Corrective Action Plans

Condition: Based upon single audit testing noted 4 applications approved in the wrong category: two applications that were approved as free but should have been reduced, one application that was approved reduced but should have been free, and one application that was approved reduced but should have been paid. Also noted that per ISBE exam, ISBE noted eight applications that were approved in the wrong category: 7 applications that were approved free but should have been reduced and one application that was approved free but should have been paid. Also, the ISBE exam noted two applications that were missing a valid SNAP case number. Recommendation: We recommend establishing a procedure to ensure household eligibility applications are approved in the appropriate category according the current income guidelines. Management Response: All household eligibility applications will be first taken be one employee, checked over by a second employee and then confirmed by a third employee. Anticipated Date of Completion: June 30, 2026

Condition: The ISBE exam found that meal counts by category for lunch were not correctly used in the December 2024 Claim for Reimbursement. Recommendation: Meal counts by category must be accurately reported each month. Management Response: Meal counts by category must be accurately reported each month. Anticipated Date of Completion: June 30, 2026

Federal grants ended in FY 2025. If we receive federal reimbursement grants in the future, we will develop a better process so this does not occur.

2025-007 – Medical Assistance Program – Activities Allowed and Allowable Costs/Cost Principles – The District is aware of the licensing requirements and will attempt to compile the information necessary in the future. Responsible Official – Karl Morrin, District Administrator Anticipated Completion Date – This finding is expected to be resolved for the 2026 annual financial report.

Recommendation: We recommend that the District review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is distinct from the individual responsible for preparing. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Taken in Response to Finding: The Business Manager and School Food Service Director met regarding the finding and agreed that the Food Service Director will continue to gather the required claim data and enter the appropriate data into DPIs required Excel template monthly. All supporting documentation as well as the Excel documents will be emailed to the Business Manager monthly. The Business Manager will verify the numbers in the Excel documents using the supporting documentation. If the Business Manager agrees with the numbers in the Excel files, they will be uploaded to DPI as is. If any discrepancies are discovered, the Food Service Director and the Business Manager will work together to ensure the correct data is sent to DPI. Name of Responsible Official: Tera Fritz, Business Manager Expected Completion Date: September 1, 2025

Management agrees with the finding and has implemented redundant scheduled reminders for the appropriate due dates for the next fiscal year.

DEPARTMENT OF THE TREASURY CDFI Equitable Recovery Program (CDFI ERP) – Assistance Listing No. 21.033 Recommendation: The Credit Union did not maintain supporting records to demonstrate that interest earned on unused funds held in interest-bearing accounts was remitted to the federal government, as required by 2 C.F.R. § 200.305(b)(7). This deficiency appears to stem from a lack of formal procedures and oversight related to the handling of advance payments and interest earned on federal funds. To address this issue, we recommend that the Credit Union implement internal controls designed to ensure compliance with grant requirements, including procedures for tracking interest earned, verifying remittance to the federal government, and maintaining appropriate documentation to support these activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement grant compliance controls and maintain proper documentation. Name(s) of the contact person(s) responsible for corrective action: Cindy Lindsey, CEO Planned completion date for corrective action plan: December 2025

Finding #2025-001: Comments on the Finding and Each Recommendation: The Corporation received a reimbursement from the reserve for replacements, as approved by HUD, for $17,400 for HVAC services based on a proposal during the year ended September 30, 2025; however the proposal was never accepted and the scheduled repairs never incurred. At September 30, 2025, the $17,400 had not been deposited back into the reserve for replacements. Management should transfer $17,400 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. On November 6, 2025, management transferred $17,400 from the operating account to the reserve for replacements.

Condition: Testing revealed that 1 of the 25 students tested were given the incorrect determination of free or reduced meal prices. Plan: The District should encourage all applications electronically. If a paper application is submitted, there should be multiple levels of review before approval. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Jason Brunaugh, Assistant Superintendent of Finance and Human Resources Management Response: The District will review procedures to determine if added steps are needed to ensure proper classification of manual applications.

Statement of Condition 2025-001 (Assistance Listing 14.155): The Corporation did not make the required residual receipts deposit computed at September 30, 2024 in the amount of $642,483 within 90 days of fiscal year end. Recommendation: Management should implement a system to ensure the required residual receipts deposit is made within 90 days of fiscal year end. Management response: Agree. Management made the required residual receipts deposit on June 9, 2025.

The District implemented the Community Eligibility Provision (CEP) beginning in FY 2025, providing free breakfast and lunch districtwide. Prior to CEP implementation, all students were required to enter Student ID information at the point of sale, which automatically generated accurate CN-6 and CN-7 reports used for reimbursement claims. With the implementation of CEP, the Food Service Director eliminated Student ID entry at the cash register for grades K-5 to simplify service for younger students and improve meal service efficiency. As permitted by Ohio Department of Education and Workforce (DEW), the District transitioned to using daily paper count sheets to record meals served. This manual process required accurate daily calculations, which introduced risk due to the absence of automated checks. Because the District had historically relied on automated point-of-sale reports, the Assistant Treasurer did not independently recalculate or verify the CN-6 and CN-7 meal counts prior to submission in CRRS. As a result, inaccuracies occurred in multiple monthly reimbursement claims. Effective November 1, 2025, the District implemented corrective measures to strengthen internal controls over meal counting and claiming. The daily count sheets were converted from a paper format to an Excel-based worksheet with built-in formulas to ensure accurate calculation of daily and monthly meal totals for CN-6 and CN-7 reporting. The Food Service Director is responsible for completing the daily count sheets and ensuring that daily totals align with CN-6 and CN-7 report data. The Assistant Treasurer has been designated as the responsible individual for reviewing CN-6 and CN-7 reports and verifying that reported meal counts agree to the reimbursement claim submitted in CRRS prior to submission. These corrective actions establish segregation of duties, improve calculation accuracy, and ensure required internal controls are in place to comply with 7 CFR § 210.8(a) and 7 CFR § 220.11(b). The District believes these measures adequately address the audit finding and will prevent recurrence of meal count inaccuracies in future reimbursement claims.

Finding # 2025-001 Type: Material weakness over allowable costs Type: Immaterial noncompliance over allowable costs Assisting Listing Number: 43.001 Federal Agency: National Aeronautics and Space Administration Name of Federal Program: Science Finding: One individual computes the indirect charges and prepares the drawdown requests without a secondary review by a senior member of management. Two out of forty expenses tested were completed by one individual with no review. Three out of four cash draws tested were submitted with no secondary review. Immaterial errors were noted in amounts charged for indirect costs. Recommendation: Management should establish a consistent procedure to ensure indirect rate calculations and monthly billings are reviewed prior to submission. Corrective Action: As a result of administrative disruption caused by a transition in the Chief Financial Officer role, we were required to catch up as quickly as possible. During this catch-up period, normal review processes were not fully in place due to the noted staff transitions. This was a one-time situation and has since been remedied through the implementation of formalized policies and procedures governing the preparation, review, and timely submission of federal reports. We have transitioned to an accounting software that limits the ability for indirect rate calculations to be completed by one individual. Monthly draw requests will be completed by the Finance Director during month-end close and submitted to the Chief Financial Officer for review prior to submission. Anticipated Completion Date: December 20, 2025

Condition During testing, auditor determined that 24 students had an incorrect eligibility status utilized for a portion of the school year. Recommendation We recommend that the District look for training opportunities for food service staff members to ensure that they have a good understanding of the program’s compliance requirements. Additionally, all students receiving free or reduced price meal benefits should be reviewed to ensure that they have a valid application or direct certification on file. Comments on the Finding The District agrees with the finding and has implemented procedures to prevent this, in the future. Actions Taken As of the date of this notice, training opportunities will be sought out to further food service staff members’ educations regarding the program compliance requirements. Eligibility for all students will be reset each year to ensure that only those who are direct certified or that have submitted an application and are eligible for free or reduced meals will receive those benefits.

2025-003 – Child Nutrition Cluster – Activities Allowed or Unallowed and Allowable Costs and Cost Principles and Reporting Condition During testing of the sponsor claim reimbursement reports, it was found that the District submitted inaccurate meal counts on two monthly reports. Recommendation We recommend that the District review its controls related to monthly reimbursement requests for the Child Nutrition Cluster in order to ensure that accurate meal counts are submitted. Comments on the Finding The District agrees with the finding and has implemented procedures to prevent this, in the future. Actions Taken As of the date of this notice, reimbursement claims will be prepared using the Power School software’s meal counts, and the claim will be reviewed by an individual other than the preparer before being submitted.

Management should ensure surplus cash is calculated in a timely matter in order to make any required deposit to the residual receipts account

Finding Number: 2025-005 Federal Program, Assistance Listing Number and Name: ALN 93.914, Department of Health and Human Services (HHS), HIV Relief Project Grants Condition: Original Finding Description: A lack of effective controls resulted in noncompliance with federal payment requirements, specifically for payments made to subrecipients. Contact Person Responsible for Corrective Action / Anticipated Completion Date: Denise Fair Razo Regina Greear Terri Daniels Anticipated completion date: March 2026 Planned Corrective Action: The three payments made were paid one to two days after the 30 day reimbursement requirement. The City will review its subrecipient payment terms and implement additional processes to help ensure compliance with federal payment requirements.

Significant Deficiency Item 2025-007 - Cash Management - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 H80CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 HBHCS46163-03-01 During our audit, we noted that there is no evidence of review and approval of drawdowns from the Health Center Program Cluster and the supporting records. Recommendation: We recommend that LBUCC implement a policy that requires all drawdowns and supporting documents to be reviewed and that such review and approval be documented. Action Taken: LBUCC revised the drawdown policy which now includes a review and approval from the CFO and the process is documented. Effectivity Date: Implemented 12/3/2025.

Material Weakness Item 2025-003 - Period of Performance - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8/-ICS46163-03-01 During our audit, we noted that LBUCC drew down $190,688 of federal grant funds under the Section 330 program for the budget period beginning June 1, 2024 to reimburse salary expenses incurred in May 2024. Recommendation: We recommend that LBUCC implement procedures to ensure that all drawdowns are supported by expenses incurred strictly within the grant's approved period of performance and train staff on grant compliance requirements. Action Taken: A change in the process to draw down funds has been implemented to determine that the funds were incurred in the proper funding period rather than the period it was paid. Effectivity Date: Process change was implemented 12/1/2025.

Material Weakness Item 2025-002 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 H80CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8HCS46163-03-01 During our audit, we noted that LBUCC did not properly determine the sliding fee discount provided to certain eligible patients based on information provided during the patient registration process. Additionally, we could not ascertain if the sliding fee discount provided to certain eligible patients were correct as LBUCC did not maintain documentation of the proof of income of those eligible patients. Recommendation: We recommend that LBUCC conduct training of all of its personnel who are involved in determining and applying the sliding fee scale of patients. We also recommend LBUCC to maintain complete and auditable documentation supporting each patient's eligibility for sliding fee discount. Action Taken: Eligibility was provided additional training which included training on a tool to assist them in determining the proper sliding fee discount. Effectivity Date: Training was held on October 28, 2025, and the tool to assist them was reviewed and provided at that time and implemented immediately thereafter.

Finding #2025-002 – Significant Deficiency and Other Noncompliance – Reporting. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.959, Passed through Texas Health and Human Services Commission, All contracts, Contract years: 09/01/23 – 08/31/24 and 09/01/24 – 08/31/25. Condition and context: In our testing of a sample of monthly billings and quarterly reports from throughout the fiscal year, we noted that reports were not being submitted within the required timelines for several reporting periods. Management communicated their delays to Texas Health and Human Services Commission (THHS), and their plan to rectify the delays. Phoenix Houses of Texas were able to file all delayed quarterly reports and monthly billings prior to June 30, 2025. THHS has approved all the delayed monthly billings and quarterly reports. Recommendation: Re-emphasize internal controls over timely grant billing and reporting to comply with grant contracts. Planned corrective action: All outstanding billings were subsequently submitted and billings are now current and submitted in accordance with required timelines. Corrective actions implemented include updates to Finance Department policies and procedures to formalize month-end closing and billing timelines and to strengthen oversight and monitoring controls. These changes ensure that billing and reporting are performed on a timely and ongoing basis. Responsible officer: Drew Dutton, CEO and Anunoy Mou, Finance Director. Estimated completion date: Completed September 2025.

2025-001 Reporting US Department of Education – AL #s10.553, 10.555, 10.559 and 10.582 Child Nutrition Cluster Condition: The District submitted monthly child nutrition reimbursement claims that contained inaccurate meal counts for multiple months during the fiscal year. Specifically, the District overstated reimbursable meal counts due to errors in including non-reimbursable meals served. Additionally, the claims were not subject to an independent review prior to submission to ensure accuracy and completeness. Name of Contact Person: Ann Berman, Business Manager Plan of Action: The District will revisit the internal control processes surrounding the grant reporting and reimbursement process to ensure meal count information submitted is within program requirements of Child Nutrition Cluster programs. In the event there are questions surrounding meal count and other information subject to reporting, the District will continue to rely on timely guidance from external governmental accounting consultants, the Oregon Department of Revenue, and the Oregon Department of Education.

2025-002 – Significant Deficiency and Noncompliance – Federal Policies Corrective Action Plan: The City will develop and adopt a comprehensive Uniform Guidance compliance manual that addresses procurement, allowable costs, cash management, subrecipient monitoring, and internal controls. A Federal Compliance Officer will be designated to oversee policy implementation and annual updates. Standard operating procedures will be issued for relevant departments, and mandatory staff training will be conducted. These actions will be completed by March 31, 2026, with ongoing monitoring through quarterly compliance meetings. Anticipated Completion Date: March 31, 2026

Management concurs with the auditor's finding. The noncompliance resulted from a communication breakdown between the College and its third-party financial aid processing company, FAME, Inc. When William R. Moore College of Technology (the College) was placed under Heightened Cash Monitoring 1 (HCMl), staff did not immediately notify FAME of the status change. Had FAME been informed, the company would have updated the system configuration to restrict drawdowns until all credit balances were determined and paid. Although this was a communication lapse, the College did follow through on all U.S. Department of Educationdirectives related to financialresponsibility and provisional certification. Specifically, the College obtained and maintained the required Irrevocable Standby Letter of Credit (LOC) each time it was instructed to do so and amended the LOC amount in subsequent years as required by the Department. To correct this issue and ensure full compliance with federal cash-management regulations, the College has implemented the following actions: Notification Protocol and Financial Protection Requirements Before notifying FAME of any change in payment method (placement under or release from HCMl), the College must verify compliance with the Department of Education's Provisional Certification Alternative requirements under 34 C.F.R. § 668.l?S{f). The institution must submit an Irrevocable Standby Letter of Credit (LOC) or cash surety equal to 10% of the most recently completed fiscal year's Title IV funding. The College has complied with this requirement by obtaining and maintaining the LOC as directed and by amending the LOC amount ea'ch time the Department requested an updated financial protection amount. The LOC ensures funds are available to make refunds, provide teach-out facilities, and meet institutional obligations should the College close or terminate classes prematurely. The CFO confirms acceptance of the LOC by the Department before formally notifying FAME of any payment method change (HCMl, HCM2, or release). System Configuration Controls Once notified, FAME has confirmed that the system includes a compliance flag preventing drawdowns prior to disbursement while the College operates under HCMl. This configuration ensures that all Title IV reimbursements occur only after funds have been properly disbursed to students. Staff Training and Awareness Internal financial aid and accounting staff will participate in refresher training with FAME in Spring 2026. The training will cover: Title IV cash-management rules Communication and notification protocols Credit-balance determination and documentation standards Documentation and Oversight A written Title IV Reimbursement Checklist and Approval Workflow has been incorporated into the College's HCMl reimbursement process. The Financial Aid Counselor verifies completion of all disbursement and documentation steps prior to reimbursement. The CFO provides final authorization for each GS drawdown. 5. Monitoring and Continuous Improvement The College conducts quarterly internal reviews of Title IV drawdowns, reconciliations, and reimbursement documentation to confirm ongoing compliance. All findings are shared with FAME to maintain consistent alignment between systems and audit documentation. Anticipated Completion Date: All corrective actions were implemented by October 31, 2025; additional staff training is scheduled for Spring 2026. Status: As of June 30, 2025, the College is no longer operating under Heightened Cash Monitoring 1 (HCMl) and has returned to the standard payment method. However, corrective actions have been implemented; continued monitoring and staff training are in progress. Views of Responsible Official Management agrees with the finding. The noncompliance occurred due to a communication lapse between the College and its third-party processor, FAME, regarding requirements under the Heightened Cash Monitoring 1 (HCMl) payment method. In response, the College has updated its Title IV cash-management policies and procedures to ensure full compliance with federal regulations and the terms of its Provisional Certification Alternative under 34 C.F.R. § 668.175(f). Corrective actions include the submission and amendment of the Irrevocable Standby Letter of Credit, implementation of enhanced notification and verification procedures before alerting FAME of any payment-method changes, and establishment of quarterly internal reviews to confirm ongoing compliance with cash management and financial protection requirements.

ELIZABETHTON CITY SCHOOLS Material Weakness JUNE 30, 2025 School Nutrition Fund 2025-001 Response and Corrective Action Plan Prepared by: Beth Wilson, Director of Finance, Elizabethton City Schools Person Responsible for Implementing the Corrective Action: Regina Isaacs, School Nutrition Coordinator, Elizabethton City Schools Anticipated Completion of Corrective Action: May 31, 2025 Repeat Deficiency: No Planned Corrective Action: The student numbers were corrected and the USDA claims were adjusted before the end of the fiscal year. The School Nutrition Coordinator has been instructed to ensure that all students are counted correctly. Richard VanHuss Director of Schools

Name of auditee: MAC Housing Development Fund Corporation TIN: 014-EE134 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: September 30, 2025 CAP prepared by: Amanda Hamilton Finance Director Franklin County Community Housing Council, Inc. (518) 483-5934 Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Finding 2025-002 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation. Please see below for action taken. (b) Action taken: Management will reach out to HUD to request a wavier of the delinquent amount of $52,634. If the request does not get approved, Management will work towards an acceptable resolution.