Corrective Action Plans

Senior Community Service Employment Program – Assistance Listing No. 17.235 Recommendation: National Able Network, Inc. should verify the eligibility of the recipients, at a minimum, annually. We recommend NAN continue to generate weekly reports identifying overdue participants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: NAN now has career coaches run a weekly report to identify overdue participants for eligibility reassessment. Manager also runs the report to keep the career coaches on task. Name of the contact person responsible for corrective action: Michelle Harris, CFO Planned completion date for corrective action plan: September 30, 2025

Finding 2025-001: Incorrect Federal Direct Loan Amounts – the auditor tested seventy-one files, sixty-seven of which were Federal Direct Loan recipients, and two students received incorrect loan amounts. It is recommended that the Institution refund $237 to the Department of Education and increase controls over packaging direct loans. There is no action required for the $333 in underawarded subsidized loans, as the student is no longer a current student, so the Institution is unable to reclassify the loans. Comments on Finding and Recommendation(s): This was an oversight on previous FA advisor when prorating loans. Actions Taken or Planned: Employee was removed from role earlier in the year and intense training has been given to the replacement. All debts have been settled with the Department of Education and appropriate student ledgers updated.

The management compnay acknowledges the important regulatory requirements for EIV documentation and timeliness required for generating reports for documentation and review within specified deadlines. To ensure ongoing compliance with these regulations, management will continue the training protocol that is in place for 2025 by reviewing and signing the EIV rules of Behavior and the EIV System Security Policy forms and completing the Cyber Awareness training annually. Management is working with on-site managers to provide additional back-up support from other departments during staffing shortages. Management also strengthened oversight procedures to ensure there are mandatory manager protocols that require an EIV report be generated and reviewed within 90 days for every new tenant move-in. For example, management implemented a checklist that the property manager must sign to confirm the EIV and other documents are properly reviewed and included in tenant files. For new tenants, the property manager will calendar the 90-day review to confirm receipt of EIV for inclusion in the tenant file. Management's housing manager and broker will also review each tenant file checklist for compliance to verify that all required EIV and other reports are in the tenant file. Additionally, management will conduct periodic reviews of files to ensure these procedures are properly followed. These additional checks and balances will ensure we are compliant with regulatory requirements.

2025-006 - Child Nutrition Cluster – Eligibility - The District is aware of the missing eligibility documents for the Child Nutrition program and will implement new procedures and a plan to reduce the missing documentation. Responsible Officials – Joe Dawidziak, Superintendent Anticipated Completion Date – The District will correct this in the subsequent fiscal year.

Condition During testing, auditor determined that 24 students had an incorrect eligibility status utilized for a portion of the school year. Recommendation We recommend that the District look for training opportunities for food service staff members to ensure that they have a good understanding of the program’s compliance requirements. Additionally, all students receiving free or reduced price meal benefits should be reviewed to ensure that they have a valid application or direct certification on file. Comments on the Finding The District agrees with the finding and has implemented procedures to prevent this, in the future. Actions Taken As of the date of this notice, training opportunities will be sought out to further food service staff members’ educations regarding the program compliance requirements. Eligibility for all students will be reset each year to ensure that only those who are direct certified or that have submitted an application and are eligible for free or reduced meals will receive those benefits.

Corrective Action Plan June 30, 2025 Finding: 2025-001 Name of Responsible Official: Angela Bass Anticipation Completion Date: December 31 , 2025 Mississippi First's Response: 1. Audit Finding Corrective Action Plan The auditor noted that Mississippi First did not submit a FFATA report for a subaward of $30,000 or more in a timely and accurate manner. 2. Root Cause The delay in submitting the FFATA report was due to a personnel transition during the reporting period. The outgoing Executive Director had been executing FFATA filings, and the incoming Executive Director and was not yet aware of this reporting requirement. Because the requirement was not captured in any written procedures or transition documents, the report was inadvertently missed. This was an isolated incident resulting from the timing of the leadership transition and a gap in knowledge transfer. 3. Corrective Action Taken / Planned A. Formal Policy Development - Mississippi First has drafted a comprehensive FFATA Compliance and Subaward Reporting Policy. B. Assignment of Responsibility - The Director of Operations is designated as the FFATA Reporting Officer. C. FFATA Reporting Checklist - A standardized checklist ensures accuracy for each submission. D. FSRS Standard Operating Procedure (SOP) - A detailed, step-by-step SOP has been developed. E. Deadline Tracking & Automated Reminders - FFATA deadlines will be integrated into the grants management calendar. F. Quarterly Internal Reviews - Quarterly internal audits will verify completeness, accuracy, and timeliness. G. Job Description Updates - Relevant staff job descriptions now include FFATA responsibilities. 4. Timeline for Implementation • Finalize and adopt FFATA Policy- by December 31, 2025 • Assign FFATA Reporting Officer role - Completed • Launch FFATA checklist and SOP - by December 31, 2025 • Implement automated reminders - by December 31, 2025 • Conduct first quarterly compliance review - by December 31, 2025 5. Preventive Measures Mississippi First will require FFATA training, include FFATA in onboarding, review the policy annually, and integrate FFATA compliance into grants management protocols.

Finding: We noted through audit procedures that one out of forty selections did not include documentation to satisfy certain eligibility criteria. Further, twelve of out forty selections related to clients with no-income, which included self-verification by the client of no income along with other supplemental documentation to satisfy certain eligibility criteria, however there was no Zero-Income Affidavit. Corrective Action Taken or Planned: The supportive housing policies and procedures manual will be updated to reflect the requirements of 24 CFR Part 574, Subparts B to F. Further, the organization will fully implement no-income affidavits to be used anytime a client self-reports no income. Anticipated Date of Completion: December 31, 2025 Name of Contact Person: Beth Frantz, Chief Finance Officer

Finding # 2025-001- Finding Description: As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the Authority to verify income eligibility (24 CFR sections 5. 2301 5. 6091 982.516) Corrective Action Plan: WHA prioritized and immediately completed all annual recertifications that were overdue, implemented standard operating procedures to initiate annual reexaminations 120 days before the tenant's anniversary date, ensured all relevant staff are properly trained on HUD requirements, and established a monitoring system to track the status of all upcoming annual recertifications. Anticipated Completion Date: Completed Contact Person: Name, Title: Belinda Kahl, Executive Director Address: 48 Chestnut Park Drive, Waynesville NC 28786 Phone#: 828-456-6377 Contact Person Signature: ~d-{

2025-004: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Casper College will implement a multifaceted plan to ensure compliance with enrollment reporting requirements under 34 CFR 690.83, 34 CFR 685.309, and NSLDS guidelines. Key corrective steps include: • Policy Revision: Formally updating institutional policies (Sections 10 and 3.11) to clarify and align the reporting roles of the Registrar and Financial Aid, mandating specific timelines for all status changes, including withdrawals. • Strengthened Internal Controls: Establishing a mandatory dual-verification process for withdrawal effective dates and R2T4 alignment and implementing weekly NSLDS monitoring by Financial Aid and monthly Registrar–Financial Aid reconciliation meetings. • Documentation and Training: Improving documentation standards, including a centralized digital archive, and providing mandatory joint cross-office training on NSLDS rules, SSCR error resolution, and accurate, effective date determination. Anticipated Completion Date: 4/30/2026 Contact Person: Joyce Lubeck-Sonenberg

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 Condition Enrollment information, including the effective date of separation from the institution, must be accurately reported to NSLDS within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. May 2025 graduates were reported to NSLDS outside of the maximum 60-day window. Corrective Actions Ellucian has since released a patch to address the known defect, and it has been successfully deployed by the University. Additionally, the University will continue to monitor subsequent submissions to NSC where errors were initially noted, to ensure status changes have been transmitted by the NSC in a timely manner to NSLDS. Responsible Official: Taylor Horner, University Registrar Completion Date: August 2025

Finding Number 2025-004 Federal Program, Assistance Listing Number and Name: ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Condition: Original Finding Description: The City lacked adequate controls to ensure annual reviews were conducted in accordance with its policy, limiting its ability to exercise proper oversight of eligibility determinations performed by the program’s contractor. Contact Person Responsible for Corrective Action / Anticipated Completion Date: Julie Schneider Anticipated completion date: July 2025 Planned Corrective Action: This finding is timing related and was resolved by the City during fiscal year. The City reviewed and updated its policies and procedures to help ensure proper segregation of duties and proper oversight of eligibility determination. Additional processes now have independent review of inspections after the program’s contractor to further support program compliance. Review responsibilities were put in place to help ensure determinations receive an independent secondary review by City staff. These changes were in place by year-end. The City will continue to monitor the program and review procedures to ensure continued compliance and to prevent the recurrence of similar timing-related issues. The City will continue to monitor the program and review procedures to ensure continued compliance and to prevent the recurrence of similar timing-related issues.

For all future stipend payments, the Alternative Payment Program Supervisor will review and confirm that all appropriate documentation is submitted along with the request for payment. This documentation will be reviewed by the Early Care and Education Senior Accounting Technician for accuracy and completeness before approving the stipend payment. Stipend payments will not be approved for payment until all appropriate documentation has been received and reviewed by the Early Care and Education Financial Services Manager.

For ALN 93.958, the discount fee was not properly calculated and/or documented on the Financial Assessment Form for 3 of the 60 clients tested. Additionally, 4 of the 60 clients tested on the Block Grant for Mental Health had dates that did not fall within one year after the FAF completion. For ALN 93.959, 1 of the 60 clients tested on the Block Grant for Prevention and Treatment of Substance Abuse did not have a completed FAF and 1 of the 60 tested had a missing client signature. For ALN 93.788, 1 of the 40 clients tested on Opioid STR Program did not have a completed FA. Our internal tracking of completion of the Financial Assessment Form at admission indicates that compliance with this requirement occurs about 90% of the time. We have identified that some of the missing FAs are a result of Telehealth appointments and clients not coming into the office. As a corrective action, the Client Service Specialist will be trained by their managers to ensure data is entered accurately and how to properly apply the FAs. SMA will also include the completion of the Financial Assessment Form both at admission and annually with data to be reviewed monthly by the managers. In addition, we will be working with IT to identify a way to collect the FAs from clients that utilize Telehealth services. Reporting will be sent out monthly and if out of compliance the managers will be required to be present at the quarterly Quality Assurance Committee meeting if not at 100%.

Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Staff have been retrained, and additional monitoring procedures have been implemented. The Food Service Director will oversee ongoing compliance. Official Responsible for Ensuring CAP: Dan Anderson, Superintendent, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: June 30, 2026. Plan to Monitor Completion of CAP: The Board of Education will be monitoring this corrective action plan. Dan Anderson Superintendent

The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 16, 2022, to administer the federal grants to ensure that the Town would comply with allfederalprogram requirements. The Town was led to believe that they were in compliance with all federal program requirements. This is the second year of both federal grant programs, and the Town is just being made aware of the suspension and debarment requirement. It should be noted that all contractors and the consultant are not on the suspension and debarment lists.

Material Weakness Item 2025-002 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 H80CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8HCS46163-03-01 During our audit, we noted that LBUCC did not properly determine the sliding fee discount provided to certain eligible patients based on information provided during the patient registration process. Additionally, we could not ascertain if the sliding fee discount provided to certain eligible patients were correct as LBUCC did not maintain documentation of the proof of income of those eligible patients. Recommendation: We recommend that LBUCC conduct training of all of its personnel who are involved in determining and applying the sliding fee scale of patients. We also recommend LBUCC to maintain complete and auditable documentation supporting each patient's eligibility for sliding fee discount. Action Taken: Eligibility was provided additional training which included training on a tool to assist them in determining the proper sliding fee discount. Effectivity Date: Training was held on October 28, 2025, and the tool to assist them was reviewed and provided at that time and implemented immediately thereafter.

Significant Deficiency Finding: 2025-001 Certification of Tenants Criteria and Condition The grant agreement requires ECS to (1) maintain complete tenant files in the San Francisco HMIS ONE System with hard-copy eligibility documents; (2) apply changes to tenant rent portions based on City and County of San Francisco Department of Homelessness and Supporting Housing (HSH) notifications; and (3) perform required initial, annual, and interim recertifications under the Housing First program model. We noted instances where tenant files did not contain complete eligibility documentation and/or where required recertifications or updates to tenant rent portions were not performed or documented in accordance with the grant requirements. Context ECS provides rental assistance under the program described in Appendix A-2, which requires full documentation of tenant eligibility and strict adherence to rent-portion updates and recertification timelines. Of our 31 selections, we noted 6 instances where homelessness verification was missing, 6 instances where the rent portions based on HSH notifications were incorrect and 10 instances where the recertifications were not completed for the grant period under audit. Questioned Cost There are no questioned costs regarding this finding. Cause The exceptions result from inconsistent file maintenance and monitoring procedures, including insufficient review over documentation completeness and timeliness of recertifications. The issues were centered on tenant files managed by a third-party service provider. Effect Incomplete tenant files and untimely recertifications increase the risk of noncompliance with grant requirements and may result in incorrect tenant rent portions being charged or insufficient support for program eligibility. Repeat Finding This finding is not a repeat finding. Recommendation We recommend that ECS enhance its documentation and monitoring processes with its third-party property managers by implementing a standardized tenant file checklist, conducting periodic supervisory reviews to confirm that all eligibility documents and recertifications are completed and retained, and establishing a tracking process to ensure tenant rent portions are updated promptly based on HSH notifications. View of responsible officials Management agrees with the recommendation. Corrective Action Planned ECS has taken and will continue to take the following steps in the 2026 fiscal year to correct this deficiency. Step 1: Resources ECS began addressing Certificate of Tenancy errors with the hiring an Associate Chief of Real Estate and Asset Management in August, a Director of Property Management in October and a Property Management Compliance Manager in September. Step 2: Best Practices ECS has hired a consulting firm to correct Certificate of Tenancy errors at its one of its sites and will apply the best practices learned to all the affiliate and master lease sites. In addition, ECS has put together policies and procedures and has offered training to both ECS and subcontracted staff on Certificate of Tenancy. ECS will continue to offer compliance training as it takes over property management across all Master Lease sites and the affiliate portfolio. Step 3: Take control of property management Replace outsourced property management with ECS staff to better control Tenant documentation at all master lease and affiliate sites. Step 4: Quality and Compliance ECS has started in a few sites to review Tenant documentation and will expand this review to all sites across its entire portfolio. Implementation Date ECS will fully correct Certificate of Tenancy errors by June 30, 2026. Responsible Personnel The Chief Operating Officer and the Associate Chief of Real Estate and Asset Management.

Finding 2025-001: Suspension and Debarment Condition: The Sponsoring Organization did not consistently document the verification that new Child and Adult Care Food Program (CACFP) centers or Family Child Care (FCC) providers were not suspended or debarred prior to enrollment. View of Responsible Officials: 4C agrees with the audit finding. Corrective Action Plan: 4C will implement a control process within the onboarding process. The onboarding check list will have sign offs for the manager and strategic director over the program. Responsible Party: Pagie Runion, Strategic Director of Business Services Anticipated Completion Date: June 30, 2026

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.