Corrective Action Plans

Statement of condition 2025-001: During the year ended March 31, 2025, management submitted a 9250 to withdraw funds from the reserve for replacements fund that included the same invoice as a previously approved 9250. The reserve for replacements account was not reimbursed for the duplicate withdrawal. Comments on the finding and each recommendation: Management should transfer $14,376 from the operating cash account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. On May 29, 2025, management transferred $14,376 from the operating cash account to the reserve for replacements account.

A policy will be put in place that only funds that approved by HUD will be withdrawn from the replacement reserve account. The policy will be in place and effective by May 31, 2026.

A policy will be put in place that only funds that approved by HUD will be withdrawn from the replacement reserve account. The policy will be in place and effective by May 31, 2026.

2025-001 Reportable Condition — Compliance: Condition: The Organization did not receive HUD authorization for three withdrawals from the Residual Receipts account totaling $18,354 during the year. Action taken: $5,000 has been returned to the Residual Receipts account. Contact person: Nancy Jordan Completion date: May 15, 2025 Explanation of Disagreement: Not applicable Repeat finding: No

Management, under new leadership and with the appointment of a new Vice President of Finance, is taking proactive steps to address the timely completion and submission of the Single Audit. The organization is strengthening its finance department by enhancing staffing levels and providing targeted training to ensure team members are fully equipped to meet reporting requirements. In addition, management is leveraging support from third-party advisors and an external consultant to improve reporting processes and internal controls. These combined efforts are focused on ensuring that the Single Audit is completed and submitted to the Federal Audit Clearinghouse within the required timeframe, thereby enhancing compliance and financial accountability.

Federal Program - U.S. Department of Housing and Urban Development Assistance Listing Number 14.157 - Supportive Housing for the Elderly (Section 202) Material Weakness & Noncompliance Category of Finding - Cash Management Name of contact person – Nation Wright, AICDC Chief Operating Officer Corrective action – The Corporation has changed management agent to Tapestry which has the procedures and controls in place to detect and prevent a similar finding to occur in the future. Completion date – Management and the Board of Directors implemented the above as of December 2024.

2024-003 Document Policies and Procedures Over Federal Awards Cluster/Program: All federal programs Type of Finding Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Condition: The Town has not formalized written policies and procedures related to federal awards required under the Uniform Guidance. Criteria: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: • Cash management • Determination of allowable costs • Employee travel • Procurement • Conflicts of interest • Subrecipient monitoring and management Cause: The Town has not developed written formal documentation of internal controls to encompass all required areas per the Uniform Guidance. Effect: The Town is not in compliance with the requirements of the Uniform Guidance as it relates to the requirement to have documented policies and procedures pertaining to the management of federal awards. No questioned costs are reported as this requirement is procedural in nature. Recommendation: Written policies and procedures should be implemented in accordance with the Uniform Guidance. Views of Responsible Official: The reconciliations of retirement board accounts were handled through a third party prior to January 2024. There have been delays in obtaining the files from the third party. With the hiring of the new director in January 2024, the reconciliations are now performed in the Retirement office, by the retirement staff. We anticipate that the records will be available upon request in the future.

Name of auditee: Hollywood West Tenant Action Committee HUD auditee identification number: 122-44641 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2024 CAP prepared by Name: Noel Sweitzer Position: President, HDSI Management, Inc. Telephone number: (323) 231-1104 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition 2024-001: During the year ended June 30, 2024, the Corporation did not make the required deposits to the reserve for replacements in the amount of $12,747. Recommendation: Management should request approval from HUD for a transfer from the residual receipt account to the reserve for replacement account in the amount of $8,498 to correct the error. Management should also make the additional deposit of $4,249 or request a suspension of deposits from HUD. Action(s) taken or planned on the finding: Management has requested approval from HUD to transfer the funds to the reserve for replacement account and will make the additional deposit during the year ended June 30, 2025.

The Tallapoosa County Board of Education will implement additional controls to ensure accurate meal counts are reported on Claims for Reimbursement for the School Breakfast Program. Procedures will be strengthened to ensure meal counts are taken daily at the point of service (where students walk through the cafeteria lines) and verified against student attendance records when preparing reimbursement claims. The Child Nutrition Program staff will review meal count reports prior to submission to ensure the number of meals claimed does not exceed the number of students in attendance. Additional oversight will be provided to ensure compliance with federal Child Nutrition Program requirements.

MANAGEMENT WILL ENSURE THAT ALL FUTURE GRANT DRAWDOWNS ARE RETAINED IN THE BANK UNTIL SPENT ON ALLOWABLE GRANT EXPENSES.

There is now a new Clerk/Treasurer in place who is aware of the federal reimbursement requirements and will not allow reimbursement requests be made prior to the vendor receiving payment.

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 Officials: Michael Elizalde, Grants & Strategic Initiatives Director / Vidal Roman, Finance Director Timeline to Complete: Estimated June 2026

H. Period of Performance Timely Payment of Financial Obligations Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: As the grant period has ended, we recommend that the Corporation works with the funding agency to remedy the period of performance noncompliance. In addition, we recommend that the Corporation reassess the design of its period of performance controls to identify where enhancement or additional controls are needed over liquidation of financial obligations subsequent to the end of a grant award. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue to educate all grant managers on (1) the reporting capabilities within the system that can be utilized in the execution of monitoring payment status on individual invoices that have been submitted to granting agencies for reimbursement, and (2) the requirement to use their grant specific general ledger coding when orders are placed with vendors that are set up under the Corporation’s group purchasing process. For the specific vendor noted in Finding 2024-003, a grant number input field has been added to the group purchasing orders to allow for enhanced tracking and review of expenditures associated with grants and the monitoring of payment of those expenditures. The use of the accurate grant general ledger coding by grant managers when orders are placed will reduce the time between placement of order and payment of the invoice. The grant manager responsible for oversight of BHSB grants will work with BHSB to remedy the period of performance noncompliance noted in Finding 2024-003. Anticipated Completion Date – June 30, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

C. Cash Management; L. Reporting Evidence and Review and Approval of the Reported Expenditures and Timely Report Submission Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: Management should reassess the design of its controls to ensure submissions to BHSB are made timely within the required 15-day period and that documentation is retained that evidences the review and approval of expenditures submitted to BHSB 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 went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue educating grant managers on capabilities within the system that can be utilized in the execution of review and approval of grant expenditures prior to timely submission to the relevant granting agencies for reimbursement. Centralized repositories have been set up for grant managers to extract specific monthly financial reports for use in the execution of their controls, as well as to retain their review and approval evidence. Additionally, management is developing standard operating procedures and policies that include the requirements for compliance and internal controls for federal grants. The policies will acknowledge that for controls to be designed and operate effectively, there must always be a segregation of duties between the preparer of the control vs. reviewer and that clear documentation must be retained to evidence the execution of the controls. 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

Finding 2024-04 Schedule of Expenditures of Federal Awards. Management concurs with the finding. IHS will be working with the new outside CPA firm to develop a grant bridging report beginning FY2025/26.

Finding 2024-03 Filing of Single Audit Reports. Management concurs with the finding. Beginning July 1, 2025, IHS will be transitioning some of its financial reporting and audit support functions to an outside CPA firm specializing in nonprofit services. It is anticipated that this transition will help assist in meeting the single audit filing deadline.

Finding reference: 2024-004 - 93.137 – Community Programs to Improve Minority Health Grant Program Significant Deficiency and Noncompliance over Cash Management Recommendation: We recommend that the City review policies, procedures and practices in place to ensure drawdowns are reconciled to the general ledger, and reviewed and approved before requests have been submitted. Action taken: With the hiring of our grant accountant, the policy is that all drawdowns are to be reconciled to general ledger prior to submitting.

Finding reference: 2024-009 - 93.224, 93.527 – Health Center Program Cluster Material Weakness and Noncompliance over Cash Management Recommendation: We recommend that the City review policies, procedures and practices in place to ensure drawdowns are reconciled to the general ledger, and reviewed and approved before requests have been submitted. Action taken: With the hiring of our grant accountant, the policy is that all drawdowns are to be reconciled to general ledger prior to submitting.

United States Environmental Protection Agency Capitalization Grants for Clean Water Revolving Funds ALN: 66.458 Condition: The Village has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The Village’s Treasurer will work on updating all policies and procedures relating to the U.S. Office of Management and Budget Uniform Guidance to ensure the Village policies are in compliance with these guidelines. Responsible Contact Person: Linda M. Morrisey Village Treasurer Village of Ocean Beach Bay & Cottage Walks, P.O. Box 457 Ocean Beach, NY 11770 Anticipation completion date: March 31, 2026

As part of the proposal negotiations for the federal program, initial discussions with the sponsoring office of the federal program included a limitation for allowable compensation for employees that were not the Executive Director. Although the limitation was intended to be removed from the final agreement, the budgeted requested salaries were not updated. The Assistance Agreement has been modified to remove any such limitation prospectively beginning with Modification 0015 in April 2024. Implementation Date – April 2025

As is touched upon in the Cause, the Organization was unaware of audit requirements which resulted in delays for both the audit of the period ending December 31, 2023 and the audit of the year ending December 31, 2024. The Organization has engaged our current auditors to perform the 2025 audit, and it is expected to be completed by the September 30, 2026 deadline. Implementation Date – January 2026

2024-001– Allowable Costs – Internal Control over Payroll and Non-Payroll Costs Programs 64.024 Veteran Affairs Homeless Providers Grant and Per Diem Program 64.055 Staff Sergeant Parker Gordon Fox Suicide Prevention Grant Program Responsible Officials Stephanie Marchetti, Executive Director Cynthia Newsham, Director of Finance Plan Detail Based on the on the findings, the Executive Director and Director of Finance will review the organizational policies and procedures and create a cost allocation plan based on employment status. Once finalized the cost allocation plan will be reviewed and approved by the board of directors, who approve any policy changes before they are implemented. Anticipated Completion Date June 30, 2025

Finding Number: 2024-006 Finding Title: Financial Policies and Procedures Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Financial Management and Standards of Financial Management Systems (2 CFR §200.302(b)); Allowable Costs (2 CFR §200.403-405); Procurement (2 CFR §200.317-327); Cash Management (2 CFR §200.305); Travel Costs (2 CFR §200.475) Note: Organization has existing Conflict of Interest policy in compliance with 2 CFR §200.318(c)(1). Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization will establish formalized accounting policies and procedures that adhere to the requirements of the Uniform Guidance. Corrective Action Plan: Corrective Action #1: Comprehensive Policy Manual Development • Action: Engage consultant or work with Contract Accountant to develop comprehensive written financial policies and procedures manual addressing all Uniform Guidance requirements, including: (a) Allowable costs (2 CFR §200.403-405); (b) Procurement (2 CFR §200.317-327); (c) Cash management (2 CFR §200.305); (d) Travel costs (2 CFR §200.475); (e) Time and effort documentation; (f) Equipment management; (g) Subrecipient monitoring; (h) Financial reporting; and (i) Record retention. Ensure policies address financial management system requirements under 2 CFR §200.302. Tailor policies to Organization's all-volunteer structure. [Note: Organization already has Conflict of Interest policy complying with 2 CFR §200.318(c)(1).] • Responsible Person/Title: Board Treasurer with Contract Accountant • Anticipated Completion Date: April 30, 2026 Corrective Action #2: Board Approval and Adoption • Action: Present draft policies to full Board of Directors for review and input. Board will formally adopt policies by resolution. Document approval in Board meeting minutes. • Responsible Person/Title: Board President • Anticipated Completion Date: May 31, 2026 Corrective Action #3: Dissemination and Training • Action: Distribute approved policies to all Board members and Contract Accountant. Conduct training session for Board members and Contract Accountant on new policies and procedures. Board members and Contract Accountant will sign acknowledgment of receipt and understanding. Make policies readily accessible (e.g., shared drive, Board portal). • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026 Corrective Action #4: Implementation Tools and Support • Action: Develop templates, forms, and tools to support policy implementation. Create workflow diagrams and checklists for common transactions. Establish Board Treasurer as primary resource for policy implementation questions. • Responsible Person/Title: Board Treasurer and Contract Accountant • Anticipated Completion Date: July 31, 2026 Corrective Action #5: Annual Policy Review Process • Action: Schedule annual review of policies to ensure continued Uniform Guidance compliance. Update policies as needed for regulatory or organizational changes. Submit material policy changes to full Board for approval. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: Annually, beginning June 2027 Corrective Action #6: Governance Structure Assessment • Action: Board will evaluate establishing Audit Committee or combined Finance/Audit Committee to provide enhanced oversight of financial management, internal controls, and federal compliance. If Board size prohibits separate committee, designate at least two Board members with specific oversight responsibilities. • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026

Management has established separate bank accounts for the security deposits, residual receipts, and replacement reserve, and required deposits to the replacement reserve have been made.

The District Office has established a separate bank account for its Cafeteria Fund in fiscal year 25. The District is also in the process of implementing procedures to ensure cafeteria funds are used exclusively for allowable food service purposes and are properly monitored and reconciled.