Corrective Action Plans

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING NO. 2024-004 Assistance Listing Number 14.181: Section 811 Supportive Housing for Persons with Disabilities See the details of this finding for segregation of duties and other designs of internal controls in 2024-001 above.

Finding 2024-001, Significant Deficiency in Internal Control over Financial Reporting. Condition: The design of the Project’s internal controls precludes certain segregation of duties and other designs of internal controls. Criteria: Proper design of the Project’s internal controls to include segregation of duties and other designs of internal controls. Cause: The size of The Project’s accounting and administrative staff precludes certain segregation of duties and other designs of internal controls that would be preferred if the office staff were larger. Effect: The segregation of duties and other designs of internal controls are limited. Recommendation: The auditor recommended that management and Project governance review their procedures and develop processes to address deficiencies in the segregation of duties and other designs of internal controls. Increased involvement of the Board of Directors in the financial affairs of the Project would provide oversight and independent review functions, thereby lessening the severity of the deficiencies. Responsible Person: Brittany Colson, Manager Planned Action: The Project agrees with the finding and the auditor’s recommendations will be adopted. Anticipated completion date: The recommendation will be applied in fiscal year ending June 30, 2025.

Cayuga Centers has changed key leadership positions and contracted in the near-term for Chief Financial Officer and Controller services. The new leadership team is working transparently to resolve internal control issues asserted in the audit report. To prevent future instances of management override, Cayuga Centers has implemented standardized procedures to ensure grant expenditures are properly classified in our financial system. Each transaction are supported by detailed documentation, including invoices, receipts, and grant-specific identifiers. Individuals responsible for grant oversight will undergo mandatory training to deepen their understanding of grant requirements, allowable costs, and reporting obligations. Additionally, Cayuga Centers is working to ensure open communication between staff and the Board. Under new leadership, the agency continues to enforce its Non-Retaliation Policy (Whistleblower). The Acting President’s office is establishing quarterly “Grant Compliance Forums” for employees to raise concerns related to grant administration.

Improve Controls over Accounting Records Department’s Response: ESAC is in agreement with the recommendation, and with the new Director of Administration and Finance and outside bookkeeper in place, ESAC will complete monthly reconciliations for all journals, sub-journals, and accounts. Entry errors will be adjusted each period to ensure that account and ledger totals are properly maintained and recorded. Views of Responsible Offices and Corrective Action Plan: ESAC has reviewed its controls over bank reconciliations, accounts payable and grants receivable. Controls and the policies and procedures have been reviewed with the new Director of Administration and Finance and outside bookkeeper and is confident that new procedures will be adhered to ensure timely reconciliations. Name of Responsible Person: Peg Drisko, CEO Projected Implementation Date: May 2026

Finding 2024-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended December 31, 2024, management did not properly accrue federal grant expenditures that were incurred during the fourth quarter of fiscal year 2024. As a result, federal grant expenses on cost reimbursement grants and related revenues were understated as of December 31, 2024, and required year end audit adjustments to properly reflect expenditures incurred but not invoiced or recorded as of year end. Recommendation We recommend that individuals overseeing the accounting and finance department continue to review the Organization’s current accounting policies and update existing policies or implement new policies, as needed, to ensure that federal grant expenditures are accrued for and recorded in the proper period and reconciliations between incurred expenditures, invoices submitted and amounts recorded in the general ledger are completed and reviewed monthly or quarterly, as appropriate. Management’s Corrective Action Plan Management is working to improve the timeliness of reconciliations and has implemented procedures to identify and accrue grant expenditures incurred but not yet invoiced at period end, as needed. Management will perform periodic reconciliations between incurred expenditures, invoices submitted to grantors, and amounts recorded in the general ledger, and will ensure such reconciliations are reviewed and approved by the appropriate personnel. Management is confident that the issues that have been noted have been rectified. Contact Person: Patricha Paul, Finance Director Anticipated Completion Date: June 30, 2026

We agree with the finding. The Hospital's annual financial statements were not issued until February 2026 and we were not able to complete the single audit filing until that time. The Hospital doesn't anticipate delays in the future.

SUSPENSION AND DEBARMENT – HIGHWAY PLANNING AND CONSTRUCTION Recommendation: It is recommended the County design controls to ensure an adequate review process is in place to review potential vendors to determine they are not suspended or debarred prior to entering into transactions with vendors. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will ensure they review all vendors for suspension and debarment. Name of the contact person responsible for corrective action plan: Candace Sonnek, Finance Director Planned completion date for corrective action plan: December 31, 2025

Views of Responsible Officials and Planned Corrective Actions The Organization’s management is aware of this material weakness and has considered adding additional personnel to assist in the monthly reconciliations and financial statement preparation. Management reviews and approves the monthly interim financial statements and uses the knowledge that management and the Board of Directors has of operations by having them review certain accounting records and reports. Also, management monitors the effectiveness of the above actions and makes changes as considered appropriate.

Views of Responsible Officials and Planned Corrective Actions The Organization’s management is aware of this significant deficiency and addresses it by obtaining the auditor's assistance in the preparation of the Organization’s annual financial statements. Management reviews and approves the completed statements and distributes them to the users.

Views of Responsible Officials and Planned Corrective Actions The Organization’s management is aware of this condition and believes that it is not economically feasible to attain the ideal segregation of duties. Management attempts to mitigate the associated risks by doing the following: (1) Identifies areas where the lack of segregation of duties exists and where there are higher risks of errors or fraud occurring. (2) Implements limited segregation to the extent possible to reduce risks without impairing efficiency. (3) Uses the knowledge that management and the Board of Directors has of operations by having them review certain accounting records and reports. (4) Monitors the effectiveness of the above actions and makes changes as considered appropriate.

Corrective Action Plan: Management acknowledges the lack of documented evidence of review and approval for disbursements. The organization has implemented a process requiring email-based approvals from appropriate managers to ensure all expenditures are reviewed and authorized. In addition, the organization is in the process of evaluating and implementing an electronic system to streamline and document approvals for accounts payable and credit card transactions. These steps will strengthen internal controls and ensure proper documentation of all approvals in accordance with organizational policies and federal requirements. Responsible Official: Abel Olivo, Executive Director, with support from the outsourced accounting firm Anticipated Completion Date: May 31, 2026

CSLFRF Reporting (ALN 21.027) Condition The required Treasury report was not submitted due to insufficient tracking mechanisms and lack of internal controls. Corrective Action Plan To ensure timely and accurate CSLFRF reporting, the City will: • Establish a Treasury reporting calendar with all required deadlines. • Assign a designated preparer and reviewer for each reporting cycle. • Provide training on the Treasury reporting portal. • Implement a pre-submission checklist to ensure completeness and accuracy. • Conduct semiannual internal reviews of reporting processes and documentation. Responsible Staff Chief Financial Officer (CFO) Target Completion Date July 31, 2026

Duplicate Payments to Vendors Condition Duplicate vendor payments occurred due to inadequate segregation of duties and inconsistent invoice naming conventions. Corrective Action Plan The Accounts Payable unit will strengthen internal controls to prevent duplicate payments and ensure compliance with federal cost principles. Actions include: • Enforcing segregation of duties within the AP workflow. • Implementing standardized invoice naming conventions. • Requiring secondary review for all grant-related invoices. • Conducting quarterly post-payment audits to detect and correct errors. • Implementing ERP system enhancements to flag potential duplicates. • Hiring an AP Manager to manage and improve the AP processes. Responsible Staff Chief Financial Officer (CFO) Target Completion Date June 30, 2026

CDBG Performance Reporting (ALN 14.228) Condition The PR28 and CAPER reports were submitted 11 months late. This is a repeat finding and resulted from insufficient controls and inadequate staff training. Corrective Action Plan To ensure timely and compliant reporting, the following actions will be taken: • Developing written procedures for PR28 and CAPER preparation and submission. • Implementing a compliance calendar with required reporting deadlines. • Assigning both primary and secondary preparers to ensure redundancy. • Providing HUD IDIS training to relevant staff. • Conducting supervisory review prior to submission. • Hired a Grants Compliance Specialist to support ongoing compliance.(10/2025) Responsible Staff Grants Administrator Target Completion Date August 31, 2026

Views of Responsible Officials Management agrees with the federal award finding identified in the audit. The System Fund will file the audit reporting package shortly after issuance and ensure that any future audits are completed and filed timely, by working closely with audit partner and frequently accessing the substantive status, stage of completion or any other pertinent aspect of the audit necessary to meet the filing deadline.

Name of Auditee: Town of Potsdam, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2024 CAP Prepared by: Marty Miller, Supervisor Telephone: (315) 265-4310 (A) Current Findings on the Schedule of Findings and Questioned Costs (3) Finding 2024-003 Management’s Response: Management will develop policies and procedures, and anticipates starting and completing the audit more timely in order to meet the required filing deadlines. Persons Responsible for Implementation: Marty Miller, Town Supervisor Implementation Date - December 31, 2026

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.