Corrective Action Plans

Type of Finding: Material Weakness in Internal Control over Compliance Division: Support Services Responsible Official: Chief, Support Services Target Completion Date: June 30, 2026 Status: In Progress 1. Summary of the Finding The FY 2024‑25 Single Audit identified deficiencies in internal controls over the District’s cash management practices for federal grants under ALN 66.001 and 66.039. Specifically, the District did not retain evidence showing that drawdown requests were reviewed and approved by the appropriate individual prior to submission. This control lapse occurred for all tested drawdowns and represents a material weakness in internal control over compliance. 2. Root Cause The District’s procedures for processing payment drawdowns did not require or document review and approval prior to submission. The lack of a formalized and documented approval step resulted in an incomplete audit trail and insufficient compliance documentation. 3. Corrective Action Plan The District will strengthen internal control over federal grant cash management by implementing formal approval, documentation, and oversight requirements for all drawdown submissions. A. Implement Formal Drawdown Review and Approval Procedures B. Establish Documentation and Retention Requirements C. Monitoring and Quality Assurance 4. Monitoring & Verification • The Chief of Support Services will oversee implementation and continuous compliance. • Compliance will be verified through quarterly internal reviews and a year‑end checklist confirming approval documentation for every drawdown. • All results will be retained and made available for future audits. 5. Expected Outcome These corrective actions will: • Ensure drawdown submissions are accurate, reviewed, and compliant with federal requirements. • Establish a complete audit trail documenting proper oversight. • Strengthen internal control over federal cash management and prevent future findings. • Reduce risk of inaccurate or unauthorized drawdowns and ensure sustained compliance with 2 CFR Section 200.303(a).

Cash Management – Assistance Listing Number 14.251 Recommendation: We recommend that management establish and implement policies to retain proof of amounts requested for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will establish and implement policies to retain proof of amounts requested for reimbursement. Name of the contact person responsible for corrective action: Joel Bailey Planned completion date for corrective action plan: December 31, 2026

Finding Number: 2025-003 Condition: The Organization failed to submit monthly reimbursement requests to HIAS by their due dates during the year ended June 30, 2025. Planned Corrective Action: The Organization has implemented system and process improvements to ensure timely submission. The Organization has and will continue to maintain appropriate staffing level and sufficient training to ensure timely submission. This plan does not account for circumstances beyond JFS’s control such as timing of funding approval from the grantor. Non-controllable delays will be documented by JFS and reports submitted in a reasonable amount of time following approval. Contact Person Responsible for Corrective Action: Justin Fisher, Senior Director of Accounting Anticipated Completion Date: August 31, 2026

Root Cause: The organization failed to correctly process claims under the correct contract. Once errors were detected, a correction was attempted in the CMBHS system, but the system reprocessed the claim with the original incorrect data and it could not be corrected. In addition, finance personnel lacked sufficient knowledge and training on how to prepare a Schedule of Expenditures of Federal Awards (SEFA) that accurately reconciles to the general ledger (GL). Corrective Action: 1. Review of existing policies and procedures for completeness. 2. Require supervisory review and approval of all grant-related expenditures prior to posting in external CMBHS system. 3. Continue to conduct training for finance staff on importance of data accuracy when processing in external systems. 4. Continue to reach out to CMBHS help desk and our contract manager to address issues as they arise. 5. Continue to perform monthly and quarterly internal monitoring reviews of grant expenditures to submitted claims. 6. Review of SEFA report with accounting team prior to submission to auditors Responsible Person: Patricia Guerra Implementation Date: • Supervisory review implementation: September 15, 2026 • Staff training: September 15, 2026 • Monthly and Quarterly monitoring reviews: Beginning September 30, 2026 Expected Outcome: All federal grant claims will be processed under the correct contract reducing the risk of future noncompliance

Finding Number: 2025-006 Condition: The Township did not have the appropriate controls in place to ensure reports and reimbursement requests that were required to be submitted under the grant were complete and accurate as well as ensuring the matching requirement was properly reviewed. Planned Corrective Action: The Township will update the Grant Policy to include a requirement for dual review on all grant reporting. Contact person responsible for corrective action: Finance Director Anticipated Completion Date: 3/31/2026

Finding Number: 2025-001 Condition: The Organization submitted a Request for Reimbursement (SF-270) that included $91,453 for the remaining balance of certain vehicle lease agreements that had not been paid at the time of the request, resulting in Federal funds held in excess of immediate cash needs. As of December 31, 2025, $51,642.70 remained unexpended. In addition, the semiannual financial reports submitted to the Forest Service reported the funds received as cash disbursed, overstating reported disbursements. Management response: Management concurs with this finding. The Organization acknowledges that Federal funds were requested in excess of its immediate cash needs and that the semiannual financial reports did not reflect actual disbursements during the year ended December 31, 2025, and is committed to implementing the corrective action described below. Corrective action plan: In response to the condition in reference, management will establish the following corrective action: • Notify the Forest Service in writing of the unexpended advanced funds and obtain a determination on whether the balance must be returned or may be applied to future lease payments. No additional funds will be requested for the vehicle leases until the determination is received. • Determine whether the advanced funds earned interest and, if applicable, remit it in accordance with 2 CFR 200.305(b). • Adopt a written procedure requiring that each SF-270 be supported by a worksheet showing that costs included in reimbursement requests have been paid, that advances do not exceed 30-day cash needs, and that prior advances have been fully expended. The worksheet will be reviewed and approved before each request is submitted. • Submit revised semiannual financial reports reflecting actual cash disbursements recorded in the accounting records. • Prepare future financial reports from actual disbursements recorded in the general ledger, reconciled to the general ledger and reviewed by a person independent of the preparer before submission. • Provide training to personnel responsible for payment requests and financial reports on the award's terms and conditions and the cash management and reporting requirements of 2 CFR Part 200.

Finding No. 2025-002 — Cash Management — Significant Deficiency Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Name and Assistance Listing Number: Low-Income Home Energy Assistance 93.568 Federal Award Identification Number and Years: 23DSS4301 EW 9/25 and 9/26 Name of Passthrough Entity: Connecticut Department of Social Services Planned Corrective Action: Management will continue to identify opportunities to streamline invoice processing along with conducting periodic reviews of processed invoices to ensure payment was made within the 10 day payment period. Management will also maximize recruitment efforts to fill vacant staffing positions. Name of Contact Person: Tiffany Bell, Director of Energy Services, anticipated completion date — December 31, 2026.

Management acknowledges the Finding regarding cash management compliance over federal awards. Background - In the first quarter of 2025, the Organization drew down funds through ASAP across several federal grants to prevent interruptions to ongoing grant activities and services for program beneficiaries. Based on the Organization’s review of drawdown requests associated with the federal awards included in the auditors’ testing, the total value of the affected transactions was $1,249,320 for the year ended December 31, 2025. Each of the grants operates differently, with its own period of performance and spending pattern, and for several grants the awarding agency subsequently approved no-cost extensions to allow additional time for grant work, which resulted in cash on hand that exceeded immediate cash needs. Status of the Funds - The Organization classified the funds as refundable advances (liabilities) on its Statement of Financial Position, reduced the liabilities, and recognized revenue as it incurred allowable expenditures. It did not draw additional funds from ASAP until the cash on hand for each respective grant was fully disbursed. Of the $1,249,320 in affected transactions, $628,754 (~50%) has been expended as of September 25, 2026. Spending on certain grants was slower than anticipated due to third party staffing and subrecipient onboarding timelines. The Organization confirms that all funds remain restricted for allowable purposes under the awards from which they were drawn. In response to the recommendation to review interest earned on federal cash balances and remit any amounts due, the total interest earned on the Organization’s operating account during the fiscal year was $201.24. Because the account contained both federal and non-federal funds, interest was not separately accumulated by funding sources. Based on the total interest earned for the year, Management does not believe the amount attributable to federal funds exceeded the $500 annual threshold permitted to be retained for administrative expenses under the Uniform Guidance. Going forward, the Organization will add an annual review of interest earned on accounts with federal funds (see Corrective Action Plan). The control listed below was in place before and during 2025. To address the timing identified in this Finding, Management reaffirms this control and adds the following new actions. Controls Already in Place • Reconcile cumulative drawdowns to actual expenditures and federal cash on hand for each grant award monthly. New Actions • Formalize the Organization’s existing monitoring of the elapsed time between the receipt of drawn federal funds and disbursement to vendors by establishing a 30- day internal benchmark for each grant award and reviewing any advances outstanding beyond that period. The Uniform Guidance does not specify an exact number of days; the 30-day benchmark reflects management’s internal target and is consistent with the auditors’ observation. • Review interest earned on accounts holding federal funds and remit any amount above the allowable threshold on an annual basis. These measures are intended to ensure that future drawdowns closely match immediate cash needs and are disbursed within a reasonable period, that interest on federal cash balances is properly evaluated, and that the Organization remains compliant with federal cash management requirements. Planned Implementation Date of Corrective Action Plan Existing controls remain in place. The formalized 30-day monitoring benchmark described above began in October 2026 and will continue on an ongoing basis. The annual interest review will begin with the fiscal year 2026 year-end review and continue annually thereafter.

Views of Responsible Officials: During 2025, the Foundation experienced an extraordinary period of uncertainty surrounding the continued availability and accessibility of Federal funding. In response to concerns regarding access to previously awarded Federal funds, the Foundation accelerated certain cash draws associated with approved Federal awards and established work plans. Shortly thereafter, access to certain award accounts within the Federal payment system changed, with access subsequently restored. As circumstances stabilized, the Foundation returned a substantial portion of the advance funding in March 2025. As of December 31, 2025, approximately $7 million remained recorded as refundable Federal advances associated with existing Federal awards. Management anticipated that these funds would be applied to eligible program expenditures and existing award obligations as activities under the approved work plans progressed. The Foundation maintains cash within pooled operating accounts and did not maintain Federal advances in separately segregated bank accounts. While Federal award activity and expenditures were tracked within the Foundation's accounting system, the Foundation's existing cashmanagement and liquidity-monitoring processes did not provide sufficient visibility to demonstrate that cash and investments equal to outstanding refundable Federal advance obligations remained available as of December 31, 2025. The Foundation also maintained access to a $1 million line of credit that was available to provide additional liquidity for short-term organizational working-capital requirements. The line of credit had not been drawn as of December 31, 2025, and therefore was not included in the cash and investments used to measure available liquidity at year-end. Nevertheless, the facility represented an available non-Federal source of liquidity that could have been utilized to address short-term organizational cash-flow requirements. Importantly, as reflected in the auditors' findings, no questioned costs were identified because expenditures unrelated to the applicable Federal awards were not charged to those Federal programs. The Foundation recognizes the need to strengthen its cash-management controls and liquidity-monitoring processes to ensure that Federal cash draws are aligned with immediate program cash requirements and that sufficient liquidity is maintained to satisfy outstanding Federal advance obligations. To address the finding, management has implemented or will implement the following corrective actions: 1. Federal Cash Draw Review and Approval – CFO/Finance Finance will maintain a formal review and approval process for federal cash drawdowns. Draws will be supported by eligible expenditures and actual and immediate cash requirements consistent with applicable federal award requirements. Federal cash draws outside the Foundation's normal reimbursement or cash-management practices will require documented review and approval by the CFO. 2. Extraordinary Federal Cash Draw Protocol – President & CEO/CFO If extraordinary circumstances arise that could affect the Foundation's access to federal awards or federal payment systems, any decision to materially accelerate a federal cash draw will be documented and subject to enhanced executive review.The documentation will include the circumstances supporting the proposed action, affected federal awards, amount of the proposed draw, anticipated eligible expenditures, expected timing of those expenditures, applicable federal cash-management requirements, and identified compliance and liquidity risks. Material extraordinary draw decisions will require approval by the President & CEO and CFO and, when appropriate, consultation with legal counsel, the federal awarding agency, and/or the appropriate Board leadership. 3. Program Certification of Anticipated Eligible Expenditures – Program Leadership When a federal cash-management decision relies on anticipated program activity, the responsible Program Executive will provide Finance with documented projections of the eligible expenditures expected to be incurred under the applicable awards. The documentation will identify the anticipated expenditures, estimated amounts, expected timing, and applicable federal awards. Program Leadership will be responsible for the accuracy and completeness of the programmatic projections provided to Finance. Finance will remain responsible for evaluating the information against applicable federal cash-management requirements. 4. Federal Advance Retention Review – CFO/Finance When a material federal advance remains outstanding, Finance will perform and document an assessment of whether continued retention of the advance is appropriate. The assessment will consider the amount of the outstanding advance, cumulative eligible expenditures, anticipated eligible expenditures, expected timing of those expenditures, applicable award requirements, and the amount, if any, that should be returned. Material advance balances will be periodically reassessed until the funds have been applied to eligible federal program expenditures or returned, as appropriate. 5. Federal Advance Reconciliation – CFO/Finance Finance will maintain an award-level reconciliation of federal cash draws, cumulative eligible expenditures, and outstanding refundable advances. The reconciliation will provide management with visibility into the amount of federal cash advanced in excess of cumulative eligible expenditures and facilitate timely identification of amounts that may require repayment. The remaining refundable advances associated with the December 31, 2025, balance will continue to be monitored through final disposition. 6. Enhanced Cash-Flow and Liquidity Forecasting – CFO/Finance Management will maintain a rolling 90 day cash-flow forecast incorporating anticipated receipts, operating expenditures, federal award activity, refundable advances, unrestricted resources, and other significant obligations. The forecast will be regularly updated and used to identify projected liquidity shortfalls and required management actions. Status: Started September 20267. Federal Advance Liquidity Monitoring – CFO/Finance As part of the Foundation's liquidity reporting, Finance will specifically compare outstanding federal refundable advances with available financial resources. If available resources approach or fall below established thresholds necessary to satisfy federal advances and other restricted or committed obligations, the matter will be immediately escalated to the President & CEO and appropriate Board leadership. This control is intended to prevent a situation in which a significant federal advance remains outstanding without management having timely visibility into the Foundation's ability to satisfy the associated obligation. Status: Started July 2026 8. Executive Accountability Responsibility for remediation will be shared across executive leadership with clearly defined accountability: Finance/CFO will be accountable for federal cash-management compliance, federal draw review, refundable advance reconciliations, cash-flow forecasting, liquidity monitoring, and escalation of identified risks. Program Leadership will be accountable for providing Finance with timely and supportable projections of anticipated eligible program expenditures when those projections are necessary to support federal cash-management decisions. President & CEO will be accountable for ensuring that organizational expenditures and operating decisions are appropriately aligned with available and reasonably forecasted financial resources and for directing organizational corrective action when established liquidity or revenue thresholds are reached. Management believes these measures strengthen the control environment surrounding an extraordinary and unusual event while establishing sustainable controls for federal cash management going forward. Management is committed to ensuring that future federal drawdowns are appropriately aligned with the Foundation's actual and immediate cash requirements and that significant federal advances are subject to documented, ongoing monitoring through their final disposition.

Corporation's Response: 1. The amount undisbursed, $15,000, was notified to the Project of awareness that we intend to return it as soon as possible. We will be contacting the Awarding Agency Officer to allow us the specific instructions for returning funds through the Payment Management System (PMS) following the agency's refund rules. Also, we have procedures to determine whether any interest earned in the advance must be remitted under 2 CFR§ 200.305(b)(9). 2. We have developed and implemented written cash management procedures to ensure that advance requests are limited to immediate cash needs and each of them is backed by paid invoices. 3. A monthly reconciliation is done for each of the funds, comparing federal disbursements with actual disbursements to avoid excessive requests for unused funds. 4. Constant monitoring has been established. Analyses are carried out of the approved and used budget. This analysis is done by someone who doesn’t handle payments, for the segregation of duties and supervision and the senior management does reviews to make sure everything gets done on time. 5. A formal training program on federal award requirements has been developed and implemented for all staff involved in administration, financial management, procurement, and reporting of federal awards. PR CONCRA management traces all CFR 200-related training and federal fund management training for the staff who can attend or participate in these seminars virtually.

Finding 2025-006: Information on the Federal Program: Disaster Grants – Public Assistance | Name of Contact Person: Anthony Gattuso, Vice President Accounting Operations | Corrective Action Plan: Atrium Health CMHA management has enhanced the FEMA expenditure review and approval process by implementing procedures to ensure all supporting documentation related to the review, approval, and monitoring of FEMA-funded expenditures is retained in a centralized and accessible location. Management established documentation requirements and provided guidance to responsible personnel to ensure sufficient evidence is maintained to demonstrate that controls have been performed and reviewed as designed. Periodic monitoring will be conducted to verify compliance with these documentation retention requirements. | Proposed Completion Date: Completed July 2025.

The funds in question either already have been, or will be prior to year-end, fully spent down in 2026. No further draws are/will be taken in 2026 unless the need is critical, and if that is the case we will only take that which will (based on budget) be spent over a three-month span. Additionally, we have returned to billing for the awards in question on a cost reimbursement basis in 2026. Anticipated Completion Date is December 31, 2026. Responsible Official - Mike Marchesano, CFO

We will implement a process to maintain documentation of review for all CalOES grants in the form of E-mail confirmation or screenshot signed by the reviewer.

Environmental Quality Incentives Program – Assistance Listing No. 10.912 Recommendation: We recommend the Organization implement a formal control where someone other than the preparer documents their review of the financial and performance reports prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Status of corrective action: This finding recurred because the controls below were implemented in October 2025 and were not in place for the full 2025 audit period. We expect it to be resolved in the 2026 audit Report review: Under the Federal Grant Report Review and Submission Protocol, implemented in October 2025, someone other than the preparer compares each financial and performance report to the general ledger and supporting documents. Both the preparer and reviewer sign and date the review form before the report is submitted, and the form is filed in the project folder. Name(s) of the contact person(s) responsible for corrective action: Jill Matchett, Grants Manager through June 2026, Lori Hall, Grants Manager June 2026 - present Planned completion date for corrective action plan: Implemented October 2025; expected to be resolved in the audit for the year ending December 31, 2026

Environmental Quality Incentives Program – Assistance Listing No. 10.912 Recommendation: We recommend the Organization implement a formal control where someone other than the preparer documents their review of the claim prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Status of corrective action: This finding recurred because the controls below were implemented in October 2025 and were not in place for the full 2025 audit period. We expect it to be resolved in the 2026 audit. Claim preparation and independent review: For each claim, the Grants Manager or designee prepares a Claim/Billing Approval Form and routes it, with the supporting documentation, to the Project Manager. The Project Manager, who does not prepare the claim, compares the amounts on the claim to the general ledger and to supporting documentation such as payroll allocation reports and vendor invoices, and resolves any differences with the preparer before approving. Signature and date prior to submission: Both the preparer and the reviewer electronically sign and date the Claim/Billing Approval Form. The claim is not initiated in the funder portal until the form is fully approved, so the documented approval date will always precede the submission date. Documentation and monitoring: The approved form, supporting documentation, and portal submission confirmation are saved together in the Organization's grant files. A member of management will periodically review a sample of submitted claims to confirm that the review was completed, signed, and dated before submission. Name(s) of the contact person(s) responsible for corrective action: Jill Matchett, Grants Manager through June 2026, Lori Hall, Grants Manager June 2026 - present Planned completion date for corrective action plan: Implemented October 2025; expected to be resolved in the audit for the year ending December 31, 2026

In early 2026, Hamilton County Area Neighborhood Development, Inc. (HAND) hired an experienced controller to prepare the parent and subsidiaries financials. HAND will establish effective internal control systems to ensure compliance with the requirements for grant agreements and cash management compliance requirements.

Management Response and Root Cause Management agrees with the finding. Five of 40 encounters tested received an incorrect sliding fee adjustment, and the approved schedule for certain dental services was not fully compliant for patients at or below 100% of the Federal Poverty Guidelines. The repeat condition resulted from incomplete alignment among the approved schedules, written policy, expanded dental services, staff workflows, income documentation, and eClinicalWorks configuration. Prior training and system optimization did not fully eliminate manual interpretation or provide sufficiently frequent monitoring across all sliding fee levels and service lines. Corrective Action Plan HealthCore Clinic will redesign and implement a single, compliant, system-supported Sliding Fee Discount Program for all services within scope. The revised process will align Board-approved policy and schedules, dental and medical workflows, income and family-size documentation, eClinicalWorks configuration, adjustment and reversal controls, staff competency, and ongoing internal audit monitoring. HealthCore Clinic will provide training on the updated program to all registration, eligibility, billing, and other affected staff. HealthCore Clinic will implement monthly internal audits using samples across tiers and service lines and investigate any errors to identify the root cause for noncompliance with the policy.

Condition: Timecards did not consistently agree with hours reported in payroll records. Discrepancies were noted between employee timecards and ADP payroll reports, and one instance was identified in which a timecard lacked required approval. Planned Corrective Action: Management will strengthen payroll controls by implementing a dual-review process. Supervisors will be required to approve all employee timecards prior to payroll processing, and accounting personnel will verify approved timecards against payroll system reports before payroll is finalized. In addition, management will conduct periodic spot checks and quarterly reviews on or around April 1st, July 1st, October 1st, January 1st to ensure payroll records are accurate, properly supported, and in compliance with established procedures. Anticipated Completion Date: December 31, 2026. Contact Person: Pam Schuellerman, Executive Director.

Condition: Management was unable to locate approved payment request forms demonstrating evidence of review and approval prior to submission for reimbursement in 15 of the 60 transactions selected for testing. Planned Corrective Action: Management will implement and enforce a standardized reimbursement packet checklist requiring documented approval before reimbursement requests are submitted. All reimbursement packets and supporting documentation will be maintained electronically in a centralized filing system. Training will be provided to accounting staff regarding documentation and record retention requirements. Quarterly reviews will be conducted to ensure compliance with established procedures on or around April 1st, July 1st, October 1st, January 1st annually. Anticipated Completion Date: December 31, 2026. Contact Person: Pam Schuellerman, Executive Director

Response: Agree Planned Corrective Action: The entity will deposit the surplus cash amount from the 2024 calculation, $44,485, into the residual receipts account.Anticipated Completion Date: 12-31-26 Contact Person: Lesilie Heredia, President

Management will implement written procedures for federal grant administration applicable to all federal awards. Reimbursement requests will be limited to costs incurred and supported by documentation at the time of the request. The reimbursement request, expenditure listing, supporting documentation, and documented allowability review will be maintained together in a referenced file and will include preparer and reviewer sign-off. For advance payments, management will document the program's immediate cash requirements supporting the amount and timing of each advance and monitor the period between receipt and disbursement of federal funds. The reimbursement log reconciliation and Schedule of Expenditures of Federal Awards will be subject to documented review by an individual who was not involved in their preparation. Management will also coordinate with the USDA Forest Service regarding the $64,969 in questioned costs and follow the awarding agency's direction.

Corrective Action Plan – Single Audit Finding Entity Name: Buffalo Mercy Housing Development Fund Company, Inc. Audit Period: For the year Ended December 31, 2025 Finding Reference Number: 2025-001 Federal Program: 14.155 MORTGAGE INSURANCE FOR THE PURCHASE OR REFINANCING OF EXISTING MULTIFAMILY HOUSING PROJECTS 1. Audit Finding Summary Describe the audit finding and the specific noncompliance identified by the auditor. In accordance with 24 CFR 891.400(e), a separate interest-bearing project fund account shall be maintained in a depository or depositories which are members of the Federal Deposit Insurance Corporation or National Credit Union Share Insurance Fund and all tenant payments, charges, income and revenues arising from project operation or ownership shall be deposited to this account. 2. Root Cause Explain the underlying reasons for the finding, such as process gaps, training issues, or lack of controls. Subsequent to the initial rental assistance contract, changes to HUD regulations resulted in the requirement that the project fund account be an interest-bearing account. This change was an oversight by the Company's management. 3. Corrective Actions Action Item: Use an interest-bearing account for project funds Responsible Person: Chief Financial Officer Completion Date: TBD Status: In process 4. Monitoring Plan Describe how the implementation of corrective actions will be monitored and evaluated. Management inquired with the bank and deemed the cost outweighs the benefit due to the fees charged for an interest-bearing account exceeding the interest that would be earned. 5. Contact Information Name: Aaron Hejmowski Title: Chief Financial Officer Phone: 716-884-7791 Email: ahejmowski@belmonthousingwny.org

ANTHONY HOUSING AUTHORITY PHONE: 915-886-4650 ·FAX:915-886-2296 1007 FRANKLIN ANTHONY, TEXAS 79821 HOUSING AUTHORITY OF ANTHONY, TEXAS CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2025 Corrective Action Plan Finding: 2025-001-Financial Distress, Interfund Balances and Management’s Plans-Allowable Costs Condition: (a)-The General Fund, which includes the Low Rent Program, owes the Housing Choice Voucher Program $265,569. As the Statement of Financial Position discloses, if this interfund balance was paid in full at year-end, the General Fund would only have current assets of $26,200. Conversely, the Housing Choice Voucher has an interfund receivable of $265,569 for which the collection of the majority of this balance is doubtful. (b)-At year-end, the Housing Choice Voucher Fund has a restricted HAP equity of $251,034. This balance is calculated by the cumulative portion of the HAP federal advances designated to pay HAP payments, less the actual HAP payments made. The fund should have a minimum of $251,034 of cash on hand to pay HAP payments. Instead, the Housing Choice Voucher Fund shows an overdraft of $141,044. (c)-The Housing Choice Voucher Fund includes an accounts payable to HUD for $126,982 of CARES Act funds. The authority received $66,018 and $60,964 on August 13 and September 1, respectively in 2020. The authority’s fee accountant repeatedly asked the Executive Director serving then to identify the 2020 and 2021 Admin or other costs that these CARES Act funds paid for. She would not do it. Consequently, HUD considers these funds to be due to HUD. (d)-The Housing Choice Voucher Program includes a separate program that was established with left over pre 2004 Section Admin fees. This was permissible prior to 2004. With part of the funds, the Program purchased a rent house. The occupant owed the authority $44,723 on a mortgage note that is continually in arrears. If this house was sold, the authority would receive a cash influx of a minimum of $100,000. (e)-Both the Low Rent and the Housing Choice Voucher Programs have an FSS program. Audit findings have been made for years that management has not properly administered this program. At year end, the HCV Program shows a liability of $53,650 with a corresponding cash account of $53,671. If the actual FSS liability verified by audit was materially correct of, for example, $10,000, the liability account would be substantially reduced. The resulting cash could be transferred to operating. (f)-The Housing Choice Voucher Program also has a Homeownership program. Audit findings have also been made for years that management has not properly administered this program. At year-end, the HCV Program shows a liability of $59,234 with a corresponding cash account of $59,234. If the actual Homeownership liability verified by audit was materially correct of, for example, $10,000, the liability account would be substantially reduced. The resulting cash could be transferred to operating. Corrective Action Planned: I am Louie Alfaro, Executive Director and Designated Person to answer these findings. As noted above, I did not become E.D. until December 4, 2024. I will take the following proposed steps to the board of commissioners for approval. The steps coincide with (a) through (f) noted in Condition Found. (a) and (b)-We will continue minimize expenses when possible, to eliminate the deficits and reduce the interfund balances noted above. (c)-I understand the auditor has talked with and communicated in writing with REAC and the HUD Albuquerque Field Office regarding the CARES Act liability of $126,982 noted in (c) above. It appears HUD regulations permit a report to be filed after the deadline for expenditures. If HUD will accept and approve this report, I will request the fee accountant or other third party to determine which 2020 and 2021 Admin and Other Costs should have been timely identified with the CARES Act funds. I understand this may result in an additional fee, due to the difficulty of obtaining and reviewing the old records. Then, after review upon audit, I understand that the liability would be eliminated. (d)-I will review whether the note receivable on the rent house noted in (d) above is current. If past-due, I will consult with our attorney about avenues to foreclosure. (e)-As of mid-September 2026, we feel we have the FSS program administered properly for the Low Rent program. Principally due to lack of available man hours, we are still behind in bringing the FSS program for Housing Choice Vouchers up to date. We are working on it as time permits. (f)-As of mid-September 2026, we believe we have determined the estimate amounts owed to 8 FSS participants. However, how to bring this to resolution has not been resolved, since all 8 were ported out to El Paso Homes (El Paso Housing Authority) over a year ago. Presently, we are considering three alternatives: (a)-pay the participants in full or in part, but here are legal issues with that, (b)-establish parameters for items we will reimburse the participants-new stoves, etc., (c)-agree to a Memorandum of Understanding with El Paso Homes. We have requested a meeting with El Paso Homes to discuss the issues and a possible MOU, but they have yet to agree to a meeting. Person responsible for corrective action: Louie Alfaro, Executive Director Telephone: (915) 886-4650 Housing Authority of the Town of Anthony, Texas Fax: (915) 886-2296 1007 Franklin Anthony, TX 79821 Anticipated Completion Date: September 30, 2026

Corrective Action Plan – Single Audit Finding Entity Name: Lancaster Housing Development Co., Inc. Audit Period: For the year Ended December 31, 2025 Finding Reference Number: 14.157 Federal Program: Supportive Housing for the Elderly (Section 202) 1. Audit Finding Summary Describe the audit finding and the specific noncompliance identified by the auditor. In accordance with 24 CFR 891.400(e), a separate interest-bearing project fund account shall be maintained in a depository or depositories which are members of the Federal Deposit Insurance Corporation or National Credit Union Share Insurance Fund and all tenant payments, charges, income and revenues arising from project operation or ownership shall be deposited to this account. 2. Root Cause Explain the underlying reasons for the finding, such as process gaps, training issues, or lack of controls. Subsequent to the initial rental assistance contract, changes to HUD regulations resulted in the requirement that the project fund account be an interest-bearing account. This change was an oversight by the Company's management. 3. Corrective Actions Action Item: Use an interest-bearing account for project funds Responsible Person: Chief Financial Officer Completion Date: TBD Status: In process 4. Monitoring Plan Describe how the implementation of corrective actions will be monitored and evaluated. Management inquired with the bank and deemed the cost outweighs the benefit due to the fees charged for an interest bearing account exceeding the interest that would be earned. 5. Contact Information Name: Aaron Hejmowski Title: Chief Financial Officer Phone: 716-884-7791 Email: ahejmowski@belmonthousingwny.org

FINDING 2025-015 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Cash Management Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Centralized Reporting: The Finance Department now mandates that all approved grant documentation (Grant Award Notifications, reimbursement forms, budget breakdowns) be submitted to Finance immediately. Succession Planning Policy: Added strict continuity protocols to the IC Manual, affirming that all data belongs to the corporation. Requirements include maintained system documentation, account deactivation within 24 hours of employee departure, and formal knowledge handoffs. Segregation of Duties: Updated policy to ensure no single individual manages any financial process (receivables, purchasing, or inventory) end-to-end. Anticipated Completion Date: September 30, 2024 (grant ended). January 1, 2025 is when grant award documentation sharing was required.