Corrective Action Plans

2025-004: Equipment Management U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425D (COVID-19—Elementary and Secondary School Emergency Relief Fund), 84.425U (COVID-19—American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (COVID-19—American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award years 2023-2025 Criteria: The Uniform Guidance (2CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Also, in accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include a description of the property, a serial number of other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. In accordance with 2 CFR section 200.313(d)(2), a physical inventory of equipment and property must be taken, and the results reconciled with the property records at least once every two years. Condition: During the fiscal year 2024 audit, it was previously reported that the District’s controls were not operating effectively to reasonably ensure the District had maintained property records with the above required information, nor had it performed the required physical inventory of equipment within the two previous years. During fiscal year 2025, the District incorporated processes and controls over equipment management that met the property record requirements. The District also performed a physical inventory during fiscal year 2025 that included counting and reconciling approximately half of the District’s equipment and property within this grant program. Therefore, the District had not yet met the requirements of performing a physical inventory of all equipment and property within the previous two years. Cause: Given the timing of when the District incorporated its processes and controls, insufficient time remained to perform a physical inventory of all the District’s equipment and property within this grant program, and only approximately half of the items were subject to the physical inventory. Effect or potential effect: The District is not in compliance with federal grant requirements over the physical inventory of equipment. Improper equipment procedures could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: As noted above, the District updated its property records for all its property and equipment, and then approximately half of the District’s property and equipment was subject to a physical inventory. Identification as a repeat finding, if applicable: 2024-004 and 2024-006. Recommendation: We recommend the District continue to perform the processes and controls it added during fiscal year 2025, and complete the inventory count for the remaining items, to be compliance with the federal grant 2 year cycle. View of responsible officials: Management agrees with this finding. Corrective Action: Management plans to continue to keep detailed records and perform physical inventories in accordance with 2 CFR section 200.313(d)(2). Anticipated Completion Date: June 30, 2026 Contact Person: Dominic Accurso, Controller 816-321-5000 Dominic.accurso@nkcschools.org

Management concurs with Audit Finding 2025-003 and will strengthen controls over USDA Food Distribution Cluster reporting to ensure accuracy, completeness, and compliance with federal and State requirements. Management will implement the following corrective actions: 1. Monthly USDA Reporting Reconciliation Process Management will implement a formal monthly reconciliation process that includes: o Reviewing confirmed USDA receipts and reconciling them to internal inventory records in CERES; and o Reconciling all TEFAP distribution reports submitted to the States to CERES data prior to submission. All reconciliations will be documented, reviewed, and retained. 2. Documentation of Shortages and Inventory Adjustments Shortages noted on signed agency invoices will be promptly documented and resolved through credit memos or inventory adjustments in CERES. Supporting documentation will be retained to substantiate all adjustments. 3. 48-Hour Receipt Confirmation Tracking Management will establish a tracking mechanism (e.g., log or checklist) to monitor submission of all required 48-hour receipt confirmations. The tracking tool will document submission dates and ensure confirmations are submitted timely and retained in accordance with record retention requirements. 4. Assignment of Reporting Responsibility Management will formally assign primary responsibility for preparation and submission of Food Distribution Cluster reports to a designated individual. Roles and responsibilities will be clearly documented. 5. Supervisory Review and Oversight A supervisory reviewer will perform documented reviews of reconciliations, supporting documentation, and reports prior to submission. Supervisory review will confirm that: o Reconciliations are completed. o Differences are investigated and resolved; and o Reports comply with applicable federal and State requirements. 6. Monitoring and Training Management will periodically monitor compliance with these procedures and provide refresher training to staff involved in inventory, distribution, and reporting to ensure consistent application of controls. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)

Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following corrective actions: 1. Required Agency Acknowledgment at Delivery Management will reinforce procedures requiring recipient agency signatures or equivalent acknowledgment on all USDA food distribution invoices at the time of delivery. Distribution staff and drivers will be reminded that unsigned delivery documentation is considered incomplete. 2. Post-Delivery Follow-Up Control Management will implement a follow-up control, such as a delivery log or checklist, to track all USDA distributions recorded at the time of delivery. The log will include verification that a signed receipt has been obtained and returned for each transaction. 3. Reconciliation of Distributions to Signed Documentation On a periodic basis, management will reconcile USDA distribution activity to signed agency invoices to identify any missing acknowledgments. Missing signatures will be promptly investigated and resolved, with documentation of follow-up retained. 4. Supervisory Review and Oversight Supervisory personnel will perform periodic documented reviews of distribution documentation to verify that signed agency receipts are obtained, complete, and retained. Evidence of review will be maintained. 5. Training and Awareness Management will provide refresher training to distribution staff and drivers on USDA documentation requirements and the importance of obtaining signed acknowledgment to support program accountability and reporting accuracy. Expected Completion Date: Within 60-90 days Responsible Parties: Andrelle Bowen, Transportation Manager, (901-373-0402)

Management concurs with Audit Finding 2025-001 and will implement enhanced internal controls over inventory adjustments to ensure accurate accounting for the receipt, distribution, and disposition of all USDA commodities in compliance with Special Tests and Provisions requirements. Management will implement the following corrective actions: 1. Formal Approval and Authorization of Inventory Adjustments Management will establish a formal policy requiring documented supervisory review and approval for all manual positive and negative inventory adjustments recorded in the general ledger and the CERES inventory system. Approval will be obtained prior to posting adjustments, and access to record adjustments will be restricted to authorized personnel. 2. Standardized Documentation for Adjustments Each inventory adjustment will be supported by standardized documentation clearly explaining the nature, reason, and calculation of the adjustment, along with applicable supporting records (e.g., receiving documents, distribution records, shortage documentation). All documentation will be retained in accordance with USDA record retention requirements. 3. Reconciliation of Inventory Activity Management will implement a periodic (at least monthly) reconciliation of inventory receipts, distributions, and adjustments to CERES and the general ledger. Reconciling items will be investigated, resolved, and documented timely. 4. Monitoring of USDA Program Inventory Management will perform periodic reviews of inventory activity related to donated inventory and Tennessee and Mississippi USDA programs to ensure that adjustments are appropriate, approved, and accurately recorded. 5. Training and Ongoing Oversight Management will provide targeted training to staff involved in inventory and accounting processes regarding USDA Special Tests and Provisions requirements and the new approval and documentation procedures. Management will monitor compliance with these controls to ensure they are operating effectively. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)

Finding 2025-001 - Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Equipment and Real Property Context: During testing, we noted the Unit spent $160,847 on flooring upgrades which exceeded the $5,000 federal equipment and real property threshold. However, the Unit did not perform any of the required federal compliance steps related to the flooring purchase (getting approval before making the purchase, adding the flooring purchase to the capital asset listing, and performing an inventory of the flooring). The Unit believed the flooring purchase did not require approval because it does not meet the criteria of a major renovation under Head Start guidelines. However, as noted in the criteria above, the flooring still qualifies as an equipment and real property purchase. Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: The Consortium management disagrees with the finding. Description of Corrective Action Plan: The Consortium plans to discuss this matter with ACF/HHS to determine if the finding is out of compliance. Anticipated Completion Date: June 30, 2026

Significant deficiency in Internal Control over Compliance and Noncompliance Corrective Action Plan: A new Executive Manager of Inventory Management has been hired. He is tasked with training, updating physical inventory practices and requirements, and ensuring that physical inventories are completed. Estimated Completion Date: March 31, 2026 Management Contact: Tony Warfield, Executive Director of Inventory Management

FINDING 2025-004 Finding Subject: Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address): (765) 795-4664 / mshrout@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We have contacted our Capital Assets vendor to add columns to the report to identify federal purchases. Anticipated Completion Date: July 1, 2027

FINDING 2025-004 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Education Stabilization Fund grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

Finding Correction Action Plan Details 2025-001 a. Name of Contact Person Responsible for Corrective Action: Michelle Cage – Chief Financial Officer b. Corrective Action Planned: Management will continue to implement policies or procedures to establish an internal control system that will ensure strong financial accountability, proper safeguarding of assets, and compliance with federal grant requirements. c. Anticipated Completion Date: Immediately.

Finding Reference: 2025-002 - Special Tests and Provisions — Accountability for USDA Foods— Questioned Costs: None Responsible Person: Todd Frease, CFO Actions & Timelines: 1. Valuation Policy (within 30 days from report issuance): Adopt an approved USDA valuation method (WBSCM price or rolling average) and document the policy. 2. Formal Inventory SOPs (within 60 days of report issuance): Issue written SOPs covering count preparation, reconciliation, and documentation retention per 7 CFR §250.19. 3. Training (within 60 days): Train finance and inventory staff on valuation requirements and new SOPs. 4. Annual Monitoring (ongoing): Review valuation application and inventory reconciliations annually and report results to leadership. Anticipated Completion Date: Initial policy and SOPs within 60 days of report issuance; ongoing monitoring thereafter.

Views of Responsible Officials and Corrective Action Plan: Responsible Officials: ● Michael Zeleny, Senior Vice President and Chief Financial Officer Corrective Action: Laptop Receipt and Custody Controls - As of the date of this letter, the University has already discontinued the exemption for receipt of laptops at the off-campus sponsor location and implemented immediate routing of all laptops through on‑campus Technology Services for standardized asset tagging and custody assignment. All laptops will be shipped to the University’s on‑campus Technology Services department, where they will be asset‑tagged upon receipt, assigned to a responsible custodian, and entered into the asset management system before distribution. Upon employee separation or reassignment, assets must be returned to the home department, which will notify Asset Management of all returns and transfers to maintain accurate records. Inventory and Monitoring - All laptops will continue to be included in the University’s bi‑annual inventory process in accordance with University policy. Training and Communication - Departments and employees will receive updated guidance on equipment distribution and return requirements by the Research Administration and Asset Management by March 31, 2026. Training will reinforce responsibilities related to safeguarding and managing federally funded equipment. Individual(s) Responsible for Corrective Action: ● Matthew McNally, Senior Associate Vice President and Chief Information Officer mcnally@cua.edu 202-319-4374 Anticipated Completion Date for Corrective Action: March 31, 2026

Finding 2025-019 U.S. Department of Health and Human Services AL No. 93.977 Sexually Transmitted Diseases (STD) Prevention and Control Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: To address reporting findings, in FY 2025 BCHD developed a Grants Management Standard Operating Procedure manual that continues to be updated as processes are adjusted to ensure compliance with all grant awards. Additionally, BCHD fiscal has completed the following steps to address this finding: • Restructured the fiscal grants management team to strengthen internal controls around grants management, standardize processes and improve efficiency. • Conducted small group training within the newly formed teams around the specifics of job responsibilities and requirements. • Created an internal grants tracker in Smartsheet to include all grant award periods, reporting requirements and due dates. • Compliance team entered required data in SAM.gov for FFATA reporting. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Conduct separate workshops with division leaders, programs directors and the compliance team to review all grant awards and compliance requirements for each award in addition to reviewing process for close out of grant awards and annual reporting requirements. • Update the grants tracker to include both fiscal and program reporting requirements. BCHD will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. Per the GMO’s guidance, BCHD will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

Finding 2025-017 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-027 Auditee’s Corrective Action Plan: To address reporting findings, in FY 2025 BCHD developed a Grants Management Standard Operating Procedure manual that continues to be updated as processes are adjusted to ensure compliance with all grant awards. Additionally, BCHD fiscal has completed the following steps to address this finding: • Restructured the fiscal grants management team to strengthen internal controls around grants management, standardize processes and improve efficiency. • Conducted small group training within the newly formed teams around the specifics of job responsibilities and requirements. • Created an internal grants tracker in Smartsheet to include all grant award periods, reporting requirements and due dates. • Compliance team entered required data in SAM.gov for FFATA reporting. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Conduct separate workshops with division leaders, programs directors and the compliance team to review all grant awards and compliance requirements for each award in addition to reviewing process for close out of grant awards and annual reporting requirements. • Update the grants tracker to include both fiscal and program reporting requirements. BCHD will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. Per the GMO’s guidance, BCHD will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

Recommendations: The District should include infrastructure items in the current inventory system. Action Taken: We agree with the recommendation. Our targeted implementation date is January 2026.

Auditor Description of Condition and Effect. The College does not have a formal process or system in place to track fixed assets acquired with federal award funds. As a result, there is no centralized or consistent documentation of asset details, location, or usage for assets purchased with federal funds. Without proper tracking, the entity is at risk of noncompliance with federal regulations, potential loss or misuse of federally funded assets, and challenges in conducting accurate inventories or audits. This could lead to questioned costs or disallowed expenditures during federal reviews. Auditor Recommendation. That the College implement a formal fixed asset tracking system that complies with 2 CFR §200.313. This system should include procedures for recording asset details, conducting periodic inventories, and reconciling records. Staff responsible for asset management should be trained on federal requirements to ensure ongoing compliance. Corrective Action. In its Jenzabar accounting system software, the College will code fixed assets that were, and will be, acquired with federal award funds. The College will also set reminders in May 2026, and at least once every two years thereafter, to conduct an inventory and reconcile this with the accounting records. Responsible Persons. Tom Zeidel, Vice President of Finance and Facilities and Troy Slater, Director of Business Office. Anticipated Completion Date. October 31, 2025.

Finding 2025-003 - Internal Control over Major Federal Program Compliance Program : Education Stabilization Fund (CFDA 84.425) Condition: Lack of policies and procedures for asset inventory management. Repeat Finding and Material Weakness Corrective Action Plan: The District will implement procedures to ensure asset physical inventories are completed and inventory records are completed and updated in accordance with the requirements of 2 CFR 200.318 of the Uniform Guidance. The district will provide training to responsible personnel. Planned Completion Date: March 31, 2026 Responsible Contact Person: Dr Marty Spence, Superintendent (417) 469-3260

Finding 2025-001 - Compliance over Major Federal Program Program: Education Stabilization Fund (CFDA 84.425) Compliance Requirement : Equipment and Real Property Management Condition: Incomplete Asset inventiory Repeat Finding and Material Noncompliance Corrective Action Plan: The District will perform a physical inventory of all assets and complete/update the assets inventory accounting report in accordance with the requirements of 2 CFR 200.318 of the Uniform Guidance. The District will provide training to personnel responsible for asset inventory procedures. Planned Completion Date; March 31, 2026 Responsible Contact Person : Dr Marty Spence, Superintendent (417) 469-3260

Views of Responsible Officials and Planned Corrective Actions: Management concurs with the recommendation. The lack of appropriate asset documentation to adhere to federal guidelines under Federal Code section 200.313 regarding asset tracking of purchases over $5,000 federal guidelines, but under County $10,000 policy threshold, was not followed for one qualifying asset out of forty-one assets purchased per the audit finding. Technology administrative staff will coordinate with Technology management for future purchases that are above the $5,000 federal threshold but below the County $10,000 policy threshold to comply with the required information.

Condition: The required capital outlay log amounts had several capital outlay line items that did not match the cost recorded in the general ledger. Recommendation: It is recommended, at year end, that the District should compare the capital outlay log to the general ledger to ensure the costs match. Management Response: The Director of Finance or designee will review all capital outlay logs and reconcile them to the general ledger before year-end. In addition, training will be provided to grant coordinators to ensure they are completing the log correctly. Anticipated Date of Completion: June 30, 2026

2025-004 - Significant Deficiency and Noncompliance - Written Federal Policies and Procedures Condition: The Village is required to have in place written federal policies and procedures in compliance with Uniform Guidance 2 CFR 200, which include procurement and suspension/debarment and equipment and real property management. Corrective Action Plan: The Village has drafted a Federal Policy/Procedure document which will be approved by the Village Council in early 2026.

Condition: The University did not complete a physical inventory of the property within the last two years. Planned Corrective Action: Management will establish a formal inventory schedule that mandates physical inventory and reconciliation at least once every two years. Designated personnel will be assigned responsibility for executing and documenting the inventory process. Additionally, internal controls will be enhanced through periodic monitoring and reminders to ensure timely completion and proper recordkeeping. Contact person responsible for corrective action: David Dettloff, Staff Accountant Anticipated Completion Date: February 26, 2026

2025-003 – Significant Deficiency and Noncompliance – Federal Equipment Corrective Action Plan: The City will implement a centralized Federal Equipment Register capturing all required data elements under 2 CFR §200.313(d) and assign responsibility to the Logistics Officers of the Fire Department, Police Department, and Department of Public Works, with oversight by Finance. A full physical inventory of federally funded equipment will be completed and reconciled by March 31, 2026, and biennial inventory procedures will be established. Staff will be trained on equipment management requirements, and documentation will be retained to ensure compliance. Anticipated Completion Date: March 31, 2026

Thank you for noting the omission of certain capital assets from the District’s depreciation schedule. Management acknowledges this oversight and appreciates the identification of the issue. To address this matter, the omitted capital assets have been reviewed and recorded on the depreciation schedule to ensure accurate financial reporting. In addition, management will develop and implement a formalized procedure for identifying, recording, and reviewing capital asset activity as it occurs. This procedure will be put into place immediately and will include periodic reconciliation and supervisory review to ensure that all qualifying capital assets are properly captured and depreciated in accordance with applicable accounting standards. Management believes that these corrective actions will prevent similar omissions in the future and strengthen internal controls over capital asset accounting. Responsible Parties Marc Graff, Assistant Superintendent for Operations Nicole Guild, Assistant Business Official and District Treasurer Anticipated Completion Date This issue was reviewed with the Program Administrators on December 22, 2025 and will be an ongoing area of review.

Home Investment Partnerships Program- American Rescue Plan Act (14.239) 2025-002 Special Tests and Provisions- Real Property Acquisitions and Relocation Assistance (URA) Recommendation: The Organization should obtain appraisals prior to the negotiations and/or purchase of real property when utilizing funds from local, state, or federal sources. Corrective Action Plan: Management was not aware of the appraisal requirement at the time the property was purchased. Upon becoming aware of the requirement, management promptly engaged a certified appraiser and obtained an appraisal of the acquired property, which substantiated that the fair market value exceeded the purchase price. To prevent recurrence, management will review and update its policies and procedures governing the acquisition of real property with public funds. Revised procedures will require that a certified appraisal be obtained prior to negotiations and purchase to ensure that the acquisition price does not exceed fair market value.

Home Investment Partnerships Program- American Rescue Plan Act (14.239) 2025-001 Special Tests and Provisions- Real Property Acquisitions and Relocation Assistance (URA) Recommendation: The Organization should obtain appraisals prior to the negotiations and/or purchase of real property when utilizing funds from local, state, or federal sources. Corrective Action Plan: Management was not aware of the appraisal requirement at the time the property was purchased. Upon becoming aware of the requirement, management promptly engaged a certified appraiser and obtained an appraisal of the acquired property, which substantiated that the fair market value exceeded the purchase price. To prevent recurrence, management will review and update its policies and procedures governing the acquisition of real property with public funds. Revised procedures will require that a certified appraisal be obtained prior to negotiations and purchase to ensure that the acquisition price does not exceed fair market value.