Corrective Action Plans

Internal controls will be created for reviewing the determination of eligibility for participation in the Emergency Rental Assistance Program.

Management agrees with the recommendation. Currently working on establishing a better setup with Administration on Google Drive to have every Sub-recipient and Contracted employee upload everything into each individual country folder.

We have implemented procedures to ensure we are in compliance with all reporting requirements. Individuals have been assigned to be responsible for the preparation and submission of reports. The Board has implemented procedures to monitor the compliance and communicate the procedures to new members.

The County does not have a complete set of written cash management policies and procedures as required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.

The organization acknowledges that time and effort procedures were not consistently followed throughout FY24. The organization has implemented a new system of reporting designed to capture time and effort of all employees charged to government grant and contracts, as well as other grants and contracts awarded to the agency from the philanthropic community. Additionally, along with the timesheet, the agency now requires that an attestation statement is prepared quarterly by Program Managers and Directors for all employees charged to grants to attest to the actual amount of time spent and allocated to the grants. The organization has expanded administrative oversite of the finance department and financial data and has hired a Finance Director who has spent a considerable amount of time training staff and managers regarding their allocations and their obligations to track their time. The Finance Director has trained our expanded finance team on ensuring that accounting policies and procedures are strictly adhered to and that GAAP is uniformly applied to all financial data of the agency.

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement policies and procedures to ensure that future awards or contracts with expenditures of American Rescue Plan (APRA) funds will follow the procurement guidelines outlined in the US Treasury rules and regulations as well as County procurement policies. Most of the 2024 expenditures were part of contracts that were already in place when the original findings came out in September 2023 so this could not be corrected. Name of the contact person responsible for corrective action: Craig McBrain, Deputy Director of Budget and Finance Planned completion date for corrective action plan: December 31, 2025

A procedure has been created for this and will be implemented and looked at 1/4ly so funds can be spent down during the school year. Immediate steps were taken to do a spenddown plan and the food serviced fund was used for the program to bring down the fund balance to less than the three-month average expenditures.

Training has been completed for staff responsible for the MOE. In the past ten years the MOE’s were completed both ways and always accepted by the STATE. A procedure has been completed, that includes an internal review process to verify the accuracy of data used for MOE reporting. We are working with the New Hampshire Department of Education to correct and resubmit the five sets of worksheets using the appropriate financial figures.

The discrepancies identified were the result of inconsistencies between internal student records and data transmitted to COD for Direct Loan origination. These errors occurred due to manual data entry and timing differences between updates made in the institution’s student information system (SIS) and those reflected in COD. Financial Aid staff received refresher training on Direct Loan data accuracy, COD reporting requirements, and verification procedures to ensure consistent documentation and communication between systems. Collaboration with IT Office is underway to establish automated data checks between the SIS and COD files to minimize the risk of future mismatches. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

This finding was related to staff turnover within the financial aid, student accounts and business offices. The hiring of qualified staff properly trained should avoid this error going forward. The Perkins program has ended and it is also likely that any personnel involved in the active years left years ago. We are currently working with UAS to reassign our Perkins portfolio back to the U.S. Department of Education. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

Finding 2024-004: Failure to Notify Secretary of HCM1 Reporting Events while Participating under the Zone Alternative Comments on Finding and Recommendations: The College agrees with this finding as determined in the examination and states that the College had deficiencies related to the Institution's failure to properly notify the Secretary of a violation of a loan agreement and a failure to make a payment in accordance with its debt obligations,that resulted in a creditor filing suit to recover funds under those obligations. Actions Taken or Planned: The College was unaware of the requirement to notify the Secretary of the concerns with the loans and is taking action to notify the Secretary at the time of generating this document. The College has hired an Accreditation and Compliance Officer to ensure that lack of understanding of requirements does not happen in the future. The College would also like to note the following: the individual referenced in the suit had given verbal, though not written permission to not pay the loan past the due date while she served as the Vice Chair of the Governing Board. Upon removal from the Board due to failure to perform duties the individual filed suit, the suit is being partially argued by the College’s attorney noting the complainant had failed in their duties while on the board and may have engaged with another individual to defraud the College. Additionally while the College is submitting notification currently, there is a Government shutdown that may interfere with the notification process.

Finding Number 2024-001: Eligibility Determination Process (Material weakness in Internal Control over Compliance and Material Noncompliance – Eligibility) Program: Housing Opportunities for Persons with AIDS Assistance Listing Number: 14.241 Response and Corrective Action Plan: Management agrees with the finding that the internal controls required for this program had material weaknesses. To ensure proper program management, program staff have created appropriate procedures and processes to demonstrate internal controls. These include a manager review of potential clients, a checklist for ensuring that the program collects and maintains required records, and a procedure for collecting and storing third-party documentation for client program intake/eligibility, diagnosis, and income. Anticipated Completion Date: by September 1, 2025 Responsible Person: Tiffany Major, Deputy Director

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Quincy, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: CBIZ CPAs P.C. 53 State Street, 17ᵗʰ Floor Boston, MA 02109 Audit period: July 1, 2023 through June 30, 2024 The finding from the June 30, 2024, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Financial Statement Finding Finding 2024-001: Certain Department Expenditures Exceeding Appropriated Amounts – General Fund – Significant Deficiency Condition: During 2024, it was noted that expenditures in the public safety and education functions exceeded the amounts appropriated by the City Council for the fiscal year. Criteria: Massachusetts general law prohibits the City from incurring liabilities in excess of appropriations in each department with certain specific exceptions, such as snow and ice removal costs, state and county charges, and debt service. Prudent budgetary control and monitoring are essential to ensure compliance with such requirements. Cause: The overspending of these appropriations occurred due to an inadequate internal control system to ensure timely budget amendments. Effect: Overspending appropriations in the General Fund constitutes noncompliance with state law and exposes the City to potential fiscal consequences, as the state may require the City to raise such deficits in the subsequent fiscal year. It may also indicate a weakness in the City's internal controls over budgetary compliance. Recommendation: We recommend that City management strengthen internal controls over budgetary compliance. Management should strengthen its’ procedures throughout the year to monitor budget-to-actual expenditures and ensure timely action, such as requesting formal budget amendments when actual expenditures approach or exceed authorized appropriations. Views of Responsible Officials: The Municipal Finance Office will be implementing procedures to ensure that the Municipal Finance Office and relevant department heads document reviews of budget to actual reports monthly throughout the year, with increased review intervals during June. The purpose of this increased monitoring is to ensure that potential budgetary appropriation deficits are identified in a timelier manner that will allow for any necessary budgetary amendments to be approved by the City Council. Finding 2024-002: Information Technology Controls in Financial Statements – Significant Deficiency Condition: During 2024, we noted the following deficiencies relating to information technology controls in the financial statement reporting process: • User Access Mirroring: When new users are provisioned in the accounting system, access rights are often “mirrored” from existing users without sufficient review of job responsibilities. This practice results in users receiving access to system functions beyond what is necessary for their roles and may compromise segregation of duties. • Privileged Access: A review of privileged user listings indicated access accounts with no exclusionary parameters. • Inadequate Controls Over System Upgrades: When implementing accounting system upgrades, controls over change management including testing, documentation, and approval, were not adequately designed or consistently applied. Instances were noted where upgrades were implemented without thorough pre-deployment testing and formal approval from finance or IT management. Criteria: Best practices and standards for internal control require: • Role-based access provisioning aligned with users’ responsibilities and effective segregation of duties. • The use of exclusionary parameters enhances the ability to monitor system access for unauthorized access. • Robust change management controls over system upgrades, including testing, documentation, and management approval, to ensure system integrity and minimize the risk of errors or unauthorized changes impacting financial reporting. Cause: These deficiencies appear to result from a lack of formalized policies and procedures for user access provisioning and for managing and documenting accounting system upgrades. Effect: The deficiencies increase the risk of: • Unauthorized access or inappropriate transactions due to excessive or incompatible user rights, undermining segregation of duties and accountability. • Errors, omissions, or unauthorized changes introduced during system upgrades, potentially affecting the integrity and accuracy of financial data and financial statement preparation. Recommendation: We recommend that City management: • Implement procedures to provision user access based on individual roles and responsibilities, with documented review and approval to ensure segregation of duties is maintained. This should be evidenced by written approval that is approved by Municipal Finance and Information Technology office. • Enhance the current process of implementing accounting system upgrades, including requirements for comprehensive pre-deployment testing, clear documentation, and explicit written approval from the Municipal Finance Office and the Information Technology office, prior to going “live” with the upgrade. • Periodically review system access and upgrade processes to ensure ongoing compliance with internal control standards. Views of Responsible Officials: The City will keep these recommendations in mind as it works to upgrade its already existing best practice IT control environment. Finding and Questioned Costs – Major Federal Program Audit Criteria or Specific Requirement: Uniform Guidance section 2 CFR § 200.430(g) requires non- Federal entities to maintain records that accurately reflect the work performed by employees whose salaries are charged, in whole or in part, to Federal awards. For employees working on a single Federal program, semi-annual certifications are required to document time and effort. Condition and Context: During testing of 40 payroll transactions for employees charged to the Special Education program, the City was unable to provide semi-annual certifications supporting that salaries and wages were properly allocated to the grant. Cause: The City did not have adequate procedures in place to ensure that required time and effort certifications were retained and readily available for payroll charged to Federal awards. Effect or Potential Effect: Failure to maintain required time and effort documentation resulted in the questioned costs documented below. Questioned costs are reported as follows: AL Number: 84.027 Name of Federal Program or Cluster: Special Education Cluster Questioned Costs: $2,572,675 Recommendation: We recommend the City establish and implement procedures to ensure that semiannual certifications are completed, maintained, and reviewed for all personnel whose salaries are charged to Federal awards. Views of Responsible Officials: This is a questioned cost due to the School Department not having completed certain administrative paperwork, required by grant regulations. We have implemented procedures during FY2025 to address this matter. The required paperwork will be retained on file going forward.

Director of Operations & Impact will draft an 18-month reporting deliverables schedule to be reviewed quarterly. The schedule of reporting deliverables will be added to a dedicated calendar in SharePoint, shared with the President and programs team staff, and a series of reminders and notifications will be integrated into the system. The system itself will be reviewed every six months going forward to address any technological issues and make recommendations for improved functionality. Planned Implementation Date of Corrective Action: 9/22/25 Person Responsible for Corrective Action: Director of Operations & Impact

Grantee Response and Corrective Action Plan: AVLF concurs with the recommendation. The Organization will take the following corrective actions: 1. Remit corrected timesheets to the Agency for information purposes. 2. Revise the organization’s policy to include review and reconciliation of SER’s and timesheets prior to submission to the Agency. Responsible Parties: Jason Levister, Controller Date to be Completed: October 2025

1. Current Findings on the Schedule of Findings and Questioned Costs A. Finding 2024-001 Supportive Housing for the Elderly (CFDA# 14.157) Reserve for Replacement Deposits The Project did not repay the $31,958 Reserve for Replacement loan advance by the due date of May 1, 2024. (1) Comments on the Finding and Each Recommendation Management concurs with this finding, agrees with the auditor recommendation, and the Project has repaid the loan advance. (2) Actions Taken on the Finding The Project has repaid the Reserve for Replacement loan advance. B. Status of Corrective Actions on Findings Reported in the Summary Schedule of Prior Audit Findings The prior year finding was resolved.

Official: Janelle Lawrence, Executive Director. Date of Discussion: October 3, 2025. Planned Corrective Actions: To reduce misidentification of expenses for allowed activities, the Organization has implemented a dual-review process for all grant expenses to ensure that eligible costs are identified and submitted. Staff will also receive updated training on allowable expense categories to reduce misinterpretation. In monitoring payroll activities, the Organization has revised its grant payroll allocation process to ensure that duties performed under specific roles are billed at the appropriate rate. Future budgets will more clearly distinguish between roles and corresponding pay rates to prevent overages. All projects will undergo budget-to-expense reconciliation on a monthly basis to safeguard against missed claims and ensure that grant resources are maximized without exceeding allowable limits.

The Organization will revisit the internal control process around invoice submissions and reimbursement request review. The Organization has since hired an outsourced accountant to assist with record keeping and assisting with ensuring compliance with Uniform Guidance. The Organization strives to remain compliant with Uniform Guidance in all respects to present both accurate and transparent records. If the Missouri Department of Social Services or the U.S. Department of the Treasury have questions regarding this plan, please call Jennifer Gadsky, MSW, LCSW, Executive Director, at (314)-938-4414.

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.063 Condition: During our audit procedures, we noted that the 1 student withdrawal did not have a return to Title IV calculation completed timely as the student officially withdrew 8/29/23 and the calculation was not completed until 3/24/25. We also noted that the calculation that was performed did not include documentation of the control process to review and approve the calculations prior to changes being made to the student’s award. Auditors’ Recommendation: We recommend the institution maintain proper documentation in accordance with federal grantor requirements and ensure that the documents are readily available for review upon request, including monitoring of students with triggering events that require a return to Title IV calculation to be completed, reviewed, and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Auditors’ Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act that have not been completed and documented and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. The new systems are Jenzebar products and are fully compliant. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Students tested in the Common Origination and Disbursement (COD) reporting were not properly reported based upon University documents, including disbursement dates and applied dates. Auditors’ Recommendation: We recommend that the University strengthen its internal controls to ensure that all disbursement dates are reported to COD accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The previous SIS was subject to frequent interruptions which prevent timely data exchange with COD. Beginning with the 2024-2025 award year a new financial aid processing system was implemented. The new processing system is a more secure environment and hosted by Jenzabar for added compliance assurance. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Student checks related to student refunds of Title IV federal financial aid was outstanding more than 240 days as of June 30, 2024. Auditors’ Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University is implementing financial internal controls policies and processes to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards and ensure compliance with the DOE. This includes procedures related to outstanding student refund checks over 240 days. Name(s) of the contact person(s) responsible for corrective action: Denise Johnson, Interim Controller, Bursar Dept. Supervisor Planned completion date for corrective action plan: June 30, 2025

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: 2 students of the 22 students selected for eligibility did not maintain academic satisfactory progress and were on probation but did not receive notifications. Auditors’ Recommendation: We recommend that the University review its satisfactory academic progress policy to ensure that all notifications are completed as required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

Due to staff turnover, additional training was provided to the person that prepares the MOE. FY25 MOEs are complete. The DOE contacts us if they are completed incorrectly. The DOE did not have any issue with the FY25 report, and all grants have been approved.

Economic Development Cluster – Assistance Listing No. 11.307 Recommendation: We recommend the College strengthen its process for obtaining certified payrolls and implement procedures to ensure timely receipt, review, and documentation of these reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A process workflow has been developed to ensure that the certified payroll reports are requested and reviewed monthly prior to paying the monthly invoices or pay applications to the contractor. Name(s) of the contact person(s) responsible for corrective action: Saundra Buchanan and Sam Draper Planned completion date for corrective action plan: 7/28/2025