Corrective Action Plans

Finding Number: 2024-005 Anticipated Completion Date: March 31, 2026 Responsible Contact Person: Brad McCain, Chief Financial Officer Planned Corrective Action: Management is strengthening controls over tracking, documenting, and reconciling federal grant expenditures to ensure compliance with period of performance requirements. Actions include implementing improved grant-level tracking within the financial system, reconciling general ledger activity to reimbursement invoices and the SEFA on a routine basis, and retaining documentation to support the allowability and timing of costs charged to federal programs. Management will also formalize procedures for payroll reallocations across programs to ensure traceability and compliance with grant requirements. Documentation will be required to be attached to all journal transactions demonstrating the linkage between the underlying payroll records to the correct grant programs.

Higher Education Institutional Aid– Assistance Listing No. 84.031 Condition: The institution did not have effective internal controls over cash management. Recommendation: We recommend the institution review and implement their internal controls and procedures over cash management so that expenditures are being properly tracked, reconciled, and reviewed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Drawdowns are currently prepared by one individual and reviewed by separate individual, however the supporting documentation does not consistently reflect that two individuals were involved in the drawdown; the procedures will require the sign off of both the preparer and the reviewer on the draw down documentation. Name(s) of the contact person(s) responsible for corrective action: Jeff Copeland Planned completion date for corrective action plan: March 31, 2025

Uniform Guidance Corrective Action Plan Management acknowledges that improvements were necessary in assuring that drawdowns of grant funds are in compliance with regulations. Accordingly, drawdowns of grant funds will be more aligned with bi-weekly and/or monthly expenditures as supported by an analysis of payroll and accounts payable system activity by the Chief Financial Officer prior to authorizing any drawdowns. Additionally, requests for drawdowns will be reviewed by a member of the Finance Team to assure that it is within acceptable parameters related to grant spending. This process revision will be implemented no later than March 31, 2026.

In accordance with HUD requirements, the Authority plans to begin drawing down operating-subsidy funds on a monthly basis. The Executive Director and Board will continue to review monthly financial statements prepared by the accountants and will research and evaluate potential investment options to increase the return on available funds. The Authority intends to develop and adopt formal written procedures for cash management and investment monitoring during the next fiscal year.

Finding 2024-004 – Insufficient Skills, Knowledge and Training, and Leadership (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land ManagementCriteria: Under Uniform Guidance 2 CFR §200.303, non-federal entities must establish and maintain effective internal control over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the award terms and conditions. This includes ensuring that:  Personnel administering federal awards possess adequate skills, knowledge, and experience.  Management and leadership provide appropriate oversight of federal award activities.  Financial management systems adequately support accurate reporting, documentation, retention, and reconciliation of federal expenditures in accordance with 2 CFR §200.302. Condition: During the audit of federal awards, the entity did not demonstrate sufficient skills, knowledge, or experience of the staff and leadership responsible for administering and overseeing federal programs. Specifically:  Adequate supporting documentation for federal award expenditures was not maintained or provided.  Leadership oversight of federal award compliance activities was limited, and management review of grant activity were not evidenced. These conditions resulted in weaknesses in financial reporting, compliance monitoring, and documentation related to federal awards. Cause: Partnership for the Umpqua Rivers has not ensured that staffing levels, qualifications, and experience are sufficient to support federal award administration and compliance. In addition, leadership lacks adequate knowledge of federal award requirements to provide effective governance, oversight, and monitoring of compliance activities. Formal training and documented procedures for federal awards management have not been prioritized. Effect or Potential Effect: As a result of these deficiencies:  Partnership for the Umpqua Rivers is at increased risk of non-compliance with Uniform Guidance requirements.  Federal expenditures may be unsupported, inaccurately reported, or unallowable.  Errors or compliance violations may not be detected or corrected in a timely manner.  The entity may be subject to questioned costs, repayment of federal funds, or additional scrutiny from grantor agencies. Questioned Cost: None identified Context: During our audit, it was found that the Partnership for the Umpqua Rivers experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. No financial files for Accounts Payable, invoices, or reporting were available to the current financial staff. Not adequately retaining supporting documents and invoices to support the expenditures of the general ledger and requests for reimbursement for grants, the organization records may be insufficient for testing and review, for internal controls or meeting federal documentation and reporting requirements. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers:  Ensure staff responsible for federal awards receive appropriate training on Uniform Guidance requirements, grant financial management, documentation, and compliance monitoring. Assign federal award oversight to personnel with sufficient experience and qualification or obtain external grant management and accounting support as needed.  Establish written policies and procedures for federal award administration, including expenditure documentation, reconciliation, compliance review, and management approvals.  Require leadership to perform and document periodic oversight and monitoring of federal awards, including review of reconciliations reimbursement requests, and compliance metrics.  Implement ongoing monitoring and internal control assessments to ensure compliance with federal award requirements. District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: _____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: ___________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

Finding: 2024-003 Material Weakness in Internal Control Over Allowable Costs/Cost Principles and Reporting – WIC Special Supplemental Nutrition Program for Women, Infants, and Children, and Immunization Cooperative Agreements (10.557, 93.268) Corrective Action: We will work to ensure that the proper indirect cost rate is applied to the various grants. Proposed Completion Date: February 28, 2026 Name of Contact Person: Tomiko Fisher, Chief Operating Officer

2024-005 Material Weakness in Internal Control over Compliance 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: During our testing of participant eligibility, we selected a sample of 40 participants receiving meals at centers contracted with the CBS Food Program. For 2 of the 40 participants, management was unable to provide complete and valid eligibility documentation. In one instance, the only available eligibility form had been prepared in a future fiscal year, and in another instance, the eligibility form could not be located at all. Recommendation: We recommend that management strengthen its CACFP eligibility documentation procedures to ensure that all required forms are properly completed, collected, and retained for every participant. This should include implementing a standardized intake process, maintaining timely reviews to confirm completeness of eligibility files, and developing a tracking or monitoring system to identify missing or outdated documentation. Management should also reinforce internal expectations for timely updating of eligibility files and ensure staff are trained on CACFP documentation requirements. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: On February 1, 2025, Community Benefit Solutions rolled out the KidKare software system wide. KidKare is a CACFP software that allows Community Benefit Solutions to digitally process all eligibility-documentation, standardize the enrollment procedures, ensure forms are completed in accordance with the relevant regulations, request updated documentation upon the expiration of enrollment forms, and digitally store all the eligibility related information for all participants. Planned completion date for corrective action plan: June 30, 2025

City of Parker Management’s Corrective Action Plan For the Fiscal Year Ended September 30, 2024 Financial Statement Finding Number: 2024-101: Reimbursement Requests were Not Formally Approved by the City Prior to Submission Planned Corrective Action: The City will update its procedures to require documented City review and approval of all reimbursement requests prior to submission to a grantor. The City will also clarify responsibilities with the consultant to ensure submission and acknowledgment are independently performed and appropriately documented. Anticipated Completion Date: 09/30/2026 Responsible Contact Person: Kimberly Dalton, Bookkeeper

We concur with this finding. The County of York has hired a Human Services Director of Finance to assist with improving systems and financial processes within the Human Services (HS) divisions. The HS Executive Director and Director of Finance are recommending engaging an expert Consultant to assist the County’s Children & Youth Fiscal team in getting caught up on internal system timelines, as well as delayed reporting. The Consulting company will also be working to adequately train the Children & Youth Fiscal team for development purposes.

Name of Contact Person: Hugh Chisholm, Chief Financial Officer Planned Corrective Action: Kaleida Health management asserts that the methodology applied to estimate and account for potential duplication of benefits with patient care revenue for FEMA Public Assistance Project #694036 was reasonable, allowable, and consistent with FEMA guidance. The project was previously reviewed, approved, obligated, funded, and closed out by FEMA. A formal appeal of FEMA’s subsequent recommended reduction was filed in September 2025. Management continues to cooperate fully with FEMA and the New York State Division of Homeland Security and Emergency Services during the appeal process. Accordingly, corrective action is contingent upon FEMA’s final determination. Planned Completion Date: Not applicable. Management will evaluate the need for any corrective action upon receipt of FEMA’s final determination on the pending appeal.

2024-007 Untimely Submission of Project and Expenditure Report: Management acknowledges the finding related to the untimely submission of the American Rescue Plan Act (ARPA) Project and Expenditure Report. To address this issue and prevent future occurrences, the City is implementing an ARPA reporting process that clearly defines reporting requirements, deadlines, and responsible personnel, along with a centralized compliance calendar to track all federal grant reporting deadlines and provide reminders to ensure timely submission. Primary responsibility for ARPA reporting has been assigned to designated Finance Department staff, with supervisory review by senior management to ensure reports are complete, accurate, and submitted on time. In addition, Finance staff have received training on federal and ARPA specific reporting requirements, and cross-training will be implemented to ensure continuity in the event of staff absences or turnover. Management will continue to monitor compliance with federal reporting requirements and update internal controls as necessary.

Finding 2024-004: (Significant Deficiency) AL# 14.218: CDBG - Entitlement Grants Cluster, U.S. Department of Housing and Urban Development, all open grants and years Condition: During testing of the PR26 – CDBG Financial Summary report, it was identified that one payroll cycle was reported twice, resulting in a duplication of payroll costs and an overstated reimbursement request. Criteria or Specific Requirement: 2 CFR 200.303(a) states that the City is required to establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The The ERP system conversion presented challenges to the City related to report development and in particular accuracy of the project management system. Effect: The reimbursement request was overstated, resulting in an excess draw of funds. This creates a risk of noncompliance with the grant requirements and potential repayment of funds. Corrective Plan: To address the underlying issues identified in the audit finding, the City will implement the following steps: 1.Coordinate with HUDResolve the duplicated payroll amount, including reimbursement or offset of the excess draw,in accordance with HUD guidance. 2.Reconcile Payroll Expenditures and DrawsPerform reconciliation of payroll-related expenditures and reimbursement draws for all HUDgrants for January 1–June 30, 2024, to ensure amounts claimed agree to general ledgeractivity. 3.Strengthen Recordkeeping and Reimbursement PracticesIn addition, the City will ensure that recordkeeping and reimbursement preparationpractices related to payroll expenses included in grant draw requests are sufficient tosupport amounts claimed and agree to general ledger activity.The Accounting Services Division will review existing departmental documentation practicesand communicate consistent expectations and best practices to promote accurate, complete,and supportable payroll draw requests.The City anticipates working with the department and having this process fully in place within3–4 months. These actions will be implemented and monitored to ensure compliance with grant requirements. Benjamin E Davis 1/7/26 Date Principal Planner Alex E Fedak 1/7/26 Date Controller

The District will be training the grant personnel about proper coding and grant expenditure timelines to ensure timely and accurate submissions of expenditure reports. Anticipated Date of Completion: Immediately. Contact Person: Alicia Evans, Ed.D., Assistant Superintendent of Business Affairs.

FINDING 2024-014 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation in the form of dated expenditure reports for all federal grant reimbursements and for the final expenditure reports. The Business Office will implement a system of internal control and review where after each month is reconciled and closed, the Federal Grants Administrator will review the program expenditures, ensuring they are correctly posted prior to filing the reimbursements. All reimbursements will be reviewed and signed off on by the Federal Grants Administrator and an additional reviewer prior to submission for reimbursement. In addition, the final expenditure reports will be reviewed and signed off on by Grants Administrator and an additional reviewer prior to submission. Anticipated Completion Date: The school district began the practice above on January 1, 2024, and anticipate it will be completed by June 30, 2026.

FINDING 2024-007 Finding Subject: Special Education Cluster (IDEA) - Cash Management Contact Person Responsible for Corrective Action: Susie Swango, Director of Special Education Contact Phone Number and Email Address: swangos@nlcs.k12.in.us (812) 277-3220 ext. 16243 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business office has worked with the Director of Special Education to create a system of internal control and review where after each month is reconciled and closed the Director of Special Education reviews the program expenditures ensuring they are correctly posted prior to filing for reimbursements. The Business Office will then notify the Director of Special Education when reimbursements for their funds are received and the Director can check that the deposit has been posted correctly. Proper expenditure and receipt documentation will be kept on hand for each reimbursement submitted. Anticipated Completion Date: June 30, 2026

F A 2O24-OO3 Strengthen Controls over Financial Reporting Compliance Requirement: Reporting lnternal Control lmpact: Material Weakness Compliance lmpact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education CFDA Numbers and Titles: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: S0104220010 (Year:2023), S010A230010 (Year.2024) Questioned Costs: $0.00 Repeat of Prior Year Finding: FA 2023-004, FA 2022-004, FA 2021-002, FA 2019-002 Description: The School District did not file accurate completion reports for the Title I Grants to Local Educational Agencies program. Corrective Action Plans: . CFO will make sure expenditures are correctly recognized on all completion reports . An independent CPA person has been hired and review completion reports before they are submitted Estimated Completion Date: Decembet 31, 2025 Contact Person:Torrence H. Freeman lll. CFO Telephone: 706-665-8577 Email:tfreeman@talbot.kl2 aus

Federal Agency: Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing No.: 84.425 Recommendation: The University should revise its cash management procedures to ensure that HEERF drawdowns are based on actual, immediate cash needs rather than anticipated expenditures. Draw requests should be timed as closely as administratively feasible to the disbursement of funds for allowable program costs. Additionally, management should implement monitoring controls to prevent excess cash accumulation and ensure compliance with 2 CFR 200.305 and HEERF guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University finished issuing student disbursements on 7/8/24. This expended all remaining HEERF monies. This account has ended and has been closed out. Name(s) of the contact person(s) responsible for corrective action: Dorothy Daley, Director of Sponsored Projects Planned completion date for corrective action plan: Complete

2024-005 – Insufficient Financial Management Finding: Our audit procedures disclosed that the Organization drew down more revenues than expenditures incurred. Recommendation: We recommend that Homeward Bound Adirondack, Inc. establish oversight practices to ensure that all revenues and expenses are recorded appropriately and reconciled to the proper drawdown requests Action Taken: We are creating a policy and procedure to include the bookkeeper submitting the weekly expenses to the Executive Director for review and sign off prior to executing the draw downs to ensure proper allocation of costs. The Executive Director has contacted the Fox grants team concerning this matter.

We concur. Since the previously issued findings, all grant reimbursement revenue has been reconciled along with expenditures to the grant and reported in a timely manner on a daily basis. The implemented review of entries into the general ledger will be used as a comparison of expenditures to ensure matching information is present and accurate before submittal of requested government funding.

We concur. For the current grant year, processes have been updated to ensure variances do not occur. Any questions of allowable cost will be reference by 2 CFR 200 subpart E and used as a common procedure for all expenses. The Executive Director and Office Manager will review expenditures prior to the distribution of expenses from among the funds, which will ensure accuracy before the request is made.

CHILD NUTRITION CLUSTER – REPORTING U.S. Department of Agriculture Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Passed Through Minnesota Department of Education Pass Through Number: 10.CNC Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend that the district ensures all changes and adjustments are communicated to the accountant who performs claim submissions. When the Nutrition Service Assistant Director’s review results in additional adjustments within PrimeroEdge, the District should only make those changes before the CLiCs cutoff date to prevent differences between client records in PrimeroEdge and CLICS reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all of the personnel involved in the reporting processes to ensure the compliance requirements are fully understood and a proper review of all reporting methods will be performed. This will be implemented by December 31, 2025, and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

Views of Auditee and Corrective Actions: GDOE partially agrees with the condition identified; however, GDOE does not agree with the stated cause that the Financial Affairs Division lacks established internal control policies and procedures to disburse funds received from the U.S. Department of Education on the same day the funds are deposited. The 24-hour payment to vendor requirement was a responsibility for the Third-Party Fiduciary Agent (TPFA). That specific condition was removed with the removal of the TPFA. The reference is no longer valid in the post TPFA environment. USEd’s Risk Management Services Division acknowledged and stated it would update the specific conditions to reflect the correct process. Notwithstanding this, GDOE is committed to processing vendor payments, when possible, within 24 hours, understanding the timing differences are influenced by operational and banking processing factors, including confirmation of fund receipt, internal review requirements, and payment processing timelines. Plan of action and completion date: GDOE acknowledges the importance of timely vendor payments and compliance with applicable cash management requirements. In response, the Financial Affairs Division is reviewing and updating standard operating procedures to more clearly incorporate the transitioned TPFA responsibilities, define roles and timelines, and strengthen monitoring controls under the current operating structure. GDOE remains committed to improving cash management processes to enhance compliance and consistency in future periods. We will now make vendor payments as soon as we see that the funds are “pending” in our bank accounts and not wait for those funds to be fully approved and deposited into our accounts. Plan to monitor and responsible officials: The DFAS and the Comptroller will ensure all payments are processed in a timely manner.

The findings have been resolved as of 4/2/2025. A $21,073 deposit was made to the residual receipt bank account on this date.

Finding 2024-010 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds passed-through the State Water Resources Control Board Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: A00059, 2024 Finding Summary: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Corrective Action Plan: Prior to the 2024 audit process being completed, the city experienced significant staff turnover particularly in the Finance Department. The city is in the process of recruiting various key positions including Finance Director, Deputy Finance Director and Accounting Supervisor. This will ensure all proper processes are followed. Responsible Individual(s): Finance Director (short-term part-time staff); Deputy Finance Director (Vacant); Purchasing Manager (Vacant) Anticipated Completion Date: January 2026

Corrective Action Plan – Section III: Cash Management Condition: Two instances were identified where advance funds were not disbursed within a reasonable period after receipt, and reimbursement requests lacked secondary approval and supporting documentation. Cause: This particular award was an exception because the funder requested that The Ocean Foundation draw the remaining balance of funds as the project was closing. Additionally, disbursement of large grant amounts was delayed due to a temporary reduction in staff. Effect: Delays in disbursement and lack of documentation increased the risk of noncompliance with Federal cash-management requirements. Corrective Action: • Implement a strict process for drawing funds beginning in FY26, including: o Written cash-management procedures compliant with 2 CFR §200.305. o Maintaining detailed reporting to support amounts drawn. o Timely program and project notifications for all drawdowns. • Establish a formal review and approval process for reimbursement requests. • Ensure advance funds are maintained in interest-bearing accounts when applicable. Timeline: • Written procedures and process implementation: FY26 • Staff training and monitoring: Ongoing Person Responsible: Jennifer Stahl, Finance Lead