Corrective Action Plans

Finding 2023-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Assistance Listing Numbers: 14.871, 14.879, and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility. Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 6,531 units. Of a sample size of seventy-seven (77) tenant files, the following was noted: - Section 214 citizen declaration form missing in 15 files - HUD 9887 consent to release information form missing in 2 files - Original application missing in 1 file - Annual inspection missing in 1 file - Lead based paint form missing in 4 files - Verification of income missing in 6 files Our sample size is statistically valid. Known Questioned Costs: 14.871 - Section 8 Housing Choice Vouchers - $36,728 14.879 - Mainstream Vouchers - $13,028 14.EHV - Emergency Housing Vouchers - $1,272 Cause: There is a material weakness in the Housing Voucher Cluster in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor, and will make the several changes to its inspection process to ensure enforcement of Housing Quality Standards (or any subsequent replacement). Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Shannon Koenig, executive director and CEO, is responsible for implementing this corrective action by December 31, 2024.

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-001 Responsible Party Name: Gina Rice Position: Director of Accounting Telephone Number: 816-238-4511 ext 131 Federal Agency U.S. Department of Agriculture Federal Program Emergency Food Assistance Program (Food Commodities) Compliance Requirements E - Eligibility Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will establish a process to ensure required eligibility documentation is maintained in accordance with federal program requirements which will include periodic monitoring and review performed by personnel not directly involved with program administration. Anticipated Completion Date June 2025

2023-001 Reporting – Late REAC Submission and Late OMB Data Collection Form Submission Section 8 Housing Voucher Cluster (Section 8): 14.871 Section 8 – Housing Choice Vouchers Material Weakness in Internal Control, Material Noncompliance Condition: The Authority’s audited Financial Data Schedule (“FDS”) filing was not submitted within the timeframes specified by HUD. The FDS filing was due by June 30, 2024, but the financials were not issued until June 3, 2025. The Authority was also required to submit the OMB Data Collection Form to the Federal Audit Clearinghouse (“FAC”) by June 30, 2024, but was not filed timely as the audit was completed on June 3, 2025. Recommendation: The Authority should ensure that they retain support for all required documentation and that it is organized and readily accessible. Storing documents electronically with frequent backups would help prevent loss of data from damage to any one location. Furthermore, the Authority should ensure that staff receives necessary training for proper document retention. Action Taken: To address the identified deficiencies and restore compliance with HUD requirements and the Trouble Recovery Agreement, the Authority will implement the following corrective actions: 1. Leadership and Governance Stabilization: Ensure that the new CEO is briefed on all relevant programs, financial updates, management, and strategic planning initiatives. Ensure that the Finance Committee, within the Board of Commissioners, continues to hold monthly meetings before all regular board meetings and monitors financial reporting, budget adherence, and audit readiness. Ensure that the Administrative Plan for the HCV Program is comprehensively updated to reflect current HUD regulations and strategies for program optimization. 2. Financial Staffing and Capacity Building: Maintain continuity in financial leadership by supporting the Interim CFO and ensuring adequate staffing, such as the new Staff Accountant in the Finance Department, to support audit preparation and HUD reporting. Develop a financial onboarding and training program for all new finance staff, with a focus on HUD systems (FDS, VMS, EPIC, LOCCS) and internal budget protocols. Ensure that Program and Finance Management staff of the HCV Program attend the HCV Financial Management and HCV Financial Accounting and Reporting sessions. 3. Budget Training and Accountability: Implement mandatory budget training for the Finance Department and the HCV Program Department, covering: Budget development and forecasting; Budget-to-actual variance analysis; HUD funding streams and eligible uses; Internal budget controls and documentation standards; Voucher Management System, FDS policies, and SOPs. Create an Accountability Chart for the Program and Financial Management of the HCV Program, outlining roles, responsibilities, and procedures for budget planning, monitoring, and reporting. Require monthly or biweekly meetings with budget reviews by department heads and mid-level managers, with variance explanations submitted to the CFO and CEO, and shared with the Board. 4. Fee Accountant Reinstatement and Optimize HCV Program Finances: Reinstate and formalize the partnership with BDO PHA Finance to support audit preparation, financial reporting, and staff training. Establish financial performance tracking, standard operating procedures (SOPs), contract compliance monitoring, and payment authorization protocols. 5. Technology and Data Management Improvements: Prepare the Chart of Accounts, Procure to Pay, and Voucher Management System (VMS), as well as the Two-Year Tool (TYT), and take other necessary financial steps to ensure a seamless transition from SACS to Reframe. Implement cloud-based storage and digital backup protocols to safeguard financial records and ensure continuity in the event of future disruptions. Establish a centralized digital archive for all financial documents, including budgets, invoices, contracts, and audit work papers. 6. Audit Readiness and Compliance Monitoring: Create an annual audit preparation calendar with clear deadlines for data collection, reconciliations, and internal reviews. Conduct monthly and quarterly internal audits to assess financial controls, procurement compliance, and budget adherence. Submit monthly and quarterly progress reports to HUD and the Board as part of the Troubled Recovery Agreement and internal HUD Recovery Strategic Plan, documenting improvements in financial management and audit readiness. 7. Transparency and Communication: Present monthly financial reports to the Board of Commissioners, including budget-to-actual comparisons and audit status updates. Publish an annual financial summary on the Authority’s website to promote transparency and public accountability

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: We will review items not fully implemented. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

Return of Title IV (R2T4) Planned Corrective Action: A process will be implemented to run a 0-credit report at the end of each semester. This will ensure withdrawals are followed up on and that R2T4s are completed timely, if required. A process will be implanted to track student attendance in classes. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

Common Origination and Disbursement (COD) Reporting and Reconciliations Planned Corrective Action: Procedures will be implemented to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

Incorrect Pell Calculations Planned Corrective Action: A process will be implemented to verify Pell is correctly awarded before disbursements are made. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

Need Analysis Planned Corrective Action: All scholarships will be marked as estimated financial assistance and an awarding check for need will be done accurately before final distribution. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

Enrollment Reporting to NSLDS Planned Corrective Action: A process will be created to ensure enrollment is reported timely and accurately. Spot checks of NSLDS will be performed on enrollment status throughout the year. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

ISIR Comment Resolution Planned Corrective Action: All ISIR comment codes will be resolved before disbursement of federal aid to students. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

Satisfactory Academic Progress Planned Corrective Action: The SAP policy will be reviewed or created as needed and a procedure will be implemented based on that policy. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

Lack of Administrative Capability Planned Corrective Action: The financial aid officer will participate in trainings specific to knowledge gaps. In addition, monthly entries will be made in the general ledger for financial aid activity and monthly balances will be reconciled between the general ledger and financial aid software. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

2023-011 Excess Food Service Fund Balance (Material Weakness) Management’s Response: We completed and Excess Balance Use of Funds report and worked with the State to understand exactly the parameters of this/ The funds were spent down and we are working hard to make sure to stay under the three months of expenses as worded in CFR Title 7, 210.14(b). Again management is trying to take on a bigger role as this monitoring was not considered prior to COVID. Fund Balances at year end averaged no more than $10,000. Name of Contact Person and Completion Date: Toni Butterfield Anticipated Completion Date - Immediately

Finding No . 2023-002: Annual Audit Submission Assistance Listing Program Title and Number: All Federal Agency: All Pass-through Entity: All Description of Finding: As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the Data Collection Form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors’ report, or nine months after the end of the audit period. The due date for the audit and reporting package submission was March 31, 2024. Statement of Concurrence or Nonconcurrence: The State Education Resource Center agrees with this finding. SERC experienced staffing shortages and related difficulties during the fiscal year. As such, SERC was not able to prepare timely for the audit for the Uniform Guidance, Data Collection Form, and reporting package to be filed by the due date. Corrective Action: In May of 2024, the State Education Resource Center hired a new Chief Financial Officer whose focus is to bring the organization up to date on all audits and reporting and to ensure that the Fiscal team has the proper tools and guidance to perform their tasks and to improve policy and process for the department. This will also aid in ensuring all necessary efforts will be taken to ensure timely submission of the audit, Data Collection Form, and reporting packages. Name of Contact Person: Jim Fried, Chief Financial Officer, 860-740-4263, fried@ctserc.org will be responsible for completing the corrective action plan. Projected Completion Date: The anticipated date for completing the corrective action plan is June 30, 2025. The action plan will be monitored on a bi-annual basis to ensure ongoing compliance.

Finding No . 2023-001: Financial Reporting Assistance Listing Program Title and Number: All Federal Agency: All Pass-through Entity: All Description of Finding: In fiscal year 2023, SERC’s accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The books and records were not closed and finalized timely. Numerous adjustments to the trial balances were made, necessitating revisions to account reconciliations, and grant schedules. Statement of Concurrence or Nonconcurrence: The State Education Resource Center agrees with this finding. The Fiscal Department experienced staff shortages and related difficulties during the fiscal year. Because of this the books and records were not closed and completed until many months after the year end. In addition, SERC’s accounting processes and internal controls over financial reporting did not function properly. Corrective Action: In May of 2024, the State Education Resource Center hired a new Chief Financial Officer whose focus is to bring the organization up to date on all audits and reporting and to ensure that the Fiscal team has the proper tools and guidance to perform their tasks and to improve policy and process for the department. Name of Contact Person: Jim Fried, Chief Financial Officer, 860-740-4263, fried@ctserc.org will be responsible for completing the corrective action plan. Projected Completion Date: The anticipated date for completing the corrective action plan is June 30, 2025. The action plan will be monitored on a bi-annual basis to ensure ongoing compliance.

Klawock Cooperative Association has switched its contract accountant. They will work closely with management to close out the books and records timely including the accuracy and completeness of the Schedule of Federal Awards and be better rained in identifying, recording and administering funds that are provided directly to its subrecipients.

Finding Number: 2023-004 Finding Title: Eligibility Program: 21.023 COVID-19 – Emergency Rental Assistance Program Name of Contact Person Responsible for Corrective Action: Daniel Rahkola, Division Director Finance Corrective Action Planned: Staff will be retrained on the procedures to ensure compliance with the needed standards. Anticipated Completion Date: June 30, 2025

State and Local Recovery Funds – Report Testing Recommendation: We recommend that the District reviews its procedures and controls over reporting for the Coronavirus State and Local Fiscal Recovery Funds program to ensure all reports are accurately reporting information and are reviewed by someone other than the preparer and that review is documented prior to submission of the report. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will establish procedures to ensure reivew of reports prior to submission by someone other than the preparer. Name(s) of the contact person(s) responsible for corrective action: Tariro Chapinduka, Director of Business Services Planned completion date for corrective action plan: June 30, 2025

Child Nutrition – Report Testing Recommendation: We recommend that the District reviews its procedures and controls over reporting for the Child Nutrition Cluster program to ensure all reports are accurately reporting information and are reviewed by someone other than the preparer and that review is documented prior to submission of the report. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will review its procedures over its reporting of claims to MDE to ensure claims made to MDE is properly supported by the District's meals count. Name(s) of the contact person(s) responsible for corrective action: Tariro Chapinduka, Director of Business Services Planned completion date for corrective action plan: June 30, 2025

Federal Award Findings: Finding 2023-004 Reporting – Late REAC Submission and Late OMB Data Collection Form Submission 14.155 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects 14.195 Section 8 Housing Assistance Payments Program Material Weakness in Internal Control – Material Noncompliance Condition: The Organization’s annual financial statement data was not submitted within the timeframes specified by HUD. The financial statement data was due by March 31, 2024, but the financials were not issued until May 20, 2025. The Organization was also required to submit the OMB Data Collection Form to the Federal Audit Clearinghouse (“FAC”) by September 30, 2024, but was not filed timely as the audit was completed on May 20, 2025. Auditor’s Recommendation: We recommend that the Organization make every effort to submit its annual financial statement data within the timeframe specified by HUD. Action Taken: The Organization has maintained contact with HUD and prioritized submitting the annual financial statement data after they were informed it was late. Effective Date: May 20, 2025 Contact Information: Kristy Hust, Director of Operations Northside Mental Health Center, Inc. Management Agent 12512 Bruce B Downs Blvd Tampa, FL 33612 (813) 977-8700

Action Taken: • We are producing a timetable and posting it to calendars of the filing dates of all key reports to the relevant authorities and are circulating it widely to all executives including the Board and Finance Committee. • This recommendation is also supported by the work undertaken on invoice approval, monthly review of financials and updates on the policy on Grants and Federal Awards. • We are also in the process of recruiting a new full-time Finance Director.

Action Taken • Updated the Association’s financial processes and guidelines around invoice approval. • Made better use of the AP/Invoice management system (bill.com) to ensure invoices are routed to the correct approvers and to the correct ledger accounts. • Simplified the chart of accounts to provide less scope for error. • Now preparing financial statements monthly, instead of quarterly and comparing variances against prior month and monthly budget, which will generate any anomalies.

Action Taken: Management has implemented the following measures to address the issue and prevent future occurrences: • Improved the segregation of duties between the approval, recording and the booking of all expense transactions. • Automated the uploads of credit card transactions directly into the accounting system to prevent any manual manipulation and reconciled the transactions to the statements. • Updated the Association policies around vendor management and allowable/non allowable operating expenses. • We terminated the employee prior to discovering the fraud.

U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted that 21 out of 40 transactions tested exhibited a variance in the recalculation of wages charged to the program. This variance was identified when comparing the wages charged to the program with the time and effort documented on the timesheet for the respective programs. Recommendation: We recommend the time and effort documentation be regularly reviewed by appropriate personnel to ensure accuracy and completeness of personnel cost documentation is appropriately reported to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a new process for wages charged to a program to ensure accuracy. This will also be monitored regularly and tracked through the accounting software in the grant spend management module. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.

U.S. Department of Health and Human Services U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance Community Service Block Grant – Assistance Listing No. 93.569 Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/24/22 - 1/6/23, which the first eight days were prior to the start of the period of performance. There was also one transaction selected for testing where no supporting documentation was able to be located and one transaction that was incurred after the period of performance for the program. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Organization expanded contract compliance to include financial contract compliance. The organization will also implement grant tracking and spend management modules in the accounting software to assist with monitoring expenses applied to contracts. A new process will also be implemented regarding payroll related expenses to ensure the correct period is used for federal expenditures. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.