Corrective Action Plans

The District is correcting the eligibility status of student participants and is providing training to those that determine the eligibility status to ensure proper eligibility determination in the future.

Corrective Action Plan For the Year Ended June 30, 2025 Finding: 2025-003 Name of contact person: Corrective Action: Proposed Completion Date: Corrective actions for Finding 2025-003 also applies to State award findings. Section IV - State Award Findings and Questioned Costs Section III - Federal Award Findings and Questioned Costs Jessica Wall, Human Services Director and Marcy Mays, Assistant Human Services Director Training to include technical assistance related to all Single County Audit Findings from the most recent audit. This training included a powerpoint presentation that covered income calculations, resources, self-employment and how to document each of these. During this training, we covered toggling into each determination to check for validity and made it a requirement that each caseworker calculate income outside of the system, upload their own calcuations into NCFast and verify that the outside calculation matches that in the system. Operational Support Representative visited the agency to provide training on self-employment, unemployment, passalong, SSI cases and passalong. Internally, we have developed second-party spreadsheets per worker to be able to better track individual performance and training needs. Internal Training completed on 09/17/25. Operational Support Training was provided on 10/22/25. Supervisors will provide at least monthly training on any new policy updates or second-party findings. 131

REFERENCE: 2025-002 – Eligibility HIV Emergency Relief Project Grants (Assistance Listing No. 93.914) Federal Grantor: U.S. Department of Health and Human Services Facility: Bailey-Boushay House Finding: The Bailey-Boushay House did not retain evidence of eligibility being reviewed prior to patient services being provided. Corrective Action Plan: Beginning in February 2025, Bailey-Boushay House Administrative staff send out upcoming Eligibility expirations occurring in the next 90 days to the Clinical Supervisor and Director of Outpatient Programs. The Clinical Supervisor forwards a list to each care manager/social worker for clients on their caseload. The Clinical Supervisor discusses the status of these updates during meetings with care manager/social worker. Notes are made on the caseload list to document the discussion of status. The Clinical Supervisor sends a list to the care management team for clients who are within 30 days of their expiration, in order to identify clients who may be out of contact or less engaged in the program. A note is provided with these clients' medications to remind them that they need to complete this eligibility update with a care manager or social worker. Quarterly and monthly emails of eligibility expirations are retained for documentation purposes. Person Responsible: Katie Hara, Director of Outpatient Programs – Bailey Boushay House Completion: February 2025

Name of Responsible Individual: Matt Cooper, Student Financial Services Corrective Action: To strengthen compliance and ensure the accuracy of student aid eligibility determinations, we will enhance Liberty’s quality control (QC) measures within the federal verification process. Our primary goal is to minimize errors, improve consistency, and ensure all Financial Aid verification activities align with federal regulations and institutional policy. We will begin by implementing a more targeted QC process aimed at validating records of students who submitted subsequent tax documents. We will increase our verification QC selections of this particular population from 35% (current) to 60% (future) to verify data accuracy, documentation completeness, and adherence to ED’s Application and Verification Guide (AVG). Findings from these reviews will be used to identify training needs and process improvements. Staff training will be expanded to focus on federal verification requirements, common error trends, and documentation standards. Refresher trainings will be held with the entire verification processing team, and supplemental individual coaching will be provided on a monthly basis to address any specific issues identified through QC. We will also create reporting to ensure the percentage of reviews mentioned above is maintained by our QC workflow. Regular data analysis will help identify any systemic issues early, allowing for corrective actions to mitigate any compliance issues. By reinforcing staff training, system monitoring, and increased reviews, we will ensure that our federal verification process remains accurate, compliant, and student-centered. Anticipated Completion Date: February 2026

Finding 2025-001: Student Financial Assistance Cluster - Student Eligibility/Special Test and Provisions Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster (84.007, 84.033, 84.063, 84.268) Criteria: In accordance with 34 CFR 668.165 (a), before an institution disburses title IV program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV program and how and when those funds will be disbursed. Additionally, when Direct Loans are being credited to a student's account, the institution must notify the student, or parent, in writing of the date and amount of disbursement, as well as the timing and process by which a parent may cancel the loan. The notification process is often completed by either an award letter or college financing plan. Controls were not in place to ensure College financing plans were emailed to all required students and/or parents that made the required notifications for Title IV program funds or that notifications were sent to students/parents with required communications regarding Direct Loan awards. Condition: The College notifies students of Title IV Funds by emailing a College Financing Plan to the student and/or parent. The College notifies students of Direct Loan awards and information through email notification via its financial aid system. Controls were not in place to ensure College financing plans that made the required notifications for Title IV program funds were emailed to all required students and/or parents or that notifications were sent to students/parents with required communications regarding Direct Loan awards. Cause: The College does not have a system in place to verify that everyone who received Title IV funding received a College Financing Plan or that all students receiving Direct Loans received required communications. Effect: As sampled, the College did not provide notification via a College Financing Plan of Title IV funding to two of its students as required and potentially could have additional students that did not receive proper notification. The College also did not provide notification of Direct Loan Awards to seven of its students, as sampled, as required and potentially could have additional students that did not receive proper notification. Repeat Finding: This is a repeat finding. Questioned costs: None Recommendation: We recommend that the College implement additional procedures to ensure all students receive notification of Title IV funding and Direct Loans as required under 34 CFR 668.165 (a). View of Responsible Officials and Planned Corrective Action: Management agrees, see separate Corrective Action Plan. Corrective Action Plan: To ensure that all students and their parents are adequately informed of the funds they can expect to receive under each Title IV Program, as well as the timing and process for disbursement, the college will implement the following actions. 1.College Financing Plan Notification: The College implemented a new financial aid management system (Jenzabar Financial Aid) during the fall 2025 semester. This new system allowed the college to create processes to notify students, via email, whenever their financial aid package is completed as well as when changes are made to their Title IV financial aid eligibility. These processes are scheduled to run nightly to ensure that notifications are sent in a timely manner without a staff member having to manually send notifications. Each notification directs students to their secure financial aid portal, where they may access the most current version of their College Financing Plan at any time. This ensures continuous access to accurate information regarding awarded aid and anticipated disbursements. 2.Loan Disbursement Notification: With the implementation of Jenzabar Financial Aid during the Fall 2025 semester the college scheduled email notifications to students when a Direct Loan is disbursed to their account. This notification informs them of their right to cancel the loan if desired. The automated process will ensure that timely notifications are sent. 3.Quarterly Review: The Director of Financial Aid and Executive Director of Finance and Financial Aid will conduct a quarterly review to ensure compliance with these procedures and verify that all necessary notifications are being issued as required.

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

2025-001 Ineligible Student Approved for Food and Nutrition Program U.S. Department of Agriculture – Child Nutrition Cluster CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: The District will implement review of household applications. 3. Official Responsible for Ensuring CAP: Maria Bezdicek, Business Manager, is the official responsible for ensuring corrective action for compliance. 4. Planned Completion Date for CAP: The planned completion date is June 30, 2025. 5. Plan to Monitor Completion of CAP: The School Board of ISD No. 2895 will be monitoring this corrective action plan.

2025-001 Recertifications 14.881 Moving to Work Demonstration Program – Award No. OCD26401344019MTW Responsible Official Sarah Scott Director of Leased Housing Plan Detail There has been a greater focus on ensuring new past dues (recertifications not completed on time) do not occur while we continue to resolve older ones. Starting with April 1, 2024 regular recertifications, we implemented a more rigorous monitoring process. The day after data entry for each recertification is due, the Director of Leased Housing generates a comprehensive report that consolidates information from multiple sources, including our software and internal tracking systems. Once verified, the Director provides these reports—including past-due recertifications from prior months—to managers for follow-up. Managers are responsible for ensuring the timely resolution of all cases on the report. Managers are held accountable for ensuring past-due cases do not reappear in subsequent months. Since the implementation of this process, we have seen a significant reduction in the number of past-due recertifications for assigned caseloads as management is proactive in ensuring no name, especially those on vacant caseloads due to numerous staff medical leaves, reaches that list. Additionally, as of October 2025, the Leased Housing Department will be operating within our new Yardi software system, a significant upgrade designed to enhance efficiency, accuracy, and user experience across all aspects of program administration. Yardi enables considerably faster processing times compared to our current platform, reducing the time needed to complete certifications, adjustments, and case updates. One of the most beneficial features of Yardi is its Recertification Dashboard, which provides staff with real-time visibility into upcoming deadlines, pending tasks, and the overall status of each case. The dashboard includes automated prompts and workflow reminders throughout the recertification process, ensuring staff stay on track and that each step is completed in sequence. In addition to speed and organization, Yardi offers enhanced data accuracy and integration capabilities, minimizing duplication and manual entry errors. These improvements will help staff manage their caseloads more effectively, provide more timely service to participants and property owners, and ensure compliance with program requirements. Anticipated Completion Date June 30, 2026 – Past due percentages will be lowered to acceptable levels with those outstanding being a result of the hearings and appeals process.

The Property Manager will be responsible for completing all income verifications and calculations to ensure accuracy and compliance with HUD requirements. The income verification documentation and rent calculation worksheets will be reviewed and signed off by the Property Manager Supervisor, which is the Chief Financial Officer (CFO) for Comprehend. This added level of oversight will strengthen interanl controls and help ensure that tenant and HUD rent portions are calculated correctly and supported by appropriate documentation.

Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – March 31, 2026

Auditor Description of Condition and Effect. During our cost of attendance recalculation, we noted that for one student, an additional semester in which the student was not taking any classes was included in their calculation. As a result of this condition, the College overstated the student's financial need for the award year. However, no action was required by the College as the corrected cost of attendance still exceeded the student's awards. Auditor Recommendation. We recommend that the College implement a review process to ensure that all manual entries into the cost of attendance system are reviewed and approved by an independent second individual. Auditor Recommendation. We recommend that the College implement a review process to ensure that all manual entries into the cost of attendance system are reviewed and approved by an independent second individual. Corrective Action. Upon discovery of the cost of attendance calculation error, the College went through and determined that this was an isolated incident and had no impact on the amount of aid received by the student. To prevent a similar problem arising in the future, the College will implement a review process to have a second individual review and ensure the cost of attendance is being calculated accurately. Responsible Person. Michelle McNier, Director of Financial Aid. Anticipated Completion Date. June 30, 2026.

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

Finding: 2025-001 Bond Covenant Compliance Finding: 2025-002 Edgecombe County, NC For the Year Ended June 30, 2025 Corrective Action Plan Section III - Federal Award Findings and Question Costs Name of contact person: Angel Joyner, Brandy Dawes, Tina Radford, and Virginia Ewuell - Medicaid Supervisors; Denise McKnight - Social Services Program Administrator Corrective Action: All Medicaid Supervisors will meet to review the findings from this audit. A PowerPoint training will be developed and delivered to staff based on these findings. During this training, supervisors will be retrained on the use of application checklist for their programs and will review the checklist to identify and add any information workers may be missing when completing their casework. The application checklist will be updated to include the dates when actions are taken to prevent workers from simply checking items off. This will require case workers to complete a second verification of each action so the date can be accurately entered. Supervisors will also receive training on pulling reports to ensure SSI terminations are reviewed and ex-parte reviews are completed timely. After the refresher training for Medicaid Supervisors, a mandatory group training will be provided for Medicaid workers on Income calculations, including pulling and viewing electronic verification sources, household composition, requests for Informaiton, SSI terminations, and Documentation. Workers will also be trained on the proper use and importance of the application checklist. Supervisors will be responsible for completing weekly random audits focusing on accuracy and timeliness. A 30-day performance improvement plan will be implemented for workers who identify through these audits as having repeated errors. Proposed Completion Date: June 30, 2026. Section II. Financial Statement Findings Name of contact person: Linda Barfield, Chief Financial Officer Corrective Action: The County acknowledges that Water District No. 4 did not meet the 100% debt service coverage requirement for general obligation and installment financing for the fiscal year ended June 30, 2025. While the District exceeded the required revenue bond coverage, the district-level net revenues were not sufficient to meet the combined debt service requirement. The County operates its water and sewer system as a single integrated utility system and does not maintain district-level rate structures. Revenues are generated and managed on a system-wide basis for financial stability and operational efficiency; however, USDA bond covenants require compliance to be measured by individual district. Although full compliance has not yet been achieved, the coverage ratio for District No. 4 continues to improve, increasing from 49% in FY 2023 to 61% in FY 2024 and to 65% in FY 2025. Management will continue to address this issue through ongoing financial monitoring and long-term system planning to achieve full covenant compliance. Edgecombe County County Administration Building 201 St. Andrew St., PO Box 10 Tarboro, NC 27886 252-641-7834 · Fax 252-641-0456 www.edgecombecountync.gov 176For the Year Ended June 30, 2025 Corrective Action Plan Edgecombe County County Administration Building 201 St. Andrew St., PO Box 10 Tarboro, NC 27886 252-641-7834 · Fax 252-641-0456 www.edgecombecountync.gov Section IV - State Award Findings and Question Costs Edgecombe County, NC Proposed Completion Date: Training and implementation of additional reviews and procedures will be implemented by January 15, 2025. Corrective actions for finding 2025-002 also apply to the State Award findings. Section III - Federal Award Findings and Question Costs (continued) 177

Condition: The School District does not properly review students’ institutional Student Information Records (ISIR) to determine that the student is eligible for federal student financial aid. Planned Corrective Action: The School District has implemented a formal review process to ensure all Institutional Student Information Records (ISIRs) are accurately evaluated for student eligibility prior to awarding federal student aid. Staff have been trained on the new procedures, including resolving required data elements and confirming eligibility criteria. The District has also instituted periodic internal checks to ensure consistent and compliant ISIR review practices moving forward. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: October 2025

Condition: The School District relies on two-third party vendors to manage key financial aid systems, including student information, eligibility determinations, disbursement calculations, and reporting. During the audit period, the institution did not perform any oversight activities or testing to verify the integrity, accuracy, or compliance of the systems managed by the vendor. There were no documented controls, service-level agreements, or monitoring procedures in place. Planned Corrective Action: The School District will establish formal oversight procedures for all third-party vendors supporting financial aid functions. This will include developing and maintaining service-level agreements, implementing documented monitoring and testing protocols, and conducting periodic reviews to verify system accuracy, data integrity, and federal compliance. Staff will be trained on these updated processes to ensure ongoing accountability. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The School District is eligible to participate in Title IV federal student aid programs; however, it does not conduct an annual review of its institutional eligibility requirements nor maintain documentation supporting such assessments. Planned Corrective Action: The School District will implement an annual review process to verify its institutional eligibility for participation in Title IV programs. Procedures will include maintaining thorough documentation of all eligibility assessments and required approvals. Staff responsible for compliance will be trained on these updated requirements to ensure accurate and timely completion each year. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The institution does not have a process or controls in place for a timely review of program eligibility, ECAR. Planned Corrective Action: The School District will establish a formal process to ensure timely and documented reviews of program eligibility in accordance with federal requirements. Staff will be trained on the new procedures, and the School District will implement internal controls to monitor program eligibility on a regular schedule. These steps will help ensure ongoing compliance and accurate determinations moving forward. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: June 30, 2026

Condition: The School District does not calculate or process any post-withdrawal disbursements for students that have withdrawn from the institution. Planned Corrective Action: The School District has implemented procedures to ensure post-withdrawal disbursements are calculated and processed in accordance with federal Return of Title IV (R2T4) requirements. Staff have been trained to identify eligible students, complete the required calculations, and issue timely notifications and disbursements. The School District will also conduct periodic reviews to ensure that all post-withdrawal disbursements are consistently met. Contact Person Responsible for corrective action: Almir Hodzic Anticipated Completion Date: October 2025

Condition: The School District did not utilize the cost of attendance when determining the maximum amount of aid a student is eligible to receive. The School District also does not maintain updated cost of attendance calculations for its programs. Planned Corrective Action: The School District will implement procedures to ensure the cost of attendance (COA) is used when determining each student’s maximum eligible aid in accordance with federal requirements. The District will also develop and maintain updated COA calculations for all programs and review them annually. Staff will be trained on these processes to ensure accurate and compliant aid determinations moving forward. Contact Person Responsible for corrective action: Mary Cooper Anticipated Completion Date: June 30, 2026

None reported Finding: 2025-001 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2025-002 Name of contact person: Corrective Action: Proposed Completion Date: Section III - Federal Award Findings and Question Costs Corrective Action Plan For the Year Ended June 30, 2025 Section II - Financial Statement Findings Corrective Actions for Findings 2025-001 and 2025-002 also apply to State requirements and State Awards. Sally Strickland, Medicaid Program Manager, and Robby Hall, Director of Social Services There will be training, additional case studies, a checklist sheet, and a knowledge test for the relevant programs. Sally Strickland, Medicaid Program Manager, and Robby Hall, Director of Social Services There will be training, additional case studies, a checklist sheet, and a knowledge test for the relevant programs. Training and additional case reads were started in November 2025. The agency will continue to complete additional training with individuals case workers as needed. Section IV - State Award Findings and Question Costs Training and additional case reads were started in August 2025. The agency will continue to complete additional training with individuals case workers as needed. 195

None reported Finding: 2025-001 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2025-002 Name of contact person: Corrective Action: Proposed Completion Date: Section III - Federal Award Findings and Question Costs Corrective Action Plan For the Year Ended June 30, 2025 Section II - Financial Statement Findings Corrective Actions for Findings 2025-001 and 2025-002 also apply to State requirements and State Awards. Sally Strickland, Medicaid Program Manager, and Robby Hall, Director of Social Services There will be training, additional case studies, a checklist sheet, and a knowledge test for the relevant programs. Sally Strickland, Medicaid Program Manager, and Robby Hall, Director of Social Services There will be training, additional case studies, a checklist sheet, and a knowledge test for the relevant programs. Training and additional case reads were started in November 2025. The agency will continue to complete additional training with individuals case workers as needed. Section IV - State Award Findings and Question Costs Training and additional case reads were started in August 2025. The agency will continue to complete additional training with individuals case workers as needed. 195

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Condition Of the twelve students selected for enrollment reporting testing, eleven students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The College concurs with the finding. The College will continue to remain vigilant in its oversight over timely communication of enrollment reporting detail to NSLDS. In both instances, the data we had sent to the National Student Clearinghouse (NSC) was not received by NSLDS in a timely fashion. We will review our reporting schedule and make the appropriate changes to our reporting timeline to ensure the data we report to the NSC is subsequently received by NSLDS within regulations. Names of Contact Person Responsible for Corrective Action: Annette MacMullin, Director of Financial Aid Anticipated Completion Date: September 18, 2025

Department of Education – Direct Programs ALN # 84.268, 84.063, 84.007, 84.033 Student Financial Assistance Cluster – Special Tests and Provision – Disbursement on Behalf of Students Finding Summary: Two students were identified who were not awarded the full amount of Pell for which they were qualified. Both students were registered in the summer session. Responsible Individual: Director of Financial Aid Corrective Action Plan: The College will implement a control process to ensure all semesters are properly identified and taken into account when creating a financial aid package for students. An evaluation will be done to ensure that no students who are eligible for Pell are precluded from receiving it. Anticipated Completion Date: Spring 2026

FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Jacob Heuchan, Business Manager Contact Phone Number and Email Address: 317-878-2100, jheuchan@nhj.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business Manager and Food Service Director will work together to implement a system of controls surrounding eligibility. The Business Manager and Food Service Director will meet on a regular basis to verify eligibility outcomes to ensure accuracy. Anticipated Completion Date: Immediate. INDIANA STATE

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