Corrective Action Plans

Incomplete FAIN Award Amount Disclosures – TANF – DPHHS - The Montana Department of Public Health and Human Services will revise its existing subaward agreements to update the required federal award disclosures, specifically by identifying the obligation amount associated with each Federal Award Identification Number (FAIN). The department will also include the obligation amount by specific FAIN in all new agreements moving forward. The department plans to fully implement this corrective action in October 2026. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 10/30/2026

Inaccurate RSA-911 Case Service Report - Voc Rehab - DPHHS - The Montana Department of Public Health and Human Services strengthened internal controls in August 2026 to ensure employment start dates are consistently and accurately captured in the RSA-911 report. The employment start date information was present in the department's case management system (Madison) and in case documentation; the condition arose in the system's reporting extraction layer, which caused accurate underlying data to be misstated in the submitted report. Because approximately 75 percent of cases in each RSA-911 submission carry forward from one reporting cycle to the next, the defect in the reporting layer affected multiple reporting periods. The department corrected the system's program field data in August 2026, prior to submitting the April through June 2026 RSA-911 report due that month. The department also implemented a validation check to detect and correct mismatches in future reports. The department has implemented corrective action and is working with its federal grantor agency to correct the reports submitted in fiscal year 2026. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 8/21/2026

Noncompliant Closeout Reporting - O&M - DMA - The Montana Department of Military Affairs concurs with the finding. In August 2024, the department and the United States Property and Fiscal Office (USPFO) identified older awards that remained open and should have been closed by prior staff. From August through December 2024, the department worked with the USPFO to identify, reconcile, and close the outstanding awards. The department has since implemented a master award tracker to identify each award’s period-of-performance end date, applicable closeout deadline, and report status. The department reviews the tracker regularly and notifies staff of approaching closeouts to ensure final reports are accurate and submitted within required timeframes. Responsible Party - Janae Brower, Chief Financial Officer, Montana Department of Military Affairs Target Implementation Date - 11/30/2026

Inadequate Grant Reconciliations - SPED - OPI - The Montana Office of Public Instruction will update procedures and desk manuals to ensure monthly reconciliations for federal programs between the agency’s grant system, the state’s accounting system, and a manually updated tracking spreadsheet contain adequate documentation and verify federal compliance. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 9/30/2026

Inadequate Payroll Certification Controls - R&D - UM - The University of Montana - Missoula will work with Information Technology to confirm that Personnel Activity Report reminder emails are sent on the correct schedule and to the appropriate individuals, including the Office of Sponsored Programs. The University will provide Personnel Activity Report certification training to the campus and will conduct targeted outreach for departments with outstanding records. After the current cleanup effort is completed, Grants and Contracts Officers will review outstanding Personnel Activity Reports quarterly and follow up as needed to promote timely certification. Responsible Party - Nicole Thompson, Director, Office of Sponsored Programs, University of Montana - Missoula Target Implementation Date - 2/28/2027

Inadequate Grant Expenditure Reconciliations - R&D - UM - The University of Montana - Missoula has implemented the remediation plan from the prior audit by establishing an additional periodic supervisory review to monitor ledger completion. Managers currently review a random sample of five files each month from each grants and contracts officer’s workload to verify that ledgers are current and complete, and any deficiencies identified are promptly addressed to ensure compliance with established procedures. Responsible Party - Nicole Thompson, Director, Office of Sponsored Programs, University of Montana - Missoula Target Implementation Date - 3/1/2026

CORRECTIVE ACTION PLAN2025-001 [2023-001]—TRACKING AND VALUATION OF MORTGAGE RECEIVABLES AND AMOUNTS DUE TO GRANTORType of Finding: (A) Material Weakness in Internal Control Over Financial ReportingStatement of ConditionWhile the Housing Trust has begun a complete review of its loan portfolio, the project has not yet been completed. Therefore, we were unable to obtain sufficient audit evidence to support the Housing Trust’s tracking and valuation of its mortgage receivables and amounts that are due to grantor.Per our audit procedures, we noted that management was unable to provide the following:A reasonable methodology for estimating its allowance for loan losses.Funding provided by grantors for the loan programs that should also be classified as amounts that are due to grantor.Not all current year loans were recorded in the general ledger (approximative $512,066) and approx. $481,201 were recorded twice.A net prior year adjustment of $36,460 for mortgages receivable and $35,000 for land leases held was necessary.Reclassification between loans accounts and grant revenue were necessaryContextThe Housing Trust has a portfolio of over six-hundred individual mortgage receivables that include both non-amortizing and amortizing loans, which management has valued at approximately $25,291,075. These loans have been funded by several sources, including federal, state, and local funding. Some of the grantors have established in their agreements that these funds do not belong to the Housing Trust, but actually belong to the grantor. CriteriaThe Housing Trust should ensure it has a board-approved policy for its loan portfolio to ensure that these assets are properly tracked, classified, and maintained with specialized loan management software that can perform the following:Loan Classification and TrackingEach loan is properly identified with its funding source (federal, state, local, etc.) and type of restriction Each loan agreement has the funding source specifiedThe current status of each loan is tracked (current, delinquent, defaulted)Loan funding that has been established as due to the grantor is properly tracked.Compliance and ReportingEnsure the loans comply with the specific guidelines of their respective funding source. Audit trails are available for all transactions and valuations.The receivables and related interest accruals supported by the loan management software should be reconciled to the Housing Trust’s accounting software.Financial TrackingThe valuation of the portfolio should be updated periodically (at least quarterly) for any changes in loan status or market conditions.All new loans should be recorded in the general ledger A loan loss policy was established that includes a loan loss methodology incorporating risk classes based on the borrower’s ability to repay. However, the calculations seem to follow a different methodology established afterwards. The policy should be updated with calculation methodology and with the backup research of historical data. A loan review committee should be responsible for reviewing and approving the classifications of loans and the associated allowance for loan losses which should be supported by high-quality data collection on each borrower’s payment history and any relevant economic indicators. The calculations and methodology should follow the approved policy, or the policy should be improved to include all factors mentioned above.EffectThe auditors were not able to verify the accuracy of the loan records and financial statements related to mortgage loans, the related accrued loan interest, the allowance for loan losses and loan funding that should also be recorded as due to grantor. CauseWhile the Housing Trust has begun a complete review of its loan portfolio, the project has not yet been completed. Therefore, the loan portfolio tracking and valuation have not yet been designed or implemented to support its policies and procedures or provide the loan review committee with a workable system for reviewing, approving and monitoring the organization’s mortgage receivable portfolio. The methodology seems to be changing, and the calculations do not seem to be accurate,RecommendationWe recommend the Housing Trust update policies and procedures for its loan portfolio as identified in the “Context” section of this finding to include methodology, risk assessment, historical loan data research, calculations method with reasoning.View of Responsible OfficialThe Housing Trust acknowledges the finding. Due to turnover in prior years, historical loan records and tracking systems were incomplete or inaccurate. Since then, SFCHT has taken the following steps:A second title company has been contracted to obtain final loan data for the 2026 loan portfolio. A title company will also be engaged annually at year-end to identify and resolve any differences arising during the year.Establish one master loan inventory using Portfol data. This inventory will serve as the master loan control schedule for monthly financial reconciliations. All differences will have a documented resolution, including reconciliation of receivables and related interest between the two systems. Reconciliations will be completed by the 15th business day of the following month.Create a new loan-recording process for every loan closing.Create a Due to Grantor Matrix based on findings from the annual loan review performed by the title company. Supporting documentation, such as grant agreements, correspondence, or other applicable documentation, will be maintained.Review the ASC 326 loan loss methodology to ensure it reflects the actual calculation methodology and is supported by appropriate research. This review will be performed quarterly.Establish a formal loan review committee and process to review loan calculations and the allowance for loan losses. The committee will meet quarterly and review reports from Portfol. Meeting minutes will document updates, decisions, and changes.Corrective Action Plan TimelineFinalize and implement the loan loss methodology: by December 2026Begin monthly Portfol-to-QBO reconciliations: by September 2026Fully hand over all loans to Amerinat by end of 2026; Land Leases will remain “in-house”Continue staff training and Executive-level reviewDesignated Employee Responsible for Corrective Action-Director of Operations-Accounting Specialist2025-002 [2023-002]—FINANCIAL CLOSE AND RESTATEMENTS TO BEGINNING NET ASSETSType of Finding: (A) Material Weakness in Internal Control Over Financial ReportingStatement of ConditionDuring the audit of the financial statements, we noted that material adjustments and restatements were necessary to correct errors in the current and previously reported financial statements. A summary of the areas and the net effect of the changes are as follows: Type Amount, net Accounts Receivable $ (13,490) Grants and Contracts Receivable 830,747 Accrued Interest 5,798 Amortizing Loan Receivable 419,551 Non-Amortizing Loans Receivable (433,722) Land Held in Trust (61,323) Other Assets (145,000) Prepaid Expenses (61,940) Notes Receivable (195,000) Developments Projects (184,559) Real Estate Inventory to Sell (333,079) Fixed Assets (785,081) ROU Accumulated Amortization (7,511) Accounts Payable (807) Due to Grantor 10,000 Grant Advances (97,963) Accrued Expenses (6,249) Other Current Liabilities 52,841 Lease Liabilities 7,845 Notes Payable (9,710) Net Assets 1,154,733 Total $ 146,081 CriteriaAccounting Standards Codification (ASC) 265 “Presentation of Financial Statements—Communicating Internal Control Related Matters Identified in an Audit” requires that deficiencies in internal control over financial reporting be communicated to those charged with governance when the design or operation of a control does not allow management or employees to prevent or detect misstatements on a timely basis.The correction of material misstatements indicates the existence of a material weakness in internal control over the maintenance of the organization’s financial statements.EffectThe material adjustments and restatements resulted in significant changes to the current year balances and beginning balances of the organization’s unrestricted and restricted net assets. These adjustments could potentially undermine the stakeholders' confidence in the financial information presented by the organization and may lead to difficulties in securing future funding or maintaining current donor relationships.CauseThe material misstatements were caused by a weakness in the development and implementation of internal controls and financial reporting processes, as well as significant turnover in the organization’s management.RecommendationWe recommend the Housing Trust strengthens its internal controls and financial reporting processes to prevent future occurrences of such errors. This could involve adding additional staff, training current accounting staff and implementing more robust review procedures to ensure that all financial reporting is in strict accordance with GAAP. View of Responsible OfficialThe Housing Trust acknowledges the finding. In prior years, however, internal controls were insufficient. There was no formal month-end close or review process, and prior audits relied on outdated balances without verification. Under new leadershipA formal monthly close calendar has been established, with the monthly close to be completed within 10-15 business days.Create a supporting schedule for every balance sheet account. These schedules will be used as part of the monthly reconciliation process and will be certified.A grant receivable roll-forward will be prepared for each grant, compared to QuickBooks, and reconciled monthly.Each development project will have its own subledger, which will be reconciled monthly.A detailed fixed asset register will be maintained and reconciled quarterly.6. To help prevent future restatements, establish a formal journal-entry control process that requires appropriate supporting documentation and approvals.7. Establish a policy requiring documentation and approval for any changes made to beginning balances.8. The CEO and Finance Committee will perform monthly analytical reviews using the balance sheet, profit and loss statement, and actual-to-budget comparisons.9. Establish a reconciliation exception and audit adjustment log to track outstanding issues requiring resolution, including a timeline for resolving each item.Corrective Action Plan Timeline The timeline to complete this is prior to December 31, 2026.Designated Employee Responsible for Corrective Action-Director of Operations-Accounting Specialist2025-003 [2024-003] - GRANT TRACKING AND SEFA RECONCILIATIONFederal Agency: U.S. Department of Housing and Urban Development (HUD)Federal Program: Housing Opportunities for Persons With AIDS (HOPWA)Assistance Listing Number: 14.241Award Number and Period: [NMH240051], [November 1, 2024 – October 31, 2027]Type of Compliance Requirements: Internal Controls Type of Finding: (B) Significant Deficiency in Internal Control Over Financial ReportingKnown Questions Cost: NoneStatement of ConditionDuring our audit, we identified initial differences between expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) and the general ledger. Management subsequently provided additional supporting schedules and completed a reconciliation of the SEFA to the general ledger. However, the reconciliation required manual effort because one federal award included program income amounts that had not been properly reconciled or corrected, another federal award had expenses that did not belong to the award, and recycled funds were tracked separately partially only from new grant funds in the accounting records. Some of expenses did not have appropriate backup documentation, however, the billing to the grant was correct. Expenses from program income for salaries did not match the timesheets. CriteriaPer 2 CFR 200.302 and 200.510(b), recipients of federal awards must maintain accurate, current, and complete records that adequately identify the source and application of funds. Grant expenditures must be traceable to the financial records and properly classified. Program income, including recycled funds, must be used and tracked in accordance with federal requirements and grantee policies. Specifically, all grants should be tracked separately in the general ledger, and the revenue and expenses should match the reimbursement grants. The SEFA reconciliation should be done thoroughly and discrepancies reconciled or resolved, if that is the case. The policies for recycling the funds should be updated with the financial tracking in the general ledger and update with all grantor recommendations. The HOPWA program policy was updated in July 2025.The recycled funds received/spent should be separately tracked and used per policies and grantor recommendations.EffectThe lack of properly tracking expenditures and recycled funds increases the risk of misstating the SEFA, billing non-allowable or duplicate costs to the grantor, and not meeting timeliness or use restrictions related to program income. This may lead to questioned costs or future audit findings.Recycled funds not properly tracked separately may result in noncompliance with the application of loan funding. CauseThe issues stemmed from frequent staff turnover and the complexity of accounting for loans and recycled funds across departments. RecommendationWe recommend the Housing Trust:Revise and implement grant management policy and procedures that ensure each grant has a dedicated general ledger account.Require all reimbursement requests to be supported by general ledger detail.Ensure program income and recycled funds are separately tracked in accordance with federal guidelines (separate classes).Establish regular reconciliations between Finance and Program records to maintain consistency.View of Responsible OfficialThe Housing Trust acknowledges the finding. Corrective Action Plan: 1. A master grant register has been created that includes all active grants and federal awards.2. Each grant will have a unique class/project established in QuickBooks to capture payroll and other grant-related expenses. Reports will be generated monthly.3. Each grant will be reconciled monthly.4. Grant reimbursement requests will be supported by appropriate documentation.5. Payroll review procedures have been established to confirm that payroll costs are properly allocated to grants.6. Program income will be tracked separately for all applicable income and expenditures.7. Monthly SEFA reconciliations will be completed for all grants, including grants that do not meet the definition for inclusion in the SEFA.8. A grant reconciliation exception log will be established to track outstanding issues, responsible parties, and timelines for resolution. Corrective Action Plan Timeline- Finalize and adopt new Grant Management Policies: by September 2026- Implement monthly SEFA reconciliations: by September 2026- Complete staff training on program income and federal grant tracking: by September 2026Designated Employee Responsible for Corrective Action-Director of Operations-Accounting SpecialistCurrent Year Findings 2025-004 - Program Income Federal Agency: U.S. Department of Housing and Urban Development (HUD)Federal Program: Housing Opportunities for Persons With AIDS (HOPWA)Assistance Listing Number: 14.241Federal Award: [NMH240051], [November 1, 2024 – October 31, 2027]Compliance Requirement: Program Income Known Questions Cost: None Type of Finding: (F, G) Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Noncompliance related to Federal Awards Statement of Condition During 2025, the Housing Trust received certain repayments of loans originally funded by HOPWA awards. Of this amount, certain amount may have remained unspent or had not been recorded/reconciled in accordance with HUD requirements as of December 31, 2025. Management did not maintain a documented control to identify HOPWA repayment receipts, determine the applicable award requirements, reconcile receipts and expenditures among IDIS, QuickBooks, and the program-income subsidiary record, and document approval of their disposition. Criteria Under 2 CFR 200.307(c), program income earned after a Federal award’s period of performance is subject to Federal requirements only when required by Federal agency regulations or the terms and conditions of the award, and the Federal agency may establish appropriate disposition requirements through closeout. HUD may require HOPWA-funded loan repayments received after the original award period to be recorded as program income.CauseThe Housing Trust had not designed and assigned ownership of a formal program-income and grant-closeout control addressing repayments generated from HOPWA-funded loans after the originating award’s period of performance. Effect Program income may have been subject to incorrect or untimely reporting/use, increasing the risk of noncompliance and misstatement of federal expenditures. Known questioned costs were unknown. RecommendationHousing Trust should implement a documented monthly program-income reconciliation and grant-closeout control that identifies the originating award, applicable HUD disposition requirement, IDIS receipt, QBO classification, eligible use, remaining balance, reviewer approval, and resolution of differences. Evidence of HUD determinations for post-period receipts should be retained with the reconciliation.Views of Responsible Officials: SFCHT acknowledges the finding and notes that the New Mexico HOPWA program is the only documented HUD grant that funds mortgages.Management has established a formal process to identify and track repayments associated with HOPWA-funded loans. Management will maintain a subsidiary program income register that identifies the originating federal award, receipts, applicable HUD disposition requirements, accounting classification, eligible expenditures, and remaining balance. Program income activity will be reconciled monthly among loan-servicing records, QBO, IDIS, and supporting program records. Written HUD determinations regarding post-period repayments will be retained when applicable.Corrective Action Plan TimelineAn onsite meeting with HUD HOPWA representatives is scheduled for September 10, 2026, at the Santa Fe offices. During this meeting, policies and procedures, including the program income policy, will be reviewed and formalized, and a HUD determination log will be established.The HOPWA Program Income Register will be implemented, and repayment schedules for HOPWA loans will be documented in the master loan inventory. Implementation date: July 2026.HOPWA program income will be expended before additional HOPWA IDIS reimbursement requests are approved.A historical review of HOPWA loans and funding sources will be completed. Target date: August 2026.QBO, Portfol, Amerinat, and IDIS will be reconciled monthly. Beginning: July 2026 and ongoing.Post-period repayments and related HUD determinations will be reviewed. Target date: September 2026.Designated Employee Responsible for Corrective Action Director of Operations, with assistance from the Accounting Specialist and HOPWA HUD program staff, as applicable.Signature Title

THE COALITION WILL MAINTAIN A CENTRALIZED GRANT REGISTER IDENTIFYING EACH AWARD NUMBER, PROJECT CODE, BEGINNING DATE, ENDING DATE, AND APPROVED PERIOD OF PERFORMANCE. FINANCE WILL USE THE REGISTER DURING MONTHLY CLOSE AND GRANT REVIEW TO VERIFY THAT PAYROLL AND NON-PAYROLL EXPENDITURES ARE CHARGED TO THE CORRECT ACTIVE GRANT/PROJECT. BEFORE AND AFTER AN AWARD END DATE, FINANCE WILL REVIEW PROJECT ACTIVITY FOR COSTS POSTED OUTSIDE THE APPROVED PERIOD, CONFIRM WHETHER ANY PRE-AWARD OR CLOSEOUT COST IS AUTHORIZED, AND RECLASSIFY MISCODED TRANSACTIONS BEFORE GRANT REPORTING IS FINALIZED. NEW AWARD/PROJECT CODES WILL BE ESTABLISHED AND COMMUNICATED BEFORE COSTS ARE CHARGED TO A SUCCESSOR AWARD. IN ADDITION, AFTER THE MONTHLY CLOSE PROCESS IS COMPLETE, FINANCE WILL DISTRIBUTE GRANT STATEMENTS TO ADMINISTRATION TO REVIEW EXPENDITURES AND REMAINING GRANT BALANCES FOR REASONABLENESS. THIS PROVIDES AN ADDITIONAL LAYER OF OVERSIGHT TO VERIFY THAT GRANT-RELATED EXPENSES HAVE BEEN RECORDED ACCURATELY.

Finding Reference Number: 2025-002 – Internal Control over Compliance in Relation to Period of Performance Requirements Description of Finding: This is a new finding. For four of the seven projects reported under the Federal Program COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (SLFRF), totaling $204,862, documentation that the signed and accepted quote was sent back to the vendor by the program obligation deadline of December 31,2024 could not be located. Statement of Concurrence or Nonconcurrence: Nonconcur. Corrective Action: For each of these projects, fully detailed quotes incorporating specific scopes of work, pricing, and binding terms and conditions were executed (signed) by authorized Town officials on or before the December 31, 2024 obligation deadline. Additionally, work or deliverables were performed in accordance with these signed terms without dispute from either party, further proving mutual intent and the existence of a binding agreement. the existence of a binding agreement.

We have established a process to calculate program income semi-annually and will keep in place until this grant is officially closed. The program income calculated will be added back to this award. We will invest those dollars back into our houses and track and report this activity as part of our semi-annual reporting to HUD.

The County will work with Rehmann to develop policies and procedures sufficient to satisfy the rules of the uniform guidance.

Condition: The Town incurred and charged expenditures totaling $30,826 to a FEMA Public Assistance project after the approved period of performance ended on October 31, 2024. The Town submitted a formal request to extend the period of performance on September 8, 2025. As of March 19, 2026, FEMA had communicated that the extension request has been denied. However, FEMA reimbursed the Town for the expenditures incurred after October 31, 2024. As of the date of this audit report, FEMA has not indicated whether the reimbursement will ultimately be retained or subject to recovery. Corrective Action Plan Corrective Action Planned: The Town will implement a grant expenditure review checklist requiring pre-approval for any costs beyond the approved period; train all grant staff on compliance requirements; update internal controls. The Town will also document all correspondence whether that be by phone, email or written correspondence with FEMA when it comes to deadline extensions. The Town’s FEMA-funded recovery projects are complex, multi-year projects associated with rebuilding the community. Many projects have extended beyond their original completion dates due to factors including the pandemic, supply-chain and world trade impacts, weather, labor availability, construction timelines, and contract procurement requirements. In addition, frequent turnover among FEMA personnel assigned to the Town’s recovery projects has at times resulted in changes in points of contact, delays in responses, and extended processing times for approvals, determinations, and extension requests. These circumstances have contributed to the length and complexity of administering projects that already require significant coordination over multiple years. The Town has continued to work closely with FEMA throughout this process and has received approvals for extensions on recovery projects. In this instance, the expenditures identified in the finding occurred after the original October 31, 2024 period and were ultimately reimbursed by FEMA. Name(s) of Contact Person(s) Responsible for Corrective Action: Aimee Beleu, Finance Director Anticipated Completion Date: The corrective action will be implemented to take effect for the audit of the FY 2025-26 financial statements.

#2025-003 - Accounts Payable Cut-Off/ Period of Performance Corrective Action Planned: Certain grants - particularly at the Center for Adult College Success - were prepaid by the funder in order to disburse funds quickly, with grant conditions permitting continued work beyond the nominal completion date. TalentFirst closed these grants out in the accounting records before the full period of performance had concluded, resulting in expenses recorded in the wrong period. Management has implemented a contract timeline document that tracks each grant and contract's actual period of performance and governs when a grant is closed out in the accounting records - grants are no longer closed out until the full period of performance has concluded. Management is also moving away from structuring large prepaid contracts, in part to ease the cash flow pressure that structure creates. Anticipated Completion Date: Already implemented. Responsible Party: Finance Manager, with oversight by the President.

Management will revise grant setup and expenditure review procedures to ensure grant cost centers are not activated prior to the authorized period of performance. A documented review will be implemented to verify that expenditures charged to federal awards were incurred within the applicable period of performance before reimbursement requests are submitted. Initial grant expenditures and reimbursement requests will be subject to supervisory review and approval. Grants and finance personnel will also receive periodic training regarding Uniform Guidance requirements related to allowable costs and period-of-performance compliance. An entry will be made for FY26 to adjust the expenditures.

FINDING 2025-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Sandra L Morton Contact Phone Number and Email Address: 812-481-7000 slmorton@duboiscountyin.org Views of Responsible Officials: We disagree with the finding that the 2025 Annual P & E report current obligations were overstated by $8,300,967, which was the amount of cumulative obligations. Explanation and Reasons for Disagreement: We do not believe there was a systemic lack of effective internal controls or noncompliance throughout the audit period. We determined that the funds were fully obligated and reported the amount based on that interpretation, as was done on the previous reports submitted.

SAMARITAS AND SUBSIDIARIES Management’s Corrective Action Plan For the Year Ended December 31, 2025 Finding 2025-001 Contact Person(s): Bridgette Zappacosta, Chief Financial Officer Corrective Action Planned: Management concurs with the finding. During the period under review, the Finance Department was transitioning to a new accounting system. The identified exceptions occurred prior to the implementation of the new system and related processes. As part of the transition to Blackbaud Financial Edge NXT, Samaritas has implemented controls designed to prevent expenditures from being charged outside of a federal award's period of performance. Grant records within the system now include defined start and end dates that prevent expenditures from being applied to awards outside the authorized grant period. In addition, Samaritas enhanced its invoice approval process by adding a required custom field to identify the service period associated with each invoice. This information is reviewed during the monthly close process to identify invoices received before or after a grant period and to ensure expenditures are recorded in the appropriate award period. The Finance Department completed training on these revised procedures in July 2026. Management will continue to monitor compliance with these controls as part of its monthly grant and financial review processes. Anticipated Completion Date: Implemented July 2026; ongoing monitoring procedures are in place.

County department personnel changes have been implemented which address this deficiency. Additional training from the Auditor’s office and state grantors has occurred and will continue for staff in departments that receive federal and state awards.

FINDING 2025-002 Sherry Lockard, 812-283-1500, slockard@townofclarksville.com A. Coronavirus State and Local Fiscal Recovery Funds The Town concurs with the finding. The Town was not aware contracts had to be signed by December 2024 for all “obligations”. The Town was under the impression the obligations were submitted on the annual SLRF report, and that only the funds had to be spent for submitted obligations on the SLRF page by December 31, 2026. The Town was not able to obtain a contract that far in advance of the work to start, let alone be completed. At this time, we will await instructions from the Federal Agency as to what the Town needs to do regarding the expenses made after the ambiguous “obligation deadline”. For all future grants, the Town will designate the staff member who is in charge of that specific grant to create a checklist of requirements and to maintain that list until the grant is complete. (ATTACHMENT A)

Period of Performance California Governor’s Office of Emergency Services In July of 2024, Cal OES implemented EMPOWER, a new electronic time reporting system. EMPOWER captures employees' daily time worked, and activities identified with service locations (funding code) by cost category. The established EMPOWER Standard Operating Procedure instructs Cal OES Administrative Services staff on how to set the service location incident period start date, which creates system controls to not allow any activities to be entered prior to the start date. To address the transaction identified by CLA and prevent recurrence, Cal OES is troubleshooting and testing potential solutions to develop a systematic fix in EMPOWER. In addition, Cal OES will provide refresher training for all first-line managers to improve their oversight of funding codes and cost categories and ensure their staff submit time entries accordingly. Cal OES Administrative Services will also integrate a resource checklist into its monthly pre-labor review and posting process to add an extra layer of transaction oversight. Currently, Cal OES Administrative Services reviews and reconciles all cost category claims and supporting documentation before submitting to FEMA for obligation. This continuous review ensures Cal OES flags and corrects ineligible or out-of-period transactions before requesting reimbursement. Furthermore, Cal OES will review and correct the identified transaction. Estimated Implementation Date: October 2026 Contact: - Mary Rucker, Assistant Director Administrative Services, Finance & Logistics Administration

Period of Performance California Department of Social Services CDSS agrees with this finding. State operations costs incurred from July through September 2024 were incorrectly charged to FFY 2025 when the federal drawdown was processed in October, rather than being charged to FFY 2024. The issue identified in the audit period has been corrected in the ACF-696 report submitted on April 30, 2026. Upon identifying the error, CDSS provided additional training to staff and added a second level of supervisory review to ensure the appropriate federal fiscal year is applied when processing drawdowns that cross both the state and federal fiscal years. These corrective actions are intended to prevent similar misclassifications and strengthen compliance with federal reporting requirements. Estimated Implementation Date: July 2026 Contact: - Rosali Bautista, Chief, Accounting and Reporting Bureau, Accounting and Fiscal Systems Branch, Finance and Accounting Division

Period of Performance Employment Development Department Employment Development Department (EDD) agrees that it did not have documented procedures or formal ongoing monitoring activities to adequately ensure that payroll charges to Federal awards fell within the authorized award dates before costs were charged to the grant. As a result, payroll costs were incurred outside of the approved period of performance and were not prevented or detected in a timely manner. EDD’s Unemployment Insurance Branch (UIB) established the procedures to be overseen by the UIB Budget Unit to ensure proper controls are in place moving forward and costs are appropriately charged to current and future grants. See artifacts titled ‘Project-Activity Code Establishment Procedure for DUA Revised 7.6.26’ and ‘UIAN DUA Template for Code Release Instructions’. To address the 25 instances where payroll hours were charged to a grant after the approved period of performance end date of May 22, 2025, the Department identified and removed those expenditures from the federal grant and reallocated them to an appropriate state funding source via ledger adjustments. Adjustments were processed during the month end closing process for May and June. As a result, all expenditures outside of the grant’s period of performance have been identified and appropriately removed from the federal grant. Estimated Implementation Date: Currently implemented Contact: - Diane Underwood, Division Chief, Unemployment Insurance Branch

FINDING 2025-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Angela Hamrick Contact Phone Number and Email Address: 260-748-7012 ahamrick@newhaven.in.gov Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: When completing the Annual P & E report I will add an internal control of a separate employee reviewing the information to make sure the correct expenditures are listed within the correct period. We will have each employee who reviews the information to sign the completed report. Anticipated Completion Date: 6/24/26 INDIANA STATE

CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: COVID-19- Coronavirus State and Local Fiscal Recovery Funds Contact Person Responsible for Corrective Action: Valeriano F. Gomez Contact Phone Number and Email Address: 219-391-8220 Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: Previous corrective action read as follows: To ensure proper implementation of the policies and procedures in place related to SLFRF reporting, in future, no submittal of reports will be approved without the City Controller and a Senior Staff Accountant reviewing and approving the P & E reports…… issue arose when City Departments responsive for entering data in P & E reports and Staff Accountant documentation differed , adding to issue both groups were not together in same room to assist each other with reporting . Corrective Action Plan: 1. All future SLFRF Quarterly reports shall require advance meetings before the data entering day; to ensure correct reporting. Meetings shall include all personnel reviewing and entering information (City department personnel and Controllers office personnel, to include two from the Controller’s Office; Controller, or Deputy City Controller and Senior City Accountant. 2. These Staff meeting shall address any differences in reporting documentation, and prepare for any editing and revising data to correct issues from previous P & E reporting, in next available report (Sec. V. Editing and Revising Data P & E Report User Guide) 3. No data shall be entered / submitted on entry day for future Quarterly P & E reports without Controller personnel present and having reviewed and confirmed data. Anticipated Completion Date: Controllers Office and City Departments involved in reporting are presently working to address and correct issues in past reporting, completion is anticipated when upcoming 2nd Quarterly Report for 2026 is opened and issues are addressed.

Bang on a Can, Inc. will adopt written policies, procedures and standards of conduct as required by 2 CFR 200, Subparts D and E.

Condition: The County approved to purchase generators for the Village of Taylor Springs on June 11, 2024 with Ordinance 2024-12. However, due to unavailability, these generators were not purchased until June 2025. Approving an ordinance does not fall under the definition of obligating funds under ARPA. Plan: We recommend that applicable County employees and board members research all procurement compliance requirements when grants are received. Name of Contact Person: Nikki Lohman, Treasurer Management Response: Due to the generator not being available at the time of ordinance, it was an oversight that the actual obligation was incurred after the period of performance. The County did try in good faith to order the generator before the deadline. Anticipated Date of Completion: March 2026, anticipated date of ARPA funds being fully expensed.