Corrective Action Plans

Finding 2026-002: Significant Deficiency – Enrollment Reporting Program: Student Financial Assistance Cluster – Federal Direct Loans and Pell Grants Assistance Listing Number (ALN): Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2026 Condition: For one of 25 students who were tested, the student’s withdrawal status was reported to NSLDS late, 71 days after the date of determination. For one of 25 students who were tested, the student’s graduation date was reported incorrectly to NSLDS. The College’s controls over enrollment reporting did not detect the errors. The sample was not a statistically valid sample. Corrective Action Plan Management agrees with the finding and is committed to strengthening its procedures to avoid similar issues in the future. Beginning in September 2026, a second and new Registrar’s Office staff member will be trained in to complete an additional review of the National Student Clearinghouse status for all students withdrawing after a particular semester. This secondary review will be completed at the end of January and at the end of June to ensure the 60-day reporting period is met. We will manually update the graduated enrollment status start date for the impacted student to the correct date through the National Student Clearinghouse. We will reach out to the National Student Clearinghouse to determine why the graduation date that was reported on the degree file does not match the date that was used when the student’s enrollment record was updated by the Clearinghouse using the graduated enrollment status from the degree verified process. Completion Date: November 1, 2026 Name(s) of Contact Person(s) Responsible for Corrective Action: Nathan Engle, Controller Email: Engle1@stolaf.com

2026-001 Period of Performance Corrective action planned: The organization will implement an additional step to review personnel cost categories that may have the potential of including out-of-period costs (e.g., performance bonus payments, contractual lump sum payments) and verify that these expenses are allocated to the correct award cycle. If out-of-period transactions are identified, the organization will ensure that these expenses are allocated to unrestricted general operating funds. Anticipated completion date: October 2026 Contact person responsible for corrective action: Harjeet Sidhu, Chief Financial Officer

FINDING 2026-003 Name of Responsible Individual: Courtney Thompson-Ballard, Director of Financial Aid Corrective Action: Upon review of the data that was reported inaccurately, it was determined that updating this data point, the earliest enrollment date for the award year, via a systems integration was not the most reliable way to update the value. An internal system within the Financial Aid Management System (FAMS) will be used to populate this date going forward. The Financial Aid Office will add an additional quality check post origination as well to ensure accuracy. Anticipated Completion Date: September 30, 2026

2026-003 Period of Performance (repeat of finding 2025-003) Corrective action planned: The former CEO of OMC did not understand Generally Accepted Accounting Principles and, specifically, Accrual Accounting. He did not allow the Accounting Department to make accrual entries monthly. At the beginning of FY 2026 - 2027, the CFO/DFO required the accrual of payroll each month to accurately reflect the personnel expense of OMC. OMC accounting staff will utilize the Sage Impact® Accounting System to accrue other expenses that were incurred in the period but not yet paid, so that only cost for goods and/or services incurred within the approved budget period are reflected accurately in monthly financial reporting and costs are not allocated outside the budget period. The CFO/DFO has developed an accrual template so that utility bills that cross periods, such as one example in this report, are properly accounted for and allocated to the correct period. This will also be monitored by the external independent financial consultant and the CEO who is a degreed accountant. Anticipated completion date: 08/31/2026 Contact person responsible for corrective action: Allen Boyd, Director of Fiscal Operations

2025-003 Period of Performance - Community Development Block Grants/Entitlement Grants Cluster Assistance Listing Number 14.218 Grant Period - Year Ended December 31, 2025 Condition Found The City did not meet program timeliness spending requirements. The City’s unexpended balance at December 31, 2025 of $2,435,653 is more than 1.5 times the $1,303,056 entitlement grant for the current year. We consider this to be an instance of non-compliance relating to the Period of Performance Compliance Requirement. Corrective Action Plan The City of Decatur met CDBG timeliness spending requirements in 2026 and is currently in compliance. To maintain compliance, the Economic & Community Development Department will regularly monitor expenditure rates, unexpended balances, and project schedules; coordinate with staff and subrecipients to address delays; and ensure timely reimbursement processing and drawdowns. These ongoing oversight measures will help identify and resolve spending concerns before future timeliness assessments. Responsible Person for Corrective Action Plan Lacie Elzy, Economic & Community Development Director Implementation Date of Corrective Action Plan September 30, 2026

U.S. Department of Health and Human Services 2025-002 Rehabilitation for Survivors of Torture in Minnesota/Ethnic Community Self- Help Program; Refugee and Entrant Assistance – Assistance Listing No. 93.576 Recommendation: Auditor recommends that organization improve grant tracking to ensure that only costs incurred within the period of performance are included in the reimbursement requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Expenditure trackers are being updated for ease of use and will include notes on exact end of contract dates instead of just the month and year. This will take place starting in Q4 2026. Name(s) of the contact person(s) responsible for corrective action: Nasreen Sajady Planned completion date for corrective action plan: 10/13/2026

Finding Number: 2025-041 Finding Name: Inaccurate RSA-911 Performance Reports for the Vocational Rehabilitation Program Finding Condition(s): The Illinois Department of Human Services (IDHS) does not have an adequate process in place to ensure the Case Service Report (RSA-911) performance report for the Rehabilitation Services Vocational Rehabilitation Grants to States (Vocational Rehabilitation) program is complete and accurate. Additionally, the auditors noted that the supervisory review procedures performed for this report were not designed to operate at an appropriate level of precision to ensure the special report was accurately prepared. Name of Contact Person(s): Rochelle Chambers-Hyndman, Audit and Quality Assurance Administrator – Illinois Department of Human Services, Division of Rehabilitation Services Corrective Action(s): The IDHS has adjusted the report query to obtain the information needed for reporting from the case management system. The new query will ensure that the information is accurate and agrees to data documented in the program beneficiary case file. Additionally, the IDHS will implement a quarterly review process to ensure reports submitted are complete, accurate, and agree with the case management system and underlying file documentation. Proposed Completion Date: October 31, 2026

FINDING 2025-017: Controls Over SRF Reimbursement Requests Response: The City again agrees with the auditor’s recommendation and will include reporting and reimbursement rules and guidelines in the new Grant & Federal Funding policy currently being developed by the Finance Department. We have also created a central location for all grant documentation to be stored in order to keep all documentation available to everyone involved in grant-related transactions. The new process/policy will also include additional review requirements.

Audit Finding Reference: 2025-002 Improve Internal Controls Over Reporting and Period of Performance Planned Corrective Action: The Town has reviewed the processes and internal controls related to reporting and the period of performance. Going forward, the Town will ensure that appropriate procedures are followed to support accurate and timely reporting and compliance with applicable period-of-performance requirements. Management will continue to monitor these processes to ensure that internal controls remain effective. Planned Implementation Date of Corrective Action: Fiscal Year 2027 and ongoing. Person Responsible for Corrective Action: Michelle Leary and Bethiny Moseley

Finding No.: 2025-006 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster (IDEA) 84.181 Special Education – Grants for Infants and Families 84.403 Consolidated Grants Federal Award No.: H027A230013 H181A220008, H181A230008 S403A220002, S403A230002 Area: Period of Performance Questioned Costs: $0 Views of Auditee and Corrective Actions GDOE does not agree with the condition that “GDOE does not have internal control to ensure that liquidation of the obligation occurs within the allowable period of time”. GDOE has existing procedures which includes bi-weekly / weekly monitoring meeting of the program team and financial affairs. The meeting agenda would always include the expiration and liquidation dates of the grants. However, GDOE acknowledges the need to include the controls and procedures addressing liquidation deadlines in the Standard Operating Procedure (SOP) 200-034 for Accounts Payable and Cash Disbursement Procedures. Plan of action and completion date: SOP 200-034 will be updated to include the controls and procedures addressing liquidation deadlines. Federal Programs, program managers, Accounts Payable, and Financial Affairs will maintain a grant closeout schedule identifying each awards period of performance end date, liquidation deadline and outstanding obligations. Periodic review will be performed before liquidation deadlines, with aging items escalated for resolution. Closeout procedures will document required coordination among program, procurement, receiving, accounts payable, and Financial Affairs. Plan to monitor and responsible officials: Federal Programs Division and Financial Affairs/Accounts Payable, with applicable program managers. Additionally, the Internal Audit Office will monitor federal grant statuses and identify associated risks to include period of performance and report any deficiencies to respective divisions and GDOE leadership.

Finding No.: 2025-009 Federal Agency: U.S. Department of Education AL Program: 84.181 Special Education – Grants for Infants and Families Federal Award No.: H181A220008 Area: Period of Performance Questioned Costs: $32,733 Views of Auditee and Corrective Actions GDOE agrees with the condition but does not agree with the cause. Management notes that the exception represented one of 36 transactions selected for testing and was identified as an isolated instance. The 2022 grant was approved for a late liquidation and was only opened for a short period of time. Nevertheless, GDOE recognizes that all federal expenditures must be liquidated within the applicable timeframe and that adequate controls should be maintained to identify and resolve outstanding obligations before the expiration of the liquidation period. Management will strengthen its grant closeout monitoring procedures to reduce the risk of outstanding obligations remaining unresolved beyond applicable federal liquidation deadlines. Plan of action and completion date: GDOE will strengthen controls over the monitoring and timely liquidation of federal award obligations. GDOE will: 1. Perform periodic reviews of outstanding obligations and unpaid expenditures in advance of applicable liquidation deadlines. 2. Coordinate among Federal Programs Division, applicable program personnel, Procurement, receiving personnel, Accounts Payable, Financial Affairs and office in-charge of the drawdown to identify and resolve outstanding transactions before the liquidation deadline. 3. Establish escalation procedures for obligations that remain outstanding as the liquidation deadline approaches so that responsible personnel and management can take timely corrective action. 4. Evaluate the need for an extension request when circumstances prevent timely liquidation and an extension is permitted under applicable federal requirements. 5. Document the resolution of outstanding obligations and retain supporting documentation demonstrating that expenditures were liquidated within the applicable timeframe. 6. Periodically review grant closeout activity to identify recurring processing delays and implement additional corrective measures when necessary. Plan to monitor and responsible officials: The Federal Programs Division, applicable program management, and Financial Affairs Accounts Payable will be responsible for monitoring the implementation of corrective actions. Corrective actions will be initiated with the FY2026 grant closeout cycle, with ongoing monitoring thereafter.

The SLFRF Project and Expenditure Report periods have been filed and no further reporting is required from these specific federal grant rewards. Future grants requiring reporting will be thoroughly reviewed for reporting specifications. Although no funds were misspent or inappropriately used, the County understands the need for correct timing when reporting the grant funds held, encumbered, and expended. The County has since created a grant acceptance template, required to be used by all departments, which will be used to identify who is responsible for future grant reporting requirements. The County will work to ensure all affected departments are aware of specific reporting requirements and that those requirements are followed.

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2025-012 1. Finding Summary The auditor determined that the institution disbursed Pell Grant funds more than 10 days prior to the first day of classes, in violation of federal Title IV disbursement timing requirements. As a result, the institution could not demonstrate compliance with applicable federal regulations governing the timing of Pell Grant disbursements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that Pell Grant funds were disbursed earlier than permitted under federal Title IV disbursement timing requirements due to a miscalculation of the days. 3. Root Cause Analysis The root cause of this finding resulted from by inaccurate or prematurely scheduled disbursement dates, limited coordination between the Financial Aid and Business Offices on the approved disbursement calendar, and insufficient controls to ensure Pell Grant funds were released in accordance with federal timing requirements. 4. Corrective Action(s) Management will implement a standardized calendar of disbursement dates annually based on the academic calendar. Description of Corrective Actions Management will prepare an annual disbursement calendar based on the academic calendar, which will be reviewed by both the Business Office and Office of Financial Aid to ensure compliance to federal Title IV disbursement timing requirements. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of early federal disbursements by strengthening oversight, implementing a disbursement calendar, and reinforcing staff understanding of federal timing requirements. 6. Responsible Party • Office/Department: Business Office • Title of Responsible Official: Senior Accountant • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: ~ Yes D No • If not fully implemented, expected completion date: 8. Status of Corrective Action (For Prior-Year or Repeat Findings) ~ Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation Academic Year 2026-2027 Disbursement Calendar. 9. Monitoring and Sustainability The University will continue to prepare a disbursement calendar annually before any new year disbursements are made. 900

The County Commissioners and Auditor will monitor this internally.

Contact Person: Manny Citron, Chief Operating Officer Recommendation: MACH2 should review and update its internal control policies and procedures to ensure transactions are consistenly processed, approvals are clearly documented, and indiviudals responsible for the recorded of transactions are aware of their responsibilities. Action: MACH2 will continue to strengthen and refine its internal control policies and procedures thorughout 2026, with a focus on improving the consistency of processing transactions, documenting payment approvals, and providing clear roles and responsibilities for individuals involved in the recording of financial transactions. Date of Completion: December 31, 2026

Finding Number 2025-227: The Division does not have documented control procedures in place to ensure compliance with period of performance requirements for the Rehabilitation Services-Vocational Rehabilitation Grants to States. Federal Program: 84.126 - Rehabilitation Services - Vocational Rehabilitation Grants to States Related to Prior Finding: N/A Agency’s view: The agency agrees with this finding. IDVR acknowledges that the controls during the audit period were insufficient to ensure expenditures were consistently allocated to the correct federal award period. Corrective Action: Since November 2025, IDVR has implemented a comprehensive period-of-performance review process designed to ensure compliance with federal grant requirements. As part of this process, the Strategic Leadership Team reviews and determines when obligations should transition between federal fiscal year awards. Based on this direction, IDVR Data Manager updates system configurations and budget parameters within the AWARE case management system to ensure expenditures are assigned to the correct federal award. In addition, IDVR implemented a testing process in which the Data Manager and Program Analyst verify that expenditures are coding appropriately following budget updates. IDVR has also incorporated period-of-performance reviews into its quality assurance and compliance review process for case service expenditures. Invoice batches are reviewed before liquidation, or reimbursement requests are submitted to ensure expenditures are allocated to the proper grant award. These reviews are conducted by Quality Assurance and Compliance Analysts, Financial Specialists, the Financial Officer, and, when appropriate, Agency leadership, including the Deputy Administrator and Administrator. Through these layered review processes, IDVR has established documented internal controls designed to ensure compliance with period-of-performance requirements and has successfully utilized these controls since implementation as evidenced by approved RSA reimbursements of expenditures based upon both period of performance and allowability reviews completed by RSA on all expenditures reimbursed as required under route payment that IDVR has been engaged in with RSA since October 2024. IDVR is in the process of obtaining approval from RSA within drafted Grant’s Management Chapters for the policies, procedures and internal controls related to assurances of proper grant assignment based upon period of performance. Once approval is provided, IDVR will finalize, implement, and train on the approved policies, procedures, and internal controls that align with processes already in practice as of November 2025. Anticipated Corrective Action Date: January 30, 2027 Responsible for Corrective Action: Heidi Smith, Financial Officer Heidi.Smith@vr.idaho.gov (208) 287-6457

Special Programs for the Aging, Title III, Part C, Nutrition Services Assistance Listing No. 93.045 Nutrition Services Incentive Program – Assistance Listing No. 93.053 Recommendation: Management at Sound Generations should review its existing control structure and ensure that there are adequate processes and controls to ensure program income is recorded correctly for Federal programs, based on the underlying supporting documentation. Management should also continue to reinforce review procedures over program income reporting to help ensure recording errors are detected and corrected on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Sound Generations is reviewing and revising our control structure using our new software and new staff with the appropriate experience. Name(s) of the contact person(s) responsible for corrective action: Kristina Morgan, Controller, at 206-445-5671. Planned completion date for corrective action plan: major initiative to be completed in 2027.

Finding 2025-006: Information on the Federal Program: Disaster Grants – Public Assistance | Name of Contact Person: Anthony Gattuso, Vice President Accounting Operations | Corrective Action Plan: Atrium Health CMHA management has enhanced the FEMA expenditure review and approval process by implementing procedures to ensure all supporting documentation related to the review, approval, and monitoring of FEMA-funded expenditures is retained in a centralized and accessible location. Management established documentation requirements and provided guidance to responsible personnel to ensure sufficient evidence is maintained to demonstrate that controls have been performed and reviewed as designed. Periodic monitoring will be conducted to verify compliance with these documentation retention requirements. | Proposed Completion Date: Completed July 2025.

In early 2026, Hamilton County Area Neighborhood Development, Inc. (HAND) hired an experienced controller to prepare the parent and subsidiaries financials. HAND will establish effective internal control systems to ensure compliance with the requirements for grant agreements and cash management compliance requirements.

Finding number: 2026-005 - Noncompliance with Required Project Deliverable Timeline Condition: Blue Krewe did not complete the required rooftop solar installation within the established Year 1 performance period. Management represented that it has remained in communication with the City regarding the status of the project and that no concerns have been raised by the City; however, written documentation from the City approving the delay was not available. Views of responsible official: Management acknowledges that the rooftop solar installation was not completed within the original Year 1 performance period. Management has been communicating with the City regarding the project and will continue to coordinate with the City regarding completion of the required deliverable and obtain and retain written documentation of any approved changes to the project timeline. Expected Completion date: November 30, 2026

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 2025-011 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

We agree that the State and Local Fiscal Recovery Funds (SLFRF) Project and Expenditure Report was overstated by $1,059,739.66 for the grant period ended December 31, 2025. We contract with Bricker, Graydon, Wyatt LLP to complete the SLFRF reporting. We understand that we should review the report as it is completed by the law firm. Interest earned on SLFRF funds do not have to be remitted to the US Department of Treasury and is not subject to the SLRFR program use restrictions. Therefore, the issue deals primarily with reporting and classification. The County will review and reconcile all expenditures reported under the SLFRF grant receipts, interest earnings, expenditures, and amounts reported to the US Department of the Treasury. The County will ensure expenditures are accurately classified and reported according to the source of funds and applicable Treasury reporting requirements. We will review the report after it is prepared by the law firm and approve the reconciliation before the report is submitted. The reconciliation will specifically distinguish SLFRF award funds from interest earnings and other non-SLFRF revenues.

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

FINDING 2025-001 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Lisa Clark/Benock Contact Phone Number and Email Address: 812-885-2502 lcbenock@knoxcounty.in.gov Views of Responsible for Corrective Action: We concur with the finding. Description of Corrective Action Plan: The annual reporting for fund 8950 – Coronavirus State and Local Fiscal Recovery Funds with the Treasury shall be reviewed by an independent accountant to verify that all the information is correct and reported per reporting compliance guidelines. In addition, the County Auditor will review the expenditures agree with the ledger. Anticipated Completion Date: April 30, 2027, the due date of the next annual reporting in 2027