Corrective Action Plans

3250 SACRAMENTO HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 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. FINDINGS—FINANCIAL STATEMENT AUDIT None noted FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Timely Deposit of Annual Residual Receipts No. 14.157. Program –Section 202 Supportive Housing for Elderly Personal Significant Deficiency 3250 Sacramento Housing should reevaluate its policies and procedures to ensure that required residual receipts deposits are made timely each year. Action Taken: This was an isolated incident for fiscal year ending 6/30/24. As soon as the oversight was realized, we took action to remedy it. In addition, we have updated our process to send out residual receipts deposits once we have a draft audit completed versus waiting until after the final audit to ensure deposits are made before the 9/30 deadline. If there are any changes post audit completion, they should be immaterial and would be deposited as soon as we have final numbers. This will ensure timely deposits. Confirmation of deposits are tracked and will be followed up on regularly to ensure we do not miss the residual receipts distributions from surplus cash in the future. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

We will deposit the delinquent amount when there is sufficient funds to do so.

Due to the number of grant programs the organization is managing, written policies will be developed and implemented to meet the requirements under the Uniform Guidance within the next year. The purpose of the policies will be to ensure that all grant funds, including reimbursable grants, are traced and recorded appropriately. Our contracted accountant is responsible for managing journal entries and recordings and will participate in these reviews. The quarterly reviews will be held on or about the third week of September, December, March, and June.

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. The third (2025-03) and fourth (2025-004) findings relate to federal cash management practices for Title Ill and TRIO grant programs. The audit determined that federal funds had been drawn down prior to immediate program expenditures, resulting in excess cash balances. To correct this issue, the College implements formal grant cash management procedures to ensure that internal controls over federal funds management are strong. Please review the details below: Corrective action 2025-004: Implement monthly grant reconciliation procedures, strengthen monitoring of federal drawdowns, and align disbursements with program spending patterns Target resolution: FY 2026

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. The third (2025-03) and fourth (2025-004) findings relate to federal cash management practices for Title Ill and TRIO grant programs. The audit determined that federal funds had been drawn down prior to immediate program expenditures, resulting in excess cash balances. To correct this issue, the College implements formal grant cash management procedures to ensure that internal controls over federal funds management are strong. Please review the details below: Corrective action 2025-003: Establish formal grant cash management procedures, implement monthly reconciliation of drawdowns vs. expenditures, and increase oversight of grant balances. Target resolution: FY 2026

Finding 2025-003 - U.S. Department of Education (USO), TRIO Programs (Significant Deficiencies): Information on the federal program - Student Support SeNices, FAL No. 84.042A, June 30, 2025; Ronald McNair Program, FAL No. 84.217A, June 30, 2025. Under 2 CFR 200.305, non-Federal entities must request Federal funds only for allowable program costs that have been incurred, and must maintain contemporaneous supporting documentation demonstrating: a. Actual, allowable expenditures existed at the time Federal funds were drawn; and b. Records supporting the nature and timing of those expenditures were on file and readily available. These requirements ensure 1. Corrective Action Description a. The College now mandates that GS drawdown requests include approved documentation stored on the accounting drive, effective July 31, 2025. b. Time and Effort reports must be submitted monthly with supervisor sign-off before reaching the Office of Sponsor Programs, showing 100% time allocation. Any changes will require a Personnel Action Form and administrative approval signatures. c. showing 100% time allocation. Any changes will require a Personnel Action Form and administrative signatures of approval. 1. Person Responsible and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu 2. Implementation Timeline This procedure took effect as of July 31, 2025. 3. Planned Preventive Measures Following the policy and procedures to support all drawdowns with proper documentation. 4. Disagreement with the Finding None

Finding 2025-002 - U.S. Department of Education (USO}, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program - Federal Pell Grant Program, FAL No. 84.063, June 30,2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Teachers Education Assistance for College(TEACH),FAL No. 84.379, June 30, 2025. Under 2 CFR 200.305 and the U.S. Department of Education's cash management requirements at 34 CFR 668.162, institutions must draw down Title IV funds only for expenditures 1. Corrective Action Description The College now requires all drawdowns to include supporting documentation of the funds requested from GS, along with sign-offs on preparation and approval. Supporting documents are stored securely on the College's accounting drive for easy access. 2. Person Responsible and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu a. Implementation Timeline This procedure took effect as of July 31, 2025. b. Planned Preventive Measures Following the policy and procedures to support all drawdowns with proper documentation. c. Disagreement with the Finding None

Management agrees with the finding and funds will be moved from replacement reserve to residual receipts account.

Finding 2025-002 –Missing Records (Repeat Finding 2024-002) Management agrees with the recommendation and will implement stronger review processes to ensure proper documentation is in place to support pay-for-performance outputs and outcomes. Specifically, all program staff providing client charting and documentation will receive related training, both internally as well as from identified external sources. Accordingly, program staff attended a training on case management provided by an external partner in November 2025. In addition, a Case Manager Case Note Template has been developed that specifically outlines documentation required to support pay-for-performance outputs and outcomes including client intake, goals, activities and progress, and outcomes, as well as best practices for documenting client services. Finally, the organization will work with its external partners (PTEs, monitoring agencies, etc.) to ensure that requirements are consistently stated across all pertinent organizations and described in common nomenclature to avoid confusion and/or inadvertent omissions, which have been key factors contributing to the reoccurrence of this finding in FY25. The contact persons for the Corrective Action Plan are Lacy Stokes, VP of Family Empowerment and Self-Sufficiency; Ted Lewis, EVP of Operations and Information Technology (IAT Co-Chair); and Aaron Hernandez, Sr. Director, Finance (IAT Co-Chair). The anticipated completion date is May 31, 2026.

Finding 2025-001 – Incomplete Eligibility Documentation (Repeat Finding 2024-001) Management agrees with the recommendation and will implement stronger processes to ensure that records confirming the eligibility of program participants are obtained and properly maintained. Specifically, all program staff documenting client eligibility will receive related training, both internally as well as from identified external sources. Accordingly, program staff attended a training on case management provided by an external partner in November 2025. Internal training will center on the Employment and Training Eligibility Determination form developed by the program pass-through entity in March 2026. This document provides a detailed checklist of the specific information required to verify client eligibility prior to delivering program services. Finally, the organization will work with its external partners (PTEs, monitoring agencies, etc.) to ensure that requirements are consistently stated across all pertinent organizations and described in common nomenclature to avoid confusion and/or inadvertent omissions, which have been key factors contributing to the reoccurrence of this finding in FY25. The contact persons for the Corrective Action Plan are Lacy Stokes, VP of Family Empowerment and Self-Sufficiency; Ted Lewis, EVP of Operations and Information Technology (IAT Co-Chair); and Aaron Hernandez, Sr. Director, Finance (IAT Co-Chair). The anticipated completion date is May 31, 2026.

The District will review their processes and procedures for quarterly financial submissions reported in the SAS Medicaid System for fiscal year 2025-2026. All contracted services will have proper documentation supporting the costs in the quarter that it relates to.

The District will review their processes and procedures for reimbursement claims. In addition, there will be a manager level review of claims for reasonableness.

The District will implement internal controls to properly record accounts payable on a timely basis prior to audit fieldwork. This will include an in-depth review and account reconciliation with substantiating support for all payables on our financials as of year-end.

Narragansett Bay Commission Corrective Action Plan For the Fiscal Year Ended June 30, 2025 NBC acknowledges and concurs with the finding 2025-001 in the Fiscal Year 2025 Single Audit of the Narragansett Bay Commission conducted by Bacon & Company LLC. The Bucklin Point Wastewater Treatment Facility Digester Complex Improvements “the Project”) has been funded by state revolving fund loan proceeds from the Rhode Island Infrastructure Bank (RIIB) and a Department of Energy grant. NBC’s contracting for civil projects has procedures in place to ensure the inclusion of all applicable Federal requirements as it relates to the use of RIIB funds. Although the Project followed Federal requirements as it relates to RIIB funds, NBC did not have appropriate controls in place to verify that applicable construction contracts for the Project included additional Federal requirements related to compliance with the Build America, Buy America Act as ostensibly required by the Department of Energy grant agreement. NBC has subsequently verified and received certification from the Project’s prime contractor that the Project satisfies Build America, Buy America Act requirements. Corrective Action Plan: In order to ensure that all applicable grant agreement terms are satisfied, NBC has hired a grant administrator to centralize all grant related activities within the Finance Division. NBC intends to develop additional procedures in conjunction with the acceptance and execution of a grant agreement to accomplish the following: 1) Coordinate with applicable Cost Center (as grant recipient) to verify that NBC has the ability to comply with the terms of the grant agreement, and 2) Create a comprehensive checklist of key obligations, including reporting deadlines, allowable costs, matching requirements, and special conditions and verify continued compliance on a regular interval, and 3) Limit award of contracts, expenditure of funds for grant funded projects, and reimbursement requests for grant funds until grant administrator verifies compliance with applicable terms and conditions. Anticipated Completion Date- May 31, 2026 Contact Person – Kevin McDonald, Chief Financial Officer

Name of Responsible Individual: Vice President of Financial Operations/CFO (Michelle Lane) Corrective Action: The University concurs with the findings. Shaw University acknowledges that this finding is a repeat condition related to excess cash balances for Pell Grant, Direct Loan, and FSEOG funds not being eliminated within the required seven business days. Management has determined that prior corrective actions were not sufficiently formalized or consistently executed, particularly with respect to reconciliation and monitoring controls. Since that time, the University has strengthened its internal controls over Title IV cash management. A formal monthly reconciliation between G5 drawdowns and the general ledger has been implemented to ensure excess cash balances are identified and resolved timely. In addition, procedures have been revised to limit drawdowns to actual or immediate disbursement needs, and monitoring controls have been established to ensure compliance with the seven-business-day requirement. Management will continue to monitor these processes to ensure ongoing compliance with federal cash management regulations. Anticipated Completion Date: June 30, 2026

Recommendation We recommend the District implement documented daily edit checks reconciling meal counts to attendance records and maintain records of this review. For food inventory, the District should establish a formal inventory system, including perpetual inventory records, monthly physical counts, and supervisory review. Staff involved in Child Nutrition operations should receive training on USDA and federal compliance requirements Management Response Corrective Action The Food Service Director will implement the federally required daily edit check process. This will include comparing daily meal counts against the attendance and enrollment figures to ensure that claims do not exceed the number of students present. Any discrepancies identified during this process will be investigated and documented prior to submission of the monthly claim. The District will also change the tracking of meals served by using an official meal tracking device or by having students use their badge/ID cards to get a more accurate meal count each day. The District has a formal inventory process for all food service supplies including canned goods, dry goods, and freezer items. This system tracks items from receipt through consumption. The District conducts monthly physical inventory counts of all food service assets. These counts are reconciled and any significant variances are reviewed by the Food Service Director and reported to the Business Manager. The District will ensure that all nutrition staff is trained on these procedures as well. Due Date of Completion: June 30, 2026 Responsible Party Business Manager, Food Service Director

Management Response The University concurs with this finding. Management has reviewed its processes for monitoring and issuing Title IV credit balance refunds and has implemented procedures to ensure refunds are processed within the required 14-day timeframe. The Financial Aid and Student Accounts offices will review credit balance reports on a regular basis to identify students eligible for refunds and confirm timely disbursement. In addition, staff have been reminded of federal requirements related to credit balance refunds. Management will monitor this process periodically to ensure ongoing compliance. Corrective Action The University reviewed the federal requirements for refunds with applicable members of the Business Office and Financial Aid departments to ensure a thorough understanding of the refund rules. The University enhanced its weekly credit balance review process to require explicit review by the Controller and Director of Financial Aid if uncertainty exists on whether a student is eligible for a refund. This review must be completed within the 14 day period with either the refund issued or the loan removed from the student’s account. Contact Person Responsible Name – Richard Jones Title – Controller Phone – 410-532-5367 Email – rjones13@ndm.edu Anticipated Completion Date – April 30, 2026

C. Cash Management; L. Reporting Evidence of Review and Approval of the Reported Expenditures Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Federal Agency: Department of Health and Human Services Department of Justice Recommendation: Management should reassess the design of its controls to ensure documentation is retained that evidences the review and approval of expenditures submitted to the DOJ and DHHS for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. ORSPA and Corporate Financial Reporting are developing standard operating procedures and policies for the required review and reconciliation of grant expenditures per the accounting system to the financial submissions to the granting agency, including requirements for maintaining evidence of the review(s). A shared central repository for financial submissions was created. For each grant, this repository includes the financial submission and evidence of review and approval of the financial report submissions. The ORSPA and Corporate Financial Reporting will monitor the repository and work with grant managers to ensure evidence of financial submission review and approval is maintained. Anticipated Completion Date – June 30, 2027 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

2025-102 The County did not develop internal control procedures over program reporting and cash management requirements, increasing risk of report errors to awarding agencies and wrongly receiving monies Cluster Name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and program names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award Numbers and years: IGA DI21-002286 July 1, 2024 through June 30, 2025 IGA DI23-002389 July 1, 2023 through June 28, 2028 Assistance Listings numbers and program name: 21.027 COVID-19—Coronavirus State and Local Fiscal Recovery Funds Award Numbers and years: 1505-0271 March 3, 2021 through December 31, 2024 CT-FM-22-149 October 1, 2024 through September 30, 2025 SLFRFP1962 January 5, 2023 through December 31, 2026 CTR069300 January 1, 2024 through December 30, 2026 GTAW-FM-23*123 October 3, 2022 through July 3, 2026 ACJC-VC-25-001A July 1, 2024 through December 31, 2024 Assistance Listings numbers and program name: 93.268 Immunization Cooperative Agreements Award numbers and years: CTR062571 July 1, 2022 through June 30, 2025 CTR059891 July 1, 2022 through June 30, 2027 Name of contact person: Art Cuaron, Director, Finance and Risk Management Anticipated completion date: June 30, 2027 The County recognizes the need to strengthen internal controls over federal reporting and cash management requirements. F&RM will complete the following actions to ensure compliance with 2 CFR Part 200: 1. Establish written internal control policies and procedures for federal program reporting. All federal financial reports will undergo an independently documented review before submission to ensure accuracy, allowability, and proper reporting periods. 2. Implement documentation standards requiring staff to retain supporting materials such as system reports, financial queries, screenshots, and reconciliations, in accordance with federal and County retention requirements. 3. Pima County has been working with each of its grant implementing entities to use Euna Grants calendaring and reminders to prompt the entities’ timely reporting activities. Grants Management and Innovation (GMI) Department sets the reminders schedule at the onset of the performance period. The reminders are then automatically emailed to the grants manager and the assigned accountant for each grant on a set schedule throughout the course of the grant. GMI and Finance – Grants will continue to work with grant implementing entities to use these reminders to trigger the necessary actions in a timely manner. Pima County was still in the process of institutionalizing this system during FY25. 4. Provide training for staff who prepare and review federal reports, focusing on reporting requirements, documentation standards, internal controls, and record retention. 5. Conduct periodic management oversight reviews to confirm that internal controls are followed and that reports are complete, accurate, and submitted on time. The County is also planning to implement the Workday Grants Module with an anticipated go-live of July 1, 2027. This solution will enhance our ability to manage the full fiscal lifecycle of grant awards and ensure compliance with federal reporting requirements. The Workday Grants Module is a native Workday solution, purpose-built to support the full fiscal grant lifecycle. The module supports the following financial grant objectives: • Grant setup and award and fiscal tracking • Cost allocation and allocability controls • Real-time grant financial reporting • Compliance with federal Uniform Guidance (2 CFR 200) • Integration with Workday Financial Management, Procurement and Human Capital Management (HCM) In addition, F&RM has submitted FY 2026/27 budget requests to fund three additional Accountant III positions in our Finance – Grants Division. These positions will expand our capacity to manage our grant portfolio and strengthen our reconciliation, billing and SEFA preparation processes. The contract for the Workday Grants Module is scheduled to go before the Board of Supervisors for approval in April. These new positions will be included in the County Administrator’s Recommended Budget and will be considered by the Board as part of the full budget adoption process in June.

Supporting Services for Veteran Families Program – Assistance Listing No. 64.033 Recommendation: The Organization should design controls to ensure the draw down requests and related support are formally reviewed and approved by the Finance Director before submitting the request to the awarding agency and that the support is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the audit period, drawdown requests were accelerated in response to communications indicating potential limitations in access to the federal funding portal. While all expenditures were supported by underlying accounting records and program activity, formal pre-submission review and documentation procedures were not consistently applied. Moving forward, the Organization will implement a control requiring that all drawdown requests be supported by documented expenditures and formally reviewed and approved by the Finance Director prior to submission. Drawdowns will continue to be performed on a reimbursement basis (in arrears), ensuring alignment with recorded program expenses, and all supporting documentation will be retained and reconciled to the general ledger to ensure completeness and compliance. Name(s) of the contact person(s) responsible for corrective action: Noah Masson Planned completion date for corrective action plan: 3/31/2026

Supporting Services for Veteran Families Program – Assistance Listing No. 64.033 Recommendation: The Organization should design controls to ensure the draw down requests and related support are formally reviewed and approved by the Finance Director before submitting the request to the awarding agency and that the support is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization understands that guidance received during the grant period for utilizing the de minimis method indicated that a modified total direct cost rate of up to 15% (capped at 10% of the total grant) may be allowable under the program; however, based on the audit interpretation, the Organization acknowledges that a modified total direct cost rate of 10% under federal guidelines may be applicable. Accordingly, the Organization will align with the applicable de minimis requirements and will obtain and retain clear documentation supporting the approved modified total direct cost rate for the program. Name(s) of the contact person(s) responsible for corrective action: Noah Masson Planned completion date for corrective action plan: 4/30/2026

Condition: During audit fieldwork, our testing resulted in a restatement of fund balance in order to correctly record interfund activity. Plan: The District will implement internal controls to properly record interfund balances on a timely basis prior to audit fieldwork. Anticipated Date of Completion: The District will correct this for the 2025-2026 school year. Name of Contact Person: John Belter, Business Manager Management Response: The District will implement internal controls to properly record interfund balances on a timely basis prior to audit fieldwork.

Condition: The District did not timely report the quarterly submissions. Plan: The District acknowledges its lack of timeliness for the quarterly reports and will continue to review its procedures for submitting the quarterly financial submissions to ensure that they are submitted to the SBS Medicaid System in a timely manner. Anticipated Date of Completion: The District will correct this for the 2025-2026 school year. Name of Contact Person: John Belter, Business Manager Management Response: The District acknowledges its lack of timeliness for the quarterly reports and will continue to review its procedures for submitting the quarterly financial submissions to ensure they are submitted to the SBS Medicaid System in a timely manner.

Condition: The District's supporting documentation for any students who filled out an online application was not properly maintained. Plan: The District will print and save copies of all online applications to enhance record retention. Anticipated Date of Completion: The District will correct this for the 2025-2026 school year. Name of Contact Person: John Belter, Business Manager Management Response: The District acknowledges the lack of supporting documentation for those students who completed online applications. The online applications did not transfer when the District rolled their systems and we no longer have access to the old system in which they were stored. The District notes this and will work to correct it in the future.

The District will work with the contractors to get the proper payroll records to meet the prevailing wage requirements agreed upon in the contract.