Corrective Action Plans

Management agrees with the finding and will put processes and controls in place to verify timely deposits in the future. The required deposit of $4,477 was made in July 2025 to the residual receipts account. The corrective response has already been put into place for this fiscal year.

Corrective Action Plan for Current Year Findings 2026-001 Deposit of Surplus Cash into a Residual Receipts Account Corrective Action Plan No later than 90 days past the end of the fiscal year, we will identify surplus cash in the project funds account and deposit into the residual receipts account. Person(s) Responsible: Aaron Franklin Timing for Implementation: Immediate

Remaining balance was deposited on April 16, 2026. In the future management will ensure deposits are made timely or obtain HUD appproval permitting delay if there were cash flows issues.

1. Employee overseeing the deposits and disbursements has been removed from the position. 2. Write a cash management policy and procedures for receipt and disbursement of funds as well as a monitoring process for receipts (federal funds, grants) that need to be disbursed in a timely manner for Board approval.

Federal Award Finding 2025-004 - Material Weakness, Material Noncompliance - Special Tests and Provisions, Cash Receipts Finding: The Organization maintained cash balances in excess of federally insured limits in financial institutions that did not meet HUD's minimum GNMA rating requirements. Recommendation: The Organization should transfer excess cash balances to financial institutions that meet HUD's GNMA rating requirements or otherwise structure its cash holdings to ensure compliance with federal insurance limits and HUD custodial requirements. Action Taken: Nevins moved to this financial institution with the first HUD loan in 2015. This is a local bank that actively supports Nevin's mission in the community. Given Nevins’ current financial struggles, the balance in the bank seldom exceeds the $250,000 threshold. In addition, the receiver established its own account with East West Bank and was in the process of fully transitioning the operating account to East West Bank at the end of the fiscal year. Responsible Person: Paul Valentine, Receiver Target Completion Date: September 30, 2026 Status: Not started

Federal Award Finding 2025-003 - Material Weakness, Material Noncompliance - Special Tests and Provisions, Mortgage Reserve Fund, Equipment Replacement Reserve Fund, and Special Escrows Finding: During the audit period, Henry C. Nevins Home, Inc. did not make all required deposits into the reserve for replacement fund in accordance with the terms of the applicable HUD Regulatory Agreement. The required monthly reserve deposits were either not made or were made in amounts less than those required. Recommendation: We recommend that Henry C. Nevins Home, Inc., in coordination with the court-appointed receiver and HUD, establish procedures to ensure that reserve for replacement deposits are made timely and in accordance with the HUD Regulatory Agreement, or that appropriate waivers or modifications are obtained from HUD where compliance is not currently feasible. Action Taken: Management acknowledges the audit finding related to the failure to make required deposits into the reserve for replacement fund in accordance with the HUD Regulatory Agreement. As disclosed in the notes to the financial statements, during the audit period the Organization was subject to a court-appointed receivership effective September 12, 2025 and is in default under its HUD-insured mortgages. As part of the receivership, control over substantially all cash management and financial decision-making activities was assumed by the court-appointed receiver. Management believes that the conditions giving rise to this finding are directly related to liquidity constraints. Given the complexities of the receivership and regulatory environment, a specific timeline for remediation is not able to be determined. As a result of the loan default, the mortgage was assigned to the U.S. Department of Housing and Urban Development. Since the appointment of the Receiver, responsibility for cash management, financial oversight, and debt service planning has transitioned to the Receiver. The Receiver and the Organization are actively evaluating available options to address the loan default which includes marketing the Organization for a sale. Interim corrective actions include enhanced cashflow monitoring, prioritization of expenses required to continue operations, and ongoing communication with HUD regarding the sale process. Management believes that these actions will address the conditions identified and result in the satisfaction of the HUD loan. Responsible Person: Paul Valentine, Receiver Target Completion Date: September 30, 2026 Status: In process

Federal Award Finding 2025-002 - Material Weakness, Material Noncompliance - Special Tests and Provisions, Mortgage Status and Reserve for Replacements Finding: During the fiscal year, the Organization experienced ongoing financial distress and declining liquidity, which adversely affected its ability to meet financial obligations as they became due. As a result, mortgage payments, including required principal, interest, mortgage insurance premiums, and escrow deposits, were not made in accordance with the loan and regulatory agreements. As of December 31, 2025, delinquent amounts totaled approximately $978 thousand. Recommendation: The Receiver and the Organization should work with HUD to develop and implement a formal workout or resolution plan, including enhanced cash-flow monitoring and debt service planning, to address the loan default and restore compliance with HUD debt service requirements. Action Taken: Management acknowledges the finding related to the failure to make required debt service payments under the HUD Section 232 and Section 241(a) insured mortgage loan agreements. The Organization experienced significant financial distress and constrained liquidity during the fiscal year, which limited its ability to remit required principal, interest, mortgage insurance premium, and escrow payments as they became due. As a result of the loan default, the mortgage was assigned to the U.S. Department of Housing and Urban Development. With the appointment of a Receiver over the Organization, responsibility for cash management, financial oversight, and debt service planning has transitioned to the Receiver. The Receiver is marketing the facility towards a sale in order to satisfy the outstanding loan balance with HUD. Interim corrective actions include enhanced cash-flow monitoring, prioritization of operational suppliers, and ongoing communication with HUD regarding the project's financial condition and sale status. Management believes that these actions will support progress towards stabilization and marketability of the Organization. Responsible Person: Paul Valentine, Receiver Target Completion Date: September 30, 2026 Status: In process

Management has provided a template, which was reviewed and approved by the CFO in April 2026, to the AP Clerk without any roundings of the allocation percentages. Management will review the calculations between January 1 and April 2026 that were used for allocations and will correct any allocations as necessary. Management will ensure the review of expenses include all calculations supporting the expense amounts. All these actions are effective January 1, 2026, and will be managed by the Chief Financial Officer.

1. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: Administration will add additional internal controls where the benefit exceeds the cost. 3. Official Responsible for Ensuring CAP: Michael Marshall, Board Secretary/Treasurer, is the official responsible for ensuring corrective action of the deficiency. 4. Planned Completion Date for CAP: The planned completion date for the CAP is June 30, 2026. 5. Plan to Monitor Completion of CAP: The School Board will be monitoring this CAP.

To satisfy this audit finding, EOHHS requested a systems solution to process Eleanor Slater Hospital (ESH) claims which would automate a recipient’s TPL, Medicare, and MCO financial obligations before Medicaid is billed. EOHHS, BHDDH, and Gainwell Technologies have been working on said system modification project (PJ0630 – Other Insurance Edits for Eleanor Slater Hospital Claims) and the Business Design Document was reviewed with all parties on 6/22/2026. Anticipated Completion Date: SFY 2027 Q1 Contact Person: Hector Rivera, Interdepartmental Project Manager, Executive Office of Health and Human Services hector.l.rivera@ohhs.ri.gov

2025-066a: In order to address repeat income deficiencies from SWICA, Medicaid added The Work Number (TWN) as a new data source in August 2025. Since then, RI Bridges has been modified to first verify earned income against TWN. With this enhancement, Medicaid has seen an improvement in how earned income is verified during the post-eligibility verification (PEV) and annual renewal processes. Medicaid has determined the individuals flagged as being enrolled under the expansion pathway beyond their 65th birthday are the result of exceptions to the mass update eligibility process. Medicaid is working with our system vendor to develop a solution that will bypass this exception and terminate expansion eligibility for those turning 65 years old. RI Bridges appropriately identified the individual in question as requiring verification of citizenship status. However, as noted in the expansion age-out response, the mass update eligibility process exceptioned out, leaving the verification as unresolved and requiring manual review. Medicaid is working with our system vendor to develop a solution that will bypass this exception and terminate eligibility. Effective December 2025, the RI Bridges system receives quarterly matches from the SSA Death Master File (DMF). The DMF is automatically sent to the State as part of the quarterly PARIS data matching process. The State has deployed temporary system measures to process the file and automatically terminate Medicaid eligibility for individuals flagged as deceased on the DMF. As per section 71104 of the Working Families Tax Cut (WFTC) legislation, signed by the President on 7/4/25, the State will be deploying a long-term system enhancement to, “at least a quarterly basis, check the DMF to identify if enrolled individuals are deceased. If an individual is identified as deceased on the DMF, then the state must treat this information as factual, disenroll the individual, and discontinue any payments for items or services furnished after the death of the individual.” This enhancement is scheduled for the March 2027 release. In July 2024, federal partners operating the PARIS interstate match informed the State of a hold on PARIS interstate matching files. PARIS lifted the hold in October 2024. In November 2024, the State identified several defects in the PARIS results and suppressed requests for verification. A temporary system enhancement was logged to address the deficiencies and ensure the process was only requesting residency verification from individuals believed to be receiving Medicaid in another State. Long-term enhancements to the PARIS interstate match process are scheduled for late 2027. 2025-066b: Medicaid will continue to work with the Department of Human Services and HealthSource RI to improve reconciliation and quality assurance monitoring of eligibility and operational processes. Including, but not limited to automated quality control checks on batch processes, manual eligibility reviews of quarterly/annual activities, creating specialized reports, improving task logic, and identifying areas of repeat non-compliance to ensure appropriate controls are in place. 2025-066c: Upon notification from the systems team, Medicaid Finance will return any identified ineligible costs to the federal grantor. Anticipated Completion Dates: 2025-066a: Q4 2026 (exception scenarios) and Q4 2027 (PARIS) 2025-066b: Q4 2026 2025-066c: Ongoing Contact Persons: Anthony Salvo, Implementation Director of Policy and Programs, Executive Office of Health and Human Services anthony.salvo@ohhs.ri.gov Dezeree Hodish, Associate Director (Financial Management), Executive Office of Health and Human Services dezeree.hodish@ohhs.ri.gov

Medicaid deployed a system enhancement to automatically run eligibility on CHIP individuals for whom TPL information was received from MMIS. This enhancement went live in May 2026. This enhancement will improve the accuracy of eligibility determinations for the Medicaid and CHIP populations. In July 2024, federal partners operating the PARIS interstate match informed the State of a hold on PARIS interstate matching files. PARIS lifted the hold in October 2024. In November 2024, the State identified several defects in the PARIS results and suppressed requests for verification. A temporary system enhancement was logged to address the deficiencies and ensure the process was only requesting residency verification from individuals believed to be receiving Medicaid in another State. Long-term enhancements to the PARIS interstate match process are scheduled for late 2027. Anticipated Completion Date: Q4 2027 Contact Person: Anthony Salvo, Implementation Director of Policy and Programs, Executive Office of Health and Human Services Anthony.Salvo@ohhs.ri.gov

RIDOH agrees with the finding and recommendations. 2025-044a: RIDOH will examine and document internal processes for requesting federal drawdowns and will create and implement revised policies and procedures to align with both federal requirements and Workday requirements for documentation of expenditures. 2025-044b: RIDOH will review and reconcile ELC and Immunization grant awards reporting excess cash drawdowns as of 6/30/2025 and will make adjustments as appropriate to ensure accurate grant award tracking. Anticipated Completion Dates: 2025-044a: June 30, 2027 2025-044b: October 31, 2026 Contact Persons: Alisha Collella, Chief Financial Office, Department of Health alisha.colella@health.ri.gov Sarah Parker, Assistant Director of Health (Budget & Finance), Department of Health sarah.parker@health.ri.gov Carla Lundquist, Deputy CFO / Federal Grants Manager, Department of Health carla.lundquist@health.ri.gov Julie DeMelo, Assistant Director of Health (Budget & Finance), Department of Health julie.demelo@health.ri.gov

Name of Contact Person: Michael Gaddy, Executive Director. Corrective Action: We will implement proper internal control procedures for the Public Housing Capital Fund. Management will establish procedures to obtain proper documentation to support all Public Housing Capital Fund expenses. Proposed Completion Date: Immediately.

Telluride Regional Airport Authority (“TRAA”) respectfully submits the following corrective action plan for the year ended December 31, 2025. Reference Number: 2025-001 Finding: TRAA’s 2025 Single Audit brought forth finding(s) which required a corrective action letter or Plan. The following item related to the Airport’s federal grant reimbursements: - Program 20.106 revenues were underreported by $1,092,801 in 2025. This underreporting stems from expenditures being incurred in 2025 but the corresponding reimbursement request, and revenue recognition, was not recorded until 2026, partially attributed to delays in submitting reimbursement requests. Corrective Action: TRAA agrees that the finding is correct. Moving forward, management will review grant expenditures at year-end to verify that the related revenues have been accrued, and management will work to file reimbursement requests for outstanding grants on a more timely basis. Personnel Responsible for Corrective Action: Linda Soucie, Business Manager Anticipated Completion Date: December 31, 2026 for fiscal year 2026

Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will prepare the monthly SNP Claim for Reimbursement Summary report and compile all supporting meal count documentation. 2. Prior to submission, the Administrative Assistant to the Director of Food Services or another designated individual independent of the preparation process will: a. Review the claim for mathematical accuracy; b. Verify meal counts against supporting documentation; c. Confirm claims are submitted within required timelines; and 3. Evidence of the review and approval will be documented through: a. Signature or electronic approval on the reimbursement summary report; and b. Retention of supporting documentation in accordance with federal and state record retention requirements. 4. A written standard operating procedure (SOP) outlining these review and approval responsibilities will be developed and communicated to applicable personnel. The Business Manager will periodically monitor compliance with the procedure to ensure controls remain effective.

Corrective Action: The City will implement formal review and approval process for reimbursement requests within grant management policy; and require documentation (signatures/dates) to evidence compliance. Responsible Individual(s): Michael Elizalde, Grants & Strategic Initiatives Director; Vidal Roman, Finance Director. Timeline: In Progress. Estimated September 2026.

2025-001 Internal Controls over Allowable Cost – Disaster Assistance Grants Point of Contact: Rachael Wilkinson, Director, APOHSEP Management’s response and corrective action plans are as follows: 1. Management acknowledges the recommendation and has taken steps to enhance oversight of the Federal Emergency Management Agency (FEMA) reimbursement requests, including those prepared by third-party consultants. Ascension Parish Government is implementing a formalized review process by the Ascension Parish Office of Homeland Security and Emergency Preparedness (APOHSEP) prior to submission to ensure that all expenditures are accurate, properly supported, and classified in accordance with FEMA requirements. 2. This process will include reconciling reimbursement requests with underlying payroll records, equipment logs, and other supporting documentation, as applicable. Management will continue to monitor FEMA submissions to ensure compliance with applicable federal guidelines and strengthen documentation of review procedures. 3. Additionally, Ascension Parish Government will amend the project worksheet to address the identified errors

Department of Homeland Security - Federal Emergency Management Agency (FEMA) Staffing for Adequate Fire and Emergency Response (SAFER) - CFDA No.97.083 Recommendation: The City should provide training for the grant administrator and/or include an additional review by individual that has been fully trained on the compliance requirements of the grant. The internal control process should include a formal way to document the review and approval of Fire Safety salary costs charged to the grant to provide evidence that internal controls are effectively designed and implemented and functioning in a timely manner throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned and taken in response to finding: The City has authorized a full-time grants specialist position within the Finance Department to oversee the administration of grants separate from the programming department. The City will strengthen internal controls over grant compliance by implementing formal policies and procedures for allowable costs, documentation, and review. All grant expenditures will be reviewed and approved by Finance prior to submission, with supporting documentation maintained for eligibility determinations. Name(s) of the contact person(s) responsible for corrective action: Rebecca Holden Planned completion date for corrective action plan: 6/30/2026

Corrective Action Plan: The NCHA has implemented enhanced financial management procedures to ensure the proper segregation of Public Housing and Housing Choice Voucher program funds and prevent the use of one program’s resources to support another program’s expenditures without appropriate authorization, documentation, and accounting treatment. Interprogram transactions are now recorded through established due to/due from accounts and reconciled monthly to ensure accurate fund accountability. Financial policies and procedures have been updated to reinforce program-specific allowable uses of funds, and Finance staff have received training on HUD financial management requirements, fund segregation, and proper accounting practices. Ongoing monthly financial reviews by management will provide continued oversight and ensure compliance with HUD requirements. 1. Program Fund Segregation and Accounting Controls The NCHA has revised its accounting procedures to ensure that all program revenues and expenditures are recorded within the appropriate program fund and cost center. Public Housing Operating Funds will only be utilized for eligible Public Housing activities, and HCV program costs will be supported through HCV Administrative Fees, HCV reserves, or other allowable funding sources. Any transactions identified as requiring temporary interprogram support will be recorded through appropriate due to/due from accounts and will not be treated as program expenditures. Interprogram balances will be tracked separately from operating activity and monitored for timely repayment or resolution. 2. Review and Correction of Historical Transactions Finance staff has completed a review of interprogram transactions to identify instances where costs were charged to the incorrect program. Necessary accounting adjustments have been processed to properly allocate expenditure to the appropriate funding source. Going forward, all program cost allocations will be reviewed to confirm that expenses are:  Reasonable and allowable under applicable HUD requirements;  Charged of the appropriate program;  Supported by adequate documentation; and  Consistent with approved cost allocation methodologies. 3. Updated Financial Policies and Procedures The Authority has updated its financial procedures to reinforce:  Program-specific expenditure requirements;  Prohibited uses of Public Housing funds for HCV activities;  Proper recording of interprogram receivables and payables;  Required approval and documentation for interprogram transactions; and  Monthly reconciliation requirements. The updated procedures establish clear responsibilities for Finance staff, program managers, and supervisory personnel involved in financial review and approval processes. 4. Staff Training and Awareness Finance and program staff have received training regarding:  HUD program fund restrictions;  Public Housing Operating Fund eligible uses;  HCV Administrative Fee limitations;  Proper accounting treatment of interprogram activity; and  Documentation requirements under federal financial management standards. Additional training will be provided as needed to reinforce compliance and prevent recurrence. 5. Ongoing Monitoring and Quality Control The Finance Director will conduct monthly financial reviews to verify:  Public Housing and HCV funds remain properly segregated;  Due to/due from balances are accurately recorded and reconciled;  Program expenditures are charged to the appropriate funding source; and  Corrective actions remain effective. Management will review monthly financial reports, including program-level income statements, balance sheets, and interprogram activity reports, to identify and address potential compliance issues in a timely manner. As part of the corrective action, the NCHA executed an Agreement with BDO to provide financial management training, technical assistance, and workflow support related to HUD program accounting requirements, fund segregation, and proper recording of interprogram activity. BDO assisted Finance staff with strengthening accounting processes, including the development and implementation of standardized Yardi workflows to ensure program-specific coding, proper cost allocation, approval routing, and accurate financial reporting. Responsible Official: CFO, Sr. Staff Accountant with oversight by Executive Director Expected Completion Date: Implemented July 31, 2026; ongoing monitoring and reconciliation

Finding Number: Finding 2025-001 Title: Improper Timing of MTW Capital Fund Program (CFP) Drawdowns (ALN 14.881) - Repeat of Finding 2024-002 Program Name: Moving to Work Demonstration Program - Capital Fund Program ALN: 14.881 Description: During testing of the Capital Fund Program (CFP) component of the Moving to Work (MTW) Demonstration Program, we determined that the Authority drew down CFP funds in advance of need. As of September 30, 2025, $1,891,326 of CFP funds drawn during the fiscal year remained unearned (undisbursed) and were carried as restricted/unearned amounts at year end. The drawdowns were not aligned with immediate, allowable obligations or expenditures at the time the funds were requested. This condition is a repeat of prior year finding 2024-002. Planned Corrective Action: The Authority concurs with the finding and acknowledges it is a repeat of finding 2024-002 involving cash management and drawdown procedures. Revise cash management procedures; require documented support and approval for drawdowns; perform monthly reconciliations; monitor interest earned on undisbursed federal cash; provide staff training; and report compliance status to the Board of Commissioners. Timeline for completion: 6 months

Title: Inadequate Tenant File Documentation in MTW Housing Choice Vouchers Program Name: Moving to Work Demonstration Program - Housing Choice Voucher Program ALN: 14.881 Description: During tenant file testing for the Housing Choice Voucher (HCV) component of the Moving to Work (MTW) Demonstration Program, variances were identified between the amounts reported on HUD Form 50058 and the actual Housing Assistance Payment (HAP)/Utility Allowance Payment (UAP) disbursements for six tenants. The Authority did not maintain sufficient documentation to reconcile the differences. Planned Corrective Action: The Authority will implement a process to reconcile all Housing Assistance Payment (HAP) and Utility Allowance Payment (UAP) disbursements to the amounts reported on HUD Form 50058. Identified variances for the affected tenants will be researched and corrected, supporting documentation will be retained in each tenant file, and staff will be trained on documentation and reconciliation requirements under the MTW HCV program. Periodic quality-control reviews of tenant files will be performed to ensure ongoing compliance.

Finding Number: 2025-002 Planned Corrective Action: Management has implemented enhanced cash management and grant monitoring procedures, including strengthened review of draw requests, improved documentation requirements, and closer reconciliation of grant expenditures to amounts drawn. In addition, the Organization is undertaking process improvements to streamline grant accounting and reporting activities, improve the timeliness of expense recognition, and enhance overall oversight of federal awards. Management expects these actions will strengthen compliance with federal cash management requirements and reduce the risk of future occurrences. Anticipated Completion Date: 12/31/2026 Responsible Contact Person: Alison Roca, Chief Financial Officer

Name of Contact Person: Brent Boren, Superintendent. Recommendation: We recommend that the District only charge costs that are allowable under the grant agreement. We also recommend that the District contact ISBE to discuss if the District will need to return the funds reimbursed by the Illinois School Board of Education for these unallowed expenditures. Corrective Action: The District will ensure that all costs charged to the Title I grant are allowable per the grant agreement going forward.

2025-003: Period of Performance Compliance Action Taken/Planned: Management acknowledges the instances identified in which disbursements were processed after the award's period of performance. While no questioned costs were noted, the University recognizes that timely processing of expenditures and drawdowns is critical to ensuring compliance with federal requirements governing grant periods. To Strengthening Grant Closeout Procedures management will establish a formal grant closeout timeline to begin 90 days prior to the award end date, require principal investigators (PIs) and grant administrators to review all outstanding obligations and ensure timely submission of final expenses and implement a standardized closeout checklist to confirm all costs are recorded within the allowable period To Enhanced Monitoring of Grant Periods management will develop and maintain a centralized tracking system for all federal awards, including start and end dates, generate monthly reports identifying grants nearing expiration (within 90, 60, and 30 days) and distribute reports to Pis, Grants Accounting, and Finance leadership for proactive management. For timely processing and drawdown controls management will require all invoices and expenditures to be submitted within a defined timeframe (e.g., within 30 days of service or project completion), establish internal deadlines for processing disbursements and drawdowns prior to the grant end date and implement a review step within Grants Accounting to verify that expenses fall within the period of performance before payment is released. The grants department will conduct mandatory training for PIs, grant managers, and finance staff on period of performance requirements and federal compliance expectations and reinforce accountability for timely submission and processing of expenditures Management will also put in place for any costs identified outside the period of performance will require, documented justification, review and approval by the Director of Grants Accounting and CFO, and verification of allowability under award terms or sponsor approval, if applicable. Anticipated Completion Date/Date Completed: This will be implemented immediately with an anticipated completion date of June 30, 2026