Corrective Action Plans

2025-003: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV Student Financial Aid for ten out of twenty-five students tested until after 45 days when the student ceased attendance. We consider the untimely calculation and Return of Title IV Student Financial Aid to be a material weakness relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan The weekly Official Withdrawal report is reviewed and processed by the Assistant Dean. As applicable, a week after the calculation is performed and funds are returned to DOE, each student recorded is reviewed on the Common Origination and Disbursement (COD) site to ensure that funds were returned. This additional step is conducted monthly by members of the Financial Aid Management and student worker teams. Additionally, the Assistant Dean performs a monthly check of the Official Withdrawal report to ensure that the Return to Title IV calculation was performed for all required students. The review includes viewing the record in Colleague as well as COD. Responsible Person for Corrective Action Plan Yvette M. McGhee Assistant Dean of Financial Aid Implementation Date of Corrective Action Plan The Correction Action Plan was implemented at the beginning of the Fall 25 semester (approximately August 15, 2025)

Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College is in agreement with the finding. At the time of noncompliance in this area the college was transitioning to a new software system for the college. The software was required to “go dark” for a period time and during this time no processing could be completed. Because of other issues with the system, the R2T4 timeline for returning the funds was not calculated correctly and the deadline was missed by a few days. Administration did not realize the error until after the deadline had passed. As soon as the error was found, the process was completed immediately. We do not expect to have this issue in the future. The R2T4 process for review has always been that one person in the financial aid office is responsible for completing the process and another person reviews the documents once the process is complete. We will continue this process and look for other procedures to implement to ensure an accurate R2T4 process is completed.

To the Department of Housing and Urban Development, During the audit of the Housing Authority’s fiscal year ended June 30, 2025 financial statements, it was determined that the unaudited financial data schedule that is utilized as the Housing Authority’s underlying financial statements were not properly stated. Significant errors existed regarding grant receivables, the allowance for doubtful accounts - tenants, capital assets, accounts payable, grant revenues and bad debt expense. Also, a desk review was performed by HUD and it was determined that the Housing Authority had not properly documented its calculation of monthly voucher leased amounts and it understated its Housing Assistance Payment expenses in its VMS reporting. The Housing Authority’s Executive Director, Ashiya Hawkins, is responsible for implementing the corrective action plan. Finding 2025-002 - VMS Reporting Deficiencies We concur with the recommendation and we will establish standard operating procedures that ensure that the HAP amounts and number of vouchers stated on the VMS report are both accurate and properly documented. We are working with our software provider to ensure that VMS reporting software is being fully and correctly utilized. We are also planning on additional training for HCV employees to make sure they are qualified to meet VMS reporting and documentation requirements.

3/20/2026 Community Action Team, Inc. respectfully submits the following corrective action plan for the year ending June 30, 2025. Kern & Thompson, LLC: Audit period: July 1, 2024 to June 30, 2025 The finding from the schedule of findings are discussed below. FINANCIAL STATEMENT FINDINGS 2025-001 Federal Award Special Reporting Federal Funding Accountability and Transparency Act (FFATA) Material Non-Compliance and Material Weakness in Internal Controls over Compliance (Repeat of finding 2023-003, 2024-002) Recommendation: The Organization should establish written policies and procedures regarding review of grant agreements for compliance requirements along with written policies and procedures for first-tier subawards including tracking and proper internal control procedures. Action Taken: Management concurs with the finding and has defined corrective action to address it. We understand a material weakness is identified in the internal control over special reporting. We have identified gaps in our reporting processes and worked to implement changes to ensure compliance with special reporting requirements. The responsibility for reporting under the Federal Funding Accountability and Transparency Act (FFATA) will be within the Fiscal Department. Policies and procedures will be updated regarding special reporting requirements. The Fiscal department will also be responsible for reviewing all contracts to identify all compliance requirements. Tracking procedures will be implemented to ensure reports are filed timely. The above identified corrective action was implemented in July 2024 and subsequent filing for 2025 and 2026 are compliant. Stacey Wilson, Fiscal Director, has implemented a tracking system for the FFATA. Should you have any questions regarding this plan, please contact me at 503-366-6563. Sincerely, Daniel Brown Executive Director

CORRECTIVE ACTION PLAN March 18, 2026 Housing for Rockdale Elders, Inc. respectfully submits the following corrective action plans for the year ended October 31, 2025: Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street Suite 1200 Braintree MA 02184 Audit period: November 1, 2024 - October 31, 2025 The findings from the October 31, 2025 schedule of findings and questioned costs is discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding 2025-003 - Eligibility - Material Weakness Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by HUD. Action Taken: Management agrees with the finding and is in the process of revising internal controls to address this issue.

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Refugee and Entrant Assistance – Assistance Listing No. 93.566 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: SCDSS will collaborate closely with SCDHHS to ensure eligibility policies and procedures for the Refugee Medical Assistance (RMA) program clearly and accurately define program eligibility requirements. SCDSS will also ensure that staff responsible for processing RMA applications receive appropriate training to apply these policies consistently and correctly. To support ongoing compliance, SCDSS will implement a quarterly monitoring plan designed to identify any individuals incorrectly categorized under RMA. SCDSS will maintain continuous communication and follow-up with SCDHHS to verify timely implementation of these corrective actions and to address any issues that arise. Anticipated Completion Date: July 1, 2026 Names of the contact persons responsible for corrective action: • Ambrea Jones, State Refugee Coordinator at 803-898-7303 • Brittney White, State Refugee Health Coordinator at 803-898-7545

Reference Number: 2025-020 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: Foster Care – Title IV-E Assistance Listing Number: 93.658 Award Number and Year: 2401VTFOST (10/1/2023 – 9/30/2025) 2501VTFOST (10/1/2024 – 9/30/2026) Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend that the Agency review and enhance procedures and controls to ensure that it correctly identifies the eligible federal program for all cases coded in CDDIS. We further recommend that children on whose behalf payments are charged to Foster Care are eligible for benefits under the program. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Agency will work with the IT systems of both the Family Services and Child Development Divisions to ensure that accurate eligibility information is shared between the systems. This will include: 1. What program each child is eligible for, adoption or foster care 2. The accurate start and end dates of eligibility 3. Any changes to eligibility during the life of a case The staff from Family Services will ensure that all Title IV-E eligibility information is shared with IT as they create the processes to share that information with the Child Development Division. The staff at the Child Development Division will work with their IT vendor to ensure all updates are completed and tested to ensure that Title IV-E funds are being claimed appropriately. Scheduled Completion Date of Corrective Action Plan: The underlying work to clarify the eligibility information needed has already begun and the process of updating the IT systems on both the FSD and CDD sides will be completed by April 1, 2026. Contacts for Corrective Action Plan: Heather McLain, Revenue Enhancement Director, Family Services, heather.mclain@vermont.gov Brenda Hallock, Revenue Team Lead, Family Services, brenda.hallock@vermont.gov Karolyn Long, Operations Director, Child Development Division, karolyn.long@vermont.gov Ed Dwinell, Financial Director, DCF Business Office, ed.dwinell@vermont.gov Peter Moino, AHS Director of Internal Audit, peter.moino@vermont.gov

Reference Number: 2025-019 Prior Year Finding: 2024-020 Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: CCDF Cluster Assistance Listing Number: 93.575, 93.596 Award Number and Year: 2401VTCCDD (10/1/2023 – 9/30/2026) 2501VTCCDD (10/1/2024 – 9/30/2027) Compliance Requirement: Special Tests and Provisions – Health and Safety Requirements Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend that the Agency review and enhance training monitoring procedures and controls to ensure that all child care providers complete required health and safety training. The Agency should update its training content to include all required elements and ensure that provider corrective action plans and documentation are properly maintained. Site visit documentation should clearly indicate the results of training requirement monitoring. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: DCF-CDD continues their rule revision process and now has the added support of a project manager and legal counsel. The revision process has been rigorous, and the rules have undergone several drafts. The public has had another opportunity to provide feedback on the latest draft prior to the formal promulgation process. Additionally, CDD received technical assistance from our federal partners to ensure our rule revisions met all CCDF requirements and will continue to refer to this document as we move the rules towards promulgation. The proposed rules will address the findings documented in this audit related to the federal requirement that pre-service orientation includes the required eleven (11) healthy and safety topics which staff will be required to complete, “before being left alone with children, counted in staff to child ratios, or within one (1) month of starting employment, whichever comes first.” DCF-CDD submitted an RFP for a new pre-service orientation training to include all the required health and safety topics that must be covered within the first month of employment. CDD will continue to work with the apparent successful bidder to ensure these modules are available to the field in 2026. DCF-CDD licensing unit will review the results of the single audit with licensing staff and our partners at Northern Lights at CCV (NL). CDD will begin a shift in our site visit preparation process that includes NL providing the division with a complete list of staff who have and who have not completed the required number of annual training hours. CDD licensing will document deficiencies in site visit reports and will require a plan from the providers to come into compliance. Scheduled Completion Date of Corrective Action Plan: DCF-CDD anticipates the licensing rules will be submitted to ICAR on February 20, 2026. This date may need to shift dependent on legal counsel’s final review of the rules and the weeks needed to prepare the documents required at this stage in the promulgation. CDD will be provided with a promulgation timeline which we aim to have completed before the end of 2026. DCF-CDD will seek outside contractual support to develop guidance manuals and training for the field on the rule changes, which includes shifts in required pre-service orientation topics. DCF-CDD pre-service orientation modules are scheduled to be completed within six (6)-nine (9) months from when the contract has been signed between the SOV and the apparent successful bidder. DCF-CDD will implement the site visit preparation practice shift by April-May 2026. This work requires NL staff to shift job responsibilities to accommodate the ongoing training review of the staff for all providers. By January 26, 2026, CDD director of child care licensing will meet with the licensing supervisors to review the results of this audit, review the CAP, and establish a plan for supervisory oversight at it relates to licensors documenting training deficiencies when conducting site visits. By January 27, 2026, CDD director of child care licensing will meet with the licensing unit to review the results of this audit, review the CAP, discuss the shift in site visit preparation practice as we partner with NL who will be reviewing compliance with annual training hours, and discuss the expectations around how deficiencies must be documented in annual site visit reports. Contacts for Corrective Action Plan: Beth Maurer, Director of Child Care Licensing, elizabeth.maurer@vermont.gov Kelly Lyford, Licensing Supervisor, kelly.lyford@vermont.gov Janet McLaughlin, CDD Deputy Commissioner, janet.mclaughlin@vermont.gov Dawn Rouse, Director of Statewide Systems, dawn.rouse@vermont.gov Peter Moino, AHS Director of Internal Audit, peter.moino@vermont.gov

Reference Number: 2025-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: National Infrastructure Investments Assistance Listing Number: 20.933 Award Number and Year: 69A36520401930BLDVT (8/1/2020 – 10/31/2026) CA0714 (4/29/2022 – 4/29/2032) CA0751 (5/1/2023 – 10/1/2028) CA0906 (1/24/2025 – 11/1/2030) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend the Agency review its procedures and internal controls to ensure that subawards are reported timely and accurately to SAM.gov in no later than the end of the month following the month of issuance or modification. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: VTrans will update procedures to ensure compliance with the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements. As part of this update, the Agency will review the current reporting workflow and clearly define roles, responsibilities, and timelines for FFATA reporting. The updated procedure will include guidance for identifying reportable sub-awards, collecting required data elements, and entering information into the appropriate federal reporting system within the required timeframe. Scheduled Completion Date of Corrective Action Plan: June 30, 2026 Contacts for Corrective Action Plan: Diane Bigglestone, Financial Director, diane.bigglestone@vermont.gov

Reference Number: 2025-006 Prior Year Finding: 2024-008; 2023-005; and 2022-012 Federal Agency: Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) 24A55UI000063 (10/1/2023 – 12/31/2026) UI370952155A50 (9/1/2021 – 5/22/2025) 23A60UB000019 (8/3/2023 – 5/22/2025) 23A60UB000024 (4/1/2023 – 5/22/2025) 24A60UD000052 (8/20/2024 – 8/20/2027) UI347462055A50 (8/20/2024 – 8/20/2027) 23A60UD000013 (7/14/2023 – 7/14/2026) 25A60UD000067 (10/1/2024 – 9/30/2027) Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Recommendation: We recommend that policies and procedures be implemented to ensure that all reports are reviewed by an authorized State official prior to submission and that supporting documentation providing evidence of supervisory review is maintained and available for audit. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: These reports are filed by our Labor Market Information division on behalf of the UI Division. The LMI employee responsible for these reports takes the data from a server/system generated report and enters it into a federal reporting system. Department will review internal controls and update as necessary to ensure that all required reports are filed timely and accurately and that reports are reviewed and approved by authorized State officials prior to submission. From now on the employee responsible for these reports will have their immediate supervisor review both reports to certify and signoff that the submitted report matches the system generated report and that they were submitted timely. Scheduled Completion Date of Corrective Action Plan: March 31, 2026 Contacts for Corrective Action Plan: Kristine Murphy, Director, Unemployment Insurance, kristin.murphy@vermont.gov Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

Reference Number: 2025-004 Prior Year Finding: 2024-004 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT402513 (10/1/2023 – 9/30/2024) 4VT433933 (10/1/2023 – 9/30/2026) 4VT437533 (10/1/2023 – 9/30/2025) Compliance Requirement: Special Tests and Provisions – ADP System for SNAP Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend that the Agency review and enhance procedures and controls to ensure that eligibility case reviews are performed timely, accurately, and are properly documented. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: A majority of the findings from the 2025 audit predate the completion of corrective actions associated with Audit 2024-004. Because the corrective action completion date was April 18, 2025, these issues resulted in repeat findings related to supervisory case reviews. To address this, the 3SquaresVT Food and Nutrition Team will review the findings with ESD Operations and present examples, along with refresher training on the Supervisor Case Review (SCR) process, at the District Directors Meeting on February 11, 2026. In addition, a new column will be added to the SCR tracking spreadsheet to allow supervisors to document the date corrective actions were completed when revisions are required following a review. The refresher training and the updated SCR tracking spreadsheet are expected to prevent the recurrence of these findings during the 2026 Single Audit. Scheduled Completion Date of Corrective Action Plan: February 11, 2026 Contacts for Corrective Action Plan: Jessica Duranleau, ESD Program Manager, jessica.duranleau@vermont.gov Leslie Wisdom, Food and Nutrition Program Director, leslie.wisdom@vermont.gov Peter Moino, AHS Director of Internal Audit, peter.moino@vermont.gov

2025-001 Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2019 Grant Award Number: INFRALUL-5459(031) Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Management’s Response: We concur. Views of Responsible Officials and Corrective Action: During most of the fiscal year (July through April), the City monitored certified payroll reports (CPRs) monthly as part of its construction oversight procedures. Documentation of this monitoring was maintained through email communications and supporting records. In April 2025, following the FY24 Single Audit, the City evaluated its procedures and implemented enhanced controls to better align with federal requirements by requiring weekly monitoring and tracking of CPR submissions. These enhanced procedures were implemented to strengthen internal controls over compliance with federal prevailing wage requirements. Beginning in May 2025, CHA Consulting (formerly Falcon Engineering), the City’s outside consultant, began providing a weekly certified payroll tracking spreadsheet and the requested payroll documentation for selected contractors to the City’s Project Manager for review. The City documented the receipt, review, and follow-up actions through email correspondence and maintained supporting records of these activities. In addition, Public Works staff and the City’s consultants responsible for contract administration and labor compliance monitoring were provided updated guidance regarding federal prevailing wage requirements, including the requirement for weekly certified payroll submissions and documentation of review. Project Manager oversight was incorporated into the process to verify the accuracy of the certified payroll tracking log and ensure that reviews are performed consistently. This oversight provides an additional level of verification that monitoring procedures are conducted in accordance with federal requirements. Although the City enhanced its monitoring procedures, contractors and subcontractors did not always submit certified payroll reports within seven days as required under 29 CFR §3.4. The City continues to reinforce timely submission requirements with contractors and monitors compliance through the weekly tracking process. When certified payroll submissions are not received within the required timeframe, the City follows up with the contractor requesting immediate submission and documents the corrective actions taken. The City remains committed to strengthening its monitoring procedures to ensure timely submission, tracking, and documented review of certified payroll reports. In the event of payroll delinquencies, the City will take appropriate follow-up actions with contractors and may withhold progress payments when necessary to enforce compliance. In addition, the City is implementing new contract provisions in federally funded Public Works contracts to establish clear authority and enforce compliance with federal labor standards. These provisions include: • Requiring weekly certified payroll reporting in accordance with federal regulations • Authorizing the withholding of progress payments for non-compliance • Requiring contractors to communicate labor compliance requirements to all subcontractors • Requiring the use of electronic certified payroll reporting systems, where applicable • Allowing the City to conduct payroll audits and worker interviews as permitted under federal labor compliance regulations These contract provisions are intended to further strengthen the City’s internal controls and ensure compliance with federal prevailing wage requirements on federally funded projects. The City will continue to monitor the effectiveness of these procedures and will update its internal controls as necessary to ensure ongoing compliance with federal labor compliance requirements. Name of Responsible Person: Jennifer Hennessy, Director of Finance Projected Implementation Date: 6.30.2026

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 HANAC, Inc. and Affiliates (HANAC) respectfully submits the following corrective action plan for the year ended June 30, 2025. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 The finding from the June 30, 2025 consolidated and combined schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None reported. FINDINGS – FEDERAL AWARD PROGRAMS AUDITS Material Weakness FINDING 2025-001 Eligibility U.S. Department of Housing and Urban Development 14.157 Supportive Housing for the Elderly Section 202 Loan Condition: During our testing, we noted that the income verification of tenant eligibility through Enterprise Income Verification (“EIV”) system was not performed timely. Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: Management agrees with the recommendation and has begun to implement the following: • A checklist form will be completed for every certification and signed off once file is approved. • An AR form will be created for the move in, transfer and move out process which is to be attached with proof of payment. Once completed it is to be sent to senior staff for review. • The file setup format and recertification updates will be monitored on a monthly basis. • EIVs are being run according to the frequency provisions related to the type of reports we are annually required to complete as per HUD. • Annual inspections are being scheduled as per Annual Recertifications are being processed. • Bi-weekly meetings will be in place to discuss the results collected with a tracking log on the progress of the project. • Trainings will be scheduled to keep on top of HUD updates/compliance procedures; Yardi software trainings; and in-house trainings covering compliance with the files and Yardi 50059 module. Expected completion date: 07/31/2026 If any cognizant or oversight agency has questions regarding this plan, please call Lola Maroulis, Chief Financial Officer at 212-840-8005, extension 111. Sincerely yours, Lola Maroulis, Chief Financial Officer

Audit Finding Reference: 2025-001 Improve Oversight Over Period of Performance of Federal Awards Planned Corrective Action: To address the material weakness regarding the period of performance, the Longmeadow Public Schools will implement the following actions: Procedure Revision: The Longmeadow Public Schools will update internal control procedures to require that all invoices charged to federal grants explicitly state the dates of service. Staff pro-cessing invoices against Federal grant funds will be instructed to verify these dates against the au-thorized period of performance listed on the Grant Award Notification before processing payment. Staff Training: The Town will conduct mandatory training for the Special Education Department and central office administrative support staff. This training will focus on 2 CFR §200.309, specif-ically emphasizing that costs are only allowable if incurred during the approved budget period, re-gardless of when the invoice is received or paid. Name of Contact Person: Thomas Mazza, Assistant Superintendent for Finance and Operations, Longmeadow Public Schools, tmazza@longmeadow.k12.ma.us Completion Date: Prior to July 1, 2026

Altus Public Schools' Construction Project Manager and Architects have included Davis Bacon requirements in all bid packages for ongoing projects to ensure the required documentation is being provided and met.

Finding Reference: 2025-005 - Cash Management (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director - Student Financial Services & Scholarships (Letherio.h.zeigler@jsums.edu) Corrective Action Planned: During the 2024-2025 award year, there was a change in leadership within the financial aid department near the end of 2024 that disrupted the normal process of reconciliation of funds to be disbursed which caused the delayed drawdowns that were outside the scope of compliance regarding allocation of funds towards student accounts. The Executive has developed a timely process of reconciliation that is in line with federal regulations to ensure that funds will drawdown timely as well as the institution has gone voluntarily to a system with COD in which drawdowns will not occur until COD receives approved response files for Federal Pell grant and Student Loans to ensure there is no delay in drawdowns. Estimated Completion Date: August 1, 2026 Finding Reference: 2025-005 - Cash Management (USM) Responsible Official: Erica Kennedy, Associate Vice President for Research (Erica.kennedy@usm.edu) Corrective Action Planned: USM acknowledges the finding related to cash management timing requirements under 2 CFR §200.305(b). To address the root cause and ensure ongoing compliance, USM will implement the following corrective actions: 1.Maintain standard monthly draw schedule. a.USM has returned to the standard monthly draw schedule, which aligns with the institutional accounting close timeline and supports accurate, reconciled requests. b.This schedule is now designated as the required default for all TRIO drawdowns, and deviations will not be permitted except in documented emergency situations approved at the VP level. 2.Reinforce internal controls linked to monthly draws. a.Existing internal controls, including pre-draw reconciliation, multi-level review, and validation of current/month expenditures, remain in place and are explicitly tied to the monthly schedule. b.Any proposed changes to the draw frequency must undergo formal written approval, including documentation explaining the reason for change and a review of associated compliance risks. 3.Monitoring a.For the next two quarters, the AVPR will conduct spot checks to confirm continued adherence to the monthly schedule and compliance with standard reconciliation procedures. Estimated Completion Date: Corrective actions are completed. The standard monthly draw process was reinstated and fully implemented, effective April 2025.

FINDING 2025-007 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The district will strengthen internal controls for ensure that all documentation are obtained from the Non- Pubs and filed accordingly in the Federal Department Office. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The district will implement strengthen internal controls to ensure of that exit conference for each student withdrawal will be held and all documentation will be files. All documents will be scanned to student software. All students will be properly document to the state and local entities. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Technology Director or assigned State Reporter will supply the Title I Director and Food Services Director with rosters reports from our SIS system prior to the certification of the October 1 count each year. Applications on file will be reviewed for accuracy and updates to our SIS will be made checking for accuracy. These reports will be retained for audit purposes and used by the Grant Coordinator to determine that enrollment numbers in the Title I application have been populated correctly. The Title I Director and Food Services Director will both sign off on this document. Anticipated Completion Date: September 2026

FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies - Internal Controls over Compliance – Assessment System Security Summary of finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Assessment System Security compliance requirement. Contact Person Responsible for Corrective Action: Julie Cramer Contact Phone Number and Email Address: 765-932-4186, cramerj@rushville.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: The Corporation’s Testing Coordinator will reiterate to our STCs in our buildings to make sure new hires are given the Test Security and Integrity sheets and follow our internal monitoring protocols to ensure that the appropriate people are trained by initialing the staff sign-in sheets verifying that the attendance information was reviewed for accuracy. These reminders for the STCs will come at least twice a year: Once in the fall before all testing begins and again in the spring before the summative tests begin. Anticipated Completion Date: March 3, 2026

The District has historically managed our Title I grant as supplemental funding and has a methodology for allocating local funds to schools without regard to whether they receive Title I funds. During fiscal year 2025, the district developed procedures to document our process, however the methodology was not included. The District will update the written procedure with the methodology to be in compliance with the Title I Supplement, Not Supplant requirement.

Recommendation: We recommend that the School implement procedures and controls to ensure the required reports are accurate and completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management has contracted with an outside firm to assist with developing the required Internal Controls and Processes with an estimated completion date of December 31, 2026. Name(s) of the contact person(s) responsible for corrective action: Mary Hunt, CFO. Planned completion date for corrective action plan: December of 2026.

Recommendation: The school should strengthen its documentation retention and record management procedures to ensure that all transactions included in audit populations—regardless of fiscal year—are readily available and adequately supported. Management should also implement controls to verify that supporting documentation is complete and accessible prior to submission for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management has contracted with an outside firm to assist with developing the required Internal Controls and Processes with an estimated completion date of December 31, 2026. Name(s) of the contact person(s) responsible for corrective action: Mary Hunt, CFO. Planned completion date for corrective action plan: December of 2026.

Recommendation: We recommend that management review controls related to financial statement preparation review at the end of each period. Financial statement preparation should include a review of reconciliations and balances to ensure that financial statement line items are properly stated and classified. Internally prepared financial statements should also be thoroughly reviewed by members of the board and management outside the finance department on a periodic (monthly or quarterly). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management has contracted with an outside firm to assist with developing the required Internal Controls and Processes with an estimated completion date of December 31, 2026. Name(s) of the contact person(s) responsible for corrective action: Mary Hunt, CFO. Planned completion date for corrective action plan: December of 2026.

Finding 2025-004 Material Weakness – Eligibility Name of Contact Person(s): Lashonda Bacote and Latonya Chambers Management agrees with the findings. Recommendation: We recommend that the County abide by the State policies in terms of the frequency and amount of case reviews each month. We also recommend that policies and procedures are documented surrounding second party reviews and be reinforced to ensure that reviews are completed and followed up as necessary. Corrective Action: The Work First program has now implemented requirements that align with policy by ensuring a minimum review of 25% second party reviews are met monthly for all Work First cases. All reviews are documented in the Quality Control (QC) tool. The Assistant Director for QAT, will monitor monthly to ensure we meet the requirements. In addition, this tool is accessible to The Assistant Director for Work First, who will also monitor monthly and ensure that all benchmarks are met. 1. Review Process: • QAT Supervisor and Staff Development Specialist (SDS): 25% of all applications completed in the month, 25% of all recertifications completed in the month, and 25% of all employment services cases completed in the month. • Additionally, the Work First Cash Supervisor, Lead Worker, and Employment Supervisor will do monthly reviews to guarantee that we are above the 25%threshold. • During vacancies, Work First staff listed above will have increased cases to review. The QAT Supervisor will identify other staff to assist. The QAT Staff Development Specialist will train other SDS staff on WF policies and procedures by April 1, 2026. 2. Policy/Training: • Candice Leathers, Program Manager for QAT, reviewed the policy for the 25%threshold requirement for WF cases and reviewed the DSS ADMINISTRATIVE LETTER NO. ECONOMIC AND FAMILY SERVICES 7-2018 EFS_WF_AL-7-2018 Policy & Procedures with WF QAT Staff on both 09/04/25 and 10/9/2025.Implementation Date: Effective immediately and on-going.