Corrective Action Plans

Finding Number: 2025-002 Condition: If an institution enters into a Tier One arrangement with a third party servicer, as defined in CFR 668.164(e)(1), the institution must provide to the secretary an up-to-date URL for the contract and contract data, as described in paragraph (e)(2)(vii) of this section for publication in a centralized database accessible to the public. Planned Corrective Action: The URL associated with Lake Michigan’s required disclosure has now been provided to the secretary via the associated Department of Education’s instructions. Contact person responsible for corrective action: Ben Burton, Director of Financial Aid Anticipated Completion Date: 03/19/2026

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent) compares the meal counts in the claim to the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Management Response: The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

2025--004 US Department of Education Material Weakness in Internal Control over Compliance and Other Matter Cash Management Auditor's Recommendation: One City Schools, Inc. should implement appropriate internal controls for reviewing funding claims prior to submission. Corrective Action: One City adopted a new grants management process which requires that all submitted claims are reviewed and signed by two responsible officials. Evidence of approvals will be maintained in the electronic grant files. In addition, One City has developed a training tool so that all staff who have grant claiming authority must participate in the training. The new Chief Financial Officer will monitor compliance with the policy and ensure proper documentation exists. Responsible for Corrective Action: Scott R Haumersen CPA, CGMA Shaumersen@onecityschools.org 608-575-4950 Anticipated Completion Date: June 30th, 2026

Corrective Action Plan 2025-003: Student Financial Aid and Accounts Receivable will work in coordination to sync the process of importing files and posting to accounts on the same day. Our new ERP has streamlined reporting to COD and catches and corrects any date discrepancies between the two systems. This finding was directly related to the migration from our old system and the disruption of data flow. Additionally, a review for matching COD disbursement dates will now be included during the monthly reconciliation process moving forward as a second layer of quality control. Anticipated Completion Date: June 30, 2026 Contact Person: Mary Reed, Director of Financial Aid & Advising

Finding No.: 2025-003 – Disbursements Reporting Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster – Pell Grant Program and Federal Direct Loan (FDL) Program ALN Number: 84.063, 84.268 Federal Award Year: July 1, 2024 – June 30, 2025 Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data ED has categorized as accepted or accepted with corrections. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found For two (2) out of 69 Pell COD Reports selected for test work, the required Pell student payment data was reported to the Common Origination and Disbursement (COD) website 52 days after disbursement, which exceeds the 15-day timeframe required by federal regulations. For one (1) out of 69 Pell COD Reports selected for test work, the required Pell student payment data was reported to the Common Origination and Disbursement (COD) website 261 days after disbursement, which exceeds the 15-day timeframe required by federal regulations. For four (4) out of 69 Pell COD Reports and three (3) out of 113 FDL COD Reports selected for test work, the Cost of Attendance was misreported to the COD website. There was no follow-up by the University to correct the discrepancies. For ten (10) out of 69 Pell and ten (10) out of 113 FDL COD Reports selected for test work, the transaction number did not agree between the FASFA Submission Summary Form and the COD website. Cause The cause of the conditions found is insufficient review to ensure that accurate disbursement reporting is occurring on a timely basis, all records submitted to COD were accepted, and, for those that were rejected, that corrected data is submitted within the required timeframe. Possible Asserted Effect The possible effect of the condition found is that the University may not be reporting Pell and FDL disbursements to COD completely, accurately, and in a timely manner. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes; 2024-002 Views of Responsible Officials Management accepts this finding and notes several issues that affected the submissions including staffing onboarding and training, submission review, and deadline controls. Management continues to fill positions experiencing unexpected turnover and to improve training for current and newly hired staff in order to restore adequate staffing levels and ensure continuity of COD reporting responsibilities. From May through September 2025, management retained Blue Icon Advisors (BIA) to provide dedicated coaching and support for improved onboarding and compliance knowledge, including providing specialized training to the Loan Manager relative to federal regulations and proper loan record management. Management is implementing processes to improve the weekly review and update of Cost of Attendance (COA) information and CPS transaction numbers to further ensure institutional records are aligned with COD data and to reduce the risk of mismatched records. Management has also strengthened internal controls with improvements to processes which enhance the monitoring of submission deadlines, review of file acceptance reports, and identification and correction of electronic records issues prior to submission. These improvements include the increased and more effective utilization of COD-delivered reports (including Pell Reconciliation and Anticipated Disbursement Reports) and institutional and PeopleSoft reports and queries, with reviews conducted on a weekly basis to promptly identify record discrepancies requiring resolution. Anticipated Completion Date March 2026 - completed Responsible Person Nicole Adner, Director of Financial Aid

Child Nutrition Cluster, ALN’s 10.553 & 10.555 Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to enhance the prevention of discrepancies between the claim for reimbursement and underlying data. Explanation of disagreement with audit finding: Management agrees with the finding. Action taken in response to finding: Newton operated the National School Lunch Program (NSLP) during the Extended School Year (ESY) for the first time during the summer 2024, which created a reporting challenge. Students from across the district's 23 schools attended ESY in seven (7) schools/sites, but their school-year home schools could not be changed in the Student Information System (Aspen). Therefore, student meal counts reported to their home school on the FP9 but had to be reported on the DESE School Report for the ESY school/site they attended. Given the system interface complexities, some counts had to be manually entered, for which two (2) meal counts were incorrectly entered for breakfast versus lunch. Given that the district did not operate the School Breakfast Program (SBP) and did not serve breakfast, these two (2) manual errors were counted as lunch counts when entered for the School Report. The total meal count did match on the FP9 and School Report. For this inconsistency, the correct action should have been to manually update these two counts in the Point of Sale system (Mosaic) so that the two breakfast counts reflected correctly as lunch counts. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: Newton was able to set conditional parameters in Aspen for ESY 2025 so that the student meal counts reported to their ESY school/site versus their home school, so this reporting issue was corrected the following summer.

Condition: The District's expenditure reports filed for September 30, 2024 included expenditures in the amount of $22,040 that were neither obligated nor liquidated by the date of the report. Plan: Management will review all expenditure reports. Only expenditures obligated within the grant period will be included on the expenditure report. Any obligations not yet liquidated will be reported as such.

Finding No. 2025-006 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that for various samples, the time between drawdown and disbursement of federal funds was up to 266 days elapsed. Indicating that cash management controls were not operating to minimize the time between transfer and disbursement. Corrective Action Plan OPSD DBEDT will ensure that program personnel are familiar with all federal requirements, including ensuring that funds are disbursed timely. Person Responsible Mary Alice Evans, Director of Office of Planning and Sustainable Development Anticipated Date of Completion April 1, 2026

Finding No. 2025-005 ALN No. 10.179 Program Title: Micro-Grants Food Security Program Grant Award No.: AM200100XXXG132 21MGFSPHI1003-00 AM22MGFSPHI1007-04 23MGFSPHI1011-00 24MGFSPHI1016-00 Condition An elapsed time of 583 days between the drawdown and disbursement date of funds for the program and that the check date of 01/24/2025 occurred after the grant period expiration of 09/29/2024. Indicating that cash management controls were not operating to minimize time between transfer and disbursement and that the period of performance was unauthorized to be extended past the budget date. Corrective Action Plan Concur. The Hawaii Department of Agriculture and Biosecurity (DAB) will change administrative procedures for drawdown and disbursement of federal funds under the Micro-Grants Food Security Program. DAB will process the grant contracts and payments in batches of about 100 micro-grants per month, and federal drawdown will not occur until about a batch of 100 contracts have been executed. Additional staff hired for grant processing will expedite the payment process to ensure conformity with the 25-day disbursement timeline. Person Responsible Brendan Akamu, Market Development Branch Manager Anticipated Date of Completion Corrective action plan will be implemented in April 2026.

Matching (Significant Deficiency in Internal Control and Noncompliance) Assistance Listings number and program name: COVID-19 93.354 Public Health Emergency Recommendation: The County should establish procedures to track matching requirements in the general ledger, ensure all in-kind contributions are supported by proper documentation (e.g., timesheets), and review match compliance before use of federal funds. Contact Person(s): Catrina Jenkins, Emergency Management Manager Anticipated completion date: June 30, 2026 County Discussion: Concur: In coordination with the Arizona Department of Health Services (ADHS), the County will implement procedures to ensure matching activity is properly tracked within the general ledger. The County will also ensure that all in-kind contributions are supported by appropriate documentation, such as timesheets or other relevant supporting records, in accordance with federal grant requirements. Additionally, the County will implement a review process to verify that matching requirements are properly documented and met prior to the drawdown or use of federal funds. These measures are intended to strengthen internal controls and ensure compliance with federal grant matching requirements.

Condition: Northeastern Illinois University (University) did not pay reimbursements within 30 days for certain subrecipients in the Research and Development Cluster. Planned Corrective Action: The University will explore procedures to address this issue. Contact person responsible for corrective action: Jannica Henry, Controller’s Office Anticipated Completion Date: 6/30/2026

Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement procedures for review and reconciliation of lunch count data with claims reports in accordance with the Uniform Guidance.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND OTHER MATTERS U.S. Department of Justice 2025-002 Department of Justice Second Chance Act Community-based Reentry Program – Assistance Listing No. 16.812 Recommendation: We recommend that TASC follow its established procedures for charging allowable expenses to the grant during the period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will follow established procedure to make sure costs are recorded in the proper period. Management will review the procedure with all accounting staff. Name(s) of the contact person(s) responsible for corrective action: Roy Fesmire, CFO Planned completion date for corrective action plan: June 30, 2026

Finding Number: 2025-003 - Inadequate Internal Control over Subrecipient Payments Condition: Western Illinois University (University) did not have adequate procedures in place to complete a timely disbursement of requested pass-through funds to subrecipients within the required time period. Planned Corrective Action: The University is committed to developing a comprehensive plan to ensure compliance with payment of pass-through funds policies and procedures. Contact person responsible for corrective action: Mary Pat Wolhford Anticipated Completion Date: 06/30/2026

Corrective Action Plan for the Year Ending June 30, 2025 Finding 2025-001: Significant Deficiency – Lack of Documented Controls – Cash Management Program: Student Financial Assistance Cluster Assistance Listing Number: various Federal Agency: U.S. Department of Education Federal Award Identification Number: various Federal Award Year: June 30, 2025 Repeat Finding: 2024-001 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition/Context: For six of eight selected G5/G6 Title IV drawdown transactions, there was no documented internal controls in place over cash management drawdowns. Despite the lack of documented controls over the cash drawdowns, there were no compliance exceptions noted. The sample was not a statistically valid sample. Cause: The College indicated the control of review was more informal/verbal and although had started documenting via email during the year, the documentation was not maintained. Questioned Costs: Not applicable Effect: The College could drawdown an incorrect amount although compensation controls/reconciliations would likely catch the error. Recommendation: The College should document controls in place to ensure cash drawdowns are complete and accurate. This should include a review by someone other than the preparer prior to the drawdown being requested in G5/G6. Action Taken: Management concurs with the finding and has taken the appropriate actions to remediate the significant deficiency. The team has made improvements to become more formal by implementing written communication among all members involved in the process. Each member of their respective roles are communicating through email presenting the step by step process of the review and approval before the drawdown of cash from G5/G6. Name(s) of Contact Person Responsible for Corrective Action: Kevin Brand, Director of Operations and Systems for Financial Aid; Laurie Klizos, Director of Student Accounts; Seong Nevins, Controller. Anticipated Completion Date: June 30, 2026 Signed by Charlie Faas and Jim Brooks

FINDING 2025 002 — SIGNIFICANT DEFICIENCY — UNIQUE ENTITY IDENTIFIER (UEI) DISCREPANCY Contact Person: Cantrese Wilson Jones, Executive Director Corrective Action Planned: The Authority will continue coordinating with SAM.gov/GSA to correct the mismatch between the UEI and the legal entity name. Periodic verification procedures will be implemented to ensure UEI information remains accurate across federal systems. Management will maintain correspondence records with the federal service desk until the issue is fully resolved. Anticipated Completion Date: This matter is dependent on federal agency processing timelines; however, the Authority anticipates completion by September 30, 2026, subject to SAM.gov/GSA resolution. Management Response: Management acknowledges the repeat issue and remains actively engaged with SAM.gov/GSA to finalize the correction.

Cash Management - Excess Cash on Hand Auditor Description of Condition and Effect. During our testing of cash management for campus-based aid, we noted one instance out of six drawdowns tested, that the College drew down Federal Work Study funds that were not needed for immediate disbursement, and was not returned timely. As a result of this condition, the College was not in compliance with the Uniform Guidance cash management principles. Auditor Recommendation. We recommend the College strengthen its cash‑management controls to ensure Title IV drawdowns are limited to immediate disbursement needs, reconciled promptly, and any excess cash is identified and returned within required regulatory timeframes. Corrective Action. The College is enhancing its federal cash management practices by limiting drawdowns for campus‑based programs, including Federal Work‑Study, to immediate disbursement needs. Drawdowns are now based on a documented three‑day cash needs forecast to ensure compliance with federal requirements. A standardized drawdown checklist requires staff to reconcile all G5 activity to the general ledger and subsidiary ledgers on the same day funds are drawn or disbursed. Any excess cash identified through this process is returned to the Department of Education via G5 within one business day. Monthly management reviews monitor drawdown timing, cash balances, and reconciliation trends to ensure continued compliance. Staff have been retrained on updated cash management procedures, and quarterly monitoring reports are produced and retained as evidence of ongoing compliance with federal cash management standards. Responsible Person. Jennifer Stimson, Director of Financial Aid with support from Scott Kemmer-Slater, Director of Accounting. Anticipated Completion Date. June 30, 2026

Research and Development – Assistance Listing No. 10.215 Research and Development – Assistance Listing No. 93.433 Recommendation: We recommend that the University review and update policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2023 audit report in May 2024. The 2023 audit was completed after substantially all of Fiscal Year 2024 had elapsed, so there was not adequate time for the University to fully implement corrective action. While these corrective measures were implemented during Fiscal Year 2025, they did not fully resolve the issue. The University continues to strengthen its accounts payable processes and sign-off approvals to help ensure reimbursements to subrecipients are paid timely. Additional updates to procedures for payment processing are also being developed. Methods for more accurate tracking of invoice receipt dates are being developed to ensure the 30-day period begins on the correct day. Principal investigators and designated administrative personnel within academic departments will be reminded of the need to initiate payments to subrecipients timely. Accounts payable training has been held for such personnel and will persist. Name(s) of the contact person(s) responsible for corrective action: Ms. Andrea Sherwood, Assistant Director, Grants and Contracts Financial Administration at Oklahoma State University and Ms. Nykkia Harris, Controller for Fiscal and Administrative Affairs Planned completion date for corrective action plan: May 2026

Finding Reference 2025-06 Corrective Action Plan: To strengthen internal controls, improve monitoring, and reduce delays in the certification and payment process, the Authority will implement the following operational improvements: The Authority is using the Finance Office Dashboard to track the status of certifications and invoices in real time, identify bottlenecks in the approval process, and support proactive management of pending payments. A standardized Construction Certification Compliance Checklist will be used to validate all required federal compliance documentation before certifications are submitted to the Finance Office. This measure is expected to reduce the number of returned submissions and prevent delays during the billing review process. The Authority will develop a Help Desk platform for certification and invoice inquiries to formally manage, document, and track inquiries or claims related to Construction Certifications and Pre- Construction invoices, improving transparency and response times. The Authority will launch the ICMM Payment Tracking Table to consolidate and monitor the payment status of certifications and invoices. Additionally, the Authority is establishing intermediate milestones to progressively reduce the payment processing cycle, with the objective of moving from the current 40-day average toward the 30-day target. As part of this initiative, the Authority is expanding the use of the Project Management Information System (PMIS) to standardize and streamline the processing of construction certifications and payment documentation. Responsible: Mr. Angel M. Felix Cruz, Acting Director, Confidential Finance Office Planned Implementation Date: In process. The first operational improvement has been implemented. The remaining three measures are pending implementation. Expected to be completed on or before June 30, 2026.

Recommendation: The Department of Social Services should provide the necessary resources and institute procedures to ensure that it uses all information from eligibility, income, and death matches to ensure that it correctly issues benefits to or on behalf of eligible clients. DSS should return federal reimbursements for unallowable expenditures claimed under Medicaid and SNAP. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with this finding. DSS staff is in the development phase of implementing new automated procedures to ensure timely and accurate action is taken to discontinue benefits of deceased clients when date of death information is received and matched to the Connecticut Department of Public Health’s State Vital Records Office. Action has been taken to correct the errors cited, including discontinuing the benefits of the individuals that were verified as deceased, and recouping the overpayments as appropriate. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Dan Giacomi, Program Division Director (860) 424-5080

Recommendation: The Department of Social Services should amend the contract with its Medicaid recovery audit contractor to comply with federal regulations. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with this finding. The Department will review the payment methodology at the next contract renewal. Anticipated Completion Date: October 1, 2027 Department of Social Services Contact Person: John Jakubowski, Director of Quality Assurance (860) 424-5855

Recommendation: The Department of Social Services should strengthen internal controls to ensure that it accurately reports and adequately reviews revenues, expenditures, collections, and contingency fees prior to submitting Form CMS 64. The Department of Social Services should strengthen internal controls to ensure that it tracks, reports, and returns the federal share of overpayments to corresponding federal and state medical assistance programs. The Department of Social Services should resolve the issues affecting the Medicaid receivable balances and file the proper adjustment to correct the errors, unsupported amounts, and corresponding federal reimbursements on Form CMS 64. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with this finding. The Department will review internal controls to identify possible corrective actions. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Briana Mitchell, Chief Officer Fiscal Administrative Services 1 (860) 424-5471

Recommendation: The Department of Social Services should strengthen internal controls to ensure that only eligible recipients receive Medicaid services in accordance with federal laws and the Medicaid State Plan. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with this finding. The Department identified cases where overrides that were applied during the public health emergency were not removed. This resulted in individuals remaining enrolled inappropriately. Our Business Systems Division is implementing a tiered resolution approach, beginning with individuals enrolled in the Medicare Savings Program and HUSKY-C coverage. Please note: The Department will not be returning the questioned costs associated with this finding. According to federal regulations, recoveries based on eligibility errors can only be pursued when identified by programs operating under CMS’ Payment Error Rate Measurement program, per section 1903(u) of the Social Security Act and regulations at Title 42 CFR Part 431, Subpart Q. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Dan Giacomi, Program Division Director (860) 424-5080

Recommendation: The Department of Mental Health and Addiction Services should strengthen internal controls over cash management to ensure federal funds it draws down for the Block Grant for Prevention and Treatment of Substance Use program are supported by expenditures. Corrective Action Plan as Reported by the Department of Mental Health and Addiction Services: To address this issue and prevent its recurrence, management is implementing the following corrective actions: 1. Enhanced Reconciliation Procedures: The Department will strengthen the monthly and pre-drawdown reconciliation process to ensure that all draw requests are fully supported by corresponding program expenditures before submission. This revised process will help prevent errors in future drawdowns and ensure compliance with cash handling requirements. 2. Updated Written Procedures: Written procedures for drawdowns will be updated to clearly define drawdown eligibility criteria, documentation requirements, and approval responsibilities. These revisions will provide clear guidance to staff involved in the drawdown process. 3. Training and Staff Development: Management will conduct training for all relevant staff members involved in the drawdown and reconciliation process. This training will focus on the importance of compliance with federal requirements, internal controls, and the proper documentation needed for drawdowns. Anticipated Completion Date: March 31, 2026 Department of Mental Health and Addiction Services Contact Person: Maureen Goff, Assistant Chief of Fiscal & Administrative Services Maureen.Goff@ct.gov (959) 276-1627

Recommendation: The Department of Public Health should strengthen internal controls over cash management to ensure that federal drawdowns align with the immediate cash needs to administer the program. Corrective Action Plan as Reported by the Department of Public Health: Management Assurance and Fiscal have worked together to identify gaps and inefficiencies in the drawdown tool. Management Assurance will periodically evaluate the drawdown tool’s usefulness and effectiveness as a cash management internal control. Fiscal will continue to monitor grant draws through the use of the improved drawdown tool. Anticipated Completion Date: Ongoing Department of Public Health Contact Person: Chuma Amechi, Fiscal Administrative Manager chukwuma.amechi@ct.gov (860) 509-7233 Ryan Wenzel, Supervising Accounts Examiner ryan.wenzel@ct.gov (860) 509-7822