Corrective Action Plans

Significant Deficiency in Internal Control over Compliance and Other Matters Recommendation: Significant Deficiency in Internal Control over Compliance and Other Matters Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management believes the issue resulted from timing overlap with the prior year audit, as the transactions occurred in July and August 2024, shortly after the fiscal year-end June 30, 2024. To address this matter, management has retrained existing staff and is in the process of training the new CFO. In addition, management has performed a re-review of accounting records to confirm that no other instances of sales tax misclassification have occurred. Name of the contact person responsible for corrective action: Karen Harshman Planned completion date for corrective action plan: June 30, 2026

Views of Responsible Officials and Planned Corrective Action – Management agrees with the finding. The Organization will return the overpaid federal funds to the grantor upon identification of the duplicate reimbursement. To prevent recurrence, management will implement the following corrective actions: (1) establish a formal reconciliation between reimbursement requests submitted and expenditures recorded in the general ledger prior to submission, (2) require secondary review and approval of all grant reimbursement requests by a supervisor not involved in preparation of the request, (3) maintain a centralized reimbursement tracking log documenting submission dates, amounts, and approval confirmations, and (4) provide refresher training on federal cash management training to staff responsible for grant drawdowns.

JCCA CORRECTIVE ACTION PLAN March 23, 2026 Health Resources and Services Administration Jewish Child Care Association of New York (d/b/a JCCA) and Affiliated Organization respectfully submits the following corrective action plan for the year ended June 30, 2025. ____________________________________________________________________________________ CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: 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 number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT FINDINGS Finding 2025-001 – Account Analyses MATERIAL WEAKNESS Recommendation We recommend that the Agency implement policies, procedures and controls to ensure that all accounting records are analyzed and reconciled on a monthly basis. Action Taken BTQ Financial is spearheading a comprehensive stabilization project to refine the chart of accounts and reconstruct historical tracking for the permanent endowment fund. BTQ already has in place a rigorous monthly closing schedule. This includes establishing automated reconciliation protocols for program service revenue, endowment tracking, and inter-company accounts to ensure GAAP compliance and timely board reporting. These policies, procedures, and controls to ensure that all accounting records are analyzed and reconciled on a monthly basis have already been incorporated into FY2026 monthly close process. Finding 2025-002 – Information Technology – General Control Activities SIGNIFICANT DEFICIENCY Recommendation We recommend the Agency follow their policy for password age. We also recommend the Agency perform a risk assessment over the information technology environment. We recommend a written risk assessment and penetration test to be performed annually and vulnerability scans to be performed quarterly. Action Taken The Agency has configured NetSuite and Active Directory to programmatically enforce password aging and complexity requirements that strictly mirror our established IT Security Policy. Furthermore, we have moved beyond interview-based assessments to an annual cadence of formal, written risk assessments and penetration testing, supported by continuous monthly vulnerability monitoring through our Security Operation Center (SOC). An interview-based risk assessment was performed in Q3 2025, and monthly vulnerability scans are managed by Arctic Wolf, our Security Operation Center (SOC) service provider. To further strengthen our posture, we will initiate an annual cadence of formal external and internal penetration tests starting in Q2-Q3 2026. FINDINGS – FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, Unaccompanied Alien Children Program (Assistance Listing Number 93.676), FAIN # 90ZU0603, 90ZU0567, and 90ZU0536, for FY 2025 - Significant Deficiency Finding 2025-003 – Reporting Recommendation We recommend that management of the Agency implement procedures to track all federal reporting deadlines and ensure that reports are reviewed and submitted timely. This could include maintaining a centralized grant reporting calendar and implementing supervisory review prior to submission. Action Taken With the outsourcing to BTQ now fully operational, a centralized Federal Grant Reporting Calendar has been established. This calendar includes automated alerts for all 30/60/90-day deadlines. BTQ has also implemented a dual-level supervisory review process to ensure that all future reports are validated against the general ledger and submitted well in advance of federal deadlines. This protocol has been strictly applied to all federal reporting for the FY2026 cycle. U.S. Department of Health and Human Services, Unaccompanied Alien Children Program (Assistance Listing Number 93.676), FAIN # 90ZU0603, 90ZU0567, and 90ZU0536, for FY 2025 - Significant Deficiency Finding 2025-004 – Cash Management Recommendation We recommend that management of the Agency implement formal controls over the drawdown process that includes establishing procedures requiring documented supervisory review and approval of all drawdown requests and ensuring drawdowns are based on immediate cash needs so that federal funds are expended within a reasonable amount of time. Action Taken The Agency, in collaboration with BTQ Financial, has implemented a formalized "Drawdown Authorization Protocol." This new workflow improves upon the existing, and adds a standardized approach to every drawdown request, documented supporting schedules (showing immediate cash needs), and formal approval from BTQ’s PM, SVPF, VPF, or AVPF. This ensures a clear audit trail and prevents the accumulation of excess federal cash on hand. If the Health Resources and Services Administration has questions regarding this plan, please call Kenneth Shieh, Chief Administration Officer at (718) 747-4367. Sincerely yours, Kenneth Shieh, Chief Administrative Officer

Management’s response: Management concurs with the auditors’ finding and recommendation and will continue to implement the timeliness backlog remediation steps outlined in the CDBG Timeliness Workout Plan revised on September 9, 2025.

Management’s response: Management concurs with the auditors’ finding and recommendation. Metro Government will implement controls to ensure grant drawdown processes are followed, ensuring approvals are obtained before drawdowns are submitted and sufficient documentation is maintained by providing additional training to staff.

The Nutrition Cluster daily building counts that are submitted for the CEP program will be entered into Infinite campus daily and then the monthly number of counts in each building will be pulled from Infinite Campus and audited each month to make sure the paper backups match the totals in the system and then the finalized numbers will be used to submit the month end claim to the state for reimbursement

Views of Responsible Officials and Planned Corrective Action: Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. For Sample Items 3, 5, 30, 37, and 40, DMS is currently developing system upgrades that will establish a revalidation date that is 60 days prior to the revalidation expiration date and auto-terminate providers at the time of their revalidation expiration date if they have not successfully completed the revalidation process. For Sample Item 24, DMS is currently developing a system change to reinstitute revalidation requirements for Early Intervention Day Treatment and Adult Developmental Day Treatment providers. Anticipated Completion Date: 6/30/2026 Contact Person: Name: Elizabeth Pitman Title: Director, Division of Medical Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-244-3944 Email Address: Elizabeth.Pitman@dhs.arkansas.gov

Finding Number: 2025-031 AL Number(s) and Program Title(s): 93.778 – Medical Assistance Program (Medicaid Cluster) Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. For Sample Item 13, DMS is currently developing system upgrades that will establish a revalidation date that is 60 days prior to the revalidation expiration date and auto-terminate providers at the time of their revalidation expiration date if they have not successfully completed the revalidation process. For Sample Items 31, 35, and 40, DMS is currently developing a system change to reinstitute revalidation requirements for Early Intervention Day Treatment and Adult Developmental Day Treatment providers. Anticipated Completion Date: 6/30/2026 Contact Person: Name: Elizabeth Pitman Title: Director, Division of Medical Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-244-3944 Email Address: Elizabeth.Pitman@dhs.arkansas.gov

Finding Number: 2025-027 ALN Number(s) and Program Title(s): 93.767 – Children’s Health Insurance Program Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. For Sample Items 8, 11, and 28, DMS is currently developing system upgrades that will establish a revalidation date that is 60 days prior to the revalidation expiration date and auto-terminate providers at the time of their revalidation expiration date if they have not successfully completed the revalidation process. For Sample Item 30, a site visit has been completed for the provider. The process used for completion of site visits has been updated to address the cause for the delayed site visit. For Sample Item 12, DMS has implemented a system change to electronically collect information contained on the W-9 form which will eliminate the need for provider to submit the form. DHS is in the process of promulgating this policy change. Anticipated Completion Date: 6/30/2026 Contact Person: Name: Elizabeth Pitman Title: Director, Division of Medical Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-244-3944 Email Address: Elizabeth.Pitman@dhs.arkansas.gov

Finding Number: 2025-026 ALN Number(s) and Program Title(s): 93.767 – Children’s Health Insurance Program Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. For Sample Item 27, a site visit has been completed for the provider. The process used for completion of site visits has been updated to address the cause for the delayed site visit. For Sample Items 30 and 35, DMS is currently developing system upgrades that will establish a revalidation date that is 60 days prior to the revalidation expiration date and auto-terminate providers at the time of their revalidation expiration date if they have not successfully completed the revalidation process. Anticipated Completion Date: 6/30/2026 Contact Person: Name: Elizabeth Pitman Title: Director, Division of Medical Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-244-3944 Email Address: Elizabeth.Pitman@dhs.arkansas.gov

Finding Number: 2025-013 ALN Number(s) and Program Title(s): 21.029 – Coronavirus Capital Project Funds Views of Responsible Officials and Planned Corrective Action: ASBO acknowledges the auditor’s observation regarding the timing of disbursements following drawdowns from the U.S. Department of the Treasury. ASBO procedures include a 15-day internal processing target intended to promote efficient payment processing. While 19 of 34 drawdowns exceeded this internal benchmark, the applicable federal standard under 31 CFR § 205.33 requires recipients to minimize the time between drawdown and disbursement. Additionally, under 2 CFR § 200.305(b)(3), when the reimbursement method is used, payment must be made within 30 calendar days after receipt of a proper payment request. ASBO recognizes the importance of maintaining strong cash management controls and ensuring timely payment to subrecipients. The State of Arkansas is enhancing tracking, reconciliation, and workflow controls within its financial management processes to better monitor drawdown-to-disbursement timing. These measures are intended to strengthen timeliness and prevent recurrence. Anticipated Completion Date: June 30, 2026 Contact Person: Name: Glen Howie Title: State Broadband Director Agency: Arkansas State Broadband Office Address: 1 Commerce Way City, State, Zip: Little Rock, AR 72202 Phone Number: 501-683-6000 Email Address: broadband@arkansas.gov

Finding Number: 2025-011 ALN Number(s) and Program Title(s): 21.029 – Coronavirus Capital Project Funds Views of Responsible Officials and Planned Corrective Action: Administrative costs charged to CPF were program-related and remained within the statutory administrative cap. ASBO acknowledges, however, that documentation supporting the internal methodology used to allocate administrative costs across multiple broadband funding streams was not sufficiently formalized during the period reviewed. The identified variance of $22,516 reflects an administrative reconciliation issue rather than an unallowable expenditure, and the variance amount was reduced from a subsequent administrative cost drawdown. Moving forward, the team will more formalize its administrative cost allocation methodology to include a narrative explanation to support allocation percentages, as well as authorizing signatures. Anticipated Completion Date: June 30, 2026 Contact Person: Name: Glen Howie Title: State Broadband Director Agency: Arkansas State Broadband Office Address: 1 Commerce Way City, State, Zip: Little Rock, AR 72202 Phone Number: 501-683-6000 Email Address: broadband@arkansas.gov

Finding Number: 2025-008 ALN Number(s) and Program Title(s): 21.027 – COVID 19: Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Views of Responsible Officials and Planned Corrective Action: During the audit, initial evidence was submitted, including monthly and daily logs from vendor coaches to verify coaching activities. Additional documentation, including daily logs obtained from vendors, is available for review. Adjustments and recommendations that have resulted from this audit will be incorporated into future processes and requirements for vendor coaches, to further strengthen our oversight and ensure ongoing adherence to required standards. There are procedures put into place to monitor vendor adherence to scheduled coaching days, with vendors consistently held to a high standard and expectation to fully complete contracted days by requiring vendors to do the following: • Submit monthly evidence of coaching activities that align with contracted days. The Division Received monthly summaries from vendors detailing coaching support, activities, and specific dates when coaching was provided. • Conduct scheduled site visits with state content leaders • Complete monthly walkthroughs with school leaders, with consistency of walkthrough data being outcomes-based and providing tangible evidence that coaching actions directly supported the improvement of instructional programs. Data is collected through Jot Form and displayed on an Air Table Dashboard. This has been maintained since 2023. • Hold ongoing meetings with district staff to review outcomes and address improvement areas, ensuring fulfillment of literacy coaching contracts under Agency requirements Transparency and compliance remain a priority. Required documentation will continue to be accessible to support any future reviews. Anticipated Completion Date: Continuous. Contact Person: Name: Greg Rogers Title: Chief Fiscal Officer Agency: DESE Address: 4 Capitol Mall, Room 204-A City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-4475 Email Address: Greg.Rogers@ade.arkansas.gov

Finding Number: 2025-003 ALN Number(s) and Program Title(s): 10.646 – Summer Electronic Benefit Transfer Program for Children Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. The agency has updated its internal procedures to comply with FNS guidance that requires Summer EBT funds to be drawn down after expenditures are made. All funds expunged from EBT cards are in the process of being returned to FNS. Anticipated Completion Date: 3/31/2026 Contact Person: Name: Renee Ikard Title: Chief Financial Officer Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-681-8985 Email Address: Renee.Ikard@dhs.arkansas.gov

Finding 2025-003- Cash Management: Untimely Disbursement of Direct Loan Funds Condition: Direct Loan funds drawn down in December 2024 were not disbursed within the required 3-day timeframe. Corrective Action Plan: The College will improve compliance with federal cash management requirements using Colleague by: • Establishing written procedures requiring same-day or next-day disbursement processing after funds are received. • Performing a monthly reconciliation between drawdowns and student account postings. • Providing training on cash management requirements established by the U.S. Department of Education. Responsible Party: Director of Student Accounts Anticipated Completion Date: June 30, 2026

PRMP partially concurs with this finding. CMS requires timely payment to ensure that expenditures are valid and that federal funds are drawn only for allowable and properly incurred costs. PRMP will strengthen internal controls to ensure that all valid requests for payment are processed and paid within the 30-calendar-day timeframe required by **2 CFR §200.305(b)(1)**. However, the delayed application of credits results from administrative practices established by PRMP in response to limitations within the accounting system. Because the system cannot process negative balances, PRMP must wait until sufficient positive fund balances are available before issuing the return of outstanding credits. Additionally, to strengthen internal controls and ensure all required approvals were obtained, PRMP follows administrative practices that include awaiting receipt of CMS’s approval prior to reimbursing funds to the subrecipient.

PRMP respectfully disagrees with this finding. The responsibility for reporting quarterly drug utilization to manufacturers within 60 days after the end of each quarter, as well as the requirement for manufacturers to remit rebate payments within 30 days of receiving utilization data, is delegated to the Puerto Rico Health Insurance Administration (ASES) through the Memorandum of Understanding (MOU). PRMP is confident in this delegated process, particularly given that it was subject to audit and resulted in no findings for the year ended June 30, 2025. PRMP obtained the Puerto Rico Health Insurance Administration (A Component Unit of the Commonwealth of Puerto Rico) Financial Statements and Compliance Audit of Federal Financial Assistance for the Fiscal Year Ended June 30, 2025, and noted the following opinion: Opinion on Each Major Program (Page 46) We have audited the Puerto Rico Health Insurance Administration’s (the Administration) compliance with the types of compliance requirements identified as subject to audit in the OMB Compliance Supplement that could have a direct and material effect on each of the Administration's major federal programs for the year ended June 30, 2025. The Administration's major federal programs are identified in the summary of auditor's results section of the accompanying schedule of findings and questioned costs. In our opinion, the Administration complied, in all material respects, with the types of compliance requirements referred to above. Furthermore, the Medicaid Program initiates reimbursement of drug rebates to CMS once the following conditions are met: - The actuarial team completes its analysis and validation of the allocation of funds to be returned to CMS for each grant and population subject to the applicable FMAP rates. - PRMP receives the corresponding invoice to process refunds to ASES, reflecting the deduction of drug rebate collections. - The Puerto Rico Medicaid Program remits drug rebate funds to the Payment Management System Accordingly, the Puerto Rico Medicaid Program does not concur with the finding asserting that rebate collections were not properly identified, recorded, or credited to the Medicaid Program in a timely manner. Refunds are processed within the same quarter—or at the beginning of the subsequent quarter—following receipt of the final actuarial data, which provides the required distribution and identifies the associated grants. This sequencing ensures that remittances are based on complete, validated information and are aligned with the applicable federal funding allocations.

PRMP partially concurs with this finding and emphasizes that claims submitted to the federal government must accurately distinguish eligibility categories to ensure the appropriate federal matching percentage is applied. A corrective action plan has already been implemented as part of the Phase 3 rollout of the MMIS project, initiated in May 2024. This phase focuses on establishing a comprehensive Financial Management solution within PRMMIS. The enhanced system capabilities support the calculation, production, and distribution of capitation and supplemental payments to carriers, including automated adjustments and reconciliations. Stabilization activities have also included the conversion and reconciliation of legacy system data to facilitate a seamless transition.

The PRDOH agreed with the findings and is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, PRDOH is working and verifying our written procedures to ensure that payments are issued promptly after the drawdown is made.

240 Day Outstanding Payments Recommendation: We recommend the District implement a review process for outstanding student payments to ensure any that include Title IV funds are refunded to the U.S. Department of Education within 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The Financial Aid Coordinator will create and maintain a SharePoint spreadsheet to effectively track and monitor outstanding student payments. The Workforce Finance Department will support the setup and ensure the spreadsheet aligns with established financial monitoring practices. Responsible party: Financial Aid Coordinator and Workforce Finance Department Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: The Financial Aid Coordinator and Workforce Finance Department will conduct monthly reviews to ensure the spreadsheet is updated, accurate, and used consistently for monitoring outstanding payments.

The Educational Service Center believes in service to kids; thus, we sacrificed timing of certain items while ensuring documentation ultimately supported proper expenditures and required services were maintained throughout the year. We were in constant communication with ODJFS as to the status of each expenditure. Beginning with fiscal 2027, if we decide to continue such programs, we will no longer delay our reporting of information to ODJFS nor accept information from third parties after required due dates.

While all the costs reported to grantors were fully allowable per our contract, we continued to have some challenges in reflecting these costs in QuickBooks at the detailed level. We have implemented several accounting improvements that have addressed most of the differences between our cost reports by contract and QuickBooks. We continue, however, to face challenges in allocating indirect costs (allowed by a contract) down to the level of individual contract accounts in QuickBooks. The second continuing challenge is allocation of certain fringe benefits such as employee savings match and contributions to Health Savings Accounts down to the contract level for staff who work on multiple contracts. In the past month we have added new staff with greater experience in accounting and are implementing new ongoing reviews that will assure that our QuickBooks information remains exactly in sync with our fiscal reports.

Finding #SA2025-002 Unallowable Expenditures Charged to the Grant Assistance Listing Number: 20.507, 20.526 Assistance Listing Title: COVID-19 – Federal Transit Formula Grants (Urbanized Area Formula Program) – Federal Transit Cluster Name of Federal Agency: Department of Transportation Federal Award Identification Number: CA-2022-083-00, 2020-206, 2020-212 • Name(s) of the contact person: Melissa Munoz, Interim Assistant Finance Director • Corrective Action Plan: The City will develop procedures for grant management, accounting and reporting to ensure that only allowable costs are claimed. • Anticipated Completion Date: 06/30/2026

Finding #SA2025-001 Cash Management and Accuracy of Federal Financial Reports Assistance Listing Number: 20.507, 20.526 Assistance Listing Title: COVID-19 – Federal Transit Formula Grants (Urbanized Area Formula Program) – Federal Transit Cluster Name of Federal Agency: Department of Transportation Federal Award Identification Number: CA-2022-083-00, 2020-206, 2020-212 • Name(s) of the contact person: Melissa Munoz, Interim Assistant Finance Director • Corrective Action Plan: The City will develop procedures to ensure all grant-funded expenditures are included on drawdown request and prepared quarterly. Finance staff plan to have regular check-ins with department staff administering federal grants to obtain status updates on expenditures and drawdowns, and reconcile activities accordingly. • Anticipated Completion Date: 06/30/2026

Finding Numbers: 2025‐002 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Eloyce Gillespie, Business Manager Anticipated Completion Date: April 30, 2026 Planned Corrective Action: Casa Blanca Community School has implemented a review process to monitor expenditures across all funds. As part of this process, Management has adopted a review process relating to expenditures of all funds to minimize any negative effect on cash for these funds. This review includes a comparison of expenditures to budgets for all funds to ensure that they do not exceed anticipated revenues. Additionally, if it is determined that the program will exceed the anticipated revenue, Management will determine if such overages (negative cash balances) are to be addressed through operating transfers using Indian School Equalization Program funding.