Corrective Action Plans

The Department will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

The College will retain all procurement documentation going forward..

The Department has hired a new audit firm that specializes in the audits of Tribes. Our new audit firm has demonstrated a commitment to allocating the necessary resources to complete our audits in a timely manner.

The College has spent a significant amount of time in FY 2025 evaluating their IT controls and policies, and procedures. New internal controls are expected to be implemented to address these findings.

Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Tyler Martin, Executive Director, is responsible for implementing this corrective action by December 31, 2025.

Action Taken: Stoneleigh Housing, Inc. agrees with the finding. The Board of Directors will be issuing a formal policy concerning fiscal management and responsibility. The Board of Directors has also approved and hired an independent booking keeping firm to alleviate the burden of staff training for fiscal matters.

Action Taken: Stoneleigh Housing, Inc. agrees with this finding and the Board of Directors will issue a formal written fiscal policy and has hired an outside bookkeeping firm to handle fiscal matters, inclusive of monthly bank reconciliations for all bank accounts.

Corrective action planned: Department managers and others involved in grants will be educated on the importance of understanding the types of grants they are requesting or receiving including any reporting requirements. Accounting staff will assist with the matching of grant revenues and expenses to verify that they are appropriate and in the correct accounting period. A procedure will be implemented to ensure that at year-end, all grant revenues and expenses are double-checked to verify they are posted in the correct period. Anticipated completion date: July 31, 2025 Contact person responsible for corrective action: Steve Lindemann, Interim CFO

2024-001 - (Noncompliance) Uniform Guidance Written Policies/Procedures Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758 Condition/Context: While the Organization has informal policies and procedures surrounding the administration of its federal programs, these policies and procedures have not been formally documented to ensure compliance with the areas of allowability of costs, cash management, procurement, travel, conflict of interest or subrecipient monitoring as required under the Uniform Guidance. Corrective Action Plan: To address this finding and strengthen our internal controls and compliance framework, CCAP will be implementing the following corrective actions: 1. Policy Development and Documentation: o We will be initiating a project to develop and formalize comprehensive written policies and procedures in the following required areas:  Allowability of Costs (2 CFR §200.403–§200.405)  Cash Management (2 CFR §200.305)  Procurement Standards (2 CFR §200.317–§200.326)  Travel Costs (2 CFR §200.474)  Conflict of Interest (2 CFR §200.112)  Subrecipient Monitoring (2 CFR §200.331–§200.333) o These policies will reference relevant Uniform Guidance sections and incorporate internal controls, approval processes, and documentation standards. 2. Internal Review and Approval: o Draft policies will be reviewed by senior leadership, legal counsel (if necessary), and the finance and grants teams to ensure alignment with regulatory requirements and operational realities. 3. Training and Dissemination: o Once finalized, all relevant staff (including program managers, finance personnel, and procurement staff) will receive training on the new policies. o Policies will be made available on CCAP’s intranet. 4. Ongoing Maintenance and Review: o A process will be established for annual review and update of these policies to incorporate regulatory changes and feedback from internal audits or grantor reviews.

The Financial Aid Office has added system controls that will assure that disbursements that are recorded on PeopleSoft is recorded on COD to assure that the Pell reporting requirements are executed in compliance with Federal statutes. The process consisted of creating automation that and reducing the manual intervention so that the issues preventing the Pell disbursement from being recorded on COD is reduced. We are adding automation for processing: FABATCH, ATB automation, and Citizenship automation.

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Iowa Department of Homeland Security and Emergency Management Federal Financial Assistance Listing #97.039 Program Name: Hazard Mitigation Grant Program Finding Summary: The Cooperative does not have an internal control system designed to provide for a complete and accurate schedule of expenditures of federal awards (the schedule) being audited. We requested our auditors to assist with the preparation of the schedule. Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for the preparation of the schedule of expenditures of federal awards and the accompanying notes to the schedule. We requested that our auditors, Eide Bailly, LLP, prepare the schedule and accompanying notes. We have designated a member of management to review the drafted schedule and accompanying notes to the schedule. Responsible Individuals: Shelly Hove, CFO and Johanna Stayskal, Director of Finance Anticipated Completion Date: Ongoing

2024 – 002 Lack of Segregation of Duties - Lack of Supervisory Review - Allow-ability of Expenses Charged to Grants The corrective action proposed for the above finding should be sufficient to account for any area of non-compliance in the evidence of supporting documentation for all disbursements. Additionally, the Business Operations Manager and Executive Director will implement a systematic review of all grant awards, contracts, and develop an addendum document charting all allowable expenses within each funding stream that will be utilized by the team when to determine proper allocation of disbursements. This chart will provide a quick guide to monitor compliance and allow-ability of expenditures to each funder at the time a check request is submitted. Checks

2024-001: Subrecipient Monitoring Controls Person responsible for corrective action: Nicole Meland, Vice President of Finance and Operations Responsible official’s response: Management is in agreement with this finding. Corrective action planned: The Chamber Foundation has a comprehensive monitoring plan to monitor all grant supported activities in accordance with program rules relative to EDA program including rules established by the program, those established by EDA, and by 2 CFR Part 200. Planned implementation date of corrective action: Ongoing

The County will work diligently to implement internal controls over its federal award program to ensure accurate reporting of any activity.

2024 – 009 Special Tests and Provisions – Wage Rate Federal Agency: Department of Interior Federal Program Title: Outdoor Recreation Acquisition, Development and Planning ALN: 15.916 Pass-Through Agency: Arizona State Park Trails Pass-Through Number(s): 04-007-652304 Award Number and Period: 04/18/2022-12/31/24 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Condition/Context: There was no support provided for the three out of three contractor vendors with construction work noted on their purchase orders to support compliance with Davis Bacon. Corrective Action Plan: Regarding the wage tests for the Park’s grant, no information was provided to the City from the contractor of employee wages paid by the contractor. An email request and answer from the contractor was forwarded to the auditors, that the contractor was not responsible to report the wages. This in the future will be part of the Grants Coordinator position for Internal Control purposes, to ensure that any future construction contracts include the wage reporting requirements. Anticipated completion date: December 2025 Contact Person: Mr. Joel Kramer, City Manager

2024 – 008 – Reporting Federal Agency: Department of the Treasury Department of Interior Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds (ARPA) Outdoor Recreation Acquisition, Development and Planning ALN: 21.027 15.916 Pass-Through Agency: Coronavirus State and Local Fiscal Recovery Funds (ARPA) N/A Outdoor Recreation Acquisition, Development and Planning Arizona State Park Trails Pass-Through Number(s): Coronavirus State and Local Fiscal Recovery Funds (ARPA) N/A Outdoor Recreation Acquisition, Development and Planning 04-007-652304 Award Number and Period: Coronavirus State and Local Fiscal Recovery Funds (ARPA) 1505-0271 3/3/2021 – 12/31/2024 Outdoor Recreation Acquisition, Development and Planning 04/18/2022-12/31/24 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Condition/Context: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) (ARPA) - Audit procedures included testing the SLFRF Compliance Report. During the testing of the Compliance report, it was noted that the report’s key line items below were not properly supported: • Current period expenditure • Cumulative expenditure Current period expenditures per the Compliance Report was $-0- and per the expenditure details provided were $907,419 creating a difference of $907,419. Cumulative expenditures per the Compliance Report was $6,714,003 and per the expenditure details provided were $4,264,421 creating a difference of $2,449,582. Outdoor Recreation Acquisition, Development and Planning - Audit procedures included selection and testing of two quarterly reports. Two out of two of the quarterly reports tested contained no separate reviewer/approver support.   FEDERAL AWARD FINDINGS (Continued) 2024 – 008 – Reporting (Continued) Corrective Action Plan: The City concurs with this finding. With the addition of the Grants Coordinator, all reporting of all departments will be filtered through this position. The City also will use an outside Grants consultant to help research, apply, and coordinate the City’s grants in entirety. Anticipated completion date: December 2025 Contact Person: Mr. Joel Kramer, City Manager

The City will work to develop a listing of report submission deadlines as well as cross training staff as appropriate.

Item: 2024-003 Assistance Listing Number: 93.940 Programs: HIV Prevention Activities Health Department Based Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Arizona Department of Health Services Compliance Requirement: Reporting Criteria or Specific Requirement: Per the grant agreements, award recipients are required to submit monthly reimbursement report within a set number of days after month end. Condition: Financial reimbursement reports were submitted after the required due date. Name of Contact Person: Rosalie Johnson, Chief Financial Officer Phone Number: (602) 595-8109 Anticipated Completion Date: January 1, 2025 Views of Responsible Officials and Corrective Actions: Management agrees with the finding. The Organization will submit required reports timely going forward.

Item: 2024-002 Assistance Listing Number: 93.940 Programs: HIV Prevention Activities Health Department Based Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Arizona Department of Health Services Compliance Requirement: Allowable Activities and Costs Criteria or Specific Requirement: In accordance with 2 CFR 200.405 - Allocable Costs - (d) If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. Condition: Costs charged to the federal program were based on an allocation methodology that was not properly updated for the current period Name of Contact Person: Rosalie Johnson, Chief Financial Officer Phone Number: (602) 595-8109 Anticipated Completion Date: January 1, 2025 Views of Responsible Officials and Corrective Actions: Management agrees with the finding. The Organization will update allocations timely going forward.

Item: 2024-001 Assistance Listing Number: 93.914 Programs: HIV Emergency Relief Project Grants Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Maricopa County Department of Public Health Services Compliance Requirement: Allowable Activities and Costs Criteria or Specific Requirement: In accordance with 2 CFR 200.405 - Allocable Costs - (d) If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. Condition: Costs charged to the federal program were based on an allocation methodology that was not properly updated for the current period. Name of Contact Person: Rosalie Johnson, Chief Financial Officer Phone Number: (602) 595-8109 Anticipated Completion Date: January 1, 2025 Views of Responsible Officials and Corrective Actions: Management agrees with the finding. The Organization will update allocations timely going forward.

Finding: 2024-002 Material Weakness in Internal Control Over Compliance and Material Noncompliance U.S. Department of Housing and Urban Development Section 8 Housing Choice Vouchers 14.871 - IA125V08001 for FY24 Housing Voucher Cluster Reporting Finding Summary: Three (3) instances were identified in which the City did not use accurate financial information or retain evidence to document the individual who reviewed the Voucher Management System (VMS) reports prior to submission. Responsible Individual: Diana Steiner, Finance Director Corrective Action Plan: We agree with the auditor’s recommendation and staff will have asecond person review the reports. Anticipated Completion Date: By the completion of the ACFR for the fiscal year ending June 30, 2025.

The Housing Authority takes the recommendation from the audit regarding CFP. All CFPs after 2021 have been designated 25% to operating. CFP 21 was changed with permission from the Portfolio Manager at the time and the annual plan included this money to go to operating. All future designations in EPIC will show the amount to go to operating. However, the HA is not currently able to access CFP 21 in EPIC to edit it – it is locked.

Finding 2024-02 – Material Weakness in Internal Control over Compliance with Allowable Costs and Reporting Management agrees that due to turnover in staff during 2023 and 2024, there were gaps in communication leading to the cost allocation formulas and leadsheet account reconciliations not being updated on a continuing basis as reimbursement requests were being to the California Department of Social Services. Management believes that all key accounting positions have since been filled by qualified personnel. A formal close process and reconciliation of all balance sheet accounts and indirect cost allocations each month will ensure reimbursement requests are complete and accurate. Process documentation is also being prepared to help personnel in the accounting department follow proper control procedures. Action: Develop and document process for drawdown calculation and year end reconciliation to accounting records. Due Date: 10/1/25 Staff: Carrie Castillo, Executive Director

FINDING 2024-004 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Christy Smiley Contact Phone Number and Email Address: 812-663-2570, auditor@decaturcounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: INDIANA STATE BOARD OF ACCOUNTS 27 At least 2 people will look over the report and check all receipts and expenditures when the next P&E report is submitted to prevent and detect any errors. Prior P&E report had already been submitted before the prior audit was complete and we were made aware of the issue and then the Auditor changed in 2025. Control will not be in place until the 2026 P&E report is submitted. Anticipated Completion Date: Submission of next ARPA report, April 2026.

July 28, 2025 Cognizant or Oversight Agency for Audit The City of Inglewood respectfully submits the following corrective action plan for the year ended September 30, 2024. Name and address of independent public accounting firm: Lance, Soll & Lunghard, LLP 203 N. Brea Blvd, Suite 203 Brea, CA 92821 Audit period: 10/01/2023 to 09/30/2024 The finding from the September 30, 2024 schedule of findings and questioned costs is discussed below with the corrective action plan. Finding 2024-001: Delays in Financial Reporting Evaluation of Finding: Material Weakness and Noncompliance Criteria: Management is responsible for providing timely and accurate financial information. Because the City has expended over $750,000 in federal awards, Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), requires non-federal entities to submit their financial statements and single audit reports to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Per HUD REAC reporting requirements and 24 CFR Part 5, Subpart H of the Uniform Guidance, auditees must submit the reporting package, including the Schedule of Findings and Questioned Costs, to the Federal Audit Clearinghouse within 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period, whichever comes first. Condition: The City did not submit its financial statements and single audit reports to the FAC within the required timeframe for the fiscal year ended September 30, 2024. The financial statements and single audit reports were submitted after the deadline of June 30, 2025. The City failed to submit the Real Estate Assessment Center (REAC) reporting package to the U.S. Department of Housing and Urban Development (HUD) within the required timeframe for the fiscal year ended September 30, 2024. The financial statements and single audit reports were also submitted after the deadline of June 30, 2025. Cause: The financial reporting was delayed primarily due to the finalization of the Inglewood Basketball Entertainment Center (IBEC) transactions, which required extensive review and adjustments to ensure accuracy and compliance. Additionally, the resolution of compliance matters related to the sale of land parcels held by the Successor Agency further contributed to the delay. These complex processes necessitated thorough examination with specialists and coordination with attorneys, ultimately impacting the timely completion of the financial reports. Effect: The late submission of the financial statements, single audit, and REAC reports impairs the ability of the federal awarding agencies and pass-through entities to monitor the City’s compliance with federal requirements and to make informed decisions regarding the continuation or modification of federal awards. The late submission also results in noncompliance with the Uniform Guidance and HUD REAC, and increases the risk of fraud, waste, and abuse of federal funds. Context: The City’s financial statements and single audit reports are used by the federal awarding agencies and pass-through entities to assess the non-federal entity's financial condition, internal controls, and compliance with federal requirements. Repeat Finding: No Recommendation: LSL does not anticipate this finding to be repeated in the next fiscal year, as the IBEC transaction is expected to be fully resolved. With the completion of this transaction and the resolution of compliance matters related to the sale of land held by the Successor Agency, the processes that contributed to the delay in financial reporting will no longer be a factor. This will enable more timely and accurate financial reporting moving forward. Management Response: Management acknowledges the auditors finding regarding delays in financial reporting, including the late issuance of financial statements, and the timing challenges caused by the accounting treatment of complex or non-routine transactions. We recognize that timely financial reporting is essential to upholding public trust, supporting informed policy decisions, and ensuring compliance with applicable accounting standards and regulatory deadlines. The delays identified during the audit were primarily attributable to the following factors: • The occurrence of a complex and non-recurring transaction during the fiscal year that required significant time for proper technical analysis and documentation. • Dependencies on information from third-party agencies, consultants, and internal departments that impacted the timing of final reporting deliverables. Corrective Action Plan: In response to this finding, the City is taking the following steps to improve the timeliness and reliability of its financial reporting process: 1. Staff Development and Capacity: The City has initiated efforts to strengthen the Finance Department’s capacity by filling key vacancies, cross-training staff, and providing targeted professional development on complex accounting topics relevant to governmental reporting. 2. Proactive Technical Review: The City will identify and evaluate complex or unusual transactions on a proactive basis throughout the fiscal year and, where appropriate, consult with the City’s external auditors or subject matter experts prior to year-end. 3. Process and Timeline Enhancements: The City is updating its year-end financial close calendar to incorporate additional review periods for high-complexity areas and to better align internal workflows and external reporting timelines. 4. Improved Coordination and Documentation: The Finance Department is implementing enhanced coordination protocols with other departments and external service providers, as well as strengthening internal documentation procedures to ensure timely and accurate support for financial entries and disclosures. The City remains committed to enhancing its financial reporting processes and internal controls. Management believes these corrective actions will lead to more timely issuance of the City’s financial statements in future periods and will continue to monitor progress and make adjustments as necessary. The name of the contact person responsible for the corrective action: Luisana Gomez, Accounting Manager If the Cognizant or Oversight Agency for the Audit has questions regarding the corrective action plan, please contact Luisana Gomez, Accounting Manager lgomez@cityofinglewood.org