Corrective Action Plans

Reserve Account Compliance – Criteria: Ecology Education, Inc. (the School) is required to fund certain loan reserve accounts on a monthly basis in accordance with requirements prescribed by the United States Department of Agriculture. Condition: During 2025, the School did not fulfill its loan reserve requirements, causing the School to be in default of its loan agreement. Cause: The School was unable to fulfill the reserve requirements as a result of cash flow challenges encountered during the fiscal year. Effect: Reserve requirements are not fulfilled in accordance with federal guidelines. Recommendation: We recommend that management should develop and implement a systematic process to restore and maintain the required levels to maintain compliance with reserve requirements going forward. Responsible Parties: Drew Dumsch (President/CEO) and Anthony Pyatt (Business Manager). Corrective Action Taken or Planned: Continuing to work with USDA Rural Development on workout plan including implementing a systematic process to restore and maintain on a monthly basis the required levels to maintain compliance with reserve requirements going forward.

2025-003 Eligibility Housing Voucher Cluster Material Weakness in Internal Control over Compliance Material Noncompliance Condition: Out of an approximate population of 1,500 Housing Voucher Cluster tenants we tested 18 tenants and the following deficiencies were noted: Eighteen files did not have annual recertifications or a required annual certification performed during the year. Auditor’s Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regard to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: Management Response / Action Taken The Authority agrees with the finding and acknowledges that timely annual recertifications and certifications are critical to maintaining compliance with program eligibility requirements. During 2026, the Authority implemented enhanced tracking and monitoring procedures for annual recertifications, including management review of outstanding certifications and recertifications, additional staff training regarding compliance requirements, and increased oversight of file processing activities. The Authority will continue to strengthen internal controls and monitoring procedures to ensure annual recertifications and certifications are completed timely and appropriately documented. The Authority is actively working to bring all required recertifications and certifications current and expects to be fully current by December 31, 2026. Management believes the corrective actions implemented during 2026 will be more fully reflected in the results of the 2026 and 2027 compliance audits. Responsible Party: Senior Vice President of Voucher Processing Time Frame: Corrective actions were initiated during 2026 and are ongoing. The Authority expects all required recertifications and certifications to be current by December 31, 2026, with continued monitoring and oversight through 2027. Management expects the full impact of these corrective actions to be reflected in the 2026 and 2027 compliance audits.

Finding 2025-003 Department of the Treasury, Passed Through the State of Michigan Federal Financial Assistance Listing 21.029, CV0019120, 2025 COVID-19 – Coronavirus Capital Projects Fund Reporting Material Weakness in Internal Control over Compliance Finding Summary: The Cooperative has no formal review process for the quarterly reports, which could result in a material misstatement of the Cooperative’s schedule of expenditures of federal awards. Responsible Individuals: Kevin Mazure, Brad Essenmacher Corrective Action Plan: The Cooperative will implement a formal review process for the quarterly reports, ensuring there is adequate segregation of duties and proper oversight. Anticipated Completion Date: December 31, 2026

Older Americans Act Title III – Assistance Listing No. 93.044, 93.045, 93.053 Recommendation: The Organization should retain suspension and debarment searches as well as retain documentation that monitoring activities and risk assessments are being reviewed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will save and retain the suspension and debarment searches and implement a process to document their review. Name(s) of the contact person(s) responsible for corrective action: Lori Vrolson, Executive Director Planned completion date for corrective action plan: December 31, 2026

Medical Assistance – Assistance Listing No. 93.778 Recommendation: The County should ensure it has proper controls in place to document the review Random Moment Time Study Participant Listings for the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will enact a process to ensure all listings are reviewed and proper documentation will be retained. Name(s) of the contact person(s) responsible for corrective action: Heather Olson Auditor/Treasurer, Amie Gendron Administrative Services Supervisor Planned completion date for corrective action plan: December 31, 2026

As previously stated, NCAAA has hired another Finance Director. In addition, procedures will be implemented to formalized monthly account reconciliations and year end closed to ensure transactions are properly recorded in the appreciate account and correct period

As previously stated, NCAAA has hired another Finance Director coupled with a Consultant an expert in the Accounting system being utilized to ensure full use. In addition, procedures will be implemented to formalized monthly account reconciliations and year end closed to ensure transactions are properly recorded in the appreciate account and correct period.

NCAAA has hired a full-time Finance Director As previously mentioned, procedures will be implemented to formalized monthly account reconciliations and year end closed to ensure transactions are properly recorded in the appropriate account and correct period.

CORRECTIVE ACTION PLAN - Concerning Findings 2025-003 Contact Person Responsible for Corrective Action: Andrew Levesque, CFO Corrective Action: The Mi'kmaq Nation will take the following actions to address finding 2025-003 as stated below: Condition: To date, the Nation lacks proper internal controls to ensure timely programmatic reporting and historical file maintenance. Management's Response: The Nation, through a new financial director, and finance team has started training staff and those responsible for these functions. With increased help in the financial department, we are now able to and anticipate meeting this function as required by the program. Anticipated Completion Date: December 31, 2026 Sincerely, Sheila McCormack, Tribal Chief

Condition: Timecards did not consistently agree with hours reported in payroll records. Discrepancies were noted between employee timecards and ADP payroll reports, and one instance was identified in which a timecard lacked required approval. Planned Corrective Action: Management will strengthen payroll controls by implementing a dual-review process. Supervisors will be required to approve all employee timecards prior to payroll processing, and accounting personnel will verify approved timecards against payroll system reports before payroll is finalized. In addition, management will conduct periodic spot checks and quarterly reviews on or around April 1st, July 1st, October 1st, January 1st to ensure payroll records are accurate, properly supported, and in compliance with established procedures. Anticipated Completion Date: December 31, 2026. Contact Person: Pam Schuellerman, Executive Director.

Condition: Management was unable to locate approved payment request forms demonstrating evidence of review and approval prior to submission for reimbursement in 15 of the 60 transactions selected for testing. Planned Corrective Action: Management will implement and enforce a standardized reimbursement packet checklist requiring documented approval before reimbursement requests are submitted. All reimbursement packets and supporting documentation will be maintained electronically in a centralized filing system. Training will be provided to accounting staff regarding documentation and record retention requirements. Quarterly reviews will be conducted to ensure compliance with established procedures on or around April 1st, July 1st, October 1st, January 1st annually. Anticipated Completion Date: December 31, 2026. Contact Person: Pam Schuellerman, Executive Director

U.S. Department of Homeland Security Emergency Operations Center Assistance Listing Number: 97.052 Passed Through Minnesota Department of Public Safety Pass Through Number: EMC-2024-EO-05011 Award Period: September 1, 2024 – August 31, 2027 Recommendation: We recommend the City establish a formal policy over the Build America, Buy America Act domestic content procurement preference that includes identifying whether a federal award is subject to BABAA requirements, classifying each item to be incorporated into the project as an iron or steel product, a construction material, or a manufactured product, determining the applicable domestic content standard for each classification, and obtaining and retaining vendor certifications supporting compliance prior to incurring costs. We further recommend the City include Buy America contract provisions in all agreements associated with federally funded infrastructure projects and request and obtain any necessary waivers from the federal awarding agency in advance of procurement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The Emergency Operations Center project was bid and awarded as part of a larger public safety facility construction project. Bid award dates for the construction contracts ranged from November 2023 through March 2024, and construction was underway prior to the City's receipt of the federal award, which carried an effective date of September 1, 2024. Because the construction agreements were executed before the City received the federal award, the agreements did not incorporate Buy America contract provisions, and domestic content certifications were not requested from vendors at the time of procurement. Upon identifying the applicability of the Build America, Buy America Act requirements to the award, the City submitted waiver requests for items subject to the domestic content procurement preference. Those requests remain pending and had not been approved as of the date of the auditor's report. The City is continuing to work with the Minnesota Department of Public Safety and the federal awarding agency to obtain a determination on the pending waiver requests and will provide any additional documentation requested in support of those submissions. Management will develop and adopt a written policy addressing the domestic content procurement preference. The policy will require staff to determine at the time of award acceptance whether a federal award funds an infrastructure project subject to BABAA, to classify each item to be incorporated into the project under the applicable domestic content standard, to include Buy America contract provisions in all solicitations and agreements associated with federally funded infrastructure projects, and to obtain and retain vendor domestic content certifications prior to incurring costs. Where compliance cannot be achieved, the City will submit a waiver request to the federal awarding agency in advance of procurement. Name of the contact person responsible for corrective action: Noel Graczyk, Administrative Services Director Planned completion date for corrective action plan: December 31, 2026

Finding 2025-001: Material Weakness over Financial Reporting Management’s Response Management agrees with the finding and the auditor’s recommendation. Management recognizes that Wellspring’s period-end close and financial reporting review procedures during the audit period did not provide sufficient assurance that material errors in significant account balances and related financial statement disclosures would be prevented, or detected and corrected, on a timely basis. The deficiencies identified during the audit occurred within a broader financial management and internal control environment that was not sufficiently developed for the size and complexity of Wellspring. During 2024 and 2025, the Organization relied extensively on an outsourced Client Accounting Services arrangement. Under this arrangement, the Organization’s accounting was migrated to Sage Intacct using base templates that were not sufficiently tailored to Wellspring’s unique financial reporting and operational requirements. As a result, the Organization did not have sufficiently developed and consistently executed processes for account reconciliation, period-end close, financial statement review, or related supervisory oversight, and the accounting system did not provide an adequate level of configuration and automated control to support these processes. Management accepts responsibility for these conditions and has taken significant steps to address them. Wellspring has strengthened its internal financial operations through the recruitment of experienced nonprofit financial leadership and accounting personnel and is implementing a comprehensive remediation of its financial reporting processes, internal controls, and accounting system. As part of this remediation, the Organization has engaged the software consultancy firm Armanino to conduct a comprehensive review of its accounting system. Based on the results of that review, Armanino will proceed to assist management with a System Remediation Project, which will include the implementation of Sage Intacct’s Advanced Grants Tracking module and Fixed Assets module, as well as a redesign of other system configurations and controls. Management believes its current structure combining internal staffing with external consulting resources positions Wellspring to effectively build and maintain an effective internal control framework over financial reporting. Corrective Action Plan Management is implementing a formal, documented monthly and year-end financial close process designed to provide consistent evidence that significant accounts and financial statement areas have been reconciled, reviewed, and appropriately supported before financial statements are finalized. The corrective action plan includes the following: 1. Formal monthly close process and close checklist Management is implementing a standardized monthly close checklist establishing required procedures, responsible parties, due dates, and supervisory review for significant financial statement accounts. 2. Account reconciliations and supervisory review Significant statement of financial position and statement of activities accounts will be reconciled and supported on a timely basis. Reconciliations will be subject to documented supervisory review, including evidence of review, resolution of reconciling items, and follow-up on outstanding or unusual balances. 3. Capital assets and construction in progress Management is strengthening procedures for capital assets and construction in progress, including reconciliation and review of capital additions, construction-related invoices, retainage, and depreciation. The implementation of the Sage Intacct Fixed Assets module will provide better system support for the Organization’s fixed asset accounting. 4. Accounts receivable and revenue Management is implementing documented review procedures for accounts receivable aging, pledges and other receivables, revenue recognition and cutoff, collectability, and subsequent cash receipts. The implementation of the Sage Intacct Advanced Grants Tracking module will also provide better system support for these processes. 5. Accrued liabilities and period-end cutoff Management is strengthening procedures for identifying, recording, and reviewing accrued liabilities and other period-end obligations to ensure that expenses and liabilities are recorded in the appropriate reporting period. 6. Net asset classification and donor restrictions The initial installation of Sage Intacct was not optimally configured for the efficient tracking of net asset classes and releases from restriction. The ability to record and view purpose and time restrictions within the general ledger and supporting modules is a key emphasis of the system remediation project. New dimensions and documented procedures will allow Wellspring to reliably track net asset classifications and reconcile supporting schedules to the general ledger and financial statement presentation. 7. Journal entry and system controls Management is strengthening controls over journal entries and transaction recording, including appropriate review, approval, and segregation of responsibilities. New system configuration controls include approval workflows, more restrictive user permissions, use of the period close function, and restrictions on direct posting to control accounts and subledger journals. The new controls will be further evaluated and developed as part of the system remediation project. 8. Financial statement and disclosure review Prior to issuance, the financial statements and related disclosures will undergo a documented review by personnel with appropriate technical accounting knowledge. Proposed audit adjustments and other significant adjusting journal entries will likewise be subject to management review and approval. 9. Documentation and evidence of review Management is establishing requirements for retaining evidence of supervisory review, review comments, and resolution of identified issues. The objective is to ensure that the Organization can demonstrate both that controls were performed and that identified issues were appropriately evaluated and resolved. Wellspring’s Board of Directors will meet with administration at least once per quarter to review the financial statements. 10. Ongoing monitoring and internal control improvement The Senior Director of Finance will oversee implementation and ongoing monitoring of these procedures and will continue to evaluate the Organization’s financial reporting processes, accounting system configuration, and other internal controls as part of the Organization’s broader remediation efforts. Responsible Official Casey Richey Senior Director of Finance Anticipated Completion Date The enhanced monthly and year-end close procedures and related supervisory review controls are being implemented during 2026. Management expects the core remediation activities to be substantially implemented by December 31, 2026, with the controls becoming part of Wellspring’s ongoing monthly and annual financial reporting processes thereafter. Management will continue to monitor the effectiveness of the implemented controls and make additional modifications as necessary to ensure that the financial reporting process provides reasonable assurance that material errors are prevented or detected and corrected on a timely basis.

The FY 2025 audit identified continuing exceptions involving Housing Voucher participant files, including HUD Form 50058 reporting and income-calculation accuracy. The finding was identified as a repeat compliance matter. HACC agrees with the findings and has strengthened the Housing Choice Voucher Program's compliance controls. Management Response and Corrective Action 1. Dedicated HCV Compliance Function. HACC has established dedicated compliance oversight for the Housing Choice Voucher Program to provide an additional level of review independent of the staff responsible for processing the underlying transaction. 2. HUD Form 50058 Timeliness Monitoring. HACC will monitor HUD Form 50058 submissions and exception reports to identify late or rejected submissions and require timely correction. 3. Income and Rent Calculation Review. Quality-control reviews will specifically test income calculations, deductions, allowances, tenant rent, utility allowances where applicable, and supporting documentation. 4. File Completion Checklist. HACC will use a standardized HCV file checklist for annual and interim recertifications to verify required documentation is present before the action is considered complete. 5. Retroactive File Review and Correction. HACC will conduct targeted reviews of participant files to identify missing documentation, untimely HUD Form 50058 submissions, and income or rent calculation errors. HACC will correct identified deficiencies and process any required adjustments consistent with HUD requirements. 6. Recurring Quality-Control Reviews. HACC will conduct periodic sample reviews throughout the year. HACC will track results by error type, responsible function, corrective action, and resolution date so management can identify recurring trends. 7. Staff Training and Technical Assistance. HCV staff will receive continuing training regarding eligibility, income calculations, verification requirements, HUD Form 50058 reporting, and applicable HUD requirements. 8. Management Reporting and Accountability. HCV staff will periodically report compliance results to HCV leadership and executive management. Repeated deficiencies will result in targeted retraining, increased supervisory review, and appropriate performance-management measures. 9. Independent Third-Party Quality Control Review. During FY 2026, HACC is engaging an independent third-party quality-control and compliance firm to conduct comprehensive reviews of Housing Choice Voucher participant files. The firm will test file completeness, eligibility documentation, income and rent calculations, HUD Form 50058 accuracy and timeliness, required verifications, utility allowances where applicable, and other HUD compliance requirements. The firm will identify deficiencies and provide corrective recommendations to help HACC strengthen internal controls. Responsible Officials: Vice President of the Housing Choice Voucher Program and designated HCV Compliance staff, under the oversight of the Executive Director/CEO. Implementation Status/Timeline: Corrective actions are underway during FY 2026 and will remain part of HACC's ongoing compliance and quality-control process.

Federal Agency Name: Department of Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: The Cooperative did not retain the supporting documentation used in the preparation of the quarterly reports. As a result, reported amounts could not be reconciled to the documentation subsequently provided by the Cooperative. Corrective Action Plan: The Grant and Compliance Accountant will be responsible for maintaining, gathering, preparing, and tracking all supporting documentation used in grant reporting. Reported amounts will be reconciled to supporting records before submission, and documentation will be retained to ensure a complete and accurate audit trail. The grant and compliance accountant brings experience working with federal awards, internal controls, compliance monitoring, and coordination with finance, project management, auditors, and funding agencies to further support the Cooperative's ability to maintain accurate grant records and meet federal reporting requirements. Responsible Individuals: Isaac Gonzales, Grant & Compliance Accountant and Cletus Stoflet, CFO Anticipated Completion Date: December 31, 2026

Federal Agency Name: Department of Energy Assistance Listing Number: 81.254 Program Name: Grid Infrastructure Deployment and Resilience Finding Summary: The Cooperative does not have an internal control system designed to provide for a complete and accurate schedule of federal expenditures of federal awards being audited. We requested our auditors to assist with the preparation of the schedule and the accompanying notes to the schedule. Corrective Action Plan: The Cooperative has addressed this finding by hiring a Grant and Compliance Accountant to oversee federal award accounting, maintain a complete inventory of federal awards, reconcile grant expenditures to the general ledger and prepare the annual Schedule of Expenditures of Federal Awards (SEFA) and related notes. The SEFA will also be independently reviewed by the Chief Financial Officer before being provided to the external auditors. Responsible Individuals: Isaac Gonzales, Grant & Compliance Accountant and Cletus Stoflet, CFO Anticipated Completion Date: December 31, 2026

Finding 2025-004: Temporary Assistance for Needy Families (TANF), Assistance Listing No. 93.558, U.S. Department of Health and Human Services Passed through Colorado Department of Human Services Compliance Requirement: Eligibility, Special Tests and Provisions Grant No.: Not applicable Type of finding: Internal Control (material weakness) Recommendation: The County should develop, document, and implement a formal TANF case file review process, including supervisory review and retention of evidence of reviews performed, to help ensure compliance with program requirements. Action Taken: Costilla County DSS will develop and fully document a formal TANF case review process that will include supervisor reviews. Costilla County DSS will retain evidence of reviews completed monthly, to ensure program requirements. If there are questions regarding this plan, please call the responsible parties listed below. Sincerely yours, Julie Albert Chief Financial Officer Costilla County, Colorado Najondine Placek County Clerk Costilla County, Colorado Tommy Vigil County Social Services Director Costilla County, Colorado

FINDING 2025-019 Finding Subject: Education Stabilization Fund – Activities Allowed or Unallowed – Period of Performance Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@sbcsc.k12.in.us , atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reimbursement Processing: Detailed expenditure and budget reports are reconciled by the Director of Federal Grants, signed by a supervisor, and reviewed by the CFO before submission. Contract & Data Retention: HR worked with Regional Data Services to update software archives to prevent lost administrative records. Grant Personnel Verification: Grant fiscal officers must review and sign Payroll Certification Reports to verify that employee charges are accurate. Payroll & Stipends: All employee compensation requires pre-approval by the School Board. Implemented a formal 10-step stipend approval workflow. Overtime Policy: Mandates supervisor pre-approval before overtime hours are worked. Pay Change Process INDIANA

FINDING 2025-015 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Cash Management Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Centralized Reporting: The Finance Department now mandates that all approved grant documentation (Grant Award Notifications, reimbursement forms, budget breakdowns) be submitted to Finance immediately. Succession Planning Policy: Added strict continuity protocols to the IC Manual, affirming that all data belongs to the corporation. Requirements include maintained system documentation, account deactivation within 24 hours of employee departure, and formal knowledge handoffs. Segregation of Duties: Updated policy to ensure no single individual manages any financial process (receivables, purchasing, or inventory) end-to-end. Anticipated Completion Date: September 30, 2024 (grant ended). January 1, 2025 is when grant award documentation sharing was required.

FINDING 2025-011 Finding Subject: Gaining Early Awareness and Readiness for Undergraduate Programs – Internal Controls Contact Person Responsible for Corrective Action: Chad Addie, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, caddie@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Director of Federal Grants generates detailed expenditure and budget reports, filtering for new transactions since prior requests to ensure alignment before CFO review and submission. Added a dedicated supervisor review signature line on supporting document sheets to confirm approval Anticipated Completion Date: Completed by June 30, 2026

FINDING 2025-008 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Dr. Bo Yan, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, byan@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: • Centralized enrollment/withdrawal document management with weekly accuracy audits. • Updated Internal Control Manual to mandate a 12-item list of enrollment documents (birth certificates, residency proof, immunizations, etc.). • Established a formal "Summary of Attempts" process requiring at least 3 documented attempts to secure residency proof before submitting signed summaries. • Standardized documentation for general transfers, mandatory 16–17-year-old exit interviews, and Title I ESSA graduation cohort tracking. Anticipated Completion Date: January 1, 2027 (Note: Specific student mobility updates corrected April 1, 2026).

Finding 2025-004 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Period of Performance Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: My office will put internal controls in place to make sure all invoices paid under the Covid-19 grant funds are entered into the correct quarter for reporting purposes. The Deputy Auditor will prepare all of the invoices for the grant funds and the Auditor will check to make sure the claims are for the correct period. Anticipated Completion Date: August 2026

We are working with our HUD field office to correct our VMS reporting. We are also working with our fee accountant and have switched our software to HAPPY so we can get better reporting.

2025-002 Policies and Procedures for Food Inventory Management Corrective action planned: Anticipated completion date: Contact person responsible for corrective action: Pmtners INW will formalize the procedures we have in place as a Board approved policy. The policy will cover the treatment for all types of inventories, including federal non-cash programs. We will provide a draft policy to the Financial Committee at the 9/22 meeting prior to board-wide approval afterward. The policy will be acknowledged at least annually and after key staff turnover. Target: 9/24/2026 Justin Carlile JustinC@partnersinw.org

2025-001 Reporting on USDA Foods Corrective action planned: Anticipated completion date: Contact person responsible for corrective action: Pmtners INW will implement a monthly reporting procedure requiring a documented inventmy reconciliation of each USDA program to the provided bills of lading prior to submission to WSDA. Each invent tory reconciliation will be reviewed and signed by a staff member who did not prepare the repmt. These reconciliations will be retained alongside monthly program inventmy repmts. Target: October 31 st . We will begin immediately with the first dual verification repmt being completed for the month of September. Justin Carlile JustinC@partnersinw.org