Corrective Action Plans

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

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

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

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

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

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

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

Audit Recommendation a) 2025-004: Full Service Community Schools-Assistance Listing No. 84.215J Grant NO. - S215J220016 Grant Period-Year ended June 30, 2025 the auditors recommend the District to implement a process that ensures an understanding of the grant revenue and expenditure recognition process. Regular reconciliations should be performed and monitored against the grant finance reports. Expenditures should be monitored against the approved budgets and overspent grants. Corrective Action Plan a) 2025-004: The District plans to ensure in-depth training on all grants the District receives and require regular reconciliations to the general ledger by using our financial program as well a spreadsheet at the end of every month and institute more oversight over the grant process. Implementation Date - June 30, 2026 Person Responsible for Implementation - Colleen Bellinger, School Business Manager

Finding Number Federal Programs Audit: 2025-001; Responsible Person: Rachelle Roby; Management Views: Management agrees with the finding and is in the process of implementing the recommendation.; Corrective Action: The District will collaborate with the Director of Food Service to ensure that, when a physical count is conducted, the figures are verified by a second staff member for accuracy. Additionally, it will be required that all supporting documentation be submitted to the Chief Financial Officer (CFO) along with the claim figures. The CFO will review and compare the documentation against the data entered into the claiming system prior to the submission of the claim.; Anticipated Completion Date: 08/01/2025

Management has implemented a year-end reconciliation for all grant funds. Due to the timing of this grant - the District was able to capture the overpayment in the August 2025 expenditure report and therefore, no overpayment was owed. The District does not expect this finding to repeat again.

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following is the finding as noted in the Northern Michigan University Single Audit Act Compliance report for the year ended June 30, 2025, and corrective action to be completed. 2025-001 – Lack of Drawdown Review Procedures Auditor Description of Condition and Effect. The University did not have documented review procedures in place for federal grant drawdowns under the Research and Development cluster. Drawdowns were processed without a formal review or approval process to verify that amounts requested were based on allowable expenditures. This deficiency increases the risk of drawing federal funds in excess of actual expenditures or for unallowable costs, potentially resulting in noncompliance with federal regulations. Auditor Recommendation. The University should implement formal review procedures for all federal grant drawdowns, including enhancing policies around reviewing drawdowns, designated reviewers, and system controls to ensure drawdowns are accurate, allowable, and properly supported. Corrective Action. The University is developing formal grant drawdown review procedures that outlines required documentation and review steps around federal grant drawdowns. Responsible Person. Jamie Beauchamp, Controller Anticipated Completion Date. January 31, 2026.

Views of Responsible Officials and Planned Corrective Actions: The District will implement a secondary review process for verifying, entering, and confirming the status of the free and reduced applications. Documentation will be maintained to indicate the individuals performing completion and secondary review of required steps to verify timeliness and accuracy of eligibility determination and reporting.

Grant Cash Management – Community Development Block Grants Condition: 2 CFR 200.403 of the Uniform Guidance mandates that only necessary, and allowable costs be drawn down off of federal grants. During the audit, we found that the Water Plant Construction project had construction invoices being drawn down from two grant sources, resulting in total draw request exceeding total expenses. Corrective Action: The City understands what happened and will work on developing and implementing procedures to ensure that all invoices are not drawn beyond the amount expended. Contact Person Responsible for Corrective Action: John Dantzer, City Manager Anticipated Completion Date: This issue will be corrected moving forward.

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2025-003 Continuum of Care – Assistance Listing No. 14.267 Recommendation: We recommend that management ensure drawdowns are strictly aligned with incurred and allowable expense. This should include: - Pre-drawdown verification of expense documentation. - Monthly reconciliations of drawdown activity to actual expenditures. - Training for staff involved in federal fund management on Uniform Guidance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures related to federal drawdowns were not followed in this case. The finance department will review all procedures and ensure that staff are trained on proper drawdowns going forward. Name of the contact person responsible for corrective action: Christine Simiriglia, President & CEO Planned completion date for corrective action plan: June 30, 2026

Funds beyond actual expenses will be credited to the grant on the next claim request. UACD has discussed the mistake with the grantor and they have agreed to this action.

Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.003 Student Financial Assistance Cluster – Cash Management and Reporting Finding Summary: During the review of the reconciliation process, it was noted that only the month of January was reconciled as required by the DOE. The school is required to reconcile funds received from G5 with actual disbursement records submitted to COD. The school is required to account for any differences between the DOE’s records and the school’s financial and business records. Responsible Individuals: Director of Financial Aid and Director of Finance Corrective Action Plan: The College will implement a process that requires regular reconciliation of funds received with disbursement records submitted to COD. This reconciliation will be reviewed by both the Director of Financial Aid and the Director of Finance to ensure the records are reconciled. Anticipated Completion Date: Fall 2025

Condition: For the year ended June 30, 2025, it was noted that meals submitted for reimbursement included meals for students that were not eligible per the District's application for the program, resulting in the District being reimbursed in excess for an estimated $33,771. Recommendation: The District should apply for reimbursement for meals that were served to students included in their program application or take measures to amend the program application. Management Response: During the 2024-2025 school year, East Alton-Wood River Community High School District #14 began providing breakfast and lunch service for the Region III Journeys Program, an off-site alternative learning program serving students from multiple districts including EAWR. This was the first year EAWR had ever provided meals for Journeys, and the District implemented this service with the good-faith intention of ensuring that all students attending the program had access to daily nutritious meals. Because this was a new service arrangement, the District did not realize that our existing Community Eligibility Provision (CEP) approval documentation needed to be amended to include the additional educational site. The meals served to students at the Journeys Program were therefore included on the monthly reimbursement claims. The variance identified by the auditors reflects only the meals served at this second site, which are not captured in Skyward because some of the Journeys students are not enrolled at EAWR. There was no intent to misclaim meals, and the District did not receive financial benefit beyond the actual cost of preparing and providing meals. The additional breakfasts and lunches prepared for Journeys (approximately 20 breakfasts and 20-30 lunches daily) do not exceed the District's total CEP enrollment capacity and represent meals that were prepared, delivered, and made available to students. Additionally, in prior years another CEP district provided meals to the Journeys Program under similar circumstances without receiving reimbursement from Region III districts, which contributed to our understanding of customary practice within the cooperative. This was an administrative oversight associated with the first year of providing meal service to an off-site program and not the result of intentional noncompliance or an attempt to secure unearned reimbursement. No financial harm occurred to the program, as all meals claimed were prepared and made available to students in accordance with CEP expectations for universal access. To ensure future compliance, the District will amend its CEP application to include all educational centers served by EAWR in subsequent program years. Anticipated Date of Completion: June 30, 2026

Finding Number: 2025-002 Planned Corrective Action: Claims reimbursement will be inspected monthly by a separate person from who is inputting the data to ensure accurate filing of meals served. If discrepancies are discovered, the district will maintain support for the numbers that are submitted to DEW. Anticipated Completion Date: 12/31/2025 Responsible Contact Person: Jared M Bunting, SFO

2025-002 Significant Deficiency over Activities Allowed and Unallowed and Allowable Costs/Cost Principles The auditors recommend that the County implements a review control over weekly timesheets to ensure the timesheets include all program time coded on the day sheets. NCDHHS policy requires program salaries to be allocated and supported by payroll and attendance records for individuals. There is no disagreement with this audit finding. Annual day sheet training is now required for all staff that submit day sheets. Additionally, all new hires are required to complete day sheet training prior to submitting their first entry. A PowerBI dashboard has been created and released in June 2025 to pull data from both Workday (the County’s system of record) and our daysheet system, ISSI that provides supervisors the ability to show discrepancies between entries in real time. The County will also conduct random reviews monthly. Any discrepancies identified will be provided to staff leadership for support and correction. Additional reviews will be conducted for those staff with identified errors until released by leadership. Semi-annual reports will be provided to HHS Senior Leadership members to show trends and compliance with day sheet and timesheet entries. These reports will be created in December and June of each year. Person responsible for correction action: Leigh Anderson, HHS Business Administrator Completion date: The County has already implemented these changes.

The finance department will monitor federal budgets within GAPS and will do timely budget amendments with the SDE in order to make sure that all federal expenditures are spent within the proper function and object codes in GAPS.

2025-011 – ALN 14.872 – Public Housing Capital Fund Program – Cash Management Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vickie Case, Interim Executive Director Anticipated Completion Date: December 31, 2025

2025-005 – ALN 14.850 – Public Housing Operating Fund – Special Tests and Provisions – Insufficient Pledged Collateral Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Vickie Case, Interim Executive Director Anticipated Completion Date: December 31, 2025

This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim used incomplete Z-Reports which resulted in the meal claim being submitted for less than it should have been. The persons responsible for the corrective action are Lisa Newton, the Food Service Director and Corey Bordo, the Director of Business and Finance. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that all meal counts are final on the Z-Report before the claim requests are made.

Finding Number: 2025-001 Condition: The 2025 Schedule was initially overstated to include federal awards relating to ALN 14.251, Economic Development Initiative, Community Project Funding, and Miscellaneous Grants, expended during the year ended June 30, 2024. Planned Corrective Action: Food Bank of the Rockies, Inc. received a reimbursement grant for vehicles from the Department of Housing and Urban Development (HUD). While we purchased the vehicles in fiscal year 2024, we could not file the claim for reimbursement until fiscal year 2025. Guidance on the HUD claims process was greatly delayed for multiple reasons. We posted the cost and asset when ordered, following accounting principles generally accepted in the United States (GAAP). However, we did not include the funding on the 2024 Schedule as we had not yet filed the reimbursement claims, nor been given assurance they would be paid. Instead, we included it in the fiscal year 2025 Schedule as that was when the claims were filed and we had confirmation they would be paid in full. We understand now that, per Uniform Guidance 2 CFR 200.51(b), those funds should have been shown the fiscal year 2024 Schedule. With this understanding, moving forward we will include in the Schedule amounts that have been spent for which we have an agreement for reimbursement, regardless of timing of the claim being filed or level of certainty of reimbursement. Contact person responsible for corrective action: Heather MacKendrick Costa Anticipated Completion Date: Completed

2025-003 - Missing Evidence that Monthly HUD-52670 Forms are Reviewed Corrective Action: Findings were related to evidence missing that Monthly HUD-52670 forms are reviewed. Corrective action has been implemented in ensuring the check list was revised to ensure parties will review of the Monthly HUD-52670 Forms and sign off as evidence of review. Additional corrective action has been implemented in ensuring checklist form will be reviewed and initialed by another staff member so there will be a cross check. Controls continue and remain in place to assure compliance, including, but not limited to, centralization of files, improved orientation procedures and periodic internal reviews conducted by Finance staff. Assigned to: Kenneth P. Parent, Director of Residential Leasing