Corrective Action Plans

Response: The District has operated the LINKS afterschool program supported by 21st Century funding for over 20 years. The Office of Public Instruction (OPI) performs monitoring of schools with 21st Century funding every 4 to 5 years. The OPI did a monitoring of the District in 2020 and found no compliance issues. In August of 2024, OPI informed the District that we were not in compliance with changes to the federal regulations made in 2018. In February of 2025, OPI sent a letter to the District indicating that parent fees charged in FY24 and FY25 would need to be applied to reduce federal funding in the future due to the new rules established in 2018. The District is in the process of appealing this finding from OPI and has stopped charging parent fees as of October 2024, while considering the impact of reduced funding to this community program.

Federal Program Information: Funding Agency: U.S. Department of Education Title: Education Stabilization Fund Assistance Listing: 84.425 U Passthrough: N/A Award Year: 2024 Criteria: APPENDIX II TO PART 200—CONTRACT PROVISIONS FOR NON-FEDERAL ENTITY CONTRACTS UNDER FEDERAL AWARDS (D) Davis-Bacon Act, as amended (40 U.S.C. 3141–3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141–3144, and 3146–3148) as supplemented by Department of Labor regulations (29 CFR Part 5, ‘‘Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction’’). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The contracts must also include a provision for compliance with the Copeland ‘‘AntiKickback’’ Act (40 U.S.C. 3145), as supplemented by Department of Labor regulations (29 CFR Part 3, ‘‘Contractors and Subcontractors on Public Building or Public Work Financed in Whole or in Part by Loans or Grants from the United States’’). The Act provides that each contractor or subrecipient must be prohibited from inducing, by any means, any person employed in the construction, completion, or repair of public work, to give up any part of the compensation to which he or she is otherwise entitled. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. Condition: During our review of the requirements of Special Tests provisions of the Compliance Supplement and the District’s implementation of controls related to compliance with these provisions for the Education Stabilization Fund, we identified the following issues: The District did not meet the requirement for the Davis-Bacon Act prevailing wage requirement. The District had not included the prevailing wage requirements in the contract with the vendor who was replacing fire panels in the District nor did the District obtain the weekly certified payroll reports from the contractor for each of the projects. Questioned Costs: Unknown. The vendor would have obtained a state wage determination rate because of the dollar-value of the contract, which would have required wages which would meet the Davis Bacon requirements. The District did obtain permission from the New Mexico Public Education Department before beginning the project, and the PED did reimburse all costs, so it is likely that questioned costs may not exist. Cause: District personnel were unaware of the requirement to include language in contracts regarding the Davis- Bacon Act or the Copeland “AntiKickback” Act with companies providing construction or maintenance work for the District when Federal funds are being used to pay for those services. State personnel told the District incorrectly that Davis-Bacon did not apply unless the value of the contract was greater than $60,000 per project or on Native American lands, even though the grant guidance puts the level at $2,000. Effect: The District is not in compliance with Federal requirements when using grant funds to pay for construction or maintenance projects in excess of $2,000. Noncompliance with these provisions could cause reimbursement of these funds to be questioned or require the District to reimburse the granting agency for any costs incurred under these projects. Additionally, companies providing these services may not know they are subject to particular wage rate determinations for the project which may cause them to bid or quote amounts that do not provide for payment of required wages to the employees participating on those projects. Auditor’s Recommendation: We recommend that the District establish a practice of including the required language for the Davis-Bacon Act and the Copeland “AntiKickback” Act in contracts with all companies which provide construction or maintenance projects to the District. When companies are selected that have Cooperative Educational Services agreements, the District should require an additional contract be signed by the company which includes these provisions. Additionally, we recommend that District personnel be trained in identifying which funds fall under Federal regulations versus State regulations so that when purchase orders are created and contracts are entered into that these individuals know they are including the proper requirements. Responsible Official’s Plan: ● Specific corrective action plan for finding: o When receiving new funding, management will review laws and regulations to make sure the district complies with them. Training will be seek if necessary ● Timeline for completion of corrective action plan: o November 30, 2024 ● Employee position(s) responsible for meeting the timeline: o Superintendent- Ray Maestas, Maintenance Supervisor- Tim Callis and business manager- Zach Barsalou

Concur. Due to key vacant positions and the inability to fill these positions, the required reports were not completed and submitted on time during the fiscal year ending June 30, 2024. During the current fiscal year, the County has been successful in recruiting these positions and will ensure that the timely and accurate reports are submitted. In addition, policies and procedures will be documented on reporting requirements to ensure that they are performed on a timely basis.

Federal Programs ALN: 93.575, 93.596, 93.558, and 93.667 Criteria: The Organization is required to remit all interest earned on federally funded advances to DEL within 30 days after the fiscal year end per DEL Program Guidance 240.01 Cash Management and 2 CFR 200.305(9). Condition: The Organization failed to remit all earned interest to DEL within the 31 day deadline in accordance with the grant agreement. Cause: The Organization experienced high management turnover which delayed the calculation of interest earned and remittance to DEL. Effect: The Organization did not meet the remittance submission deadline requirement as set forth by DEL Program Guidance 240.01 Cash Management and 2 CFR 200.305(9). The earned interest was remitted on March 11, 2025. Recommendation: We recommend the Organization designate an individual to calculate interest earned and closely monitor the submission deadline. Corrective Action Plan: Coalition management will make sure that measures are in place to ensure all interest earned is reconciled monthly and paid timely back to DEL. Responsible Party: Xaviera White, Chief Executive Officer Anticipated Completion Date: March 2025

Contact Person Dara Lee, Executive Director of Clay County HRA (Authorized Representative and Agent) Corrective Action Plan The Corporation is aware of the issue and has taken subsequent steps to ensure internal procedures are followed as established. Planned Completed Date for CAP Immediately

Finding: 2024-003 – Special Tests and Provisions – Return of Title IV Funds Condition: During the testing of the return of Title IV funds, it was noted that on three (3) of five (5) tested calculation of funds to be returned had no documentation to determine if returns were completed timely as the College did not retain the lists of students associated with drawdowns and/or returns and two (2) of five (5) tested had not been returned as of the date of fieldwork which exceeded the required timeframe to return funds. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns, including returns, from Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of students withdrawing and a control in place that allows the financial aid department to know the student financial aid was returned to Department of Education within the required timeframe. Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies and procedures for the Financial Aid office, including the area of disbursements that includes additional controls and documentation of such. Our objectives will be that all Financial Aid staff will be required to maintain documentation of any drawdowns of funds related to student financial aid. We have put in place a shared OneDrive electronic folder with restricted access to provide confidentiality and provide documentation of the shared communication between offices. Documentation of drawdowns and/or returns will be maintained within this folder. Staff will be trained on using the daily generated reports from Poise to monitor students who have withdrawal on their records so that this can be updated and proper calculations done. All financial aid staff will attend training to stay up to date on regulations and changes. Starting in July 2025 the new J1 system will be integrated with JFA (financial aid system). This will create operational efficiencies and reporting capabilities that are not currently available. Less manual transactions will also provide more accurate student reports. Measurable targets will be achieved by documenting the records within the OneDrive shared electronic folder between the Financial Aid office and the Business Office, who handles the return of funds. Daily changes and/or withdrawal of students will be monitored and funds will be returned as required. This will become of a part of the regular duties of staff.

Finding: 2024-002 – Special Tests and Provisions – Payment to Students Condition: During our testing of the financial aid disbursements, it was noted the College is not maintaining records of what students the drawdowns were for, therefore we were unable to determine if the amounts were posted to the student accounts within the required time frame and subsequently were paying out any credit balances created on student accounts. Recommendation: Policies and procedures should be written to provide internal control over the documentation used to complete the drawdowns from the Department of Education. We recommend the College establish a communication and record retention process that allows for the notification of the student financial aid proceeds and a control in place that allows the financial aid department to know the student financial aid was applied to the student’s account timely. Views of responsible officials and planned corrective action: Areas of Focus will be in the documentation of policies and procedures to provide clear expectations of internal control documentation used to complete the drawdowns from the Department of Education and for a process of record retention. Our objective would be to formalize the policies and procedures in the Financial Aid policy manual. The policies and procedures will have shared access between the Financial Aid office who approves the aid, the Business Office who ultimately pulls down from the Department of Education, and with the Cashier who distributes any refunds. A OneDrive electronic folder has been created with restricted access to provide confidentiality and provide documentation of the shared communication between offices. The POISE system generates a listing of students. The list of students will be created for each draw-down that is initiated and will be placed in the shared folder in OneDrive. Draw-downs will not be initiated without a corresponding student list that shows the student account has been credited with the financial aid award. The documentation will be found in the shared OneDrive electronic folder, which has already been implemented. The transfer (interface) of student records into the financial system is being done weekly and documentation is retained of students for which transactions occur.

2024-003: Segregation of Duties – Significant Deficiency a. Prior Year Findings • The current year finding is not a repeat finding from the prior year. b. Comments on Findings and Recommendations • We concur with the findings. c. Action Taken or Planned • Management and the Board will review the accounting functions and will strive to improve the areas that are economically feasible.

CORRECTIVE ACTION PLAN U.S. Department Education Hobart and William Smith Colleges respectfully submit the following corrective action plan for the year ended June 30, 2024 Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully's Trail Pittsford, NY 14534 Audit period: July 1, 2023 - June 30, 2024 The findings from the 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS SIGNIFICANT DEFICIENCY 2024-001 Timely Return of Title IV Funds Recommendation: We recommend that the Colleges assess and address staffing levels in the Student Financial Aid Department to ensure adequate resources are available to process Title IV fund returns timely. Additionally, the Colleges should develop policies and procedures to ensure timely processing of returns within the required 45-day period. Corrective Action Plan: Additional staffing has been put in place to ensure that we have enough resources to complete title IV refund processing in a timely fashion. A new assistant director (hired in November 2024) will be monitoring the notifications that students have withdrawn and notify the director when title IV refunds are required. The new assistant director is also currently being trained in title IV refund processing and has experience with title IV refunding prior to being hired. The associate director (hired in July 2024) is also an expert in the return of federal funding through EDCONNECT and perform a supportive role in this process. Lisa Hoskey, Director of Financial Aid, is responsible for implementing this plan and can be reached at Hoskey@hws.edu.

In accordance with the 2014 Appropriations Act Section 242, the utility allowance for a family shall be the lower of: (1) the utility allowance amount for the family unit size; or (2) the utility allowance amount for the unit size of the unit rented by the family. However, upon the request of a family that includes a person with disabilities, the PHA must approve a utility allowance higher than the applicable amount if such a higher utility allowance is needed as a reasonable accommodation in accordance with HUD's regulations in 24 CFR part 8 to make the program accessible to and usable by the family member with a disability. This provision applies only to vouchers issued after the effective date of this notice (June 12, 2014) and to current program participants. For current program participants, a PHA must implement the new allowance at the family's next annual reexamination, provided that the PHA is able to provide a family with at least 60 days' notice prior to the reexamination. During the audit, we noted two (2) HUD Forms 50058 had utility allowances calculated not in accordance with the above criteria. The Authority had roughly 120 vouchers issued throughout the fiscal year under examination which would translate to 1,400 Housing Assistance Payment transactions for the year. Of these we reviewed 40 individual Housing Assistance Payment transactions and found 2 instances of noncompliance. Recommendation We recommend that Management implement procedures to ensure compliance with the above regulations as it relates to the Section 8 Housing Choice Voucher Program. Corrective Action Plan File audits are being done quarterly beyond regularly quality control audits. Staff are required to do additional annual compliance training to ensure procedures are being followed.

Significant Deficiency 2024-001. Procurement United States Department of Education, passed through New York State Department of Education Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Youth and Children ALN: 84.425W Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District’s Assistant Superintendent for Business and Operations will work on updating all policies and procedures relating to U.S. Office of Management and Budget Uniform Guidance to ensure that District policies are in compliance with these guidelines. Responsible Contact Person: Jeremy Feder Assistant Superintendent for Business and Operations Lawrence Union Free School District 2 Reilly Road Cedarhurst, NY 11516 Anticipated completion date: June 30, 2025.

Corrective Action Plan Finding 2024-001 Finding Summary: The Center did not exclude charges for patient care when calculating modified total direct costs (MTDC) in accordance with Uniform Guidance and TxGMS and thus the indirect rate used in calculating the indirect amount charged to the grant was not consistently accurate. Corrective Action Plan: The Center has historically calculated the indirect amount using the same methodology over time. Given the small volume of patient receipts, the impact on the total indirect amount is minor. We believe that had we modified our calculations, we would have had enough modified total direct costs to cover the change in the calculation. The Center will modify all future calculations to ensure alignment. We will also review the fiscal year covered under this audit to understand what the impact of the change would have been on the split between cost types. Note that since we are midway through our next fiscal year, and we consider the differences minor, we have determined that we will correct for any future reimbursement requests, but will not modify prior reimbursement requests. Similarly, we will conduct a review of that fiscal year to determine the impact of the change and verify it is not significant. Responsible Individuals: Rusty Taylor, CFO Joe Carrington, Director of Financial Planning and Analysis Anticipated Completion Date: August 2025

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: A financial policy for managing receipt of federal awards is in the process of being created by the Financial Policies Committee Anticipated Completion Date: December 31, 2025 Contact: April Steward, Town Administrator

Finding 2024-001 Name of Responsible Individual: Alexis Ritter, Director of Cash Management Corrective Action: To prevent similar occurrences in the future, we will transition from monthly program reconciliations to weekly FSEOG reconciliations and bi-weekly FWS reconciliations, which will allow for more effectively monitoring of award reversals or negative adjustments. Upon completion of these reconciliations, any excess cash identified will be promptly returned via G-5. Additionally, we will explore the feasibility of automating the notification process for negative adjustments posted in the ERP system, ensuring that we can capture excess cash in a more timely manner. Anticipated Completion Date: February 2025

Corrective Action Plan 2024-003: The University concurs with the finding and has made the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed on the disbursement screen for these students and pass that to COD. The University has implemented a control to complete the disbursements each time and then verify the date reflects correctly in COD afterwards. While this should be an automatic process, and has been in previous years, it will be something the University verifies now with each aid posting. Completion Date: August 2024 Contact Person: Megan Morton, Director of Financial Services

FINDING 2024-006 Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Federal Agency: Department of Education Federal Program: COVID‐19 ‐ Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass‐Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Chad Yencer, Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: We concur with this finding Description of Corrective Action Plan: Internal Control 1. For state reporting related to ESSER grants, the Grants/Data Specialist will compile all required information and maintain thorough supporting documentation. The Corporation Treasurer will then review the compiled financial data for the reporting period, verifying its accuracy before presenting it to the Superintendent. Finally, the Superintendent will review the information and supporting documentation, confirming its accuracy prior to submission to the Indiana Department of Education (IDOE). All workpapers and calculations will be recorded and kept for verification Anticipated Completion Date: August 2025

Reference Number: 2024-015 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education Federal Program: Student Support and Academic Enrichment Grants Assistance Listing Number: 84.424 Award Number and Year: S424A220047 (7/1/2022 – 9/30/2024) Compliance Requirement: Cash Management Type of Finding: Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend that the Agency review and enhance its internal controls to ensure that drawdowns are reviewed and approved in accordance with the Agency’s policies and procedures. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Agency will review its current Federal draw procedures and identify appropriate role assignment to ensure appropriate internal controls exist to allow for a separation of duties and dual control of critical process steps. Scheduled Completion Date of Corrective Action Plan: July 1, 2025 Position Responsible for Implementation of Corrective Action Sean Cousino, Interim CFO sean.couisno@vermont.gov

Reference Number: 2024-013 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Federal Transit Cluster Assistance Listing Number: 20.500, 20.507, 20.526 Award Number and Year: VT-04-0021-01 (3/14/2013 – 6/30/2016) Compliance Requirement: Cash Management, Period of Performance Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that VTrans review and enhance grant closeout procedures and internal controls to ensure that grants are closed out timely. We further recommend that VTrans review and enhance procedures and internal controls over cash management to ensure that cash draws are performed only against grants for which the period of performance has not expired. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The following factors contributed to the noncompliance: VTrans experienced staff turnover, at which point close out processes were missed in 2016. This resulted in a grant remaining with an open status in the TrAMS system well beyond the period of performance. During the 2024 review by program staff, a drawdown was inadvertently processed for this grant with the expired period of performance. At the time, VTrans lacked a formal, documented grant closeout process for FTA grants in the TrAMS system. Additionally, there was a breakdown in communication between the Accounts Receivable (AR) team and the Public Transit Program team regarding period of performance eligibility prior to processing the draw. VTrans has taken the following steps to strengthen internal controls and prevent recurrence of this issue: 1. Formalized Closeout Procedures: VTrans has implemented a structured grant closeout process for the AOT Public Transit Program that clearly defines responsibilities, timelines, and verification steps to ensure all federal awards are closed timely and in compliance with FTA requirements. This process assigns specific tasks to designated staff members and ensures that no drawdowns occur after the period of performance has ended. 2. Annual Period of Performance Review: VTrans has established and documented an annual review process for FTA grant periods of performance. This review has been formally integrated into the Agency’s Public Transit cash management procedures, ensuring that grant end dates are proactively monitored, and necessary extensions or closeouts are addressed before expiration. 3. Enhanced Communication and Documentation: VTrans has updated the internal Excel file used to facilitate communication between the Public Transit Program team and the AR team. The file now includes a designated column for period of performance, ensuring that all drawdowns are reviewed for eligibility before processing. This is also addressed in an update to the Agency’s Public Transit cash management procedure memo. VTrans will coordinate with FTA to determine the appropriate resolution for these funds. Any necessary repayment or adjustments will be completed in accordance with FTA guidance. At this time, FTA has not requested the funds be returned. Scheduled Completion Date of Correction Action Plan: All corrective actions will be implemented as of March 1, 2025. Contacts for Corrective Action Plan: Ross MacDonald, Public Transit Director ross.macdonald@vermont.gov

Reference Number: 2024-026 Prior Year Finding: 2023-023 Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Finance and Management Federal Program: SNAP Cluster Temporary Assistance for Needy Families CCDF Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.575, 93.596 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) Compliance Requirement: Cash Management Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that Finance review and enhance its internal controls and procedures over the CMIA Annual Report to ensure that it verifies the correct interest rate is applied and that State and Federal interest liabilities are properly calculated in accordance with 2 CFR section 200.514. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The current available rate at the time of calculation, review, entry, and moving to draft were all accurate to what U.S. Treasury had available at the time. The rate was updated on December 3rd, after our submissions had already been locked via the draft process in the CMIAS portal done on November, 26th. The process was not fully submitted due to issues with the CMIAS portal not allowing us to submit which has been extensively documented via multiple email chains with U.S. Treasury CMIA over the past two years. Finance and Management will take a screenshot of the CMIA interest rate page dated on the review date of the CMIA Annual Report submissions from departments to ensure that we maintain the historical rate posted to the U.S. Treasury CMIA page at the time of review. Additionally, AHS will take their own screenshots of the CMIA Interest Rate page from U.S. Treasury website on the date of their Annual Report Summary submissions for record and to show that the rate from this time was checked and applied to the current year’s program. If during the review, there is any discrepancy between the review screen of the rates and the calculations screenshot of the rates; the calculation spreadsheets will be kicked back to AHS to be updated. Scheduled Completion Date of Corrective Action Plan: November 30, 2025 Contacts for Corrective Action Plan: Jordan Black-Deegan, Statewide Grants Administrator jordan.black-deegan@vermont.gov Sarena Boland, Financial Manager III sarena.boland@vermont.gov

Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the cash management compliance requirement. During the testing of claim reimbursements, we noted for two monthly reimbursements in a sample of six claims that the claim reimbursements were not being reviewed by an independent individual before being submitted to IDOE. In March 2023, the School Corporation implemented a review control over the monthly claim reimbursement. The lack of controls was isolated to the period of July 2022 through February 2023 during fiscal year 2023. For all six claims tested, we agreed the number of meals claimed for reimbursement to underlying meal system reports without exception. Contact Person Responsible for Corrective Action: Brisha Dunbar Contact Phone Number: 317-729-5122 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Food Service Director Brisha Dunbar will complete the claims reimbursement form each month. Once completed it will be reviewed by the business manager for correct amounts before submitting the request for reimbursement. The FSD will print out the claims and both she and the reviewer will initial the form. Anticipated Completion Date: Ongoing, effective 03/24/2025

The Emergency Rental Assistance Program was developed in response to the pandemic and was implemented swiftly to meet the needs of low-income tenants affected by Covid-19. The program design involves fourteen partner agencies and their varying accounting systems. In the current fiscal year, all partnering agencies were required to submit program data through the online Neighborly software along with providing a general ledger report that supports and is reconciled to the data submitted prior to receiving reimbursement. In response to the compliance finding for our June 30,2024 Single Audit, United Way Monterey County will implement a year end ERAP closeout with all partners who received direct financial assistance. There will be monitoring visits done by the Vice President of Community Investments. Any record of noncompliance will be documented accordingly. The UWMC staff member overseeing these monitoring visits for us is: Josh Madfis VP, Community Investments Josh.madfis@unitedwaymcca.org (831) 372-8026

The Agency agrees with this finding and will implement the following: Make all necessary accounting adjustments to reflect the changes in the indirect cost charged for FY2023 & FY2024; Notify all affected funding agencies of the need to adjust the indirect cost charged, thus correcting any overcharges made through the remittance of funding and/or budget amendments; Update the indirect cost allocation worksheet with the correct provisional rate as per the current Nonprofit Rate Agreement from the Department of Health and Human Services.

Corrective action plan: To strengthen SEFA preparation and review, DSHS has designated the recently hired DSHS Financial Reporting Unit Manager and Accounting Section Director to oversee the following corrective action plan actions:  Formal updates to procedures to better implement policy;  Completion of hiring key financial reporting positions;  A refresher training for staff and contractors involved in SEFA preparation and review; and  Development of an internal quality review process for implementation during the next SEFA. Implementation dates: November 30, 2025 Responsible persons: Paige Lovejoy, DSHS Financial Reporting Unit Manager

Corrective Action Plan: The unaudited statements were corrected for FY2024 and are reflected in the audited statements. FY2023’s were corrected through the retained earnings that show on the FY2024’s audited statements as well in the prior year’s number on the statements. The FY2024 Single Audit reflects these changes as well. Management invoices at the times allowed upon the different grant funders based upon percentage of completion of the project/s. We will review all on-going projects at the end of each fiscal year during the audit with the auditors to determine what reporting has to be done in order to comply with the requirements of the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance), Subpart F, Audit Requirements.

Name of Contact Person: Sara Graul Corrective Action: Case File Oversight: • The Program Director has always reviewed case files but previously failed to sign the checklists. This has now been corrected and checklists are being signed upon review. • This process will continue to ensure proper documentation and compliance. • The Department structure is currently being reviewed with additional staff likely to add capacity and oversight. Financial Review & Approval Process: • The Finance team will continue preparing projection worksheets reconciled to the general ledger. • The Program Director will formally review and approve these financial documents before reimbursement requests are submitted. • We resolved this deficiency in April 2024 and have put the following additional controls in place to prevent this deficiency from recurring. Training & Standardization: • All program staff, including case managers and finance personnel, will receive training on compliance and proper documentation. • A standardized process and accountability measures will be in place to maintain adherence to these corrective actions. Monitoring & Reporting: • Quarterly internal audits will be conducted to verify compliance with the updated review and approval process. • An internal compliance officer or manager will oversee adherence to the new protocols. Completion Date: Full compliance with these measures is expected by the end of the next reporting quarter.