Corrective Action Plans

Finding 2025-001: Reporting – Material weakness in internal controls over compliance and compliance finding. Management Response Effective May 12, 2026, the agency enhanced its performance reporting oversight by requiring the Chief of Mission and the Executive Vice President of Victim Services to review and approve preliminary reports to funding entities drafted by the compliance department, prior to submission. The agency’s compliance department, which consists of a Database Manager, Compliance Manager, and Executive Vice President of Compliance, is tasked with ensuring reliability and validity of client-level database entered in the client database. Monthly, the agency’s compliance department reconciles the number of new and unduplicated participants served by the agency as a whole and within each grant-funded program. The compliance department’s report originator will save the source data electronically, ensuring it matches the official figures submitted to the funding entity. Source data reports will be available upon request by agency staff and/or funders.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Supportive Housing for the Elderly Section 232 ALN Number: 14.129 Award Period: Year Ended December 31, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Home was required to obtain written approval for the member substitution transaction with The Carmelite System, Inc. prior to closing. Condition: Membership transfer agreements must be in place and signed by HUD during the transition of Ownership / Governance. Context: Formal HUD approval was not obtained in relation the Member Substitution in which the Carmelite System, Inc. became the sole member and sponsor of the Home. Recommendation: The Home should adhere to the Regulatory Agreement and obtain HUD’s approval prior to taking any actions specifically precluded in the Regulatory Agreement. Action taken in response to finding: There is no disagreement with the audit finding. Management is working to obtain the necessary HUD approvals.

Community Project Funding (CFP) Program – Assistance Listing No. 14.251 Recommendation: We recommend the City ensure environmental review requirements are completed and documented prior to incurring any project-related expenditures for the Community Project Funding program. The City should continue to maintain procedures designed to prevent project activities from beginning before environmental review requirements are satisfied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: City management noted that procedures have been implemented for this grant, including a memorandum of understanding that is annually reaffirmed by the City Council, to ensure environmental review requirements are completed prior to incurring project expenditures and to prevent similar occurrences in the future.. Name of the contact person responsible for corrective action: Zach Doug Planned completion date for corrective action plan: December 31, 2026

Community Project Funding (CFP) Program – Assistance Listing No. 14.251 Recommendation: We recommend the City implement procedures to ensure appropriate internal controls over compliance related to reporting, including documentation of review and approval of all required reports by someone other than the preparer prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: City management acknowledges that limited staffing and experience constrain segregation of duties; however, the City will evaluate and implement procedures to improve documentation of review and approval of required reports for the Community Project Funding program. Name of the contact person responsible for corrective action: Zach Doug Planned completion date for corrective action plan: December 31, 2026

Housing Choice Vouchers – CFDA 14.871 Recommendation: The Commission should consider reviewing its current policy regarding rent certifications. The Commission should ensure all persons involved in the certification process are properly trained and understand regulations in order to accurately identify errors. Additionally, the Commission should implement a thorough second party review of annual certifications to verify accuracy. Action Taken: Management will implement stronger controls over tenant files including a more thorough second party review. Anticipated Completion Date of Action: August 31, 2025

Corrective Action Plan For the Year Ended June 30, 2025 Finding: 2025-003 Inaccurate Resources Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2025-004 Inaccurate Resources Entry Name of contact person: Corrective Action: Section III - Federal Award Findings and Question Costs Darren Phillips, Quality Assurance and Program Integrity Supervisor We are building a training slideshow presentation to provide tenured caseworkers refresher training for all of the Internal Error findings. This will cover Incorrect Resources, Incorrect Income, Incorrect HH and Residency issues. The SSI expartes that were in error have been completed as of 12/10/2025. We will cover the use of NCFAST reports to ensure that they are worked in a timely manner. A greater emphasis will be placed during training of new hires in the areas of the errors found. Supervisors will provide policy updates and review the income and recertification policies in the Monthly Unit Meetings. The Medicaid Division Director will meet with the Medicaid supervisors to address the untimely reviews and put a plan into place to work them in a timely manner. A review of the Recertification process for Family and Children's Medicaid in terms of timeliness and pending notices will also be accomplished. Training will be provided by 2/28/2026 for all Medicaid personnel. Darren Phillips, Quality Assurance and Program Integrity Supervisor We are currenty building a training slideshow presentation to provide tenured caseworkers refresher training on how to update income on cases. The training will cover Self-Employment, the use of pay stubs and pulling income from OVS and TWN. The training will cover both error findings, Incorrect Income and Inadequate Request for Income. A greater emphasis will be placed on the training of new hires for the areas of the errors found. A Desk Reference will be created to assist caseworkers with their duties. Supervisors will provide policy updates and review the income and recertification policies in their Monthly Unit Meetings. The Medicaid Director will meet with the Medicaid Supervisors to discuss the Untimely Reviews to ensure that cases are completed in a timely manner. A review of the Recertification process for Family and Children's Medicaid in terms of timeliness and pending notices will also be accomplished. 230

Corrective Action Plan For the Year Ended June 30, 2025 Finding: 2025-003 Inaccurate Resources Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2025-004 Inaccurate Resources Entry Name of contact person: Corrective Action: Section III - Federal Award Findings and Question Costs Darren Phillips, Quality Assurance and Program Integrity Supervisor We are building a training slideshow presentation to provide tenured caseworkers refresher training for all of the Internal Error findings. This will cover Incorrect Resources, Incorrect Income, Incorrect HH and Residency issues. The SSI expartes that were in error have been completed as of 12/10/2025. We will cover the use of NCFAST reports to ensure that they are worked in a timely manner. A greater emphasis will be placed during training of new hires in the areas of the errors found. Supervisors will provide policy updates and review the income and recertification policies in the Monthly Unit Meetings. The Medicaid Division Director will meet with the Medicaid supervisors to address the untimely reviews and put a plan into place to work them in a timely manner. A review of the Recertification process for Family and Children's Medicaid in terms of timeliness and pending notices will also be accomplished. Training will be provided by 2/28/2026 for all Medicaid personnel. Darren Phillips, Quality Assurance and Program Integrity Supervisor We are currenty building a training slideshow presentation to provide tenured caseworkers refresher training on how to update income on cases. The training will cover Self-Employment, the use of pay stubs and pulling income from OVS and TWN. The training will cover both error findings, Incorrect Income and Inadequate Request for Income. A greater emphasis will be placed on the training of new hires for the areas of the errors found. A Desk Reference will be created to assist caseworkers with their duties. Supervisors will provide policy updates and review the income and recertification policies in their Monthly Unit Meetings. The Medicaid Director will meet with the Medicaid Supervisors to discuss the Untimely Reviews to ensure that cases are completed in a timely manner. A review of the Recertification process for Family and Children's Medicaid in terms of timeliness and pending notices will also be accomplished. 230

Condition: Suspension and debarment compliance was not verified for nine covered transactions. Corrective Action Plan: The Town will verify that all vendors paid with ARPA (SLFRF) funds are not suspended or debarred by checking sam.gov prior to payment. Documentation of the verification will be retained with the supporting payment records. Anticipated Completion Date: June 30, 2026 Contact Information: Eric A. Kinsherf, CPA, Town Accountant

2025-002 Cash Management Corrective action planned: Management will implement controls over all draws from the Payment Management System to minimize the time elapsed between the drawdown of funds from PMS and the payment for expenditures. The controls will incorporate the following: Prepare a detailed listing of expenditures claimed for reimbursement for each drawdown request. The expenditures listing will be reviewed by appropriate personnel to ensure cash payments for the expenditure are made before the date of the draw or within a reasonable time after the draw. Drawdowns are authorized and approved by the appropriate personnel before the drawdown is made and will be tracked and summarized in a ledger. Anticipated completion date: June 2026 Contact person responsible for corrective action: Harjeet Sidhu, Chief Financial Officer

a. Administrator: V.P. Finance/ CFO ................... Victor Parker 601-857-3961 b. Administrator: V.P. Student Services ....... Jennifer Scott-Gilmore 601-857-3250 Student Financial Assistance Cluster: The District did not properly calculate the total amount disbursed or to be disbursed which lead to incorrect calculation of funds to be returned to Title IV. Additionally, the District did not provide evidence of date of determination used in calculation. Corrective Action Plan: The District is an attendance taking institutional and has reviewed its internal controls on how total days in the semester are calculated correctly and timely disbursements are made. The District understands that it should be using the Last Day of Attendance in the calculation of earned aid and made that modification Spring 2025 in collaboration with the U.S. Department of Education and outlined the calculation variables to align with that calculation change. Management has revised its Policy and Procedures accordingly and was submitted to the Hinds Board of Trustees for final approval December of 2025. The correction implementation date was June 2025 and finalized December 2025. With the corrected action initially taking place June 2025, this will be a continuation into this FY2025 audit. The correction implementation date was June 2025 and finalized December 2025. With the corrected action initially taking place June 2025, this will be a continuation into this FY2025 audit.

Project NOW, Inc. submits the following corrective action plan for the identified finding for the audit period July 1, 2024 through June 30, 2025. 2025-001 - Delinquent Audit Submission, Audit Preparedness, Timely Reconciliations and Material Adjustments Corrective Action: Lack of audit preparedness, reconciliations not done or not completed timely, and material adjustments either not completed properly and accurately or just not done at all were the cause and the reason for the delinquent audit submission. The Accounting Manager and one Grant Accountant left the organization early to mid FY2025. The CFO then decided to scale back her work hours before eventually leaving the organization prior to completing her agreed upon task of preparing the organization for the audit. The new CFO was hired in September 2025, and a temp Grant Accountant was hired full time in November 2025. Instead of replacing the Accounting Manager, a third Grant Accountant was brought in as a temp in February 2026 and will be hired full time in June 2026. Steps in the Corrective Action Process: Train and Crosstrain Finance Staff and Grant Accountants: Upon the new CFO's arrival, many of the duties for grant reporting as well as the majority of the month-end closing entries fell under one grant accountant. Some duties were delegated to the temp grant accountant, but a majority of the workload still fell to the other accountant. We will make sure that each grant accountant is trained on the grants they are responsible for as well as cross trained on other grants so grant reporting obligations do not go undone in the absence of one accountant. Person(s) Responsible: Steve Morenz, CFO Timing for Implementation: Current and ongoing Training the Accounting Staff in month end closing entries and the handling of material acquisitions and disposals: It was found during the audit that a new agency acquisition was not added to Project NOW's books properly, a new LLC had not been properly set up in the accounting system, and the sale of houses and the sale of vehicles were not handled correctly. The CFO will monitor such activities and make sure the proper accounting for such transactions is completed in the accounting system either at the time of sale or time of acquisition. Person(s) Responsible: Steve Morenz, CFO Timing for Implementation: Current and ongoing Returning to and following a strict month end closing schedule, having the books closed by the 15th of each month: At one point, from the last corrective action plan to this one, the Finance staff was current with their month end closings. But with the transitions that occurred they had again fallen behind, and at one point being up to six months behind in closing the months. With a fully trained Finance department, starting in January 2026 we were able to close two months during each calendar month and were current with our statement's closings by March 2026. The staff will work diligently to maintain this schedule. This will also help ensure grant reporting is done on a timely basis as well. Person(s) Responsible: Steve Morenz, CFO Timing for Implementation: Current and ongoing Balance Sheet Account Review and Reconciliation: Apparently other than monthly bank reconciliations, there has been no balance sheet account review done for quite some time. Moving forward, the CFO will work with the accounting staff to see that reconciliations of all balance sheet accounts for all entities will be done regularly and correctly so we are better prepared for audit season. Person(s) Responsible: Steve Morenz, CFO Timing for Implementation: Current and ongoing Monthly departmental revenue and expense reports distributed to each director by the 20th of each month: Again, prior to the latest staffing transitions, R&E reports were sent to department directors every month. This practice then fell by the wayside. We have re-implemented the distribution of month financial reports to all directors showing all revenues and expenses for the departments they manage and the grants they are responsible for. Regular meetings will be held between the CFO, specific grant accountant, and the directors to review their statements to see how their department is running and their compare financial results versus their budget. This will also help monitor activity on the organization's income statement, making sure those balances are accurate and complete. Project NOW, Inc. submits the following corrective action plan for the identified finding for the audit period July 1, 2024 through June 30, 2025. 2025-001 - Delinquent Audit Submission, Audit Preparedness, Timely Reconciliations and Material Adjustments Corrective Action: Lack of audit preparedness, reconciliations not done or not completed timely, and material adjustments either not completed properly and accurately or just not done at all were the cause and the reason for the delinquent audit submission. The Accounting Manager and one Grant Accountant left the organization early to mid FY2025. The CFO then decided to scale back her work hours before eventually leaving the organization prior to completing her agreed upon task of preparing the organization for the audit. The new CFO was hired in September 2025, and a temp Grant Accountant was hired full time in November 2025. Instead of replacing the Accounting Manager, a third Grant Accountant was brought in as a temp in February 2026 and will be hired full time in June 2026. Steps in the Corrective Action Process: Train and Crosstrain Finance Staff and Grant Accountants: Upon the new CFO's arrival, many of the duties for grant reporting as well as the majority of the month-end closing entries fell under one grant accountant. Some duties were delegated to the temp grant accountant, but a majority of the workload still fell to the other accountant. We will make sure that each grant accountant is trained on the grants they are responsible for as well as cross trained on other grants so grant reporting obligations do not go undone in the absence of one accountant. Person(s) Responsible: Steve Morenz, CFO Timing for Implementation: Current and ongoing Training the Accounting Staff in month end closing entries and the handling of material acquisitions and disposals: It was found during the audit that a new agency acquisition was not added to Project NOW's books properly, a new LLC had not been properly set up in the accounting system, and the sale of houses and the sale of vehicles were not handled correctly. The CFO will monitor such activities and make sure the proper accounting for such transactions is completed in the accounting system either at the time of sale or time of acquisition. Timing for Implementation: Current and ongoing Returning to and following a strict month end closing schedule, having the books closed by the 15th of each month: At one point, from the last corrective action plan to this one, the Finance staff was current with their month end closings. But with the transitions that occurred they had again fallen behind, and at one point being up to six months behind in closing the months. With a fully trained Finance department, starting in January 2026 we were able to close two months during each calendar month and were current with our statement's closings by March 2026. The staff will work diligently to maintain this schedule. This will also help ensure grant reporting is done on a timely basis as well. Person(s) Responsible: Steve Morenz, CFO Timing for Implementation: Current and ongoing Balance Sheet Account Review and Reconciliation: Apparently other than monthly bank reconciliations, there has been no balance sheet account review done for quite some time. Moving forward, the CFO will work with the accounting staff to see that reconciliations of all balance sheet accounts for all entities will be done regularly and correctly so we are better prepared for audit season. Person(s) Responsible: Steve Morenz, CFO Timing for Implementation: Current and ongoing Monthly departmental revenue and expense reports distributed to each director by the 20th of each month: Again, prior to the latest staffing transitions, R&E reports were sent to department directors every month. This practice then fell by the wayside. We have re-implemented the distribution of month financial reports to all directors showing all revenues and expenses for the departments they manage and the grants they are responsible for. Regular meetings will be held between the CFO, specific grant accountant, and the directors to review their statements to see how their department is running and their compare financial results versus their budget. This will also help monitor activity on the organization's income statement, making sure those balances are accurate and complete. Person(s) Responsible: Steve Morenz, CFO Timing for Implementation: Current and ongoing Person(s) Responsible: Steve Morenz, CFO

Consolidated Health Centers Grant – Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have found that our electronic medical record (eCW) is automatically classifying the federal poverty level (FPL) for all patients no matter if we have their insurance or household income inputted into the system. This has led to some inaccuracies in the rating of their FPL in eCW. We are actively manually overriding this setting, so we will have full control when to run the FPL after patient information is collected.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2024/2025 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2024/2025 P063P201430 Special Tests & Provisions: Enrollment Reporting Material Weakness in Internal Control over Compliance and Noncompliance not Considered Material Finding Summary: Fourteen instances were identified where the enrollment status reported to the National Student Clearing House did not match the student’s actual enrollment status. Responsible Individuals: Robert Hoover, Director of Financial Aid and Kristi Bagstad, Registrar Corrective Action Plan: The University will strengthen controls over enrollment reporting by implementing a reconciliation process that includes sampling of enrollment statuses prior to submission. In addition, procedures will be updated to ensure reports are submitted within required timeframes. A secondary review of enrollment files will be conducted prior to submission, and staff will receive training on reporting requirements. Periodic reviews will be performed to monitor ongoing compliance and accuracy. Anticipated Completion Date: August 1, 2026/ongoing

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2024/2025 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2024/2025 P063P201430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance not Considered Material Finding Summary: Two instances were identified where the amount of Title IV funds to be returned was not remitted correctly, and two instances were identified where the funds were returned in the correct amount but not in a timely manner. Responsible Individuals: Robert Hoover, Director of Financial Aid and Ashley Hantelmann, Associate Director of Financial Aid Corrective Action Plan: The Financial Aid Office will continue strengthening its Return of Title IV (R2T4) procedures to ensure accurate and timely processing. The secondary review process has been expanded and formalized, now including the Associate Director of Financial Aid to provide additional oversight. The R2T4 checklist has been updated to better align with compliance standards and ensure consistent documentation. Staff will receive ongoing training, and periodic internal reviews will be conducted to monitor compliance. Anticipated Completion Date: August 1, 2026

Disaster Grants - Public Assistance (Presidentially Declared Disasters) – Assistance Listing No. 97.036 Recommendation: We recommend the County establish and implement formal procedures requiring supervisory review and approval of all reports submitted to grantors. Evidence of review should be documented and retained, including the reviewer’s signature or electronic approval, the date of review, and the date of submission, to support compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County has established a review and approval process for quarterly reports. Reports will be reviewed and signed by a member of management to ensure accuracy and completeness of the data being submitted. Name of the contact person responsible for corrective action: Tanya Cannady, Business Services Director Planned completion date for corrective action plan: June 2026

Disaster Grants - Public Assistance (Presidentially Declared Disasters) – Assistance Listing No. 97.036 Recommendation: We recommend the County implement a formal review and reconciliation process to ensure that employees' hours reported on Activity Logs are verified against the reimbursement request prior to submitting it to the grantor. This review should be performed by personnel knowledgeable of the grant requirements and documented to evidence the review was completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will establish a process to maintain effective internal controls to ensure that the documentation is complete and accurately reflected in the reimbursement requests. An internal review and reconciliation process for employee activity logs will be performed prior to submitting to the grantor. Name of the contact person responsible for corrective action: Tanya Cannady, Business Services Director Planned completion date for corrective action plan: June 2026

2025-006 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit “in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.” 34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…” Condition: The College did not correctly report enrollment status changes for 21 out of 40 students tested (52.5%). We consider this condition to be a material weakness of the Special Tests and Provisions compliance requirement and is a repeated finding shown in Section IV of this report as prior year finding 2024-004. Statistical sampling was not used in making sampling selections. Responsible Person: Director, Financial Aid and Veteran Affairs, Director, Admission and Registration, and Administrative Information Systems (AIS) Corrective Action Plan: The Director of Financial Aid and Veteran Affairs will work with the Director of Admissions and Registration to review and update enrollment procedures, evaluate system configuration and reporting process related to the recent transition to Jenzabar One and Jenzabar Financial Aid, and establish a secondary review process to verify enrollment status changes prior to and after submission through the National Student Clearinghouse. Periodic internal monitoring will also be conducted to ensure compliance and strengthen internal controls. Implementation Date: May 2026

Finding 2025-002 Late Reporting and Noncompliance with Reporting Requirements Name of Contact: Charlanne Thomas, Finance Director Corrective Action Plan: The delay in completing the FY 2025 audit was an isolated occurrence resulting from a combination of staffing challenges and an audit timeline that did not align with the Borough's established accounting close cycle. The Borough has engaged Maureen Crosby, Contract Controller, to provide audit preparation services to ensure that the books are closed and all necessary documentation is available to auditors in a timely manner. The FY 2026 audit has been scheduled in accordance with the Borough's normal close cycle, with fieldwork beginning in the August and on-site work the last week of October, to ensure completion well in advance of the nine-month Uniform Guidance reporting deadline. Proposed Completion Date: May 31, 2026

Federal Program: 93.045/93.053, Department of Health and Human Services, Aging Cluster Condition per Auditor:The County engaged a third party contractor to perform certain eligibility reassessments, including obtaining verification of medical necessity, when required. While the County had a process in place to properly identify when reassessment was required and to follow up with the contractor about the status of reassessments, controls did not ensure the third party contractor followed through on reassessments on a timely basis. Planned Corrective Action: The Department of Senior Services would like to clarify that the third party contractor is contracted through The Senior Alliance, the Area Agency on Aging for region 1 C and not Wayne County.Wayne County Senior Services will continue to monitor the third party vendor for timely assessments and reassessments through the existing controls which include:• Providing the third party contractor monthly lists of clients in need of assessment/reassessment• Generating monthly lists of outstanding reassessments (clients not reassessed from the monthly list)• Reminding clients of the requirement for 6 month reassessments• Obtaining updated information (phone numbers, emergency contacts, etc.) twice per year • Providing updated information to third party contractor• Documentation of communicated information regarding third party contractor’s performance to The Senior Alliance Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Joan Siavrakas

Plan: Please see below the new process regarding filling vacancies and completing management duties in a timely manner: Immediate Focus on Vacancies: We are prioritizing the filling of vacant units by having two staff members complete move ins at the same time. Streamlined Recertification Process: We have updated our process to ensure all tenants are recertified in a timely manner. There has been a new system in place to monitor deadlines and improve efficiency. Staffing and Training: We are actively recruiting and training additional staff to ensure these tasks are handled promptly, preventing future delays. These steps will address the backlog of management duties and ensure that all tasks, such as filling vacancies and completing tenant recertifications, are handled in a timely and efficient manner. Completion Date: 5/1/2026 Contact: Jackie Oliveira-Director of Affordable Housing

Finding 2025-004 Plan: Please see below the new process regarding filling vacancies and completing management duties in a timely manner: Immediate Focus on Vacancies: We are prioritizing the filling of vacant units by having two staff members complete move ins at the same time. Streamlined Recertification Process: We have updated our process to ensure all tenants are recertified in a timely manner. There has been a new system in place to monitor deadlines and improve efficiency. Staffing and Training: We are actively recruiting and training additional staff to ensure these tasks are handled promptly, preventing future delays. These steps will address the backlog of management duties and ensure that all tasks, such as filling vacancies and completing tenant recertifications, are handled in a timely and efficient manner. Completion Date: 8/31/2025 Contact: Jackie Oliveira-Director of Affordable Housing

Management acknowledges through our previous responses that this finding is aligned with lack of leadership experience in financial aid. This has been resolved with the hiring of Ruth Casper and the separation of one individual where most of the finding’s evidence associated. Ruth Casper has been given specific direction of expectations and the latitude to enact immediate changes to the Barton College Financial Aid awarding/reporting processes to ensure timely and accurate operations/reporting. All Department of Education and Barton internal deadlines will be adhered to at all times going forward.

Finding 2025-004: Allowable Costs – Material Weakness in Internal Controls Over Compliance and Compliance Finding Summary of Finding: Duplicate charges were identified within grant reimbursement submissions across reimbursement periods. Management Response During FY2025, grant reimbursement review procedures were not sufficiently standardized to consistently identify duplicate charges submitted across reimbursement periods. Management is currently evaluating and formalizing enhanced grant reimbursement review workflows designed to improve consistency of review and reduce the risk of duplicate charges within reimbursement submissions. Planned procedures include reconciliation of reimbursement schedules to the general ledger, review of previously submitted reimbursement activity prior to submission of subsequent requests, and clarification of review responsibilities between management and the outsourced accounting team. Management is in the process of documenting these procedures and plans to implement the enhanced review workflow as soon as practicable. Separately, as part of ongoing remediation and compliance monitoring efforts, management has implemented a recurring quarterly Grant Utilization Review process intended to improve oversight of reimbursement activity, grant utilization, and reconciliation procedures across reimbursement periods. The first review meeting is scheduled for June 2026.

Summary of Finding: Supporting documentation for certain grant-related expenditures could not be located during compliance testing. Management Response The Organization maintained procedures requiring supporting documentation for grant-related expenditures during FY2025; however, supporting documentation was not consistently centralized or retained in a manner that allowed for efficient retrieval during audit testing. Management has since implemented centralized electronic document retention procedures for invoices, grant support, reimbursement documentation, and related approvals. Responsibilities for maintaining and reviewing grant documentation have been clarified between management and the outsourced accounting team to improve accountability and consistency of execution. In addition, grant reimbursement support is now reviewed prior to submission and retained electronically to strengthen ongoing compliance monitoring and audit support procedures. Management has also developed and implemented a recurring Grant Utilization Review meeting process designed to support periodic review of grant activity, supporting documentation, reimbursement status, and compliance-related matters. The first quarterly review meeting is scheduled for June 2026.

Summary of Finding: Documentation evidencing management approval was not available for certain expenditures selected during compliance testing. Management Response The Organization maintained procedures requiring management approval of invoices and expenditures during FY2025; however, documentation evidencing approval was not consistently retained during periods of staffing transition and operational change. Management has since enhanced and centralized invoice approval workflows within Accounting Seed to improve consistency of approval documentation retention. Approval responsibilities have been clarified by department and management level, and supporting approval documentation is now maintained electronically within the accounting workflow system. Management has also reinforced approval and documentation retention expectations with department leadership and accounting personnel and implemented periodic review procedures to improve ongoing compliance with internal policies and grant requirements.