Corrective Action Plans

2. Finding 2024-002 Section 1A of the grant agreement requires that the Credit Union expend its CDFI ERP Award in eligible activities including providing financial products in low-or moderate-income majority minority census tracts that are also ERP-Eligible geographies. a. Action(s) Taken or Planned on the Finding Management agrees with the finding and has established procedures to identify eligible loans deployed in the eligible ERP-Eligible geographies. These loans will be reconciled to the underlying loan servicing systems. b. Implementation Date: Procedures were developed and implemented in June 2025.

Finding 2024-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Assistance Listing Numbers: 14.850 Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Selections from the Waiting List. The PHA must have written policies in its Admissions and Continued Occupancy Policy for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203(Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with certainty that new move-ins were selected from the wait list in an order that is in accordance with the Authority’s policy. Context: Two (2) names were selected from the new move-in list and those names were to be traced to the waiting list to verify new move-ins were chosen in an order that was in accordance with the Authority’s policy. It was determined that two (2) out of two (2) new move-ins selected could not be traced with certainty back to the Authority's waiting list Known Questioned Costs: $8,691 Findings – Federal Award Program Audit (continued) Finding 2024-003 (continued) Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to selections from the waiting list. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Public and Indian Housing Program is in material non-compliance with the special tests and provisions type of compliance related to selections from the waiting list. Recommendation: We recommend the Authority design and implement internal control procedures related to selections from the waiting list that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Public and Indian Housing Program and will implement internal control procedures related to selections from the waiting list that will ensure compliance with federal regulations. Ivy Melendez, Executive Director, will be responsible to implement this corrective action by September 30, 2025.

Finding 2024-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Enforcement. For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct all life threatening HQS deficiencies within 24 hours after the inspections and all other deficiencies within 30 days or within a specified PHA-approved extension. Condition: Based upon inspection of the Authority’s files and on discussion with management, the Authority did not properly abate or provide proper extension documentation for failed inspections selected for testing. Context: The Authority did not provide proper extension documentation or properly abate four (4) out of nine (9) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Known Questioned Costs: $9,282 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to HQS enforcement. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Voucher Program is in material non-compliance with the special tests and provisions type of compliance related to HQS enforcement. Findings – Federal Award Program Audit (continued) Finding 2024-005 (continued) Recommendation: We recommend the Authority design and implement internal control procedures related to HQS enforcement that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Voucher Program and will implement internal control procedures related to HQS enforcement that will ensure compliance with federal regulations. Ivy Melendez, Executive Director, will be responsible to implement this corrective action by September 30, 2025.

Finding 2024-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions - Reasonable Rent Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Reasonable Rent. The Authority must do the following: The Authority must determine that the rent to owner is reasonable at the time of initial leasing. Also, the Authority must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 5 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The Authority must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). Condition: Based upon inspection of the Authority’s files and discussion with management, there were newly leased units for which the evaluation of rent reasonableness was not performed. Context: There were approximately 6 newly leased units. Of a sample size of one (1) newly leased unit, one (1) unit's documentation of reasonable rent was not available for examination. Our sample size is statistically valid. Known Questioned Costs: $8,661 Findings – Federal Award Program Audit (continued) Finding 2024-004 (continued) Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to reasonable rent. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers program is in material non-compliance with the special tests and provisions type of compliance related to reasonable rent. Recommendation: We recommend the Authority design and implement internal control procedures related to reasonable rent that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers Program and will implement internal control procedures related to reasonable rent that will ensure compliance with federal regulations. Ivy Melendez, Executive Director, will be responsible to implement this corrective action by September 30, 2025.

Federal Award Finding: 2024-002 Material Weakness in Internal Control and Noncompliance – Allowable Costs/Cost Principles: Indirect Costs Name of Individual Responsible for Corrective Action: Sara Kinjo-Hischer, Tribal Administrator Corrective Action: Skagway Traditional Council will work closely with the contract accountant to ensure that indirect costs charged to each grant are within the grant’s budget and are in accordance with the terms and conditions of each grant award and with Uniform Guidance. Planned Completion Date: September 30, 2025

Finding 2024-001 – Rural Rental Assistance Annual Inspection Deficiencies: We concur with the recommendation and we will establish controls that ensure that annual inspections are performed at each Rural Rental Program property. This would include careful review by Housing Authority management of annual inspection files.

Condition: The Organization had a control in place to approve contractor expenditures prior to charging the expense to the Program; however, the control was ineffective and resulted in a cost being requested for reimbursement that had not been incurred by the Organization. Planned Corrective Action: The Organization will implement a mandatory documentation checklist, including verified contractor invoices and proof of service completion, prior to approving any expense charged to the Program. The Organization will adopt a two-level approval process- requiring sign-off by both the Program Manager and the Finance Department to validate incurred costs. Contact person responsible for corrective action: Kristen Miller, Director and David Anderson, Assistant Controller Anticipated Completion Date: August 2025

Condition: The Organization did not have a formal cash management policy in place for the period under audit. Planned Corrective Action: The Organization implemented a Federal Awards Administration Policy which includes a formal cash management policy in February 2025. Contact person responsible for corrective action: Valeria Watson Anticipated Completion Date: February 2025

Condition: The Organization had a control to review and certify the Financial Request for Payment; however, the control was ineffective and resulted in untimely submission of the request to the awarding agency. Planned Corrective Action: The Organization will revise its internal process to include a dual-review system. Two designated staff members will now be cross-trained and authorized to review and certify Financial Requests for Payment to ensure timeliness. A formal submission calendar will be developed, including internal deadlines that precede the agency's due dates by a minimum of five business days. Contact person responsible for corrective action: Jennifer Turner/Kristen Miller, Nurse Family Partnership Anticipated Completion Date: August 2025

n July 2024, the contracted community action agency assisted with drafting a new purchase order policy and began training on this to implement one department at a time. The new policy requires the use of a payment authorization form authorized by the program manager or the Executive Director to ensure that all expenses have documentation of review and approval prior to purchase.

Management of the School agrees with the findings and will work on increasing the number of board members and increasing the number of meetings. There are several individuals who periodically meet with management to review the activities of the School. These individuals have suitable management skills and knowledge of the School’s operations. Management has agreed to formally elect these individuals as voting members of the Board of Directors.

Management of the School agrees with the findings and will coordinate with the State of Florida, Department of Agriculture the repayment of the contractually non-reimbursable use of funds.

2024-004: Material Weakness and Noncompliance – Written Policies Required by the Uniform Guidance Statement of Condition/Criteria: The County does not have written policies and procedures to implement the requirements of 2 CFR section 200 for the administration of federal awards. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. Planned Corrective Action: County management will develop written policies and procedures for grants.

Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing Number: 10.766 Finding Summary: As a part of the audit process, a reclassification entry was made to move the funds from the cash sweep general fund to a separate bookkeeping account. Management did not track the funds in a separate bank or bookkeeping account throughout the year. The Hospital had excess cash available to cover the required reserve amount for the fiscal year. Responsible Individuals: Renae Karst, Chief Financial Officer Corrective Action Plan: Management will establish a separate bookkeeping account in the general ledger to establish the correct reserve amount of cash held within its general operating bank account. The separate bookkeeping account will be utilized throughout the year to ensure the reserve requirement is met. The reserve account will be part of total cash in the bank to maximize interest earned on the reserve balance. Anticipated Completion Date: October 1, 2024.

Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing Number: 10.766 Finding Summary: The Hospital does not have an internal control system designed to provide for a complete and accurate schedule of federal expenditures of federal awards being audited. Management requested the auditors, Eide Bailly LLP, to assist with the preparation of the schedule of expenditures of federal awards. Responsible Individuals: Renae Karst, Chief Financial Officer Corrective Action Plan: It is not cost effective to have an internal control system designed to prepare the schedule of expenditures of federal awards. We requested that our auditors, Eide Bailly LLP, to assist with the preparation of the schedule of expenditures of federal awards. We have designated a member of management to review the drafted schedule of expenditures of federal awards, and we have reviewed with and agree with the final Schedule of Expenditures of Federal Awards. A Grant Award Policy and Procedure Manual was implemented defining tracking and reporting of awards to ensure accurate and up-to-date communication of award requirements. This communication will include implementing additional processes to improve our internal controls over identifying and reporting of expenditures in compliance with the Schedule of Expenditures of Federal Awards (SEFA) if applicable. We will provide staff training annually for any updates or adjustments to the policy. Anticipated Completion Date: Ongoing

The Town has hired support for the Treasurer will allow more time to be spent preparing monthly and year end financial reporting, and subsequent audit preparation so that all are done in a timely manner and are more in alignment with the Uniform Guidance.

We have assessed the time requirements of the Treasurer position given the changes to the growing amount of funding sources the town now has and The Town has hired support for the Treasurer.  This will allow more time to be spent on obtaining the skills and knowledge necessary for proper recording and reporting as well as updating our procedures and our general ledger to better serve our reporting requirements.  We will also collaborate with our accounting firm on ways to improve and streamline our methods of accounting and grant reporting to further align with standards.

The Town feels that this is an isolated instances due to the increased funding during the year. Management has reviewed the accounting requirements and is confident that they can correct these deficiencies during the year.

Reference Number: 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Authority’s Response & Actions Taken The Authority has made considerable progress in addressing the backlog of annual re-examinations that resulted from the transition of a third-party contractor to new third-party contractors to administer its Project-Based and Tenant-Based Voucher Programs. The material weakness was further exasperated by tenants not responding to re-examination notices or failing to provide the required income and household documentation by established deadlines. In an effort to avoid unnecessary subsidy terminations and protect vulnerable tenants, the Authority’s administrative plan allows for extended grace periods and repeated follow-ups. While this tenant-centered approach helped mitigate adverse outcomes for families, it also contributed to delays and ultimately resulted in noncompliance with HUD’s timeliness requirements. The Authority recognizes the critical importance of conducting timely and accurate annual reexaminations to maintain program integrity, ensure proper subsidy determination, and remain in compliance with HUD regulations. With that said, the Authority continues to work diligently with its third-party HCV contractors, city department partners, onsite service providers and property management companies to ensure the Authority is timely recertifying all assisted households. Although the Authority has established procedures to initiate reexaminations 150 days in advance of their due dates, a significant portion of the delays cited in the recent audit were the result of tenant non-responsiveness—specifically, the failure to provide required documentation despite multiple notices and outreach efforts. Importantly, all overdue reexaminations identified during the audit were ultimately completed. Each of the affected households was determined to be eligible under HUD guidelines, and housing assistance payments (HAPs) were accurately processed based on verified household information. The Authority remains committed to its tenant-centered mission, which prioritizes preventing unnecessary subsidy terminations and supporting household stability. At the same time, the Authority fully recognizes the importance of complying with HUD’s reexamination timelines. The corrective actions outlined below are designed to ensure that tenant-related delays are minimized, documented, and managed in a way that prevents the recurrence of this material weakness. To address this finding and in accordance with the Authority’s Administrative Plan and HUD rules and regulations, the Authority has already implemented the following actions starting fiscal year 2023-24: • Initiating the Annual Re-examination process 150 days before the required anniversary date to give households more time to comply. • Reviewing the report of outstanding Annual Re-examinations on a weekly basis. • Scheduling additional partner calls with property management and resident services to assist non-compliant families. • Enforcing Annual Reexamination compliance through the Intent to Terminate process • Scheduling and completing on-site visits for senior-disabled sites and non-restricted sites with large numbers of families out of compliance. • Reviewing discrepancies between the Authority’s System of Record and PIH Information Center, the official database of HUD. Per CFR 24 985.3, Section 8 Management Assessment Program (SEMAP) Indicator 9 for Annual Reexamination, 95% of all households must be recertified within 14 months of their last annual recertification to maintain full compliance, and 90% of all households must be recertified within 14 months to maintain partial compliance with the SEMAP Assessment standards required by HUD. The Authority expects to hit 90% by the end of the SEMAP year September 30, 2025. Anticipated Implementation Date September 30, 2025 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations

2024-008 Material Weakness and Noncompliance, Reporting Audit Finding: The Town improperly included encumbrances in expenditures on one of four quarterly reports due to a lack of understanding of reporting requirements (ARPA). Corrective Action Taken: We agree with this finding and will not include encumbrances in expenditures for these purposes going forward. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

2024-006 Material Weakness, Reporting Audit Finding: Per terms and conditions of the award, Local Education Agencies (LEAs) must report annually on activities funded by the ESSER funds, and the Connecticut Department of Education utilizes the Electronic Grants Management System (eGMS) to collect this reporting. The Town did not have documentation to support review of the annual report before submission. Corrective Action Taken: We agree with the finding and will review the annual report before submission going forward. This will be overseen by the BOE Director of Finance. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

Finding Number: 2024-002: Allowable Costs – 19 out of 38 samples were not 100% charged to the grant and/or were not supported by a cost allocation plan for how the percentages charged to the grant were determined. This issue was previously identified and remained unresolved at the time of this audit because the finding and subsequent corrective action was implemented after the end of this fiscal year, following the timing of the last single audit. Planned Corrective Action: The Turning Point has updated the existing cost allocation plan and the appropriate staff have been trained on the updated plan. Monthly reviews with the Executive Director have been implemented to review monthly reconciliation statements and grant invoice statements. Cost allocation calculations are now kept on file to document how the allocation was determined. We have also established and maintained a more robust allocation process to include updated Allocation Tables and Grant Ledgers to eliminate future errors. Completion Date: October 1, 2024 Responsible Contact Person: Tana Rice, Director of Finance

Finding Number: 2024-001: Allowable Costs – 2 out of the 38 samples tested included charges that were either unsupported or refunded back to the Organization and not corrected to return those funds to the grantor. Planned Corrective Action: The Turning Point has updated policies that include a process for managing refunds and crediting them back to grants. We also updated our Expense Reimbursement and Credit Card policies in 2024 to simplify our payment process which includes both the Finance Director and Executive Director checking all expenses have the proper documentation prior to paying the statements/invoices and submitting to payors (funders) for reimbursement. Completion Date: June 1, 2025 Responsible Contact Person: Tana Rice, Director of Finance

Condition: The Board could not provide a copy, with supporting documentation, of the annual required information submission to the Alabama Department of Education for the federal program. Planned Corrective Action: The Board will keep a copy of all annual required federal programs submission and supporting documentation to the Alabama State Department of Education. Anticipated Completion Date: Effective immediately Point of Contact: Gwendolyn Rogers

Condition: Construction contracts for three federally funded projects did not include the required prevailing wage rate clauses. Monitoring for compliance with the prevailing wage requirements was not performed by the Board. Planned Corrective Action: Going forward, all federally funded construction projects will include the prevailing wage rate clauses. The Board will monitor for compliance with the prevailing wage requirements. Anticipated Completion Date: Effective immediately Point of Contact: Dr. Timothy Thurman