeping (Assistance Listing 16.575 and 93.958) Persons Responsible: Irene Math, Chief Financial Officer; Shannon Van loon, Chief Operating Officer Comment: Per 2 CFR § 200.430 requires that the distribution of salary and wages charged to federal awards be based on actual employee activity as reflected in personal activity reports (timesheets), prepared after-the-fact, that include the total activity for which employees were compensated. Response: In January 2025, WJCS implemented an automated time and attendance system for staff to track time which integrates with the payroll and financial systems to ensure appropriate allocations to Federal awards. Prior to implementation of the new system weekly manual timesheets were used to track staff time and attendance on Federal contracts. However, these manual timesheets were not integrated into a standard agency-wide payroll processing system. The new system enhancements to payroll tracking will allow WJCS to completely and accurately allocate payroll costs to grants with fewer mechanical steps which increase the risk of miscalculations. Management will continue to monitor the automated timekeeping system through periodic supervisory reviews and payroll-to-grant allocation reconciliations to ensure ongoing compliance with 2 CFR §200.430. Estimated Completion Date: The agency-wide time and attendance system was implemented in January 2025.

Finding 2025{D2, Accuracy of the SEFA Persons Responsible: lrene Math, Chief Financial Officer; Jack Babwah, Director of Revenue and Reimbursement Comment: The Uniform Guidance requires that the auditee prepare a SEFA for the period covered by the auditee's financial statements. The SEFA included 100% of expenditures for each grant, even if the grant was not 100% federally funded. Proper identification of federal funds and their related allocations is critical to ensure compliance with federal requirements and accurate reporting. Management subsequently reviewed the funding allocations and revised the SEFA during the audit to properly reflect only the federally funded portion of expenditures. The final SEFA included in the financial statements reflects these corrections. Response: Management acknowledges the importance of accurately reporting only the federal portion of grant expenditures in the SEFA. To address this, management is implementing enhanced procedures. During the current year, a master grants listing was developed to strengthen the grants onboarding process. As part of this process, the team will determine the federal funding details at the outset of each award, when not clearly specified in the contract, and will proactively contact funders to obtain the Assistance Listing Number (ALN)/Catalog of Federal Domestic Assistance (CFDA) number and related information. In addition, federal funding allocation percentages will be appropriately identified, calculated and reported on the SEFA. These actions are expected to improve accuracy and compliance with federal requirements. Estimated Completion Date: The additional review procedures will be implemented by the June 30, 2026 financial statement close process.

Finding 2025‐001: Contact Person NAME: Julia Delgado PHONE: (503) 280-2600 E-Mail: jdelgado@ulpdx.org Explanation and Specific Reasons for Disagreement with the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned The Urban League of Portland is committed to an environment of continuous improvement. Further training shall be provided to Program Managers regarding the organizations’ documented internal controls and the importance of adhering to the established approval process. Urban League has currently hired a seasoned Controller and is in the process of hiring an experienced Accounting Manager. Tracking expiring grants more thoroughly and having further reviews in place to assure transactions are recorded within the grant’s agreed upon period of performance shall provide confidence expenses are recorded properly. Anticipated Completion Date May 1, 2024

Views of Responsible Official: Management notes that the Federal Payment Management System (PMS) automatically tracks when different users enter information such as submitting and certifying/approving draw-down amounts. During the time of the grant there were periods when only one staff member had access to PMS due to technical issues and delays in adding new users. To ensure there is back-up documentation of the approval workflow, we will institute a form to capture the individual signatures of the preparer and submitter of each draw down as additional evidence of multiple people connected to the process.

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

The Board of County Commissioners will work toward assessing and identifying risks to design written county-wide controls.

City of Marshall, Missouri respectfully submits the following Corrective Action Plan for the year ended September 30, 2025. Contact information for the individual responsible for the corrective action: Aimee Klinge, Finance Officer City of Marshall, Missouri Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended September 30, 2025 The findings from the September 30, 2025, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Significant Deficiency 2025-002 Uniform Guidance Audit Submission Recommendation: The City should submit its single audit reporting package to the federal audit clearinghouse no later than 9 months after fiscal year-end. Action Taken: The City will ensure their single audit submission will be submitted within the nine month deadline in the future.

Completion Date: September 30, 2026

Sincerely, Aimee Klinge, Finance Officer City of Marshall, Missouri