Corrective Action Plans

Views of Responsible Officials and Planned Corrective Action: QARI acknowledges the finding and has developed and implemented policies and procedures to ensure that all participant information is retained and for management to perform and document periodic reviews of eligibility determinations. While eligibility documentation was collected at intake, original records were not retained in a centralized system and the organization has since implemented a new data tracking and management system (DPP Express) in FY2026. QARI confirms that all participants enrolled in the program met eligibility requirements and that all required data has been accurately submitted to the Diabetes Prevention Recognition Program (DPRP) in accordance with CDC requirements to maintain Pending Recognition status. To address the finding, QARI has implemented the following corrective actions: 1) Standardized procedures to ensure original participant eligibility documentation is retained within the data management system; 2) Management-level periodic reviews of eligibility determinations, with documented oversight; 3) Cross-training and role clarification to ensure continuity in data collection and record retention despite staffing changes. These actions will strengthen documentation practices while maintaining the integrity and compliance of QARI’s program enrollment and reporting processes.

Cognizant Agency: U.S. Department of Health and Human Services (HHS) Western Arizona Council of Governments (WACOG) respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024 – June 30, 2025 The finding from the schedule of findings is discussed below. FINDING—FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF AGRICULTURE 2025-001 Child and Adult Care Food Program – Assistance Listing No. 10.558 Recommendation: WACOG should enhance internal procedures related to the continued review and monitoring of vendors used under cooperative contracts. Management should implement standardized checklists and maintain a centralized repository for documenting vendor due diligence activities, including prequalification evaluations and suspension and debarment verifications. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Vendor due diligence will be performed every three years, encompassing the assessment of two prequalified contractors and verification that vendors are not suspended or debarred via sam.gov, as required by CFR 200 and consistent with WACOG’s purchasing policies and procedures. Records will be maintained in alignment with the record retention policy and provided to auditors upon request. These records will include procurement staff suspension verifications as well as documentation of all vendor due diligence processes. Program staff responsible for procurement will store these records in a centralized repository, with an additional copy submitted to the fiscal department. Names of the contact persons responsible for corrective action: Susan Dempsey, Deb Schlamann, and Gina Whittington Planned completion date for corrective action plan: June 30, 2026. If HHS has questions regarding this plan, please call Susan Dempsey at 928-217-7130 or Deb Schlamann at 928-217-7146.

Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally, we recommend the district designate an individual to review eligibility and verification determinations for accuracy and proper input into software. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Food Service Director will review eligibility and verification determinations for accuracy and proper input into the software. The District will continue to improve on reviewing and approval of claims. Name of the contact person responsible for correction action: Jessica Holtz Planned completion date for corrective action: June 30, 2026

The Lafayette Parish School Board has a defined process in place to ensure debarment verifications are being performed. As new vendors are setup, a debarment verification is performed when federal funds are to be associated with a vendor. In addition, many vendors are utilized year after year, which is after an initial debarment verification is performed. In this case, debarment verifications for three vendors could not be found, and despite key personnel turnover, staff will ensure that debarment verifications are being performed and stored digitally.

FINDING 2025-005 Corrective Action Plan The Organization lost funding during 2025 and therefore there is no corrective action plan. Responsible party: Jason Youngclaus; Chief Financial Officer; (978) 930-3830 Anticipated completion date: Not Applicable

Corrective Action Plan 2025-004 – Missing Impact Aid Tribal Source Checks (Material Weakness) Federal Program Information: Funding Agency: U.S. Department of Education Title: Impact Aid (Title VII of ESEA) FAL Number: 84.041 Passthrough: N/A Award Year: 2025 Responsible Official’s Plan: The district Superintendent and Associate Superintendent of Federal Programs have received training from Impact Aid in identifying eligible students. The recommended process will be used when submitting the next funding application. Specific corrective action plan for finding: The 2026 and 2027 applications were submitted using the process outlined in the corrective action plan. Timeline for completion of corrective action plan: Effective immediately. Employee positions responsible for meeting the timeline: Superintendent-Lynda Spencer Federal Programs Associate Superintendent-Dr. Julie Pierce

Care Alliance Health Center, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2025. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: October 31, 2025 The findings from the October 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Federal Award Findings: Finding 2025.001 - Special Tests and Provisions - Sliding Fee Scale Documentation Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken FY 2025 Corrective Actions and Objectives Documented Process, Procedures and Policies • By June 30, 2026, Care Alliance will update, standardize, and implement a unified, documented workflow for full-fee collection at check-in for all encounters. • Key Performance Indicators (KPI) • ≥90% of self-pay encounters have documented collection attempt • 100% of quarterly review cycles by October 31, 2026. • By April 15, 2026, Finance and Operations will develop a concise list of commonly used CPT/HCPCS procedure codes with associated full fee amounts for Patient Services Representatives (PSRs). The list will be updated quarterly. • KPIs • 100% staff acknowledgment of list each quarter • ≥85% accurate fee quotes of random sampling • By May 1, 2026, Finance and Operations will review and update finance policies governing full-payment determination and collections (FS 106 Sliding Fee Scale Discount Program and FS 107 Billing, Credit, and Collection). • KPIs • 100% staff acknowledgment of updated policies • ≥95% compliant monthly audit of SFS documentation (random sampling) Training and Education • By June 30, 2026, Care Alliance will provide training to front desk staff members responsible for determining eligibility and applying sliding fee discounts. Training will cover documentation requirements, verification of family size/income, and correct SFS application. • KPIs • 100% Staff Training and Education Sign- Off • 100% Completion of annual competency for SFS • By May 31, 2026, Operations will implement a process that ensures Sliding Fee Scale (SFS)/self-pay indicators, Federal Poverty Level (FPL) are accurately entered and maintained for all visits, across all guarantor accounts. • KPIs • ≥90% of self-pay encounters have documented collection attempt • ≥85% accurate fee quotes of random sampling • By April 30, 2026, PSR will use standardized documentation during collections (amount owed, partial payments, attempts, patient ability to pay) for every applicable visit and incorporate into monthly audits. • KPIs • ≥90% documentation compliance of sampled encounters • By July 31, 2026, Finance will clarify treatment and procedures of bad debt previously written off and integrate post-write-off recovery efforts into policy and monthly reporting. • KPIs • 100% staff acknowledgment of updated policies Review and Auditing By May 1, 2026, and continuing throughout FY26, the Revenue Cycle Manager and Controller will conduct monthly audits to verify that all Sliding Fee Scale (SFS) discounts are accurately calculated, properly supported, and fully documented in accordance with FS 106. Additionally, the Controller will conduct quarterly reviews to evaluate overall compliance, identify areas for improvement, and assess the effectiveness of the sliding scale fee program in meeting patient needs and federal guidelines. Responsible Parties and Reporting Cadence • Controller and Director of Operations: Owns policy updates (FS 106/FS 107), quarterly documentation reviews, and oversight of FPL table updates. • Revenue Cycle Manager: Monitors adherence to workflow, conducts monthly audits, and drives corrective actions with Clinical Support Manager. Maintains the common procedures fee list and coordinates quarterly updates. • Clinical Support/Patient Access Manager (PSR Manager): Oversees PSR training, documentation compliance, and daily operations. Provides staff coaching and remediation based on monthly audit results. If there are any question regarding this plan, please e-mail Dr. Derrick Howell at dhowell@carealliance.org. Sincerely, Dr. Derrick Howell CFO

1. Prior to final submission of the monthly claim to ISBE, staff will: o Print off each page of the ISBE claim entry. o Compare the printed claim data to the original backup documentation (meal counts, reimbursement worksheets, etc.). o Verify that all numbers align with the supporting records. 2. Any discrepancies found during this review will be corrected in the ISBE system before final submission.

Finding 2025-001: Rural Rental Housing Loans Assistance Listing Number: 10.415 U.S. Department of Agriculture (Repeat of Finding 2024-001) Compliance Requirement: Eligibility, Program Income Type of finding: Internal Control Over Compliance (significant deficiency) Recommendation: The Organization should strengthen its internal controls with adopted policies and procedures to ensure a review process is established through adequate segregation of duties. The Organization should consider assessing and realigning the duties and responsibilities of the Executive Director, Administrative Assistant, and Alamosa Property Manager to provide for a review process of tenant eligibility determinations and the monthly housing assistance payment requests for the Sierra Vista Alamosa Housing Complex. Action Taken: This finding was from the actions of the pervious on-site manager, concerning the Alamosa Complex only. Sierra Vista/Alamosa Complex has already implemented the internal control concerning compliance in house. Priscilla and Alonzo will make sure that all internal compliance issues are segregated and check by at least 2 persons in the office, and if needed, the Executive Director can request viewing of internal control procedures as well. Alonzo and Priscilla prepare and review along with signatures of the review and approval dates of internal affairs. "This institution is an equal opportunity provider." If there are questions regarding this plan, please call the responsible party at (719)852-5505. Sincerely yours, Corinna Garcia Executive Director Monte Vista Community Center Housing Authority, Inc.

We recommend Christian Care management strengthen internal controls and oversight over the rental assistance calculations and tenant eligibility documentation to ensure accuracy of all assistance payments.

Views of Responsible Officials: CVT has reviewed training in timely FFATA reporting with Finance staff working with sub-recipients.

Finding 2025-001 Reconciliation of Records Name of Contact Person: Philip Steffen, Finance Director Corrective Action: Proposed Completion Date: Finding 2025-002 Late Submission of Audit Name of Contact Person: Philip Steffen, Finance Director Corrective Action: Proposed Completion Date: Finding 2025-003 Inaccurate Information Entry Name of Contact Person: Alice Wilson, Medicaid Program Administrator Corrective Action: Proposed Completion Date: Section III - Federal Award Findings and Questioned Costs Section II - Financial Statement Findings Refresher training will be provided to all Medicaid staff for areas of deficiency. Beginning 2/1/2026, all LTC/CAP/PACE applications wil be reviewed by a supervisor prior to disposition. All adult Medicaid caseworkers will keep a pending recertification log and/or applicaction log that will be updated and emailed to supervision weekly. Caseworkers will continue to use the checklist created and implemented in October 2025. Beginning 2/1/2026 all extensions for Adult Medicaid recertifications will be staffed with the Program Manager prior to any action keyed. Beginning 2/1/2026, a designated supervisor or lead worker will complete targeted second party reviews for Family Medicaid specifically to ensure household composition is correct. For the Year Ended June 30, 2025 Corrective Action Plan In order to complete the audit on time for FY26, finance staff and auditors will create a detailed plan of which items are due at specific dates to ensure auditors have the information needed with enough time to complete the audit on time. 6/30/2026 Refresher training will be completed by 1/31/2026. Targeted second party reviews, pending logs, staffing for case extensions will begin 2/1/2026. Section IV - State Award Findings and Questioned Costs Corrective Action Plan for Finding 2025-003 also apply to State Award Findings. The County has implemented procedures to ensure reconciliation of records are done timely. In addition to assigning specific accounts to individuals best suited to reconciling them, the management staff will verify reconciliations are completed on time. 5/1/2026 141

Annual and Aggregate Loan Limits The University acknowledges the finding regarding the awarding of unsubsidized loan funds in excess of annual limits without adequate supporting documentation. We recognize that federal regulations require either a valid PLUS denial or fully documented professional judgment to support additional unsubsidized eligibility. Corrective Actions 1. Strengthened Documentation Requirements: Effective immediately, financial aid staff will maintain complete professional judgment documentation, including the rationale, supporting evidence, and approval, in the student’s file before any additional unsubsidized loan is awarded. 2. Verification Controls: A mandatory checklist has been implemented to ensure that a PLUS denial or documented professional judgment is obtained and reviewed prior to disbursement of any loan amount exceeding standard limits. 3. Staff Training: The Office of Financial Aid will conduct targeted training to reinforce Title IV loan limit rules and proper documentation standards. 4. Ongoing Monitoring: Supervisory review will be performed on all professional judgment decisions and on any loan increases exceeding the standard $2,000 annual limit. The University believes these corrective measures will address the root cause of the finding and ensure full compliance with federal loan regulations going forward.

Finding 2025-004 Finding Summary: Elko County School District did not have sufficient internal controls to ensure eligibility determinations of Title I fund amounts disbursed were being appropriately followed. Corrective Action Plan: The grants department will update allocation procedures to ensure equitable distribution of Title I funds to all eligible schools in rank order by low-income student count. Responsible Individual: Megan Cox Grant Manager Anticipated Completion Date: June 2026

Corrective Action: The University agrees with the findings. The project Directors will continue to validate data input into the system prior to the submission of the APR. We will establish a cut-off date for rolling the system fmward to prevent these administrative clerical errors. Contact Person: Mikael Davis, SSS Director And Dr Ferguson Gregg, Upward Bound Director Anticipated Completion Date: June 15, 2026

BAY BRIDGE CORPORATION 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Bay Bridge Corporation respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.181. Program –Supportive Housing for Persons with Disabilities Significant Deficiency Recommendation: Bay Bridge should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: We hired a new Property Manager for Bay Bridge Apartments, who has worked diligently to complete outstanding recertifications and this property is back on track. All recertifications are now current with one exception due to a lack of tenant cooperation which is being properly managed with legal action. To ensure that staff changes and vacancies do not result in late recertifications in the future, we have employed Property Operations Specialists (roving personnel) to provide coverage if there is staff turnover. We have also increased oversight by the Regional Manager to ensure roving staff remain on track and that recertifications are completed timely. Additionally, senior leadership at the John Stewart Company has implemented enhanced tracking of recertifications across the full portfolio and conducts monthly progress meetings with the management team to monitor compliance, identify risks early, and ensure accountability. We are confident that these corrective actions will result in sustained improvement and ongoing compliance. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

VERNON STREET HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Vernon Street Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.181. Program –Supportive Housing for Persons with Disabilities Significant Deficiency Vernon Street Housing, Inc. should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Unanticipated staff shortages created gaps in performance of annual recertifications at this location. New staff has since been hired in the Regional Manager role and the Director role. Both new employees are providing greater oversight and visiting the property regularly to track progress. In addition to our permanent staffing efforts, we have deployed a Property Operations Specialist to bring recertifications current at Vernon Street Housing This specialist is focused specifically on compliance tasks and critical deadlines. Additionally, senior leadership at the John Stewart Company has implemented enhanced tracking of recertifications across the full portfolio and now conducts monthly progress meetings with management team to monitor compliance, identify risks early, and ensure accountability. We are confident that these corrective actions will result in sustained improvement and ongoing compliance. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

Corrective Action Plan For the Year Ended June 30, 2025 NorthamptoN CouNty Finance Department 9467 Hwy 305 Jackson, North Carolina 27845 Leslie Edwards Finance Director Finding 2025-009 Inaccurate Information Entry Name of contact: Sammantha Thomas, Program Manager Corrective Action: Proposed Completion Date: Corrective Actions for finding 2025-010 also apply to State Award findings. Section IV - State Award Findings and Question Costs Section III - Federal Award Findings and Question Costs The program manager held a staff meeting to discuss audit results and all errors. The Program Manager will be requiring policy training for all Medicaid supervisors and caseworkers. The program manager will have another staff meeting to discuss new procedures for caseworkers and supervisors. New actions for caseworkers will include a new detailed checklist that will be reviewed by a lead worker or supervisor when requesting information for cases that result in a termination, reduction or denial. Additionally, all caseworkers will be responsible for generating a report of all outstanding and overdue reviews and will prioritize cases nearing compliance deadlines. New actions for Supervisors will include a review of all cases completed by new employees. Currently second party reviews are being completed on five cases weekly per caseworker, however, going forward this will be increased to 8-10 cases weekly per caseworker. Additionally, supervisors will be responsible for implementing a real-time tracking log for review due dates, review timeliness of these reports daily, and supervisors will meet with the Program Manager monthly to report timeliness metrics. Supervisors and staff will be required to complete yearly policy training provided by the Program Manager to ensure they are clear on review timelines and accuracy. A meeting with all staff and supervisors was held on 2/25/2026 to discuss the findings of the Audit. All trainings will be completed no later than 3/31/2026. All new requirements by the program manager will be implemented immediately. 156

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. The second (2025-002) finding pertains to compliance with federal eligibility requirements for the TRIO Upward Bound Program. Federal regulations require at least two-thirds of program participants to be both low-income and first-generation college students. The audit identified that the program fell below the required threshold. To address this issue, the College is strengthening participant eligibility verification procedures and implementing additional monitoring to ensure compliance throughout the program year. Recruitment strategies are also being enhanced to increase the number of eligible participants served by the program. In addition, staff will continue to receive targeted training to ensure accurate eligibility documentation and consistency between program records and federal reporting requirements. Corrective Action 2025-002: Strengthen participant eligibility verification, improve recruitment of eligible participants, enhance APR reporting accuracy, and provide compliance training for TRIO staff. Target resolution 2025-2026 Program Year

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. Corrective Action 2025-005: Administrative and Fiscal Affairs 1235 Fifteenth Street, Augusta, GA 30901 Implement the Return to Title IV monitoring system, weekly credit balance tracking, counseling verification procedures, and strengthen coordination between Financial Aid, Registrar, and Business Office Target resolution: Spring-Summer 2026

Finding 2025 - 001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (material weakness): Information on the federal program - (Federal Award Identification): - Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025. Institutions must determine a student's financial need by subtracting the expected family contribution and estimated financial assistance from the cost of attendance. 34 CFR 668.2 and 34 CFR 637.S(a). 1. Corrective Action Description The College has engaged a financial aid consultant to support the development of cost-of-attendance budgets and ensure they align with industry best practices, thereby making improvements to the College's financial aid operating system. After evaluating the auditors' sample of forty students, the College confirmed that no instances of over/under awarding occurred. There were clarifications and changes made to the initial cost of attendance budgets provided to the auditors that led to the questioned cost. The College will implement ongoing monitoring each semester to further enhance operational efficiency and effectiveness. The cost of attendance budgets has been uploaded into the College's financial aid system to prevent the recurrence of this issue for the current and future years. a. Responsible Person and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu b. Implementation Timeline January 18, 2026, for the spring semester c. Planned Preventive Measures The College hired a financial aid consultant to assist the financial aid Director with best practices and to make modifications to the ERP system to provide better operating efficiency and effectiveness. d. Disagreement with the Finding None

2025-001: Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, Grant Period - Year Ended August 31, 2025 Condition Found During our student file testing we noted two students out of forty were disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need, the University over awarded the students by $1,229. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Financial Aid office will make sure the correct amount is awarded based on the student enrollment status and need of the student. EWU will make the proper adjustments to the Direct Subsidized Loan to reflect the correct amount for the two students. Responsible Person for Corrective Action Plan Director of Financial Aid Cesar Campos Implementation Date of Corrective Action Plan March 06, 2026

Finding 2025-003 – Incomplete Eligibility Documentation Management agrees with the recommendation and will implement stronger processes to ensure that records confirming the eligibility of program participants are obtained and properly maintained. Specifically, all program staff documenting client eligibility will receive related training on eligibility requirements and best practices for related recordkeeping. While the organization will take these steps to help prevent reoccurrence of this finding, management also states that it directly sought and followed guidance from the program pass-through entity specific to client eligibility which was deemed in this audit to be inconsistent with requirements guiding the federal program. At the time of writing, this matter is being evaluated by the pass-through entity with further guidance forthcoming. Therefore, in addition to the steps outlined above, the organization will also further verify any guidance received from pass-through entities or other monitoring agencies to ensure its internal processes align directly and specifically with all requirements of the federal program. The contact persons for the Corrective Action Plan are Bill Threlkeld, VP of Community Resources Partnerships; Ted Lewis, EVP of Operations and Information Technology (IAT Co-Chair); and Aaron Hernandez, Sr. Director, Finance (IAT Co-Chair). The anticipated completion date is June 30, 2026. In addition to these specific steps, Cornerstones has strengthened its compliance review operations overall through the addition of a staff member who will focus primarily on compliance issues across the organization. Cornerstones has also formed an Internal Audit Team (IAT) comprised of organizational leadership that will provide objective assurance that the organization operates in full alignment with laws, regulations, contract provisions, and ethical standards.

Finding 2025-001 – Incomplete Eligibility Documentation (Repeat Finding 2024-001) Management agrees with the recommendation and will implement stronger processes to ensure that records confirming the eligibility of program participants are obtained and properly maintained. Specifically, all program staff documenting client eligibility will receive related training, both internally as well as from identified external sources. Accordingly, program staff attended a training on case management provided by an external partner in November 2025. Internal training will center on the Employment and Training Eligibility Determination form developed by the program pass-through entity in March 2026. This document provides a detailed checklist of the specific information required to verify client eligibility prior to delivering program services. Finally, the organization will work with its external partners (PTEs, monitoring agencies, etc.) to ensure that requirements are consistently stated across all pertinent organizations and described in common nomenclature to avoid confusion and/or inadvertent omissions, which have been key factors contributing to the reoccurrence of this finding in FY25. The contact persons for the Corrective Action Plan are Lacy Stokes, VP of Family Empowerment and Self-Sufficiency; Ted Lewis, EVP of Operations and Information Technology (IAT Co-Chair); and Aaron Hernandez, Sr. Director, Finance (IAT Co-Chair). The anticipated completion date is May 31, 2026.

Finding 2025-009-U.S. Department of Education (ED) TRIO Cluster Programs (significant deficiency) Information on the federal program-Educational Talent Search, FAL 84.044A This memorandum serves as management’s response to the audit finding regarding internal control weaknesses in participant eligibility documentation for the Educational Talent Search Program under 34 CFR § 643.3. Acknowledgment of Finding Management acknowledges the condition identified in which two participants’ applications lacked incorrect information to verify age eligibility requirements. Management notes, this condition reflects a perceived control weakness that may impact compliance with TRIO Talent Search Program requirements. Management Response During the initial application process, parent and student data is entered into a system-generated application. Management acknowledges that, in instances where inaccurate information is entered (e.g., date of birth), established procedures require verification against official documentation, such as the student’s transcript. Supporting documentation for Shayla Adams and Madison Wallace is provided as evidence. Upon identifying omissions or incorrect information during the review process, management verifies the applicants’ information directly with the participants’ school as part of the secondary review process. Official documentation is obtained and reviewed, and the verified date of birth is recorded as documented on the students’ official transcripts and maintained in the participant files. The applicants’ information is entered correctly in the student database (Blumen) prior to acceptance, ensuring compliance with eligibility documentation requirements under 34 CFR § 643.3. Management is committed to addressing this issue promptly and strengthening internal controls to ensure full compliance with federal regulations. Procedures governing participant intake, eligibility verification, documentation retention, and supervisory oversight will be consistently monitored. These measures include standardized processes, increased staff accountability, and ongoing monitoring to maintain program integrity. Corrective Action Plan 1. Standardized Eligibility Verification Process A comprehensive eligibility checklist will be implemented and required for all participant files to ensure consistent documentation collection and verification prior to acceptance. Before an acceptance letter is provided to students, and the information is entered into Blumen, birthdates will be checked by the school transcript. Responsible Party: Assistant Director and Program Director Implementation Date: Immediately upon receiving the application 2. Secondary Review and Approval Control A mandatory secondary review process will continue. Participants’ acceptance will not be approved until all eligibility documentation is verified as accurate complete. Responsible Party: Assistant Director Accountable: Program Director Implementation Date: Immediate 3. Staff Training and Procedure Reinforcement All staff will participate in mandatory training on eligibility requirements and documentation standards. Written procedures and required intake documentation will be provided to reinforce compliance expectations. Responsible Party: Assistant Director and Program Director Accountable: Program Director Implementation Date: Monthly 4. Documentation Tracking System Management will implement a tracking procedure to identify and monitor missing or incomplete documentation, ensuring deficiencies are resolved prior to participant approval. Responsible Party: Assistant Director and Senior Counselors Accountable: Program Director Implementation Date: Immediately upon receiving the application 5. Ongoing Monitoring and Internal Reviews Quarterly internal file reviews will be conducted to assess compliance with eligibility requirements. Findings will be documented and corrective actions enforced. Responsible Party: Assistant Director and Senior Counselor Accountable : Program Director Implementation Date: Quarterly 6. Documentation Retention Controls Uniform file management protocols will be established to ensure all eligibility documentation is properly maintained, organized, and readily accessible. Responsible Party: Assistant Director Accountable Program: Director Implementation Date: Ongoing Conclusion Management takes this matter seriously and is committed to ensuring that all corrective actions are fully implemented within the stated timeframes. These measures are designed to strengthen internal controls, ensure compliance with federal requirements, and enhance the integrity of participant eligibility determinations. The College has already initiated corrective action by hiring entirely new staff in key positions and is committed to fostering a culture of compliance through rigorous procedures and training. 1. Staff Expertise: Financial Aid team members are becoming certified in the enterprise resource program module, specifically related to financial aid, as a first step. 2. SOP Implementation: The core of this plan involves the creation of seven new or updated Standard Operating Procedures (SOPs) (as highlighted above) to standardize compliance activities and reduce reliance on individual employee experience. 3. Proactive Monitoring: We are implementing mandatory monthly and quarterly reconciliation and audit reports to ensure adherence to timelines and documentation requirements, moving from reactive to proactive compliance management. 4. Cross-Training: Training will be conducted across multiple departments (Financial Aid, Business Office, Registrar) to ensure shared understanding and accountability for Title IV compliance.