Corrective Action Plans

Finding 2024-001 Allowable Cost Principles and Activities Allowed or Unallowed Material Weakness in Internal Control Over Compliance Assistance Listing Number 21.029 While Wabash currently maintains informal procedures for coding and reviewing invoices and payroll records, we recognize the need for a formalized, written policy governing expenditures charged to federal awards. To address identified material weaknesses, Wabash is committed to implementing a comprehensive written policy by June 30, 2026. This policy will formalize the coding, review, and reporting processes for all federal expenditures. Key improvements will include: • Enhanced Internal Controls: We will establish a clear segregation of duties to ensure oversight and accuracy. • Timely Reporting: We are refining our payroll allocation process. Previously, payroll expenditures were withheld pending budget verification, which occasionally led to reporting delays. New controls will ensure that all expenditures, including payroll, are reported within the required quarterly timeframes. • Monitoring: The Controller will oversee the development of these procedures and remain responsible for ongoing monitoring and compliance. These steps will ensure our financial practices meet federal standards and provide rigorous oversight of project funds. Contact person(s): Cheryl Gaither, Controller Justin Gephart, Chief Operating Officer

Finding 2024-012 - Single Audit Reporting Auditee's Response and Planned Corrective Action The Town will work with the accounting department, fee accountant, and audit fmn to file the required reports timely. Planned Implementation Date of Corrective Action: January 2026 Person Responsible for Corrective Action: Fred Costello, Town Supervisor

CORRECTIVE ACTION: Management is in agreement with the auditor’s recommendations and acknowledges that these issues have continued through our March 31, 2024 and March 31, 2025 fiscal year ends. We continue to make every effort to get our filings up to date by our March 31, 2026 year end due date of December 31, 2026.

CORRECTIVE ACTION PLAN March 13, 2026 Chickahominy Indian Tribe - Eastern Division respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, VA 22801 Audit period: December 31, 2024 The findings from the December 31, 2024 Schedule of Findings and Questioned Costs (the "Schedule" ) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS- FINANCIAL STATEMENT AUDIT 2024-001: Payroll Tracking and Allocation (Material Weakness) Condition The client was unable to provide a payroll allocation by fund that agreed to the payroll registers. Criteria Payroll allocations were not supported by adequate documentation and were not consistent with methods used in the prior year. Cause The prior CFO had created an allocation method in which the existing employees could not follow . After the CFO's departure, emailed allo cat ions were sent which only specified which funding source the payroll expendit ures would be paid from, not the fund the expenditures were incurred in. Effect Material audit adjustments were required. Recommendation We recommend that payroll allocations be supported by a logical method and be allocated by fund. Corrective Action The Tribe has implemented corrective actions to strengthen internal controls over payroll allocations including: • Development and implement ation of a standardized payroll allocation model beginning with payrolls processed from September 2024 forward. • Preparation of documented allocation schedules for each pay period reconciling payroll costs to payroll registers and accounting records. • Use of standardized spreadsheet templates to support calculation and documentation of payroll allocations across funding sources . • Direct upload of payroll allocation entries into the accounting system to reduce manual entry and improve reconciliation accuracy. These procedures have established a consistent and supportable methodology for allocating payroll expenditures by fund and maintaining documentation sufficient to support financial reporting and audit requirements. The payroll allocation model was implemented beginning September 2024 and was further refined during 2025. The corrective action is considered implemented. 2024-002: Material Audit Adjustments (Material Weakness) Condition In fiscal year 2022, the Tribe elected to convert from the cash basis of accounting to governmental accrual accounting. During 2024, the Tribe continued to function on a cash basis and did not record most accruals. Criteria Financial information provided shou ld be accessible and materially correct. Cause Tribe has not consistently used the accounting software and has relied on program­ specific spreadsheets. The Tribe did not fully switch to accrual basis for internal reporting. Effect Material audit adjustments were required. Recommendation We recommend that monthly reports be generated from Abila and reviewed for accuracy. Any discrepancies between Abila reports and program-specific spreadsheets should be reconciled or adjusted. These reports should be reliable and able to be used to present to Council as part of monthly financial reporting. Corrective Action The Tribe has taken steps to strengthen the use of the accounting system as the primary source of fi nancial reporting and to improve the reliability of financial reports generated for internal management purposes including: • Continued use of the accounting system (Abila/ M IP) as the system of record for all financial t ransact ions. • Development and implementation of a revised chart of accounts structure to improve financial reporting and fund tracking. • Comprehensive review and correction of historical accounting activity to improve data integrity within the accounting system. • Use of spreadsheets as supplemental tools for monitoring estimated fund balances and grant acti vit y where necessary. • Ongoing efforts to customize financial reports generated direct ly from the accounting system so they align with the reporting format requested by Tribal leadership. The Tribe is currently working to finalize customized accounting system reports that will allow monthly financial reports to be generated directly from the accounting system in the format required for Tribal Council repo rt ing. Substantial improvements were implemented during 2025. Full implement atio n of customized accounting system reporting will be completed in the second quarter of 2026. 2024-003 : Budget Approval and Adherence (Material Weakness) Condition The budget was not approved until February 2024 and did not contain sufficient detail nor was it an accurate reflection of financial operations. Criteria Budgets should be developed with sufficient detail to track organizational performance throughout the year. Budgets should be approved by Council prior to the start of the fiscal year. Cause Unqualified staff or lack of attention to the budgeting process. Effect A budget was approved after the fiscal year and was not measured to actual performance during the year. Recommendation A thorough and detailed budget should be developed at the fund and entity level and adopted by Council prior to the start of the fiscal year. We also recommend Council meetings include a formal discussion of budget to actual results, thus giving Council an opportunity to question variances. Corrective Action The Tribe has taken steps to strengthen its budgeting process and improve financial oversight by Tribal leadership including: • Development of a detailed fiscal year 2025 operating budget at the fund and entity level to improve monitoring of financial activity across funding sources. The FY2025 budget was adopted by Tribal Council on February 8, 2025. • Development of a detailed fiscal year 2026 operating budget at the fund and entity level. This budget was presented to Tribal Council on December 19, 2025 and formally adopted with minor revisions at the January 12, 2026 Council meeting very near the start of the fiscal year. • Implementation of enhanced monthly financial reporting for Tribal leadership to support improved financial monitoring and oversight. • Ongoing development of budget-to-actual comparison reporting to support regular review of financial performance by Tribal Council. Budget development improvements were implement ed during fiscal years 2025 and 2026. Full implementation of budget-to-act ual repo rting will becompleted in the second quarter of 2026. 2024-004: Segregation of Duties (Material Weakness) Condition Certain key financial operational responsibilities are not sufficiently segregated. Criteria Proper segregation of duties shou ld be in place detect of irregulariti es in a timely manner. Cause Small staff size combined with significant turnover. Effect Segregation of duties could not be maintained in several signi fi cant rol es during the year. Recommendation Management should review the current process and implement changes to better separate responsibilities so that no one individual is responsible for a transaction cycle. Where proper segregation is not possible, mitigating controls can be put into place to detect errors. Corrective Action The Tribe recognizes the importance of segregation of duties as an internal control and has taken steps to strengthen oversight and implement mitigating controls where full segregation is not feasible due to staffing limitations including: • Increased oversight of financial transactions and accounting activit y by the Director of Finan ce. • Implementation of improved documentation and reconciliation procedures for key accounting processes. • Development of standardized processes and templates to improve consistency and transparency in financial transactions. • Implementation of enhanced financial reporting to Tribal leadership to support independent review offinancial activity. • Ongoing review of financial responsibilities and workflows to identify opportunities for improved separation of duties as staffing capacity permits. Where complete segregation of duties is not possible due to organizational size, the Tribe will continue to rely on management review and reconciliation procedures as compensating controls that have proven effective in detecting errors and irregularities. Mitigating controls were implemented during late 2024 and throughout 2025 and will continue to be refined as staffing capacity allows. 2024-005: Grant Tracking and Reporting (Material Weakness) Condition Poor financial record keeping and lack of thorough grant expenditure and status tracking. Criteria Grant funding should be recorded in separate GL accounts and be reconciled to any ext ernal spreadsheets or drawdown requests and grant reporting. Cause Turnover and unqualified staff. Effect Some grant funding sources were drawn down without documentation of qualifying expenditures, while others appear to have had qualifying expenditures that did not have matching drawdowns. Recommendation Accounting systems should be properly uti lized to track expenditures incurred under each grant and be reconciled to external reporting and spreadsheets. Once a grant is fully expended, the grant shou ld be closed out by ensuring revenues match expenditures. If expenditures are greater than the revenue provided by the grant, a transfer from the general fund would be needed. If revenues are greater than expendit ures , it could be an indication of improper drawdowns or expenditures have not been properly recorded. Corrective Action The Tribe has taken steps to strengthen grant financial management and improve reconciliation between accounting records, grant expenditures, drawdown activity, and monitoring of fund balances including: • Implementation of a revised chart of accounts structure to improve tracking of grant revenues and expenditures within the accounting system. • Continued use of the accounting system as the system of record for all financial transactions associated with grant programs. • Review and reconstruction of grant financial records to ensure expenditures, drawdow ns, and grant balances are properly documented and reconciled. • Use of standardized tracking spreadsheets as supplemental tools to monitor grant activity and reconcile grant balances to the accounting system. • Implementation of improved financial reporting and reconciliation procedures to ensure grant revenues, expenditures, drawdo wns, and balances are reviewed on a regular basis. Beginning in 2026, the Tribe has established a process to perform grant drawdowns monthly to ensure that drawdowns are aligned with recorded expenditures and that grant balances are monitored on an ongoing basis. Corrective actions began during late 2024 and continued throughout 2025. Monthly grant drawdown and reconciliation procedures were implemented in the first quarter of 2026. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2024-006: Bureau of Indian Affairs -105(1) Leases ALN 15.048 and Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments ALN 10.182, Late filing of Data Collection Form Condition The Tribe did not file the data collection form for the years ended December 31, 2022, 2023, or 2024 timely. Criteria Under the requirements of the Uniform Guidance and the Office of Management and Budget (0MB), all entities are required to file the annual data collection form with the Federal Audit Clearinghouse the earlier of 30 days after the issuance of the entity's annual audit or nine months after the entity's fiscal year-end. Management did not complete and certify the auditee portion of the form before the deadline. Questioned Cost N/A Repeat Finding Yes RecommendationManagement should take steps to ensure that the form is filed timely Corrective ActionThe Tribe has taken steps to ensure timely completion and submission of the annual data collection form going forward including: • Assignment of responsibility for preparation, review, and submi ssion of the auditee portion of the data collection form to the Director of Finance. • Establishment of a formal process to complete and certify the annual data collection form immediately upon completion of the annual audit. • Implementation of internal tracking procedures to monitor audit timelines and ensure compliance with Federal Audit Clearinghouse submission requirements. • Coordination with external auditors to ensure timely communication regarding audit completion and reporting deadlines. This corrective action has been implemented and the tribe anticipates comp liance in all future audit reporting periods beginning with FY202 5. 2024-007: Bureau of Indian Affairs -105(1) Leases ALN 15.048, Lack of Approvals (Material Weakness) Condition Criteria Cause Questioned Cost Repeat Finding Perspective Information Recommendation Corrective Action There were several instances of lack of approvals for disbursements. Federal grant recipients are required to maintain effective internal controls over federal awards, as out li ned in 2 CFR §200.303. Turnover and inadequate staffing. N/A N/A Nine of 27 tested. All disbursements should have one approval and ensure the expenditure is eligible under the grant. The Tribe has taken steps to strengthen internal controls over disbursement approvals and ensure that all expenditures are properly reviewed and documented including: • Establishment of a standardized disbursement approval process requiring documented approval prior to payment for non-routine/recurring expenditures. • Implementation of procedures to ensure all disbursements are reviewed for allowability under applicable grant requirements before payment is issued. • Maintenance of supporting documentation, including approval evidence, within the accounting records. • Ongoing review of disbursement procedures to ensure compliance with internal control requirements under 2 CFR §200.303. These measures are designed to ensure th at all disbursements are properly authorized, documented, and compliant with applicable grant requirements. Corrective actions began implementation during throughout 2025. These procedures are currently in place and will continue to be refined as part of ongoing internal control improvements. If the Federal Audit Clearinghouse has questions regarding this plan, please call Tim Emery, Director of Finance at 804-488-9392. Respectfully submitted, r Chief

Management acknowledges that personnel turnover during the fiscal year resulted in temporary gaps in segregation of duties and continuity of financial oversight. Since September 2024, the accounting team has achieved stability in key positions, significantly improving consistency in financial processes and oversight. In addition, the Organization is implementing Blackbaud Financial Edge in FY2027, which will enhance internal controls through system-based workflows, role-based permissions, and audit trails. These system improvements, combined with stabilized staffing, will strengthen segregation of duties and reduce reliance on manual compensating controls. Management is committed to maintaining appropriate staffing levels, cross-training team members, and clearly defining backup responsibilities to ensure continuity of financial operations and compliance with internal control standards. Actions Taken - Stabilized accounting and finance team staffing beginning September 2024 - Implemented cross-training and defined backup roles for key financial functions - Increased supervisory review and oversight during periods of transition - Initiated implementation of Blackbaud Financial Edge with enhanced internal control capabilities (go-live planned for FY2027)

CONTACT PERSON: A. Nicole Verner, Finance Director, averner@cityoflakecity.org CORRECTIVE ACTION: The City acknowledges the finding related to expenditures not being approved prior to disbursement for federally funded programs. Management recognizes that staffing changes contributed to insufficient oversight and monitoring of grant-related expenditures. To address this finding, the City is implementing strengthened internal controls over grant expenditures to ensure that all costs are properly reviewed and approved prior to payment. The City will require that all expenditures charged to grant funds, including Coronavirus State and Local Fiscal Recovery Funds, receive documented pre-approval from appropriate management personnel prior to disbursement. This approval will confirm that the expenditure is allowable, properly classified, and consistent with the purpose of the grant. A standardized grant expenditure approval form or checklist will be implemented to document the review process. This documentation will be maintained with the supporting records for each transaction. The City will establish a segregation of duties within the grant management process so that no single individual is responsible for initiating, approving, and processing grant-related disbursements. In addition, a secondary review process will be implemented for all grant expenditures to ensure compliance with federal requirements and City policies. The City will also maintain detailed records of all grant expenditures and perform periodic internal reviews to ensure compliance with applicable guidelines, even when funds are used under the revenue loss provision. Training will be provided to staff responsible for grant administration and financial processing to ensure a clear understanding of allowable costs, approval requirements, and documentation standards. Management will monitor compliance with these procedures on an ongoing basis and take corrective action if any deficiencies are identified. PROPOSED COMPLETION DATE: June 30, 2027

CONTACT PERSON: A. Nicole Verner, Finance Director, averner@cityoflakecity.org CORRECTIVE ACTION: The City acknowledges the finding regarding the failure to submit the required Coronavirus State and Local Fiscal Recovery Funds compliance report by the established deadline. Management recognizes that staffing changes contributed to a breakdown in tracking and fulfilling grant reporting requirements. To address this finding, the City is implementing enhanced grant management and compliance procedures to ensure all reporting requirements are met in a timely manner. The City will develop and maintain a centralized grants management schedule that identifies all reporting requirements, including due dates, responsible parties, and submission procedures for each grant. This schedule will be monitored regularly by management to ensure compliance. Responsibility for grant reporting will be clearly assigned to qualified personnel, and a secondary reviewer will be designated to verify that all required reports are completed accurately and submitted on time. The City will implement a formal review and approval process for all grant reports prior to submission to ensure completeness and compliance with applicable requirements. In addition, the City will establish reminder and tracking mechanisms, including calendar alerts and periodic status reviews, to prevent missed deadlines. The City will also provide training to staff responsible for grant administration to ensure a clear understanding of compliance and reporting requirements associated with federal and state funding. Management will monitor compliance with all grant reporting requirements and will take corrective action promptly if any issues are identified. PROPOSED COMPLETION DATE: June 30, 2027

Management acknowledges the finding. During the initial stages of administration of the FEMA Public Assistance Program (ALN 97.036 – PA-4339), the Company relied substantially on existing operational, administrative, and accounting procedures while management worked to further tailor, document, and formalize grant-specific compliance policies, procedures, and internal controls required under Uniform Guidance and FEMA regulations. Management notes that the Company maintained supporting documentation for expenditures and transactions related to the grant and that no questioned costs resulted from this matter. Management has substantially developed and implemented a significant number of corrective measures, policies, procedures, and internal controls designed to strengthen the Company’s internal control environment and support compliance with applicable federal award requirements. These actions included: Development and formal documentation of Financial Policies and Procedures; Implementation of procedures related to allowability of costs, disbursements, cash management, and property/equipment management; Enhancement of internal compliance monitoring procedures; Documentation and communication of grant administration responsibilities; Implementation of employee training and compliance guidance processes related to federal award administration. Management continues to enhance and formalize certain grant-specific controls, procedures, and compliance documentation as part of its ongoing efforts to further strengthen its federal award administration framework. Certain policies and procedures that had not yet been fully finalized remain in process and/or have been scheduled for completion and implementation. Management will continue periodically reviewing and updating these policies and procedures to ensure continued compliance with applicable federal regulations, FEMA guidance, and grant requirements.

Management acknowledges the finding and recognizes that the year-end financial closing and reconciliation process was not completed within the desired timeframe during the audit period. The delays were primarily attributable to limited staffing resources within the finance and accounting department and the concentration of significant accounting and reporting responsibilities among limited personnel. Management notes, however, that the Company maintains its accounting records in an integrated accounting system capable of supporting timely financial reporting and that transactions are substantially recorded, classified, reconciled, and segregated by fund and grant throughout the year. In addition, all material adjustments and reconciliations were ultimately completed as part of the audit and financial reporting process. To address this matter, management has implemented and continues to enhance several corrective measures designed to improve the timeliness, efficiency, and overall effectiveness of the financial reporting and closing process, including: Strengthening internal accounting procedures and closing processes; Implementing enhanced monthly and year-end reconciliation procedures; Redistributing and segregating accounting responsibilities to the extent practicable; Increasing the use of the accounting system’s reporting and reconciliation capabilities; Establishing internal timelines and schedules for interim and annual closing procedures; Evaluating additional accounting and administrative support resources. Management will continue working to further strengthen the financial reporting process and improve the timeliness of future financial closings and related reporting requirements.

The City will design and implement controls to ensure that federal awards are expended only for allowable activities.

Concerning Finding 2024-002 Reporting Contact Person Responsible for Corrective Action: William Dobbins, Superintendent Corrective Action: The Limestone Public Schools will take the following actions to address finding 2024-002: Limestone Community School will strengthen internal controls over federal reporting to ensure all required reports are completed, submitted timely, and properly retained. The school will develop written procedures outlining reporting requirements for all federal programs, including ESSER (ALN 84.425). These procedures will identify responsible personnel, submission deadlines, and documentation retention requirements. Copies of all submitted federal reports, including Annual Performance Reports and Annual Performance and Expenditure Reports will be saved electronically and maintained in a centralized grant compliance file. The School will also maintain documentation confirming submission, such as submission receipts or screenshots from the online reporting system."Please note, all Invoices, and back up materials were available along with the draft of the final report. The final report was not obtainable due to the web page being closed. Also, the audit was competed half way through FY-26." Anticipated Completion Date: February 2, 2026

Concerning Finding 2024-001-Wage Requirements Contact Person Responsible for Corrective Action: William Dobbins, Superintendent Corrective Action: The Limestone Public School will take the following actions to address finding 2024-001: The school will strengthen internal controls over federally funded construction projects to ensure compliance with federal wage requirements. Specifically, the School will: 1. Implement procedures to property identify construction projects charged to federal grants prior to payment approval. 2. Update procurement and contract review processes to ensure that all construction contracts exceeding $2000.00 include required federal wage rate clauses in accordance with 2 CFR Appendix II to Part 200 and 29 CFR Parts 5.2 and 5.5. 3. Require contractors performing construction work funded by federal awards to submit certified payrolls and accompanying Statements of Compliance before payments are processed. 4. Maintain documentation of certified payrolls and Statements of Compliance in accordance with federal record retention requirements. 5. Provide training to applicable administrative and finance staff on federal wage rate requirements related to construction projects funded by federal awards. Anticipated Completion Date: February 2, 2026

Finding 2024-002: Allocation of Payroll Costs - Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance – Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services – Medicaid Cluster Response and Corrective Action Plan: Management acknowledges that documentation supporting payroll allocations for PATH CITED-related activities did not fully align with Uniform Guidance expectations for federal awards. However, similar to Finding 2024-001, the Organization was not aware that PATH CITED funding constituted federal assistance during FY2024 due to the absence of federal identifiers in grant documentation and related communications from DHCS. As such, payroll costs were managed under the Organization’s standard operational practices rather than federal compliance-specific requirements. The Organization applied a reasonable and consistent allocation methodology based on supervisory oversight and expected levels of effort, which management believes appropriately reflected the work performed, given the nature of the program at that time. Upon confirmation of the federal nature of the funding, management will take the following corrective actions which includes enhancing a time attestation/time studies process for personnel working on federal awards and strengthening policies requiring periodic after-the-fact review of payroll allocations and documentation retention requirements for supervisory approvals. Anticipated Completion Date: by June 30, 2026 Responsible Person: Virginia Lui VP, Controller

The School Board agrees that, while the reimbursable expenses did not include personnel costs, the Wage Rate (Davis Bacon Act) was not included in the contract language as required for federally funded projects. Management has implemented processes to ensure that any current and future contracts for federally funded projects will include the Wage Rate (Davis Bacon Act) and DOL regulations to ensure compliance.

CONTACT PERSON: Mandy Hess, Finance Director, mhess@pickenscity.com CORRECTIVE ACTION: The City has implemented procedures to ensure that amounts reported for grant reporting amounts are accurate and are consistent with the City’s general ledger. PROPOSED COMPLETION DATE: December 31, 2026

2024-001 – Data Collection Forms Finding: Our audit procedures noted Alliance for Rights and Recovery, Inc. did not certify or submit the required Data Collection Form for the fiscal year ended December 31, 2023 related to the 2023 Single Audit. As of the date of our 2024 audit, the Data Collection Form and accompanying reporting package remain unsubmitted. Recommendation: We recommend that the organization implement procedures to ensure the timely preparation, certification, and submission of the annual Data Collection Form and reporting package. This should include assigning responsibility for tracking deadlines, establishing a completion checklist, and documenting management review prior to submission. Action Taken: The Agency will assign the CFO the responsibility of reviewing all 9melines and documents needed for the annual audit.

The Authority implemented a new policy to track and document program income: a. Upon receipt of program income, it shall be entered individually into IDIS and assigned to an activity or activities within fifteen (15) calendar days of receipt. b. At the next request for funds for an activity which includes funding from program income, program income shall be used prior to requesting federal funds for the activity. c. The request for federal funds shall be prepared by the Fiscal Officer and reviewed by one of the Assistant Fiscal Officers to determine if program income is being used prior to the request of federal funds. d. If it has been determined and documented that program income is being used prior to the request for federal funds, the request shall be forwarded to the Executive Director for approval. This finding has since been resolved in 2025, with a new policy developed and implemented on April 1, 2025.

In general, management agrees with the finding. It should be noted that internal controls for supervisory review of reporting requirements were in place but were not written controls or processes. Reporting for the CDBG Program is accomplished through the preparation of the annual Comprehensive Annual Performance and Evaluation Report (CAPER). Written policies and procedures for the CAPER have been developed. Reporting for the Emergency Rental Assistance Program is accomplished through an online reporting system of the U.S. Treasury and by email to the Pennsylvania Human Services Department. This finding has since been resolved in 2025, with a new policy developed and implemented on December 12, 2025.

Planned Corrective Action: The Division will design and implement a precise control to ensure that the inventory reports are reviewed prior to being submitted to the grantor and that the backup documentation is maintained. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller

Planned Corrective Action: The Division will design and implement a precise control to ensure that the amount of food distributed is properly reviewed and that the Division maintains such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller

VIDCOE will establish and document capitalization thresholds and procedures for identifying, recording, and depreciating capital assets, including maintaining a fixed asset register with periodic reconciliations. Procedures will also be implemented to ensure prepaid expenses are recorded appropriately and amortized over the periods benefited. In addition, grant accounting policies will be strengthened to ensure that funds received in advance are recorded as refundable advances and recognized as revenue only as allowable expenditures are incurred, in compliance with grant agreements and federal requirements. To further strengthen internal controls, VIDCOE will implement formal supervisory review and reconciliation procedures, including routine account reconciliations and financial statement reviews, to ensure transactions are properly classified, supported, and recorded. VIDCOEs’ Management expects to fully implement all corrective actions by July 30, 2026.

Finding No.: 2024-051 Period of Performance Responding Agency: Guam Homeland Security (GHS) Responsible Personnel: Esther Aguigui, Director GHS will create a Standard Operating Procedure (SOP) to establish internal policies and procedures over compliance with applicable period of Performance requirements, as well as retention of all grant agreements. GHS will also identify department personnel responsible.

Finding No.: 2024-047 Special Test and Provisions Provider Eligibility (Screening and Enrolment) Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director DPHSS agrees with this finding. DPHSS is aware that deficiencies exist with the Medicaid provider enrolment process. DPHSS’s response to this deficiency is addressed in its modernization plan, which will automate certain provider enrolment functions. In March 2024, DPHSS performed site visits for 21 providers, and since then has continued to perform site visits year-round. Memorandums regarding provider compliance topics have also been communicated to providers and published on the provider portal, including information regarding criminal background checks. DPHSS is currently contracted with a consultant that is assisting in the implementation of compliant provider enrolment operations, which includes policy revisions, updates to provider applications and disclosure forms, development of standard operating procedures, and training for both staff and providers. In addition, DPHSS is currently in the process of establishing a Medicaid Program Integrity Unit (PI Unit) with a mission to conduct independent and objective Medicaid program integrity functions adherent to federal and local laws. The PI Unit will also assist DPHSS in addressing and managing Medicaid related Corrective Action Plans.

Finding No.: 2024-044 Special Test and Provisions Health and Safety Requirements Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director The Bureau of Child Care Services (BCCS) disagrees with this finding. All applicable providers were monitored and met necessary health and safety requirements. All supporting inspection reports and certifications exist and were provided to the auditors via a OneDrive link on February 9, 2026, following a subsequent request for information. Additionally, in accordance with the Rules and Regulations Governing Child Care Facilities Section 1.5.00 (a), Relative Care facilities are exempt from Sanitary Permits. BCCS requests a detailed breakdown of the $3,726,391 valuation to clarify if the audit team applied a total disallowance of payments or a weighted penalty for perceived documentation gaps. We maintain that this dollar amount is fundamentally inaccurate if the assessment did not properly factor in the specific regulatory exemptions applicable to these providers. Furthermore, BCCS questions the rationale used to assign such a substantial fiscal impact to an administrative-heavy finding, especially where the core program requirements and services were successfully fulfilled.

Finding No.: 2024-024 Reporting Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency is reviewing its federal grants management to ensure robust handover and succession plans are in place of future programs.