Corrective Action Plans

Reporting Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN Office of Grants and Contracts Post-Award Management has advised the grant’s principal investigator (PI) that underlying documentations must match the data reported on the Annual Performance Reports submitted to the award sponsor. The CSN GEAR UP PI and GEAR UP First Year College Advisor have refined the reporting and record keeping process to ensure accurate reporting and supporting documentation is kept in compliance with the grant. The Senior Accountant of Grants and Contracts also reviews the data before each report is submitted to the sponsor. ● How compliance and performance will be measured and documented for future audit, management and performance review. CSN GEAR UP PI and GEAR UP First Year College Advisor will continue to ensure accurate reporting and supporting documentation is kept in compliance. CSN Office of Grants and Contracts Post-Award Management will continue to communicate with PIs to ensure all reports have been reviewed for adequate and accurate supporting documentation prior to submission to the sponsor. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Program Director, who is the Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) Principal Investigator (PI), is accountable for exercising oversight and responsibility. GBC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o Establishment of a formal review and approval workflow requiring secondary review by the Grants Office of participants numbers prior to submission of any financial or performance report. This will require: (1) Identification of the reporting period; (2) Review of all source documents supporting reported totals; and, (3) Mathematical reconciliation of reported figures o Training provided to grant program staff and administrative personnel on documentation standards and reporting accuracy expectations. o All corrective actions were implemented immediately upon identification of the finding and will be fully in place within 30 days of notification. The revised procedures are now standard practice for all grants reporting participant numbers. ● How compliance and performance will be measured and documented for future audit, management and performance review. o Reports may not be submitted to the pass-through entity without documented secondary review and written approval from the Grants Director or the Grant and Asset Coordinator. o Interim and final program reports will be reviewed to ensure: (1) Participant totals match underlying documentation; (2) Source documentation is retained and accessible; and, (3) Approval signatures are present prior to submission. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and the Director of Business Operations are responsible for oversight of grant compliance. NSU – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; NSU has reviewed the finding and has put additional measures in place to ensure compliance. Staff responsible for preparing reports were retrained and multi-layered quality checks have been implemented to safeguard integrity of data entered in shared databases. NSU’s multi-layered quality checks include written confirmations from staff involved in service activities and backup of documentation within NSU’s local storage to support the numbers being reported. The latter represents a move away from using a database that is accessible to multiple institutions to a centrally controlled location within NSU. This process outlined herein was implemented in August 2025 and ensures that the source documentation reconciles with reports and is available for auditing purposes. ● How compliance and performance will be measured and documented for future audit, management and performance review. To ensure compliance, NSU staff who are responsible for the program and technical reporting have reviewed and updated internal policies and procedures relating to reporting. Performance targets and benchmarks have been reestablished and will be measured at set intervals. Any errors detected will be documented and remedied. Additionally, errors will serve as the basis for continuous improvement processes and retraining as needed. These will be documented in performance reviews. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The NSU GEAR UP Principal Investigator and First-Year College Advisor Supervisor are responsible and accountable for ensuring reporting is supported by underlying records. TMCC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; TMCC reports on the number of participants for all services rendered under the GEAR UP grant through both the Interim Progress Report (IPR) and the Final Progress Report (FPR). The identified issue concerns a discrepancy between the reported participant count on the IPR and the underlying supporting records. To ensure data accuracy going forward, TMCC will implement an additional review of participant reporting. Prior to the submission of progress reports, a second technical reviewer within the GEAR UP team would verify the participant counts entered into GEARS (GEAR UP’s designated data-reporting platform) against the supporting documentation (the attendance sheet). Should a discrepancy be identified, the GEAR UP team will follow up with the individual responsible for the data entry on GEARS to reconcile the difference. This may include requesting correction of data entry errors or obtaining additional documentation to support the reported participant count, as appropriate. Additionally, attendance sign-in sheets will be collected and retained by TMCC staff to allow for direct verification prior to reporting. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured by the implementation of a second reviewer for the participant data reported through GEARS and included in the progress reporting. This review can be documented through an internal checklist, internal communication, or other appropriate records demonstrating that the participant data was reviewed and validated prior to the submission of progress reports. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Primary responsibility for accurate participant reporting will remain with the TMCC First Year College Advisor (FYCA) or other designated staff responsible for preparing grant performance reports. Responsibility for completing the secondary verification review will be assigned to a designated GEAR UP technical reviewer or program staff member who is independent of the initial data entry and report preparation. If repeat or similar observations occur, program leadership will evaluate adherence to established procedures and implement additional corrective actions, which may include staff retraining, revision of internal procedures, or reassignment of reporting responsibilities, as appropriate. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP will continue to work with PIs to ensure there is a documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. Additionally, if reports require financial expenditures, the Office of Sponsored Programs will require validation before submission. Communication dissemination will occur twice within the academic year. ● How compliance and performance will be measured and documented for future audit, management and performance review. UNLV OSP will continue communications through Research Weekly (an internal communication newsletter) to remind PIs to ensure timely submission of progress reports and retention of records such as, lab notes, testing, populations served, activities performed, etc. to demonstrate activities supported by the grant. UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with the applicable Deans. UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; All participant counts reported in Interim Progress Reports will be supported by retained underlying source documentation that directly reconcile to the reported totals. Standard documentation expectations and retention requirements will be communicated to program staff. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance will be measured through pre-submission review of reported participant data against underlying records and through post-submission spot checks conducted by Program Director. Documentation supporting reported counts will be retained in the official project file and made available for future audit, management review, and internal monitoring. Evidence of reconciliation will be documented via checklists or certifications retained with the report. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Program Director WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Sponsors have determined grant practices and required reporting documentation, which have not been consistently required or expected of subrecipients. WNC will maintain its own sign-in sheets and documentation for all grant-sponsored activities to ensure compliance with overall grant requirements. The corrective action was implemented in July 2025. ● How compliance and performance will be measured and documented for future audit, management and performance review. The GEAR Up coordinator will create and maintain sign-in sheets or other documentation for every grant-sponsored activity. The coordinator will maintain records in accordance with federal and state guidance and will ensure that supporting documentation is sufficient to support the reported figures. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Final responsibility and accountability fall on the GEAR Up coordinator and grant administrator. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP will continue to work with PIs to ensure there is a documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. Additionally, if reports require financial expenditures, OSP will require validation before submission. Communication dissemination will occur twice within the academic year. ● How compliance and performance will be measured and documented for future audit, management and performance review. UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with the applicable Deans. UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management staff, independent of preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion Context: The School Corporation did not obtain the weekly payroll reports certifications from a company that performed renovations to replace HVAC equipment and install windows in the building. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $696,118 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Nathaniel Day Contact Phone Number: 317-462-4434 . Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will comply with Bacon Davis on future projects using federal funds.

For the Year Ended June 30, 2025 Corrective Action Plan Finding 2025-002 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed completion date: Corrective actions for Finding 2025-005 also apply to State Award findings. Section IV - State Award Findings and Questioned Costs Taylor White and Michelle Ogle - Medicaid Supervisors Family and Children Leadership Training: On October 29, 2025, staff received training on self-employment income calculations, including guidance on interpreting tax forms. This training ensures caseworkers correctly document and budget income in the case files going forward. Adult Medicaid Leadership Training: On June 6, 2025, Adult Medicaid leadership conducted SSI Ex Parte training to reinforce policy requirements and timeliness standards for processing program changes. A follow-up SSI training was also held on July 15, 2025, to emphasize the importance of timeliness and policy compliance. Policy and Process Improvement Training: On December 18, 2025, Family and Children Leadership will conduct training on “Noncompliance with Program Requirements and Inadequate Requests,” focusing on online verification review procedures, appropriate notice requirements for undocumented aliens, and appropriate policy sections. This session will include time management training and the implementation of a timeliness checklist to improve case processing efficiency. Adult Medicaid Policy Training: By December 31, 2025, Adult Medicaid Leadership will conduct training covering appropriate policy sections including - Financial Resources verifications, income limit reduction rules, and Transfer of Assets verifications. Adult Medicaid caseworkers will also complete some online trainings and update the review documentation template to include the income limit reduction rules. These corrective actions are designed to strengthen staff knowledge of policy requirements, improve documentation accuracy, and ensure ongoing compliance with timeliness and program standards. All trainings and documentation updates will be completed by December 31, 2025. Section III - Federal Award Findings and Questioned Costs 159

FINDING 2025-002 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Wage Rate Requirements Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. Context: The School Corporation had one project for a bus garage addition that which was funded with ESSER III (84.425U) grant awards. The School Corporation did not execute a formal contract with the vendor as the transaction was under the simplified acquisition threshold of $150,000. As such, there was no internal controls to communicate required prevailing wage rate requirements to the vendor prior to entering into the transaction. The School Corporation did obtain the weekly wage reports from the vendor. The total project cost disbursed during the audit period was $88,727, which included materials and labor. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. We did not have a formal contract for this project. It was below a threshold that we had used before that necessitated a formal contract. We now understand that we should have gotten a formal contract in place because this is federal funding. We used the quotes that were provided, and the school board approved the expenditures at a school board meeting. In the future, we will secure a formal contract for all federal funds. Responsible Party and Timeline for Completion: Tara Bishop, Superintendent. Completed 3/1/24.

Finding 2025-007 Finding Summary: The OMB Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by applicable accounting or performance records, and are fairly presented in accordance with governing requirements. The annual reported cumulative expenditures were overstated by $464,672, current period obligations were overstated by $3,059,105, and the current period expenditures were overstated by $610,505. Responsible Individuals: Richard Braithwaite, City Manager Corrective Action Plan: Management understands the importance of correcting this deficiency. Management is working on controls to establish a secondary reviewer requirement. All annual reports must be verified against source documentation (receipts, payroll registers, and contracts) by a staff member independent of the original data entry process prior to reports being submitted. Anticipated Completion Date: June 2026

Material Weakness in Internal Control over Compliance and Compliance 2025-002 Special Tests and Provisions. Criteria The District is required to maintain records that support the removal of a student from the adjusted cohort, such as documentation to transfer to another diploma granting program, emigration, consistent with federal reporting requirements. Statement of Condition We identified instances in which the District had students removed from the adjusted cohort, but did not maintain sufficient written documentation to support the removal. Statement of Cause The District did not have adequate procedures to ensure that the documentation supporting adjusted cohort removals was obtained, reviewed, and retained. Possible Asserted Effect Without appropriate documentation supporting removal of students from the adjusted cohort, the District is unable to demonstrate compliance with federal record keeping requirements. Questioned Costs None noted. Context A sample of 25 students that had withdrawn was selected and 3 student files were not able to be provided. Repeat Finding: This is not a repeat finding. Recommendation We recommend that a process be implemented to ensure appropriate written documentation is maintained for all student withdraws. Views of responsible officials and planned corrective action To ensure compliance with this standard in the future, we have created a specific folder within our Student Information System for uploading and maintaining all withdrawal paperwork. All staff responsible for processing withdrawals have received instructions for this updated procedure via email and the guidance has also been added to the Secretary’s Manual.

Condition: The College did not send out the post-disbursement email notifications to a group of students. Planned Corrective Action: While the University has documented procedures in place for the disbursement of federal funds and required post-disbursement notifications to students, the finding identified related to only students who received both a Federal PLUS loan and a Federal Direct Loan during 2025. University did not properly send a post-disbursement notification to 117 out of 247 students who received both a federal PLUS loan as well as a Federal Direct Loan on a specific date during fiscal year 2024-2025. The University will adjust its internal processes to ensure all students who receive federal loans are sent post-disbursement email notifications by performing a review of the IT system and working toward fully automated notification settings to ensure all students are captured in the post-disbursement notification process. Contact person responsible for corrective action: Leah Alderink, Director of Student Financial Aid Anticipated Completion Date: Immediately

Finding 2025 – 001: Restatement to Net Position for Capital Assets Condition: During audit fieldwork, our testing resulted in a restatement of net position in order to correct capital assets due to a new appraisal. Plan: The District implemented a new capital asset appraisal in order to have accurate historical records of all assets owned by the District. These schedules will be updated on an annual basis to reflect accurate reporting requirements. Anticipated Date of Completion: Fiscal Year 2026 Name of Contact Person: Kirsten Perkins, Director of Finance and Human Resource Management Response: The District implemented a new capital asset appraisal in order to accurately reflect historical asset detail. The District will work to update these schedules, including accumulated depreciation on an annual basis. 13

FINDING 2025-005 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls for reimbursement requests will include necessary documentation of expenditures from the accounting program attached to the reimbursement form for all grants. Each reimbursement request will be checked and approved by two school employees. The treasurer will keep the packet until funds are received and receipted and then the packet, with the receipt, will be filed in two places; the respective grant folder and in the monthly receipt folder. Anticipated Completion Date: 2/16/2026

FINDING 2025-003 Finding Subject: Title I Grants to Local Educational Agencies – Eligibility Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Due to continued turnover in the Title I administrator position, application details have not been mastered. The treasurer and current Title I administrator are continuing to learn the process through guidance from our DOE Title I specialist and what we have learned from this audit. We will continue to work together on applying for future Title I grants and for the necessary implementation of the current Title I grant. Internal control over the processes will be developed and implemented, and will be notated with a “reviewed by” signature and date. Anticipated Completion Date: 2/16/2026

Finding 2025 – 001: Restatement to Fund Balance/Net Position Condition: During audit fieldwork, our testing resulted in a restatement of fund balance in order to correct retainage payable and capital assets that were improperly recorded in prior years. Plan: The City will implement effective internal controls in order to provide an accurate assessment of reporting requirements. This implementation of improved controls would result in the appropriate recognition for financial reporting requirements Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Elizabeth Hannan, CFO/HR Director Management Response: Management acknowledges this comment and will work to implement and correct by the anticipated date of completion noted above.

Grant Accounting Finding 2025-006 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the administrative costs were appropriately billed as allowed under uniform guidance. Corrective Action Plan: CCSPM will adhere to uniform guidance specific to Administrative Expenses ensuring Administrative Expenses plus Indirect Expenses are no more than 10% of the total award over the grant period. Adherence will be monitored as part of an expanded monthly secondary review process across Continuum of Care grants. Responsible Individuals: Mary Ammer, Senior Director of Accounting and Finance and Grant Accountants: Jen Goeppinger and Ashley Feldick. Anticipated Completion Date: Adherence will be met by the end of the current grant period or end of FY26 (6.30.26), whichever is sooner for each currently active Continuum of Care grant.

FINDING 2025-002 Finding Subject: Title I - Annual Report Card Contact Person Responsible for Corrective Action: Phyllis Ritenour Contact Phone Number and Email Address: 317-205-3332 x 77218 pritenour@msdwt.k12.in.us Views of Responsible Officials: We disagree with the finding. Explanation and Reasons for Disagreement: In a sample of 15 students, only 3 did not have the requested supporting documentation for removal from the Cohort. As discussed with the auditors, registrars are required to remove students who are no longer in attendance at our schools within two weeks. Students without 50% attendance cannot be included in ME counts and therefore may not remain in the Cohort. Registrars make multiple attempts to obtain the reason documentation from parents when students are no longer in attendance. However, the district does not have the authority to compel parents to provide the requested documentation. INDIANA STATE

Finding 2025-007: Reporting Material Weakness/Noncompliance Special Tests and Provisions Management agrees with this finding. The required owner certified annual financial report for the Section 202 Capital Advance Program was not submitted to HUD within 90 days of fiscal year end because year end financial records were not completed in time. To prevent this from happening again, management will establish a simple year end reporting calendar, assign responsibility to a designated staff member to track HUD deadlines, and work more closely with the fee accountant to ensure financial information is completed earlier and ready for timely submission. These procedures will be in place for the next fiscal year end reporting cycle.

Finding 2025-006: Replacement Reserves Material Weakness/Noncompliance LHA agrees with this finding. While monthly replacement reserve reconciliations were being completed and reviewed, the review focused on making sure the ending balance matched and did not include a detailed review of the activity in the account. Because of this, multiple deposits were made in some months without being noticed. One replacement reserve payment was also mistakenly deposited into another program’s replacement reserve account. Although the fee accountant properly recorded this as money due back to Eastlawn East, staff did not identify that the funds had not yet been returned as of June 30, 2025. In addition, we were unable to locate documentation showing HUD approval for a $13,329.48 replacement reserve withdrawal. We understand that HUD approval is required for all withdrawals and that documentation should be maintained. To address this issue and prevent it from happening again we are updating procedures as follows Replacement Reserves: A spreadsheet is being made for each month for each account. LHA will keep track of the date each deposit for the Eastlawn and Eastlawn East Accounts are made and verify by a second party (one that does not do the deposit) that they are being placed in the correct account. Management will perform an additional review of replacement reserve activity each month. We are working with the other program to ensure the misapplied funds are returned to Eastlawn East. We will contact HUD to determine the appropriate next steps regarding the withdrawal without approval documentation and will ensure all future approvals are properly retained.

Condition: The City failed to file their CAPER within the 90 day reporting window. Planned Corrective Action: The City will ensure that all future reporting requirements under this program are met, including reporting deadlines. Contact person responsible for corrective action: Monique Guerrero Anticipated Completion Date: June 30, 2026

Condition: The City did not accurately prepare a SEFA that included all federal expenditures in fiscal year 2025, which resulted in a difference of approximately $7.6 million. Planned Corrective Action: The City will ensure that all future expenditures of federal awards are included on the SEFA by assigned staff to prepare and review the SEFA and track the amounts throughout the year. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2026

Condition: The City applied the same expenses to pass-through and direct funded awards, which resulted in reported quarterly reports and SEFA expenditures including approximately $2.7 million of expenditures that were being double counted. Planned Corrective Action: The City will ensure that all future expenses under this program are in compliance and under ARPA guidelines. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2026

Condition: The City initially reported $30,000 of expenditures on the SEFA that related to activity not related to fiscal year 2025. Planned Corrective Action: The City will ensure that all future expenses under this program are in compliance with CDBG guidelines. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2026

Responsible Person(s): Monique Majeus, Economic Assistance and Employment; Christie Bruce, TANF Consultant Corrective Action Planned: Change Request submitted to fix and implement the changes requiring correction in 2025. Estimated Completion Date: 11/25/2025

Responsible Person(s): Clara Harris, Chief Financial Officer/Fiscal Officer Corrective Action Planned: Review 2 CFR 200 § 200.430; send to all Program Area Directors to distribute to their staff. February 28, 2026, CFO/Fiscal Officer to disburse. Develop payroll cost allocation policy and plan for federally funded employees in accordance with federal guidance. Include method of allocation and how it is documented. Also develop monthly reconciliation to do reviews of payroll by March 9, 2026, and present for review. The Grant Manager, Finance Manager and Human Resource Manager (team) will create and review with CFO, CPO and Internal Auditor. Develop written procedures: March 16, 2026, team will write procedures to present to CFO, CPO and Internal Auditor for approval. Training to be held by March 31, 2026 for all program areas via in-person training or team meetings. Coding descriptions will be sent out to all program areas to ensure information of coding on system time sheeting is easily accessed by the employee. Implement plan: Time sheeting will commence in the system on April 10, 2026. Test the implementation: Review results with management. Audit reports to ensure compliance set forth in policy and procedures. May 1- 31, 2026, team reports findings to CFO, CPO and Internal Auditor. Estimated Completion Date: 5/31/2026

Workforce Investment Opportunity Act Cluster – Assistance Listing No. 17.258, 17.259, 17.278 Recommendation: We recommend that all grant reports are reviewed and approved by an individual knowledgeable of the program and the reporting requirements. It is recommended that this individual is not a subordinate of the individual preparing the reports. The review and approval should be formally documented and retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Fiscal Director has implemented a new process utilizing Adobe e-sign beginning with the current program year. All required reporting will be sent to the Programs Director through Adobe e-sign for her to review and initial. This process was started in September 2025 and the reviewed reports, along with audit trail reports, will be retained in the pdf format. Name(s) of the contact person(s) responsible for corrective action: DeAnn Bock Planned completion date for corrective action plan: Completed prior to audit – subscription purchased in September 2025. If the U.S. Department of Labor has questions regarding this plan, please call DeAnn Bock at 509-734-5944.

Finding 2025-001 - Material Weakness - Borrowings from Endowment Fund Condition Found: The College has borrowed from its endowment funds for campus renovations and to cover certain operating expenses of the College prior to and immediately following its accreditation and approval to participate in federal student financial aid programs. As such, the fair value of assets associated with the donor-restricted endowment funds has fallen below the level that the donor or UPMIFA requires the College to retain as a fund of perpetual duration. Corrective Action Plan: Antioch College obtained guidance from legal counsel regarding the appropriateness of borrowing from the endowment fund under Ohio UPMIFA. Borrowing from the endowment fund by Antioch College was approved by order of Judge Robert Hagler of the Probate Division of the Court of Common Pleas of Greene County, Ohio, in 2013, and Judge Hagler declared in the order the endowment loans “are prudent ‘investment decisions’ pursuant to Ohio Revised Code §1715.52.” [Antioch College Corporation, et al. vs. Antioch University, et al., Greene C.P. No. 10938MIS (Feb. 14, 2013)]. March 6, 2020 forensic audit of the endowment by CliftonLarsonAllen LLP, noted Antioch College has appropriately accounted for endowment transaction. Antioch College has developed long-term plans for maintaining and sustaining its financial stability through key strategies outlined in the board-approved Social Enterprise and Enrollment (SEE) Plan:  Investing in advancement capacity for increased revenue across all areas including annual giving, major gifts, grant income, and events  Identifying a core college footprint and reducing ongoing facilities expenses through building sale, investment, and/or long-term leasing, considering our needs today and in the future  Adjusting financial aid packages and increasing student-derived revenue  Investing in increasing admissions of new and varied students (UG, transfer, incarcerated, adult, visiting) from all religions, races, ethnicities, political ideologies, abilities, genders, gender expressions, sexualities, languages, countries of origin, nationalities, and retention of current students resulting in higher overall enrollment numbers  Adopting and implementing interdisciplinary curriculum pathways and generating these developments as noteworthy through strategic communications and highlighting our world-class faculty  Supporting learning hubs to sustain the cost of their operations through earned and philanthropic revenues, alongside contributing to college overhead  Working towards a sustainable cost structure and business model that keeps us from borrowing from restricted sources, strengthens our financial position, and enables us to begin repaying our endowment over time  Exploring, but not relying on, potential game changers, including the Federal Work College model, transfer pathways, prison education, and community-based learning Office of the President One Morgan Place Yellow Springs, OH 45387 Antioch College is seeing success with the SEE Plan. In 2024, Antioch College was designated a Federal Work College. Advancement continues to meet and exceed revenue goals, including the 2025 End of Year Campaign. Antioch College continues to reduce expenses by “right sizing” both campus footprint and staff, including the prior sale of the old Student Union and pending property sales in fiscal year 2026. Investments in enrollment are succeeding as demonstrated by the record (post 2011 reopening) Winter-term enrollment achieved in January 2026. As Antioch College continues to improve long-term financial stability, in December 2025, its Board of Trustees has established an Endowment Repayment Plan Working Group. The Endowment Repayment Plan Working Group is tasked with assessing and considering options for repayment of borrowed endowment funds, and then reporting back to the Finance Committee of the Board of Trustees. Person Responsible for Corrective Action Plan Implementation: Board of Trustees

Finding 2025-002 – Education Stabilization – Special Tests and Provisions - Wage Rate Requirements Context: The School Corporation did not obtain the weekly payroll reports certifications from a company that performed renovations to replace fan coil units and HVAC equipment in the building. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $119,190 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-766-2214 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Director of Business Affairs and Human Resources has reviewed the Davis-Bacon Act. We will collect weekly payroll documentation for any constructions projects where Federal Grant money is used. Anticipated Completion Date: February 2024