Corrective Action Plans

The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. A. Current Findings on the Schedule of Findings and Recommendations 1. Finding 2025-001 - Residual receipts deposits not made timely - Significant Deficiency Federal Program Name: Project-Based Rental Assistance - Section 8 Project Based Cluster Assistance Listing Number: 14.195 Federal Award Identfication Number and Year: MA06T831033-25Z, MA06T791016-25Z. Program year - 2025. a. Issue: During the year ended June 30, 2025, management did not make the required residual receipts reserve deposit in the amount of $34,811, within 90 days of June 30, 2024 as required by HUD. The residual receipts amount was deposited in October 2025. b. Recommendation: Management should establish internal controls and procedures to ensure that required residual receipts reserve deposits are made timely. c. Action taken: Management agrees with the finding and has implemented controls to ensure the residual receipts deposits are timely made within 90 days of year end. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Audit Findings, Questioned Costs and Recommendations No prior year audit findings identified.

The School District should always reconcile its reimbursement requests with documented workpapers. The School Business Administrator will prepare and retain documentation for each and every reimbursements request, etc. School Business Administrator / Asst. School Business Administrator. 2025-2026 Fiscal year.

The grant employee that was hired in this last fiscal year resigned and there was a period that it was handled by the county manager. The county has since contracted with an outside agency to handle the grants far Catron County.

Audit Finding Number: 2025-001 – Cash Management Agency: Public Housing Capital Fund Responsible Person, Title: Stephanie Schmutzer, Accountant Completion date: 7/1/2025 Agency Response: Concur Corrective Action Plan: Management concurs with the recommendation to implement timely LOCCS fundings that coincides with our normal accounting cycle when receiving Capital Funds in the future.

Corrective Action Plan FYE 6/30/2025 Audit Finding # 2025-0001 – Cash Management The Housing Authority of the City of Prichard acknowledges the audit finding regarding interfund balances and accepts responsibility for implementing corrective actions to strengthen internal controls and ensure long-term financial sustainability. At the onset of the fiscal year, management recognized the need to reduce expenses and thus implemented an expense reduction strategy. In reviewing the overall operating expenses for the agency, comparing FYE 2025 to FYE 2024, overall operating expenses declined by approximately $1M, supporting management's goal to reaching a more sustainable long term financial strategy. To further this initiative and continue improving the cash flow position, management will pursue ongoing expense reductions and financial planning strategies to ensure long-term financial sustainability for the agency. This will be accomplished by implementing the following strategies: 1. Engage site management, maintenance, finance, and executive leadership in comprehensive reviews of approved budgets and financial statements to strengthen fiscal oversight and identify additional cost-reduction opportunities. 2. Executive management will review and approve specific categories of expenses to promote accountability, fiscal responsibility, and effective cost control. 3. Continue with enhancement of the agency's home ownership program, providing increased cash flows for operations and improved financial sustainability. 4. Evaluation measures will continue in which intercompany account balances will be reviewed on a monthly basis, determining which entities can support an intercompany reimbursement to the lending property. Upon determining entities with available cash flows, reimbursements will be processed. 5. Continue the agency's initiatives to increase revenues through transition of properties to other revenue streams that would provide more flexibility in establishing an increased rent structure (i.e. PBVs, market rate rents, etc.) As cash flow conditions improve, management will develop and implement a repayment plan to address intercompany balances, recognizing this as a long-term initiative critical to the Agency’s financial sustainability.

Issue: The reconciled grant balance for all grant accounts is not compared against the total compostion of all grant accounts maintained in the general ledger's individual grant funds. Corrective Action: Staff will compare all grant account reconciliations agains the total composition of all accounts maintained within the general ledger's indvidual grant funds. Confusion occured this year with a review from NFWF of unallowed expenses that were booked as receivables in a previous fiscal year.

Management agrees with the findings and recommendations, this finding has been resolved.

Management agrees with the findings and recommendation is working with ownership on reimbursement to property. Management will gain prior approval for replacement reserve withdraw in accordance with HUD going forward.

Management agrees with the findings and recommendations and has implemented reviews of the financial statements by senior management prior to approving transfers to ensure accuracy of information.

Management agrees with the finding and is working with ownership on reimbursement to the property. Management will collect in accordance with HUD going forward.

Management agrees with the findings and recommendations, however due to insufficient funds at the property, we will collaborate with HUD to secure appropriate funding.

Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and Neglected Audit Finding Reference: 2025-001 ________________________________________ 1. Finding Summary The Single Audit identified a deficiency in the documentation and communication of federally funded position percentages and the alignment of Time & Effort attestations with the actual period of work performed. Specifically, the current CPS Federal Funds platform (Oracle) generates Time & Effort Attestation reports based on the month reimbursement claims are submitted, rather than the period during which the work was performed, creating a compliance gap. ________________________________________ 2. Root Cause ● Staff were not consistently informed of the exact percentage of their position funded by federal sources at the start of each semester. ● Time & Effort attestations were generated from the CPS Oracle system based on claim submission timing, not the actual work period. ● There was no formal internal SOP layer to supplement Oracle-generated reports with staff attestation aligned to Semester 1 and Semester 2 work periods. ________________________________________ 3. Corrective Actions Action 1: Internal Funding Percentage Notification System Description: PIE-IL will implement an internal tracking and notification system to ensure all staff funded in whole or in part with federal funds are formally notified of the exact percentage of their position supported by federal funding. Implementation Steps: ● Develop a standardized Federal Funding Allocation Notice template. ● Distribute notices to all applicable staff at the start of Semester 1 and Semester 2. ● Require staff acknowledgment (electronic or signed) confirming receipt and understanding. ● Maintain records centrally in the federal compliance folder. Responsible Party: Manager of Instructional Compliance Timeline: Implemented by the first day of each semester Monitoring: Semester-based review of acknowledgment logs ________________________________________ Action 2: Semester-Based Time & Effort Attestation Description: All federally funded staff will complete and sign a Time & Effort Attestation for both Semester 1 and Semester 2, certifying that time worked aligns with the funding source and percentage assigned. Implementation Steps: ● Issue Time & Effort forms at the end of each semester. ● Require staff to certify actual work performed during the semester. ● Collect supervisor verification signatures. ● Store completed attestations in the federal compliance repository. Responsible Party: Site Administrators / Federal Compliance Officer Timeline: Within 10 business days of semester end Monitoring: Quarterly internal compliance audits ________________________________________ Action 3: Internal SOP as Supplemental Documentation Layer Description: PIE-IL will implement a formal Standard Operating Procedure (SOP) for Time & Effort as a self-managed, internal documentation layer that supplements CPS Oracle-generated attestation reports. This SOP will ensure that Time & Effort documentation reflects the actual period of work performed, rather than the month in which reimbursement claims are submitted. Implementation Steps: ● Draft and approve a written SOP outlining: ○ Semester-based attestation requirements ○ Alignment between funding percentages and staff assignments ○ Reconciliation process between internal records and Oracle reports ● Train administrators and federally funded staff on SOP procedures. ● Maintain SOP as a controlled document with annual review and updates. Responsible Party: Federal Programs Director / Compliance Manager Timeline: SOP finalized within 30 days of audit response submission Monitoring: Annual SOP review and internal compliance testing ________________________________________ 4. Reconciliation Process with CPS Oracle System PIE-IL will perform a monthly reconciliation between: ● Oracle-generated Time & Effort Attestation reports (claim-based), and ● Internal Semester-Based Time & Effort attestations (work-period-based). Any discrepancies will be documented, corrected, and reviewed by the Federal Compliance Officer prior to reimbursement submission. ________________________________________ 5. Evidence of Implementation The following documentation will be maintained for audit and monitoring purposes: ● Federal Funding Allocation Notices with staff acknowledgments ● Signed Semester 1 and Semester 2 Time & Effort Attestation forms ● Approved Time & Effort SOP document ● Training sign-in sheets and materials ● Monthly reconciliation logs between Oracle and internal records ________________________________________ 6. Completion Dates Corrective Action Target Completion Date Funding Percentage Notification System [9/30/2026] Semester-Based Time & Effort Attestation Process [02/06/2026] SOP Finalization and Staff Training [02/28/2026] Monthly Reconciliation Process Ongoing ________________________________________

The Academies will implement a monitoring system to ensure there are no clerical errors recording data in the system.

The City concurs with the finding. Audit testing identified no reporting errors, no noncompliance, and no questions costs; however, the City acknowledges that documentation of independent supervisory review was not formally required or retained prior to submission of federal reports and reimbursement requests. To strengthen documentation of internal control over compliance, the City will implement a formalized and documented secondary review process for all federal financial reports, performance reports, and reimbursement requests, to be retained in grant files in accordance with CFR §200.334 record retention requirements.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.559 2025-002 Internal Control Over Compliance with Allowable Activities Requirements Finding Summary 7 CFR § 210.8 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program allowable activities, including meal count requirements applicable to child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls over meals counts submitted for afterschool snack reimbursement claims. For two months tested, the District’s internal tracking records for afterschool snacks served did not agree to the meal counts submitted to the Minnesota Department of Education (MDE) for reimbursement. In both cases, the internal records had been altered after the meal counts submissions to the MDE had been completed to add eligible afterschool snacks that had been missed. This resulted in underclaimed meals for eligible snacks served. Corrective Action Plan Actions Planned – The District will review and update its policies and procedures relating to eligible afterschool snack meal tracking and reimbursement submission for its child nutrition cluster federal program to ensure compliance with the Uniform Guidance in the future. Official Responsible – The District’s Director of Food Service, Dorie Pavel. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Director of Food Service, Dorie Pavel, will assure appropriate internal controls and procedures are updated and in place for afterschool snack meal tracking and reimbursement submission to ensure the accuracy of District claims for eligible meal reimbursements in the future.

Corrective Action Plan The Central Columbia School District respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the Single Audit Report Year Ended June 30, 2025 included in the schedule of findings and questioned costs are discussed below. Finding 2025-001: Reporting Contact Person: Steven Dolak, Business Administrator Recommendation: The District should revise procedures to ensure the data entered into the claim for reimbursement is reviewed for accuracy prior to the report being submitted. Evidence of the approval of submission should be documented in writing, such as with an initial, to demonstrate the review of the information has been performed. Action: The Business Administrator will prepare the reports for submission. Prior to submitting the report through the reimbursement system, a second individual will review the information entered. Upon satisfactory completion of the review, the second individual will acknowledge review by initialing and dating the document(s). Date for Completion: This procedure will be implemented at the beginning of the 2025-26 school year.

Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager will provide a listing of all students receiving a refund. A grace period of 5 days for students to provide direct deposit information will be established, if after 5 there is still no direct deposit information, a check will be issued.

Response and Corrective Action Plan prepared by: Leanne Green Person Responsible for Implementing the Corrective Action: Leanne Green Anticipated Completion Date of Corrective Action: Vickie Dunaway, School Nutrition Director, corrected and resubmitted the claim in question, as soon as the issue was revealed. USDA paid the difference owed on October 28, 2025. Planned Corrective Action: Once the School Nutrition Director completes the monthly claim, Leanne Green, Finance Director, reviews the paperwork, verifying that all is correct before the claim is filed.

Identification Number: 2025‑002 – Cash Management Finding: The University maintained excess cash for Federal Supplemental Educational Opportunity Grants and Federal Direct Student Loans beyond the seven‑day tolerance period, resulting in noncompliance with cash management requirements. Corrective Action Plan: Management agrees with the finding. The University will strengthen internal controls over cash drawdowns and excess cash monitoring to ensure compliance with federal regulations. Procedures will be implemented to require regular review of drawdown activity and timely reconciliation of funds to student disbursements. Any identified excess cash will be returned within the allowable timeframe. Responsible Officials and Implementation Date: The Director of Student Financial Services, in coordination with the Vice President for Administration and Finance, will monitor cash drawdowns and excess cash balances. Procedures will be implemented immediately and fully in place by March 1, 2026.

Corrective Action Plan 2025-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Fall 2025 semester to ensure that all Title IV funding sources including FSEOG are drawn down in accordance with the Heightened Cash Monitoring requirements. Completion Date: August 2025 Contact Person: Laura Crawley

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Jessica Johnston, Chief Financial Officer Anticipated Completion Date: August 20, 2025, immediately following the determination that the number of meals reported for reimbursement for the January and March claims did not agree to supporting documentation. Planned Corrective Action: The District has modified its internal controls related to child nutrition claims. The revised procedures include a secondary verification of reimbursable meals, which is completed and submitted by personnel independent of the data entry process.

Corrective Action Plan: Upon assuming the role of Executive Director in July 2024, it became clear that rent reasonableness studies were not being conducted under the previous administration, as required. Recognizing the importance of compliance with HUD regulations, I initiated the implementation of a rent reasonableness policy and process. To support this effort, we entered into a contract with MRI to provide us with the rent reasonableness software. Last year we supplied MRI with the necessary property addresses and zip codes to begin the analysis. Due to the complexity of the implementation and the volume of data required, the setup process took time. We are now actively incorporating rent reasonableness determinations into all tenant files during annual recertifications and interims. With nearly 700 families in our program, this is an ongoing process, but significant progress has been made. Our team is fully committed to ensuring full compliance with HUD regulations, and we continue to work diligently toward that goal. In addition, to ensure continued compliance and to maintain the integrity of our files, the HCV Supervisor will be conducting weekly audits. This internal quality control measure helps us identify and address any inconsistencies or issues in a timely manner.

GRTC acknowledges this finding and will continue to address this issue via updated grant management processes and training additional finance staff on grant writing, pre-award and post-award activities.

GRTC acknowledges this finding and will continue to address this issue via updated grant management processes and training additional finance staff on grant writing, pre-award and post-award activities.

New Management will work internally to report WIOA and Work First NJ grant into the District's financial reporting system. In the meantime, regular and timely closing procedures are already being performed in order to adequaely integrate detail of grant reporing with the financial reporting system.