Corrective Action Plans

The District Office will work directly with the Federal Programs Coordinator to ensure more timely submissions of Reconciliation of Cash on Hand Quarterly Reports and Final Expenditure Reports are prepared accurately and submitted timely in accordance with grant requirements. The Business Manager will do this by creating reminders on the Business Manager’s calendar that include due dates each quarter and reminding the Federal Programs Coordinator when their respective reports are due. The District will implement and form a review and monitoring process and provide any necessary training to staff responsible for grant reporting to ensure ongoing compliance.

The City will ensure that all future expenditures are tracked and reported to the proper periods and recorded appropriately.

Management will implement standardized cash drawdown procedures to ensure federal funds are requested only for immediate cash needs in accordance with Uniform Guidance. A consistent drawdown calculation template will be used, supported by incurred and allowable expenditures. Monthly reconciliations of drawdowns to actual expenses will be performed, and staff involved in federal fund management will receive training on federal cash management requirements.

Management Response: We acknowledge that some 1571 reports were submitted after the required deadline due to internal staffing transitions and competing reporting priorities. Planned Corrective Action: Management has implemented a compliance calendar with automated reminders and a secondary review process to ensure timely submission of all DSS-1571 forms. Cross-training has been completed to ensure adequate coverage during staff absences. In addition, a formal procedure is now in place to request extensions when a reimbursement cannot be submitted by the 10th of the month. Name of Contact Person: Anna Eaton, Executive Director

Management Response: Management acknowledges that certain expense and salary allocations were not fully aligned with the approved grant budgets, primarily due to staffing transitions and evolving program priorities. These changes temporarily impacted the consistency of allocation methods and review processes. methods and review processes. Planned Corrective Action: Management has implemented monthly reconciliations between expense allocations and the approved budgets to ensure ongoing accuracy and compliance. An ORR tracking sheet is now used to verify expenditure allocations against current budgeted amounts prior to each reimbursement submission, ensuring that all costs are allowable, properly supported, and aligned with approved grant budgets. Name of Contact Person: Anna Eaton, Executive Director

2024-007: Material Weakness and Noncompliance – Written Policies Required by the Uniform Guidance Statement of Condition/Criteria: Delta County does not have written policies and procedures to implement the requirements of 2 CFR section 200 for the administration of federal awards. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. Planned Corrective Action: County management will develop written policies and procedures for grants. Contact person responsible for corrective action: Emily DeSalvo, County Administrator Anticipated Completion Date: March 2026

FINDING NUMBER 2024-002 Reporting views of responsible officials: The Company will monitor cash balances or monitor the bank ratings. Concur or do not concur with the finding: Concur with the finding Auditors' summary of auditee's comments on the findings and recommendations: The Company should monitor the investments held by these financial institutions to ensure that HUD’s requirements are met. Response indicator: Agree. Response: The Company should monitor the investments held by these financial institutions to ensure that HUD’s requirements are met. Completion date: December 31, 2025

Corrective Action Plan Year Ended September 30, 2024 Finding 2024-002 AL Numbers: 97.036 Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Correction Action: Brown Health management asserts that the methodology applied to estimate and avoid duplication of benefits was reasonable, allowable, and consistent with FEMA guidance. The projects were previously reviewed, approved, obligated, funded, and closed or in pending close status by FEMA. Formal appeals of FEMA’s subsequent recommended reduction for Bradley Hospital and Newport Hospital were filed. Management continues to cooperate with FEMA and RIEMA during the appeal process. Accordingly, corrective action is contingent upon FEMA’s final determination. Contacts: Stephen Almonte, VP of Finance and Corporate Controller Salmonte3@brownhealth.org Mark Adelman, Director Public Policy and Federal Advocacy Madelman@brownhealth.org Planned Completion Date: Not applicable. Management will evaluate the need for any corrective action plan upon receipt of FEMA’s final determination on the pending appeals.

Management Response: Management concurs with the auditor’s finding and recommendation. For audit years ending on December 31, 2020, to 2024, HTHA recognizes that former Finance Director failed to timely reconcile some general ledger balances. We recognize that timely and effective account reconciliations are a critical component of internal control over financial reporting to prevent and detect material weaknesses. Anticipated Completion Date: To address the root causes of this material weakness, HTHA hired a Chief Financial Officer who will now implement the following corrective actions:  Standardized Operating Procedures: We will develop and implement a formal Standard Operating Procedure (SOP) by Spring 2026, to document the required frequency, format, and supporting documentation for all material reconciliations.  Staff Training: Mandatory training on the new reconciliation protocols will be conducted for all accounting personnel by June 2026, to reinforce accountability and technical proficiency. Responsible Party: Finance Director (responsible party for financial internal control during the audit year ending on December 31, 2024); and Chief Financial Officer (CFO) (responsible for internal control implementation starting in the year ending on December 31, 2025).

Finding 2024-002 Grant Budget Management Corrective Action Plan: Kankakee County Community Services, Inc. has implemented a comprehensive system to manage its grant budgets efficiently. Following the restructuring of its fiscal department and the engagement of an accounting firm, the organization established a robust, holistic process for overseeing all grant-related finances. Central to this approach is a budget monitoring calendar, which outlines key dates for report submissions, budget deadlines, and grant renewal periods. This calendar is accessible to all managers, fiscal staff, and the executive team, ensuring everyone remains informed of critical timelines. The Executive Director conducts weekly meetings with the senior leadership team to review ongoing tasks and discuss budget updates. During these meetings, the consultant CFO presents detailed reports on both required actions and the expenditures for each program. Person(s) Responsible: Mr. Anibal Vega Timing for Implementation: 3/1/2026

Finding 2024-001 Internal Controls over Financial Reporting and Late Filing of Data Collection Form Corrective Action Plan: Kankakee County Community Services, Inc. has reorganized its fiscal department to strengthen compliance with regulatory accounting standards. The organization engaged an accounting firm to assist in updating and restructuring its accounting policies and procedures. An accounting calendar was established to guide the fiscal team in preparing and maintaining internal controls as well as reporting requirements. Additionally, the board of directors’ finance committee convenes on the fourth Monday of each month to review all fiscal operations. Person(s) Responsible: Mr. Anibal Vega Timing for Implementation: 3/1/2026

2024-005 UNIFORM GUIDANCE AUDIT REPORTING REQUIREMENTS Federal Agency: Department of Transportation Federal Program: Formula Grants for Rural Areas and Tribal Transit Program Assistance Listing Number: 20.509 Federal Award Identification Number and Year: MN-2020-020-01 Pass-Through Agency: Minnesota Department of Transportation Pass-Through Number: MN-2020-020-01, MN-2023-045-00 Award Period: Year Ended December 31, 2024 Compliance Requirement: Cash Management Type of Finding: Material Weakness in Internal Controls over Compliance Recommendation: The deadline for filing an audit report with the Federal Clearinghouse is 30 days after receiving the audit report or 9 months after year-end, whichever occurs first. It is recommended that prior to year-end, the operation board annually approve an audit schedule timeline. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Transit Board will annually approve a schedule and timeline prior to year-end. In addition, the Transit Board has hired new external auditors who will have sufficient resources to complete the audit by the September 30, 2026 deadline for the December 31, 2025, audit. Name of the contact person responsible for corrective action: Cecilia Mutharia, Transit Director Planned completion date for corrective action plan: June 30, 2026

2024-004 INTERNAL CONTROLS OVER CASH MANAGEMENT Federal Agency: Department of Transportation Federal Program: Formula Grants for Rural Areas and Tribal Transit Program Assistance Listing Number: 20.509 Federal Award Identification Number and Year: MN-2020-020-01 Pass-Through Agency: Minnesota Department of Transportation Pass-Through Number: MN-2020-020-01, MN-2023-045-00 Award Period: Year Ended December 31, 2024 Compliance Requirement: Cash Management Type of Finding: Significant Deficiency in Internal Controls over Compliance Recommendation: It is recommended the Transit Board designate qualified personnel for conducting the quarterly reporting review. The review should be performed and documented. Formal procedures should be documented to ensure consistency and effectiveness of the quality review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Transit Board will continue to evaluate their internal staff capacity to determine if an internal control policy over cash management and other areas is beneficial. Name of the contact person responsible for corrective action: Cecilia Mutharia, Transit Director Planned completion date for corrective action plan: June 30, 2026

Corrective Action Plan: The City of Chicago impedes the submission of expenditure reports by delaying the finalization of budgets or by not allowing GCI to submit expenditures when a budget change is submitted during the period when the change is approved. GCI will submit required expenditures upon execution of City contracts and will update them on time. Estimated Correction Date: GCI does not currently have any City contracts. When GCI enters into new City contracts, GCI will submit expenditures in a timely manner if the proper City documentation is available to complete the tasks. GCI has a new full-time Operations Manager, who will submit expenditures. Having a full-time manager familiar with all the expenditures and processing should make this task easier and timelier. Responsible Official: Nedra Sims Fears, Executive Director

Finding 2024-003 – Career and Technical Education - Perkins CFDA No. 84.048 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over compliance with cash management requirements as it relates to the Career and Technology 2023 AL No. 84.048 we discovered that in multiple instances requests for funds (Form RF-1) related to the grant was not based, as much as possible, on actual expenditures, rather than what is obligated. Criteria: Title 34 of the Code of Federal Regulations Section 80.20: Standards for financial management systems requires the following: (b) The financial management systems of other grantees and subgrantees must meet the following standards: 1) Financial reporting. Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or subgrant. 2) Accounting records. Grantees and subgrantees must maintain records which adequately identify the source and application of funds provided for financially-assisted activities. These records must contain information pertaining to grant or subgrant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. State Finance Regulations • Form RF1 for requesting funds through an on-line process has been developed to document the Department's distribution of funds on an "as needed" basis. The requests should be based, as much as possible, on actual expenditures, rather than what is obligated. Unexpended balances should not exceed 10% of funds received to date for any DESE administered grants. It is incumbent upon grant recipients to observe their expenditures closely and submit their RF1 forms within the designated timeframe, usually the last two weeks of the month, for requesting cash advances. Grant recipients may make requests in excess of the allotment schedule but must include a justification explaining the need for additional funds and additional documentation may be required. By submitting a request the grantee certifies that the request is in compliance with the "Cash Management Act" (31CFR part 205) and EDGAR regulations (34 CFR part 80.20 and 80.21), which allow for cash advances provided grantees maintain procedures to minimize the time elapsing between the receipt and disbursement of grant funds. Additionally, the grantee certifies that the obligations incurred under this project for which funds are requested, were made within the period of availability (project duration) stated in the grant award notice. The grant records in support of each request must be in sufficient detail to properly substantiate all claims for payment and expenditures made under the grant. Effect: Cash balances in excess of needs may be earning interest in excess of federal guidelines and would need to be returned. Questioned Costs: None Context: During our test of cash disbursements for the Career and Technology 2023 Final Request for Funds indicated fully spent however the grant was not fully spent as of 10/30/23. The School had to return the drawdown on 10/30/23 which also included additional unspent funds on 1/10/24. Cause: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Due to this, training in Edgrants was extremely limited and the FY23 grants mentioned where not handled correctly. Identification as a Repeat Finding: This is a not a repeat finding. Recommendation: The grantee’s administrative staff should establish procedures to ensure compliance with the cash management requirements as described in 31 CFR part 205. These procedures should include a thorough review of cash needs based on expenditures incurred as of the date of an anticipated draw down and how quickly those related liabilities are anticipated to be liquidated through the normal warrant (bill) payment process. Responsible for Corrective Plan: Sabrina Howley Estimated Completion Date: 11/5/25, Ongoing Action Taken: Going further no funds will be requested unless they have been expensed.

The Organization hired a new grant and partnership specialist. This specialist reviews all draws to ensure that the draw is for reimbursement for actual expenditure and not estimated expenditure. Reports and draws are also reviewed by the vice president of finance.

Audit Response to Finding 2024-002 to Uniform Guidance Audit - Advanced Drawdown Acknowledgement and Concurrence: Management acknowledges that two out of the six drawdowns selected for testing within the Research & Development (R&D) cluster were requested prior to the actual incurrence of the underlying expenditures. The University identified that the noncompliance was timing related only. A full year of stipend expenses were advance recorded in the general ledger and triggered the drawdown process prematurely. The University determined that this was an isolated incident unique to only one of the federal awards, and this issue has subsequently been corrected. While the grant was ultimately in a cumulative underdrawn position by year-end, we recognize that the reimbursement method under Uniform Guidance requires expenditures to be paid or incurred prior to the request for federal funds. Corrective Action Plan: • Enhanced Management Review: The University Controller’s Office will perform a "secondary review" of the GL date of the underlying expenditure versus the drawdown request date to ensure no "future-dated" or "anticipated" costs are included. • AP Policy Change: The University has revised its stipend processing workflow to ensure that payments are scheduled according to the service period rather than the entry date, and no longer will 12 months of stipend payments be entered in AP at one time. Responsible Party: Joseph J. Piccirilli, Chief Accounting Officer and Controller Completion Date: March 2026

Follow administrative costs cap guidelines for projects.

View of Responsible Officials: ICMEC discovered an error during FY2024 that resulted in overdraws for their Federal awards as well as drawing expenses from one award that should have been drawn under a different award. After meeting with the funder, ICMEC began to reduce its draws to reduce the overdraw balance. Additionally, ICMEC has received a modification and extension to one of its grants that allows for retroactive indirect and salary costs. As of 8/31/25, the net balance of all JTIP grants combined is close to zero. We are working to correct the individual balances.

Finding Type: Compliance with Uniform Guidance Requirements. Name of Contact Person: Mr. David Wyman, City Administrator, (573) 624-5959. Recommendation: We recommend the City develop written policies and procedures related to cash management, cost allowability, procurement, and conflict of interest provisions for federal funds it received. Corrective Action: We have already adopted the appropriate policies. Proposed Completion Date: Immediately.

Management acknowledges the need to streamline the fund reconciliation process and plans to improve.

Finding 2024 – 005 Lack of Individual with appropriate skills, knowledge, and experience Name of Contact Person: David Rosado, Executive Director Corrective Action: The Council agrees with this finding. The Council has hired a new Finance Director effective January 02, 2025, with the appropriate skills, knowledge, and experience to oversee the Finance Department. The Finance Director has identified and corrected internal control issues. Completion Date: May 19, 2025

The department will adopt written policies with the Uniform Guidance for federally funded grant programs accepted by the department.

JFS is in the process of hiring a new Chief Financial Officer (CFO) with pertinent experience for non-profits, governments, and billing. That person will lead the finance team to ensure best accounting and internal control practices are implemented and followed. During 2025, JFS strengthened its governance and internal control environment by implementing a centralized system for tracking all grant-related data in a single, secure location. All grant documentation is now maintained electronically within the organization’s OneDrive system, improving record retention, transparency, and audit readiness. The Finance Department established regular internal finance meetings, in addition to standing leadership meetings, to promote consistent communication, segregation of duties, and oversight across the finance function. Management continues to provide the Finance Committee of the Board with monthly financial reports; supporting ongoing fiscal monitoring and informed decision-making.

Condition: The board of education designated a limited number of individuals to authorize transactions. However, a signature stamp with the signatures of the board designated individuals was available for use by non-designated individuals. Plan: The District will stop the use of signature stamps to approve purchase orders and sign payment remittances. Anticipated date of completion: June 30, 2026. Name of contact person: Dustin Day, Superintendent. Management response: We no longer use signature stamps. All purchase orders and payment remittances are signed manually by the designated individual.