Corrective Action Plans

Criteria: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In accordance with §200.213 and §180.300, Suspension and Debarment, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Nonfederal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our review of procurement, suspension, and debarment compliance requirements for the selected vendor sample, we observed that while management conducted a suspension and debarment check prior to contracting with the vendor, documentary evidence of this check was not retained. Although management has maintained an ongoing working relationship with this vendor over several years and indicated that the required check was performed, they were unable to provide documentation confirming that the check was completed at the time the most recent contract was executed on April 1, 2025. Cause: The Organization’s current policies, procedures, and internal controls do not require the retention of documentation evidencing that suspension and debarment checks have been performed. Corrective Action: CCUSA Finance team will ensure that all contractors on federal grants certify that they are not suspended or debarred, and CCUSA Finance team will also verify that information on third-party and/or government websites. CCUSA will retain all documentation of the certification and verification. In addition, CCUSA will attend uniform guidance training either provided by an outside company, or by BDO. Anticipated Completion Date and Contact Details Anticipated Completion Date: March 31, 2026 Contact Person: Katie Spillane Title: Chief Financial Officer Phone Number: (703) 236 6250

Finding 2025-001 Reporting Federal Agency- U.S. Department of the Treasury Program Name - Coronavirus State and Local Fiscal Recovery Funds (SLFRF} Federal Assistance Listing Number: 21.027 2 CFR 200.303 requires that a non-federal entity must "(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States and the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The terms and conditions of the funding require the recipient to submit quarterly Project and Expenditure Reports to the U.S. Department of the Treasury {Treasury). Information required to be included in these quarterly reports includes projects funded, expenditures, obligations, and other information. Treasury's Coronavirus State and Local Fiscal Recovery Guidance requires that "Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1." Responsible Officials: The City of Charleston utilizes an outside agency to compile and submit the required quarterly reports to the Department of Treasury for the State and Local Fiscal Recovery Funds. City officials provide the details of the projects funded, expenditures, obligations, and all other required information to the outside agency, who will then compile and submit the report. Upon review of prior period reports, City officials discovered that the expenditure amount for one of the projects was less than the amount provided to the outside agency for the report. The City brought this to the attention of the outside agency, then increased the project expenditures of the report in question so that the project to-date.

Finding Number: 2025-002 Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Control Requirement - Return of Title IV Funds Management’s Response The University of Puerto Rico concurs with this finding. Institutional units have identified opportunities for improvement in internal controls related to the timely return of Title IV funds and have implemented, or are in the process of implementing, corrective measures to ensure compliance with the regulatory timeframe of 45 days. The Cayey unit identified that the delay in the return of Title IV funds was related to an unintentional administrative error in the handling and filing of R2T4 documentation, within a context of operational transition and temporary staffing limitations. As a corrective action, the Fiscal Office will strengthen periodic reviews of total withdrawal reports generated in the NEXT system, ensure proper classification and monitoring of R2T4 cases, and provide continuous follow-up until funds are effectively returned within the 45 days regulatory timeframe. As a control mechanism, direct oversight of the R2T4 process by the Finance Director has been established, including recurring reviews of total withdrawal reports and reconciliation of these reports with refund vouchers, in order to ensure that all cases are processed and returned in a timely manner. The Humacao unit acknowledged that the cases identified by the auditors were related to specific circumstances, including system errors, technical limitations, and operational workload associated with the implementation of the shared services model. As a corrective measure, the unit implemented changes to the total withdrawal request form and process to ensure coordinated handling between the Office of Financial Aid and the Fiscal Office, allowing for early identification of cases subject to R2T4. Additionally, the Fiscal Office will review total withdrawal reports generated by the NEXT system on a recurring basis, perform R2T4 calculations timely, and coordinate with the Office of Finance to process returns within the regulatory timeframe. Oversight of the process has been strengthened through the designation of responsible personnel and continuous monitoring of active cases through completion. The Carolina unit identified that delays in the return of Title IV funds were due to discrepancies in attendance reports that were subsequently amended. As a corrective action, the Office of Financial Aid will formally notify the Fiscal Office of any corrections or amendments to attendance reports to ensure that R2T4 cases are identified timely. In addition, the use of “Never Attended” reports has been reinforced at the conclusion of the census period and upon completion of the grade submission period. Once the R2T4 calculation is completed in the COD system and a return is determined, the refund process will be initiated immediately, accompanied by continuous follow-up and the scheduling of key dates to ensure compliance with the 45 days regulatory requirement. The Central Administration Finance Office will conduct a meeting with Finance Directors, Financial Aid Directors, the Office of the Registrar, and Fiscal Directors to discuss this finding and establish a uniform procedure to address the following scenarios: • Students who request a total withdrawal. • Students who stopped attending. • Students who never attended. Additionally, a control mechanism will be implemented through the SharePoint platform, whereby each Fiscal Director will certify that system reviews have been performed for cases approaching the 45 days regulatory deadline. This control will be performed on a bi-weekly basis and will allow for timely monitoring of active cases, ensuring proper compliance with the required return of funds. For cases related to grade-based census determinations, which are processed once faculty submit grades in the system, an additional control mechanism will be established. Specifically, the SharePoint tool will be used for Fiscal Directors to document the academic calendar deadlines for grade submission. Furthermore, Fiscal Directors will schedule Outlook calendar events with these deadlines, including the Director of Financial Aid and the Office of the Registrar, and will establish automated reminders to ensure timely follow-up. These procedures will be documented and incorporated into the internal control manual applicable to the R2T4 process. Responsible Person or Office: Central Administration Finance Office and the finance offices of each of the eleven (11) institutional units. Implementation Timeline: 2026-2027

FINDING 2025-003 Finding Subject: Education Stabilization Fund - Earmarking Contact Person Responsible for Corrective Action: Lori Bennett Contact Phone Number and Email Address: 317-539-9200, LBennett@mccsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: While the school corporation no longer has any active funds with the COVID-19 Education Stabilization Fund the school corporation will ensure that the designed or implemented a system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance for any future federal program. Anticipated Completion Date: January 1, 2026 INDIANA STATE

Direct Loan Disbursement Notifications Correction Action Planned: For the 2025-2026 academic year, notifications are scheduled in our FAMS system to be sent immediately after student loans are disbursed to the student account. This action started with the Fall 2025 semester. Policy and Procedures have been updated to include the Direct Loan notification statement. This is in Section 10.5, Student & Parent Notifications, on Page 48 of the Financial Aid Policies and Procedures manual. This action has already been completed and in progress as of September 2025. Person Responsible for the Corrective Action: Denise Welch, Director of Financial Aid

Noncompliance with Enrollment Status Change Reporting. Auditor Description of Condition and Effect. Of 18 enrollment status changes tested, we noted 1 change that was not reported to the National Student Loan Data System (NSLDS) within 60 days due to a student being assigned a different coding structure within the College's system which resulted in the student being excluded from the standard status-change reporting process. As a result of university personnel using the incorrect semester start dates. As a result of this condition, the College was temporarily out of compliance with enrollment reporting requirements. Auditor Recommendation. We recommend the College review and update its enrollment reporting processes to ensure that all students-including those with unique or foreign-student coding-are captured in routine status-change monitoring and NSLDS reporting procedures. The College should implement controls to detect nonstandard coding and ensure that all enrollment changes are identified and reported within required federal timelines. Corrective Action. Bay College took swift action after determining some students were being excluded in our enrollment reporting. Our reporting process was excluding students who were noted as being a citizen of a foreign county. We now review these students prior to each reporting cycle to determine if they should be included in the reporting. The Financial Aid team reviews this report to determine if the student is eligible for federal student aid. Students who are eligible are indicated and provided to the Institutional Effectiveness team to include in the enrollment reporting. This process is completed prior to each reporting cycle. For students who were not included in our prior reporting, the Financial Aid team working directly with the Institutional Effectiveness team, determined which should be reported and completed their enrollment reporting directly through NSLDS. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. June 30, 2026

Reportable Condition: See Condition 2025-001 Recommendation We recommend the Local Area monitoring the earmarking procedures for the Youth Program on a quarterly basis to ensure that at the end of the to two years meet the requirement establish. If deviations or failure to meet the earmark are noted, communications must be generated to youth program staff to take corrective actions before the elapse of the funding period. Action Taken The Executive Director has begun meetings with staff to establish a short-term plan to discuss strategies to increase the number of youth participants in the Program. In addition, at these meetings, the Executive Director has instructed the Program Executive and Program Manager to maintain control over the budget allocated and the activities to be carried out and to coordinate the planning of future activities. With regard to the Finance Area, the Chief Financial Officer is instructed that at least every two months or at the request of the Assistance Manager submit the “Encumbrance Budget Report” to see the changes in budget and be able to make decisions related to changes in the approved budget by the Labor Department Program. In the meetings to be held, the results obtained and the status of the activities carried out in order to be accountable for the actions carried out must be reported. This to maintain continuous monitoring of the program, before the end of the validity of the funds.

R2T4 Audit: FY25 Corrective Action Plan To address the audit findings, the FCC has initiated the following actions: •Spring 2025, Completed: oRevised Processing Timeline: All R2T4 calculations and returns are now completedwithin 30 days, reserving the final 15 days exclusively for QA. (Responsible Leader:Director of Financial Aid) oCross-Training and Succession Planning:Staff cross-trained; onboarding/offboardingdutiesdocumented to eliminate single points of failure.(Responsible Leader: Director ofFinancial Aid) •September 2025, Underway: oLeadership Communication Protocol:A formal process is beingfinalized to ensurecompliance issues are documentedand escalatedforawareness to the President and theCFO/VP for Administration. Thisprotocol alsoreinforcesa cultureof accountability where compliance concernsare escalated promptly and transparently. (ResponsibleLeader: AVP for Student and Financial SupportServices) •Monthly Monitoring and Reporting:Compliance reviews reported monthlyto the VP for Student Experience and then to the President and the CFO/VPfor Administration for awareness. (Responsible Leader: VP for StudentExperience). oQA Tracking Form: Implemented to document each review and correction for auditverification. (Responsible Leader: Director of Financial Aid) •Fall 2025 – Spring 2026, To Be Planned and Executed: oExternal Program Review: FCC will engage an external consultant agency (TBD) toconduct a comprehensive Financial Aid Office program review in FY26, validatingcompliance, staffing adequacy, and process integrity. (Responsible Leader: AVP forStudent and Financial Support Services) •Timeline, Next Steps, Responsible FCC Leader: oOctober 6, 2025: Submit formal corrective action plan to Auditors (VPSE) oOctober 15, 2025: Receive first compliance review report for AVP to VP reporting toPresident’s Council, as part of enterprise risk management awareness. (AVP/VPSE) oJanuary to April 2026: Conduct external program review of the Financial Aid Office andreport findings to President and the CFO/VP for Administration by June 2026. (AVP) •Expected completion date: June 2026 •Person responsible: Dr. Edmund T. Cabellon, Interim Vice President for Student Experience

Management acknowledges the missing internal control over the late submission of the updated financial model/plan for the fiscal year end June 30, 2024. Management has maintained an effective internal control tool for many years in the form of a master spreadsheet called the Annual Task Calendar that the entire Finance staff reviews at every biweekly Finance meeting, but the WIFIA deadlines were errantly not incorporated into that tool until January 2026. While management agrees with the finding, it should be noted that management was not operating without controls. Rather, the deadline being adhered to was just the wrong date. Management submitted updated financial model/plan by January 31, 2025, which was within the month following the close of the calendar year, similarly to the quarterly construction reports that are due 30 days after the end of the preceding quarter. In addition, the data on the annual model reflected current information near the time of release of the report, not June 30, 2024. So, in substance, management provided an even more current, relevant document. Management acknowledges the additional finding language that the June 30, 2025 quarterly construction monitoring report was submitted on day 31 rather than day 30 following the close of the quarter. Finally, management acknowledges that the annual updated financial model/plan for June 30, 2025, will be submitted in January 2026 as the internal control, as mentioned above, was not corrected until January 2026, which will result in the same finding on the Single Audit for June 30, 2026. However, management believes that we have taken the appropriate measures required to avoid ongoing replication. Responsible Official: Matt Zook, Finance Director

The Organization has created a tracking system that identifies when the last inspection was completed and when the next inspection should be due based on the number of units at each complex. NOTE: Inspections are not due until June through October of 2027 for complexes under the jurisdiction of the City of Salem.

The Salvation Army submitted a BBRI which requested increased rents and releases from reserves to pay accounts payable as well as approval of loans from the Sponsor to cover accounts payable that could not be paid from reserves. This would enable the reserves to be paid on a go forward basis. In addition, the next step will be a BBRI for the RAD for PRAC conversion.

The Salvation Army submitted a BBRI which requested increased rents and releases from reserves to pay accounts payable as well as approval of loans from the Sponsor to cover accounts payable that could not be paid from reserves. This would enable the reserves to be paid on a go forward basis. In addition, the next step will be a BBRI for the RAD for PRAC conversion.

U.S. Department of Health and Human Services Program Name: Maternal and Child Health Services Block Grant Federal Assistance Listing Number: 93.994 Significant Deficiency, Nonmaterial Noncompliance – Reporting Finding 2025-010 – Repeat Finding Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per 2 CFR 200.334 the recipient must retain all federal award records for three years from the date of submission of their final financial report. Condition: During the audit we tested 9 reports and noted the following: a) There was one (1) instance out of (9) nine reports tested where the submitted reports were unable to be provided, including the date of submission for the reports. b) There were four (4) instances out of nine (9) reports tested where the County was unable to provide evidence the report was reviewed prior to submission. c) There were two (2) instances out of nine (9) reports tested where the County was unable to provide the date of submission for the reports. Questioned Costs: None of the nonmaterial noncompliance items resulted in questioned costs. Effect: By not having the required documentation and underlying support, the County is not able to demonstrate compliance with the applicable requirements. Cause: The County did not have a formal policy to ensure documentation was retained to evidence review and submission of all reports. Recommendation: While the County made updates to policies and procedures surrounding reporting during the current year to address the prior year finding, the County should ensure these policies are adhered to ensure all submitted reports and underlying data are retained in accordance with the Uniform Grant Guidance requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: As of July 2025, The Health Department has created and adopted policy FIS-05 Retention of Reporting Requirement Submissions to ensure that federal award reports and data are retained in accordance with Uniform Guidance. The Health Department will document with screen shots as outlined in the FIS-05 Policy, to address circumstances when the required report consists of answering a NCDHHS survey or form that does not have “save” or “download” capability, to maintain record of documented submissions. In addition, the Health Department has developed a standard operating procedure whereby fiscal compliance Management Analysts, in collaboration with Program Managers, ensure they have reviewed federal award reports prior to submission and file documentation of review and approvals. While review of grant reports is common, the Health Department did not have adequate documentation to demonstrate completion of this step prior to July 2025. An additional training, to be recorded, will be held with program staff Friday December 19th, 2025. Anticipated Completion Date: December 19,, 2025 Responsible Person(s): Autumn Watson, Business Operations Director

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 Significant Deficiency and Nonmaterial Noncompliance – Child Support Non-Cooperation Finding 2025-008 Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each sanction for noncooperation. Condition: a) There was one (1) instance out of two (2) sanctions tested where the required form to be sent was dated after the sanction start date. b) There was one (1) instance out of two (2) sanctions tested where the sanction was not properly documented. Questioned Costs: None of the nonmaterial noncompliance items resulted in questioned costs. Effect: When required sanction notifications are not issued prior to the sanction start date and sanctions are not properly documented, there is an increased risk that clients may not be properly informed of program actions and that the County may not comply with program requirements. Cause: The County did not have adequate procedures in place to ensure that required sanction notifications were issued prior to the sanction start date and that all sanctions were properly documented in accordance with program requirements. Recommendation: The County should implement procedures to ensure all required sanction notifications are issued prior to the sanction start date and that sanctions are properly documented in accordance with program requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this, which is further discussed in the Corrective Action Plan. Corrective Action Plan: Performance Improvement Strategy: Collaborate with Child Support Services to improve understanding of their processes and ensure accurate case handling. Responsible Individuals: Sarah Carter, Tatyenne Rone, Karl Parisien, Denize Cuff (Sr. Quality and Training Specialist), Danisa Concepcion (Quality and Training Supervisor), Staphon Snelling (Training and Development Manager), Scott Fritz (Social Services Manager), Program Supervisors Training: Non-Cooperation Sanction Training Anticipated Completion Date: To be completed quarterly. Responsible Individuals: Sarah Carter, Tatyenne Rone, Karl Parisien, Denize Cuff (Sr. Quality and Training Specialist). Danisa Concepcion (Quality and Training Supervisor), Staphon Snelling (Training and Development) Anticipated Completion Date: Completed by January 2026.

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 Material Weakness and Nonmaterial Noncompliance – Eligibility and Special Tests: Income Eligibility and Verification System Finding 2025-007 Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each eligibility determination, and the information entered into NCFAST. We noted several errors related to the following compliance criteria: a) An OVS inquiry must be completed and agreed to information reported in NC FAST. b) For the month of application, Work First cash assistance payments are prorated from the date of application, with the date of application being day one. c) All Work First applicants must provide a Social Security number or apply for a Social Security number if they do not have one. d) Parents and step-parents who apply for children must be included in the case with the child, unless they are otherwise ineligible. Condition: The following are the results of nonmaterial noncompliance noted for each criteria listed above out of the 25 program participants selected for testing a) There were two instances where the OVS query was not run at the time of the determination. b) There was one instance where a hearing extension was incorrectly prorated. c) There was one instance where the social security number was not verified. d) There was one instance where kinship was not documented. Lastly, the following are the results of 60 program participants tested for control testing: a) There were three instances where the County did not remediate the errors identified within their internal review timely. b) There was one instance where a participant received benefits for one month where they should not have. c) There was one instance where incorrect forms were sent to a participant. Questioned Costs: None of the nonmaterial noncompliance items resulted in questioned costs. Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified and monitored throughout the year for adherence to the policy. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: Performance Improvement Strategy: The Economic Services Division (ESD) Quality and Training Specialist will conduct a 25% sample review of all ongoing cases. Errors identified during these reviews will be documented and communicated to both the Social Services Supervisor and the assigned Eligibility Specialist for correction within a defined timeframe. Failure to comply with correction timelines will result in corrective action. Case Review and Error Notification • ESD Sr. Quality and Training Specialist will review 25% of all ongoing cases. • Errors will be documented on checking sheets and emailed to both the supervisor and the assigned Eligibility Specialist. • Corrections must be completed within 5 business days of notification. Corrective Action • If corrections are not completed within the extended timeframe: o Corrective Action will be initiated in accordance with departmental performance management protocols. Responsible Individuals: Sarah Carter, Tatyenne Rone, Karl Parisien, Denize Cuff (Sr. Quality and Training Specialist), Danisa Concepcion (Quality and Training Supervisor), Staphon Snelling (Training & Development Manager), Scott Fritz (Social Services Manager), Program Supervisors Anticipated Completion Date: To be completed monthly. Training: Training Completion Required for the Following Quality Review Errors: • Ensure the OVS inquiry is completed, and that the information aligns with data reported in NC FAST. • Understand that Work First cash assistance payments are prorated from the application date, which is considered Day One. • Confirm that all Work First applicants must provide a valid Social Security number or apply for one if not already obtained. • Review and apply the rules of kinship, specifically regarding parents and stepparents. Additionally, train supervisors and eligibility specialists on the importance of timely resolution of quality sampling errors and how delays can impact audit outcomes. Responsible Individuals: Sr. Quality & Training Specialists, Quality & Training Supervisor, Training & Development Manager. Anticipated Completion Date: An email will be sent by the Staff Development Unit to the Eligibility Specialist with errors by January 2026, and in-person training will be completed by February 2026.

Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Eligibility Finding 2025-005 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: There were 6 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely. Questioned Costs: None Effect: Failure to promptly remediate errors identified during internal review increases the risk that program participants may receive benefits or incur costs that do not comply with program requirements, potentially resulting in noncompliance and questioned costs. Cause: The County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified and monitored throughout the year for adherence to the policy. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: The WIC Sr. Quality and Training Specialist conducts quarterly monitoring by observing staff and completed random chart reviews. However, due to retrospective nature of audits significant time elapses between the occurrence of the error and its identification. Late corrections in the crossroads system will compromise data integrity and disrupt some of the certification processes in crossroads. Crossroads also lacks the ability to alert supervisors of missing documentation which in turn creates a huge administrative burden to monitor missing documentation in real time. WIC program leadership will create a policy that will address documentation standards. WIC staff will be instructed not to alter the original entry, instead a correction addendum will be documented to acknowledge missing data. WIC program will continue to provide policy refreshers every quarter to address these findings and provide staff updated information. WIC supervisors will review the quarterly audits results with their staff and ensure staff follow the standards set by the department leadership. The following the phases of the corrective action plan will be completed by March 31st, 2026. Phase 1: Review of Federal and State Guidelines Phase 2: Creation of Document Standard Policy Phase 3: Implementation of new documentation standards policy. Anticipated Completion Date: March 31st, 2026 Responsible Person(s): Ali Raza, WIC Director

Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Allowable Costs/Costs Principles Repeat Finding 2025-003 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: There were 3 out of 40 samples tested where clear and consistent documentation of a control over allowable costs and activities was not present. Effect: Without consistent documentation and adherence to departmental policy for approving allowable costs, there is an increased risk that unallowable expenditures may be charged to the program, potentially resulting in noncompliance with federal requirements and questioned costs. Questioned Costs: None. Cause: The departmental policy to approve expenditure documents as an allowable cost for the program was not followed. Recommendation: The County should consistently follow departmental policy by ensuring all expenditure documents for the program are properly reviewed and approved as allowable costs before being approved for payment and maintain clear documentation of controls over program activities to support compliance with federal requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Correction Action Plan: Program leadership will collaborate with the County Finance Team to ensure departmental policy is followed when purchases are made using WIC Federal funds. Internal purchase approval documents will be created to enhance the approval workflow. All purchases will be submitted to the WIC Program Director for approval. The program Director and the Sr. Admin Assistant will review the orders and ensure they are allowable items per the NC State WIC program guidelines. A shared folder will be created to save the purchase order forms, and the invoices to ensure Mecklenburg County Health Department Policy A-13, Retention of Administrative Documents is followed. The following the phases of the corrective action plan will be completed by March 1st, 2026. Phase 1: Review of Federal and State Guidelines Phase 2: Mecklenburg County Procurement Policy Review Phase 3: Creation and Implementation of new internal purchase approval processes. Phase 4: Staff Training Anticipated Completion Date: March 1st, 2026 Responsible Person(s): Ali Raza, WIC Director

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Medical Assistance Federal Assistance Listing Number: 93.778 U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Children's Health Insurance Program Federal Assistance Listing Number: 93.767 Material Weakness and Nonmaterial Noncompliance - Eligibility Finding 2025-002 - Repeat Finding Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each eligibility determination, and the information entered into NCFAST. We noted several errors related to the following compliance criteria: a) Self-attestation wages should be compared to information in NC FAST. b) All countable resources should be confirmed and recalculated and ensure they are computed accurately in NC FAST. c) The caseworker should prepare and submit a DMA-5097 form in the case of incompatible income verification and self-attestation income as described in the Eligibility Review Document. d) Citizenship should be documented within NCFAST. e) Household information should be entered correctly into NCFAST. Condition: The following are the results of nonmaterial noncompliance noted for each criteria listed above out of the 124 program participants selected for testing: a) There were six instances where the participants self-attest wages did not agree to the wages entered into NC FAST. b) There was one instance where the countable resources were inaccurate within NC FAST. c) There were five instances where the income was incompatible between the income verification and self-attestation income but no DMA-5097 was sent. d) There was one instance where the participant's citizenship was not documented in NCFAST. e) There was one instance where the participant's household size was entered incorrectly into NCFAST. Lastly, there were 6 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely. Context: There were 8 out of 124 unique participants tested with the errors noted above. Questioned Costs: We noted no federal questioned costs for the County as the State of North Carolina makes all benefit payments to participants directly. Due to split eligibility determinations between the Counties and the State of North Carolina for Medicaid, we found $25,105 in benefit payments made by the State of North Carolina to ineligible participants based on an improper eligibility determinations at the County related to three individuals in item "a" above. Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified and monitored throughout the year for adherence to the policy. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: Performance Improvement Strategy: The County has identified specific opportunities to strengthen accuracy and consistency in eligibility case documentation. While overall performance has improved, with total errors reduced from 14 the prior audit period to 8 in the current period, continued focus is necessary to further reduce errors and sustain compliance across case files. The Economic Services Division Strategies are as follows: • Social Services Supervisors will conduct targeted reviews of identified error trends, emphasizing policy application, documentation completeness, and process standardization to ensure consistent eligibility determinations across the program. • The Economic Services Division's Staff Development Unit will continue to quality sample cases to promote accuracy and accountability. • Social Service Supervisors, in coordination with Medicaid Social Services Managers will coach staff based on audit findings, monitor trends and ensure required corrections are completed within 5 business days of notification. • Failure to complete corrections within the approved timeframe will result in corrective action to both the Social Services Supervisor and the assigned Eligibility Specialist in accordance with departmental performance management protocols. • Supervisory staff will ensure all updates to the Quality Sampling Tracking Log are finalized no later than the 20th calendar day of the subsequent month to support timely monitoring, trend analysis, and corrective action. These actions are designed to strengthen internal controls, support staff performance and maintain compliance with applicable state and federal requirements. Responsible lndividual(s): Kim Konior, Lynn Martin (Medicaid Program Managers), Staphon Snelling (Training and Development Manager), Danisa Concepion, Donnie Munson (Quality and Training Supervisors), and Social Services Medicaid Supervisors. Anticipated Completion Date: Ongoing Training: The Economic Services Division's Staff Development Unit will review the Single Audit findings and develop targeted training for staff responsible for determining Medicaid eligibility, as well as their supervisors and managers. This training will specifically address the errors identified in the audit and will be delivered by the end of March 2026. In addition, Staff Development will provide quarterly training to Medicaid eligibility staff, supervisors, and managers based on error trends identified through quality sampling conducted by the unit. To ensure effectiveness, a structured training approach will be used: • A pre-test will assess staffs current understanding of relevant policies. • The County will deliver targeted training materials tailored to address identified gaps. • A post-test will be developed, with a minimum passing score of 90%. This approach will allow the County to: • Measure knowledge gained through the training • Track training completion, identify staff who have or have not completed the training • Ensure consistent understanding and application of policy across the team Staff who do not achieve the required score will receive additional refresher training to reinforce key concepts and ensure compliance. Responsible lndividual(s): Staphon Snelling (Training and Development Manager), Danisa Concepion, and Donnie Munson (Quality and Training Supervisors), and Sr. Quality and Training Specialists (Medicaid). Anticipated Completion Date: March 31, 2026

2025-003 Distance Learning and Telemedicine – ALN No. 10.855 Compliance: Name of contact person – Brandon Studer, Business Manager Recommendation: We recommend management contact the Grantor to determine necessary actions in response to the excessive interest earned on federal funds, including the potential return of earnings to the grant agency. Action Taken: Management agrees with the recommendation and will contact the Rural Utilities Service to determine whether excess interest earned on the funds is due back to the agency. Proposed Completion Date: March 31, 2026

Finding 2025-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing: 84.007, 84.033, 84.063, 84.268 Finding Summary: In testing of 60 students, 3 students did not receive a timely notification of their award from the District. Corrective Action Plan: To address missed disbursement notifications, the Financial Aid team identified affected students and sent the required notices, including an official explanation from the Director of Financial Aid. The issue was traced to a system malfunction during the SU24 term, which has since been resolved by implementing a process that alerts IT and the Director if notification counts do not match disbursement records. The notification script has been enhanced to track missing letters over the previous 30 days, and IT has established a weekly audit comparing sent notifications to disbursement records for accuracy. Additionally, coding updates in the CX system now ensure all disbursements are properly captured, regardless of the date entered by Financial Aid, thereby preventing similar oversights in the future. Responsible Individual(s): Christopher Natelborg Anticipated Completion Date: December 2025

FINDING 2025-002 Finding Subject: COVID-19- Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Summary of Finding: State Board of Accounts has asserted that the school corporation did not ensure that the contractor for the elementary building’s roofing project, which was partially funded through a federal ESSER grant, had paid prevailing wage rates on this project. Contact Person Responsible for Corrective Action: Debra Elder, Treasurer and John Scioldo, Superintendent Contact Phone Number and Email Address: 812-547-3300; debbie.elder@tellcity.k12.in.us and john.scioldo@tellcity.k12.in.us Views of Responsible Officials: We concur with the finding.. Description of Corrective Action Plan: While we will agree that the school corporation did not physically have on file and/or review the detailed certified payroll timesheets from Eskola, the awarded contractor for the project, the school corporation had hired in good faith Universal Design Associates (UDA) to manage all facets of the project. UDA has managed other capital improvements on the school’s campus, and their services have been exemplary. A school corporation of our size simply does not have the manpower, resources or expertise to oversee a project of this size, and therefore we rely on the hired project manager/architectural design company to ensure all federal Davis-Bacon wage scale requirements and the construction project as a whole are being fully followed, in addition to their close oversight of the day-to-day project management. The Application to Pay statements for payment to Eskola were provided by, and assumably thoroughly reviewed by, UDA. These pay applications obviously included payment for payroll, again assumably of which UDA checked certified payroll for federal wage compliance. The project was completed in the spring of 2025, and therefore this is no longer an issue. We have determined as a result of this finding that the current school administration will not consider funding future capital projects with federal grants due to the complexities of the involved federal compliance requirements. Anticipated Completion Date: N/A – Based on Corrective Action Plan

HRSA Grant Self-Reporting Memo Deficiencies, Investigation, Reporting and Corrective Actions January 15, 2026 RE: Grant Number (FAIN): CE152520, under Assistance Listing Number: 93.493, Award Number: CE1HS52520-01-06 (the “Grant”) Federal Award Date: 9/21/2023 Grant Title: Community Project Funding/Congressionally Directed Spending - Construction Grantee: Spokane Guilds’ School (Unique Entity ID: DZJ5TZ4LGWH3, EIN: 91-0863163) (d/b/a Joya Child & Family Development “Joya”) 1016 N Superior St. Spokane, WA 99202 Grantee Contact: Colleen Fuchs, Executive Director Grant Purposes: Alteration and Renovation to Existing Facility, and related Equipment and other costs, to create Joya’s Neurodevelopmental Research & Training Institute Grant Amount (Per Notice of Award, Section 31. Approved Budget): e. Equipment $ 690,195.00 h. Construction/Alteration and Renovation $ 2,377,431.00 i. Other $ 117,114.00 Total Direct Costs $ 3,184,740.00 Less: Cost Sharing or Matching $ 184,740.00 Total Amount of Federal Share $ 3,000,000.00 Background: Joya’s facility was constructed from March 2021 to June 2022, and funded via private charitable contributions received from donors and a loan from Joya’s bank. The facility was placed in service in June, 2022 for a total approximate cost of $13.0 million. The facility is utilized by Joya, a 501(c)(3) non-profit organization, to house programs that provide physical, occupational, speech and other therapies to children with neurological and developmental delays, primarily from birth to three years of age. In Fall of 2022, Joya applied for a $3.0 million grant from HRSA to improve its facility to include a Neurodevelopmental Research & Training Institute and expand its services. The Grant was awarded to Joya, and Joya awarded a construction contract to the General Contractor who had completed its facility in 2022. The facility improvements were substantially completed in 2025. As of the date of this memo, approximately $123,000 remains available to Joya under the Grant. Procedural Deficiencies: 1. Competitive Bid (Eide Bailly Finding # 2025-001): In April 2025, during a selfreview of Joya’s compliance with 45 CFR Sections 75.326 to 75.335, specifically the required procurement procedures, management discovered that Joya’s procurement procedures were deficient in the following specific area. Joya’s policies and procedures did not require public notice to be issued regarding a competitive bidding process for the facility improvements, specifically the construction contract award, as required in the CFR. The contract was awarded to the same contractor who had recently constructed the original facility, as the contractor possessed critical knowledge of the facility along with the requisite skills to perform the improvements. However, market cost information (obtained through a public bid process) was not available. Further, a sample of nine transactions (out of 43 total transactions) indicated that contracts for three vendors between $10,000 and $250,000 required Joya to follow simplified acquisition procedures and obtain rate quotations in advance of procurement. 2. Proportion of Federal to Non-Federal Share (Eide Bailly Finding # 2025-002): Later in 2025, Joya engaged its independent CPA firm, Eide Bailly to audit its financial statements, and as part of that, to issue an opinion on its internal controls over financial reporting and on compliance with certain provisions of laws, regulations, contracts and grant agreements. During its review, the CPA firm discovered that Joya’s procedures regarding matching/cost sharing were deficient. Joya’s policies and procedures did not have su􀆯icient internal controls to ensure that grant funds were drawn down following the required proportion of (i) the Federal Share of Grant funds in proportion to (ii) the Cost Sharing/Matching Grant funds. Following a review of Joya’s financial records, it was determined that Joya’s contribution of its Non-Federal Share of improvement costs was approximately $12,000 lower than the amount required by the defined contract proportion, through June 30, 2025. Self-Investigation and Reporting: Joya’s investigation and specifically its review of the Grant requirements and the CFR language in April 2025, along with its seeking an independent review of its internal controls resulted in identifying both procedural deficiencies described above. Corrective Actions: The following corrective actions to address the Procedural Deficiencies have all been completed, as further described below. 1. Joya’s Director of Business and Accounting (B. Judge) timely notified its independent CPA firm, Eide Bailly, which described the internal control deficiencies in its qualified opinion to its Independent Auditor’s Report on Internal Control and Compliance for the year ended June 30, 2025. The CPA firm did not qualify its separate opinion to Joya’s Audited Financial Statements for the year ended June 30, 2025. 2. In April 2025, Joya’s Director of Business and Accounting (B. Judge) sought technical guidance and approval from Joya’s board of directors and its independent CPA firm. By June 2025, Mr. Judge had updated Joya’s policies and procedures to include the required internal controls described above. 3. Joya’s Director of Business and Accounting (B. Judge) engaged MACC Estimating Group, an independent construction estimation firm in Liberty Lake, WA, to obtain an itemized cost estimate for the facility improvements funded by the grant. The independent results issued on June 24, 2025 were only 6% higher than the awarded contractor bid. Joya’s management believes this provides a reasonable market cost for its awarded project. 4. On April 18, 2025, Joya’s Director of Business and Accounting (B. Judge) emailed HRSA sta􀆯 members A. Glasser and C. Barnes, o􀆯icially notifying HRSA of its procurement policy deficiencies. HRSA (A. Glasser, Grants Management Specialist) responded via email on April 18, 2025, asking about the procurement process Joya ultimately used, and informing Joya as follows: “At this time, all HRSA conditions for award CE1HS52520 have been met, and you are free to draw down funds from document number 23CE1HS52520 in the Payment Management System. However, please ensure that the terms outlined on the Notice of Award dated 9/21/23 are followed. If you have specific questions regarding these terms, I am happy to discuss further.” Joya has received no further correspondence from HRSA on the matter. 5. Joya’s Director of Business and Accounting (B. Judge) continued to monitor its procurement process and proportional cost sharing to remain in compliance with 45 CFR Sections 75.326 to 75.335. Specifically, Joya’s Accounting Policies were updated in 2025 to include the following internal controls, as reviewed and amended from time to time: “If a purchase is funded in whole or in part by a Federal Grant, any related procurement or payment must comply with Federal Grant Procurement policies and applicable Federal Regulations under 2 CFR §§ 200.317– 200.327, including, but not limited to: • Following allowable procurement methods (micro-purchase, small purchase, sealed bids, competitive proposals, or noncompetitive proposals) • Obtaining multiple quotes when required and providing public notice requesting sealed competitive bids for expenditures over $250,000 • Avoiding conflicts of interest • Ensuring that contractors have not been suspended or debarred • Documenting the basis for selection and price reasonableness • Ensuring that Joya monitors expenditures to ensure that it maintains the appropriate proportion of Federal Share of Grant funds in proportion to the Cost Sharing/Matching Grant funds”. 6. In February 2025, Joya received a private grant in the amount of $178,000 from a private donor, which served as 96% of the required shared/matching funds Joya required for the entire Grant. These and other Joya funds are su􀆯icient to meet 100% of the required shared/matching funds.

2025-001 – Direct Costs-Compensation Grantor: Centers for Disease Control and Prevention - Aids Activity and Coordinating Office (AACO), National Institute of Health Award Name: High Impact HIV Prevention and Surveillance Programs, Research and Development Assistance Listing Number: 93.940, 93.838 Assistance Listing Title: HIV Prevention Activities Health Department Based, Lung Diseases Award Year: July 1, 2024 to June 30, 2025 Award Numbers: CP4043 and CP5043 (2220536), 1OT2HL161847-01 Management’s Views and Corrective Action Plan Management acknowledges the finding related to delayed effort report certification. We recognize the importance of timely and accurate effort reporting as well as ensuring compliance with federal and institutional requirements. Children’s Hospital of Philadelphia Research Institute has implemented a new Effort Compensation Compliance system for effective July 1, 2025. This new system will enhance monitoring of timely effort certifications through automated reminders and greater transparency. With this implementation, training and reference materials will be provided to all personnel involved in effort reporting to ensure they understand the importance of timely certification and the potential impact of delays on grant compliance.

Finding Summary: 2 CFR Part 200 (Uniform Guidance) requires that the non-Federal entity must establish and maintain effective internal control over the Federal award. Eide Bailly noted two out of five reimbursement requests had no evidence of approval. Responsible Individuals: Samantha Nance, City Clerk Corrective Action Plan: Create a checklist for all reimbursement request procedures to include prepared by and approved by signatures with every request. Anticipated Completion Date: Immediately

Reportable Condition: See Condition 2025-001 Recommendation We recommend the Local Area monitoring the earmarking procedures for the Youth Program on a quarterly basis to ensure that at the end of the to two years meet the requirement establish. If deviations or failure to meet the earmark are noted, communications must be generated to youth program staff to take corrective actions before the elapse of the funding period. Action Taken The Executive Director has begun meetings with staff to establish a short-term plan to discuss strategies to increase the number of youth participants in the Program. In addition, at these meetings, the Executive Director has instructed the Program Executive and Program Manager to maintain control over the budget allocated and the activities to be carried out and to coordinate the planning of future activities. With regard to the Finance Area, the Financial Director is instructed that at least every two months or at the request of the Assistance Manager submit the “Encumbrance Budget Report” to see the changes in budget and be able to make decisions related to changes in the approved budget by the Labor Department Program. In the meetings to be held, the results obtained and the status of the activities carried out in order to be accountable for the actions carried out must be reported. This to maintain continuous monitoring of the program, before the end of the validity of the funds. We expect to comply with the requirements this next year.