Corrective Action Plans

Finding 2024-001 Federal Agency Name: Department of Health and Human Services Program Name: Block Grants for Prevention and Treatment of Substance Abuse Federal Financial Assistance Listing Number: 93.959 Finding Summary: The Organization must establish and maintain effective internal controls over federal awards that provides assurance that the organization is managing the federal award in compliance with federal statutes, regulation, and conditions of the federal award. The Organization did not have documented review completed prior to invoice payments being made or reimbursement requests being submitted to ensure all costs incurred were allowed and in the correct period of performance under the program. Responsible Individuals: Carlie Stevens, Wellcome Manor Finance Manager; Karen Klabunde, Wellcome Manor Center Director Corrective Action Plan: On a monthly basis, the Finance Manager will provide the month’s expenditures, receipts, reimbursement requests, and recap spreadsheet to the Center Director. The Center Director will agree all items to the grant and sign the recap spreadsheet to document her review and approval. Anticipated Completion Date: December 31, 2025

Finding 2024-239: 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. Related to Prior Finding: N/A Agency’s view: Agree 3.1 Corrective Action Plan: Document Control Procedures: Develop and implement formal, written procedures (Grants Management Manual Chapter) for verifying that expenditures are assigned to the correct period of performance in both Aware and Luma. 3.2 Training: Train IDVR team members on policies and procedures tied to Period of Performance. Anticipated Corrective Action Date: 04/01/2026 Responsible for Corrective Action: Eric Bjork, Fiscal Officer

Finding Number: 2024-032 Audit Type: Single Audit Finding Title: Delayed Final Reimbursement Due to Unresolved Agency Requests Related Finding: 2024-023 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will designate a grants coordinator to monitor agency requests and ensure timely responses. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will improve communication with funding agencies. 5. Status of Prior Year Finding This is a newt finding.

2024-006 – WATERSHED REHABILITATION PROGRAM – LACK OF CONTROLS AND IMPROPER PERIOD OF PERFORMANCE – WRD – ALN 10.916 – MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition Pembina County Water Resource District applied costs to the Watershed Rehabilitation Program after the period of performance, which shows a lack of internal controls. The total value of the expenses past the period of performance end date was approximately $170,468 which occurred through September 14, 2024, more than a month past the period of performance end date. Corrective Action Plan: We agree we will ensure costs are in the proper period of performance going forward Anticipated Completion Date: FY2025

Auditors Recommendation: CBPSC should ensure that its records are completed and reconciled in a timely manner, so that the single audit can be performed and completed on time, and the reporting package and data collections form can be submitted before the deadline. Corrective Action Plan: Management acknowledges that the reporting package and Data Collection Form for the 2023 audit were not filed by the required September 30, 2024 deadline. Management also acknowledges that this finding will appear for the next audit year, however to correct this and prevent recurrence of this issue the organization has implemented the following actions: Established external filing deadlines. Enhanced monitoring and tracking. Assignment of oversight responsibility. Improved coordination with external auditors. Staff Training. Anticipation Completion Date: These corrective actions were initiated in the 2025 fiscal year and will be fully in place for the 2025 audit cycle, ensuring timely submission by September 30. 2026 Management Statement: Management believes these corrective steps will ensure full compliance with federal reporting requirements going forward and prevent recurrence of late submissions. Responsible Individual: Managing Director, Fred Fogg

Finding 2024-002 Contact Person responsible for corrective action: Kevin Couey The corrective action planned: Strengthen our processes to ensure all grant expenditures are made within the authorized period of performance. The anticipated completion date (or starting date if ongoing): We immediately put new processes into action effective October 1, 2025 and will be validated at next audit in May 2026.

Finding 2024-010 – Period of Performance (Material Weakness) Finding: The Organization did not have good controls to ensure the period of performance requirements was met due to staff turnover. Management Response: Management concurs. Corrective action plan: •Implement a grant compliance checklist and training for staff by the end of 2025 to ensure expenditures are within the grant period. •Require pre-approval for all expenditures near grant end dates. •Quarterly compliance reviews. Responsible Party: CFO Completion Date/Status: Expected to be Implemented by end of 2025; ongoing review.

Federal Program Information Federal Agencies: Department of Health and Human Services (“HHS”) Pass-Through Entity: Virginia Department of Health; Not Applicable Pass-Through Entity Number: INORWB611-GY23; INORWB611-GY24; Not Applicable Awards: Assistance Listing 93.917 – HIV Emergency Relief Project Grants; Assistance Listing 93.918 – Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease Award Periods: April 1, 2023 to March 31, 2024; April 1, 2024 to March 31, 2025; May 1, 2023 to April 30, 2024; May 1, 2024 to April 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Description: Timely Application of Program Income Prior to Requesting Additional Cash Payments Recommendation: During the latter part of the fiscal year and as a result of prior year audit findings, IJP implemented various checkpoints in their monthly processes to ensure that program income was disbursed prior to requesting cash reimbursements. IJP should continue to assess existing policies and procedures to ensure the program income balance is spent timely. HRSA recommends that recipients and subrecipients strive to proactively secure and estimate the extent to which program income will be accrued. View of responsible officials: Management concurs with the finding and has implemented procedures to ensure appropriate and timely application of program income. Corrective Action Planned: Inova Grants Accounting and Inova Juniper Program (IJP) directors will work collaboratively to disburse funds available from program income prior to requesting additional cash payments from RWHAP funds. Inova implemented a Program Income from Sponsored Programs policy in February 2025. Inova will assess this written procedure and revise as necessary to ensure that program income is applied before requesting federal reimbursement. Inova will review federal grant requirements related to program income and identify sources of program income during kickoff meetings for new awards. Mandatory training will be conducted for program and finance staff responsible for the administration of these awards. (2 CFR 200.307 and 200.305) Inova will require a monthly reconciliation of program income earned and expenditures by grant. Program income tracking will also be included in monthly grant variance reports. Planned Completion Date for Corrective Action Planned: Ongoing with completion date of December 31, 2025.

This Finding is related to the failure to correctly report grant funds being expended and to the lack of a Department’s filing one quarterly report timely related to the SLFRF Funds. The Department has been contacted and is carefully reviewing guidance for all future remaining reports. Future Reports are expected to be filed correctly and timely, with future education being sought as needed.

We are working to change the standard for document retention and organization. This will help ensure all costs are properly approved before they are charged to federal programs, and that management understands the imperative nature for the record retention.

Audit Finding 2024-002 Reference: Expenses charged to federal awards outside the designated period of performance. (2 out of 40 sampled) ________________________________________1. Issue Summary The audit identified two instances where expenses were charged to a federal grant outside the approved period of performance. These expenses were tied to invoices that began within the period of performance and a portion extended beyond the performance period. The root cause was insufficient review of transaction timing and lack of controls to ensure compliance with Uniform Guidance requirements. ________________________________________ 2. Root Cause Analysis Lack of a formalized review process for validating transaction that span extended period dates that may extend past grant period of performance. ________________________________________ 3. Corrective Actions A. Implement a Formal Expense Review Protocol • Develop and document a standard operating procedure (SOP) for reviewing all grant-related expenses. • Require validation of invoice service dates and delivery dates before posting to federal awards • Include a checklist for SPF accountants to confirm alignment with the period of performance. B. Staff Training and Awareness • Conduct mandatory training sessions for all staff involved in grant accounting and expense processing. • Include guidance on: o Allowable costs under 2 CFR Part 200 o Period of performance compliance o Documentation standards ________________________________________ 4. Responsible Parties • Finance Director: Oversight and implementation of corrective actions • Sponsored Projects Finance Team: Execution of SOP and transaction reviews ________________________________________ 5. Timeline Action Item Target Completion Date Policy Development Already implemented Staff Training Completed initial training, additional will be ongoing

Finding 2024-003: Activiites Allowed or Unallowed & Allowable Costs/Cost Principles & Period of Performance (Clean Energy Demonstrations - ALN 81.255). Contact Person: Manny Citron, Chief Operating Officer. Recommendation: MACH2 should establish an internal control policy to ensure transactions are reviewed and approved prior to being charged to the grant and the approval should be documented for each transaction. Action: MACH2 has created and implemented written policies prior to execution of cooperative agreement regarding the review and approval of grant expenditures. These policies ensure transactions are reviewed with multiple approvals and for accuracy, allowability, allocability, and eligibility prior to being submitted for reimbursement. In addition, MACH2's policies are designed to demonstrate compliance with 2 CFR 200 by esbalishing internal controls that maintain documenation of approvals and ensuring segregation of duties so that no single individual has control of processing of transactions. Date of Completion: October 31, 2025.

Corrective Action Plan – Federal Funds Review and Processing Audit Finding Reference: Response to Finding 2024-002: Improvement Control Over Period of Performance for Federal Awards Name of Contact Person and Completion Date: Krystal De Gray, COO of Nashua School District 09-22-2025 Planned Corrective Action: The Nashua School District acknowledges the finding related to the control over the period of performance for federal awards (Finding 2024-002). In response, the district will develop and implement a formal internal procedure to ensure that all purchases funded by federal awards are both placed and received within the established period of performance. This procedure will include appropriate review, documentation, and oversight to maintain compliance with federal grant regulations. To further strengthen internal controls, the Nashua School District will implement a procedure limiting purchases to occur no later than 15 days prior to the grant’s end date. Additionally, all necessary services must be received and completed prior to the expiration of the grant period. Mario Andrade Krystal De Gray Superintendent Chief Operating Officer

Management acknowledges the error and agrees with the recommendation to strengthen reporting controls. While the report was ultimately corrected and resubmitted, CU1 recognizes the importance of ensuring all reports align with the required performance timeframe. It should be noted that this reporting error occurred prior to the recent merger. Following the merger, the Credit Union is no longer a member of the CDFI Fund, and therefore the CDFI ERP reporting requirements will not apply going forward. To address the finding, CU1 has: • Corrected and resubmitted the Year 1 reports to ensure compliance with the grant agreement at the time. • Documented the issue as part of merger due diligence to ensure transparency and closure. As CDFI Fund membership and related reporting obligations no longer apply post-merger, no further corrective actions are necessary beyond these steps. Expected Completion Date – Completed Responsible Parties – Wendy Gorevan, CFO (FAFCU pre-merger) and Scott McDonald, CFO (post-merger)

2024-003 The City charged costs that were incurred prior to the beginning of the period of performance of the grant. Helen Tomic, Long Range Planning Manager December 31, 2025 The City will implement control procedure to prevent the charging of costs before the period of performance.

Audit Finding Reference: 2024-001 Description of Finding: The audit revealed that grant expenditures were incurred outside the authorized performance period, resulting in non-compliance with grant regulations and potential cost disallowance. Planned Corrective Action • Conduct a comprehensive assessment of existing procedures to identify gaps that led to noncompliance with grant regulations. • Ensure timely submission of grant applications. • Implement enhanced oversight and monitoring processes for all grant-related expenditures to ensure alignment with policy 2 CFR 200.1. • Maintain detailed documentation of all award dates and expenditures to provide a clear compliance record. • Ensure all documentation is easily accessible and systematically organized for audit purposes. • Ensure pre-award costs are allowable only to the extent they would have been allowable if incurred after the effective date and only with written approval from the Federal awarding agency (as per 2 CFR 200.458). • Establish a process for obtaining and documenting written approval for pre-award costs. • Provide comprehensive training on compliance with Uniform Grant Guidance to all relevant staff. • Review and update policies and procedures related to grant expenditures regularly to ensure they are current and compliant with federal regulations. • Assign accountability for monitoring and reporting compliance to specific roles within the organization. The Business Manager, Elizabeth Bouchard, will be responsible for implementing this plan beginning with the Fiscal Year 2026 grant cycle. As of September 2025, non-compliance issues have been identified and addressed, documentation has been maintained to track award dates, and training has been provided to designated roles within the District. In addition, procedures to maintain detailed documentation of all award dates and expenditures to ensure a clear compliance record have been shared with all District Administrators utilizing grant funds.

City of Aledo Program Specific Audit Recommendation 2024-001 We recommend that the Organization review the requirements of 2 CFR Section 200.302 to develop allowable cost, activity, and period of performance activities to be followed. Management Response: The organization recognizes the importance of having written policies and procedures to ensure cost are allowed and reasonable for the federal program. To address this finding, the agency has implemented the following corrective actions:  Review requirements of 2 CFR Section 200.302 as it relates to internal controls and financial management  Create documented policies and procedures that details how the grantee will review and approve invoices, cost allocation, efforts of personnel, fringe benefits and indirect charges for allowability, adherence to cost principles, accuracy, and completeness  Create documented policies and procedures that details how the grantee will review and approve invoices, cost allocations, efforts of personnel, fringe benefits and indirect charges to ensure they were incurred during the period of performance Responsible Staff: City Official Implementation Date: October 1,2025 90

Corrective Action Plan: Atrium Health CMHA management in the future will ensure that all correspondence, including notes from review meetings and approvals of key decisions, will be documented and retained as part of the support records for FEMA related awards. Proposed Completion Date: No further action is required until future needs arise for Atrium Health CMHA to obtain FEMA funding awards at which time management will ensure all documentation supporting the process and key decisions are retained.

Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Cash Management compliance requirements. Management's Corrective Actions: During 2025, Hamilton County Area Neighborhood Development, Inc. (HAND) hired a controller to assist with the preparation of the parent company and subsidiaries financials while instituting improved internal control policies. As such, HAND with the assistance of its controller will establish effective internal control systems to ensure the compliance with the requirements for grant agreements and cash management compliance requirements

Finding No. 2024-001: Obligation Requirement for Capital Fund Program Drawdowns (Significant Deficiency Corrective Action Plan: NBHA has reviewed its internal controls regarding the obligation requirement for CFP LOCCS and will implement additional monitoring procedures to ensure timely obligation of funds. This includes developing a tracking spreadsheet and assigning a staff member to review obligations quarterly. The Executive Director will receive quarterly reports to ensure compliance going forward. Responsible Person: Reginal Barner, Executive Director Expected Completion Date: December 31, 2025

With the addition of personnel, the finance team has been restructured to allow for a more streamlined month-end process. As part of the month-end process we have implemented more collaborative and robust communication between the grants management and finance teams to ensure accuracy in our grant management process.

Findings Reported by Uniform Guidance – The following steps have been taken or will be taken to address Finding 2024-005: • Heart City Health Center, Inc. will refine and change controls that deal with tracking of when expenses are incurred to confirm that no drawdown receipt is received before then or in the incorrect grant period

Management has updated its compliance responsibility procedures to clarify roles and responsibilities and to ensure accountabilities for all federal reporting requirements. Specifically: • A compliance calendar will be established to track all non-standard reporting deadlines (other than monthly or quarterly cost reimbursement grant request). • Responsibility for preparing and submitting DRGR reports has been formally assigned to Finance Department. • Verification procedures have been implemented to confirm that all reports are filed timely. • Periodic internal reviews will be conducted to ensure compliance with reporting requirements.

The Organization will continue efforts to obtain written confirmation from the Department of Commerce, compile all available email correspondence and notes from verbal conversations, and prepare a detailed timeline of authorization requests and responses. Further, the Organization will submit a formal response to the Department of Commerce regarding questioned costs, provide documentation supporting the allowability of expenses, and request a formal resolution of questioned costs. Person Responsible: Steve Sanders, Grant Manager, Tel: 207-249-8578 Estimated completion: December 2025

2023-002: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout procedures, consequently, the district will monitor closely all grants spending throughout each grant cycle. For both state-administered and direct grants, regardless of the period of availability, the District must liquidate all obligations incurred under the award Reports not later than 90 days after the end of the funding period unless an extension is authorized. These procedures are included in the Financial Procedures Manual (pages 226-230 under Section G— Timely Obligation of Funds) Key Control Key Actions Resources Needed Timeline Outcome Grants Management Use appropriate resources to mitigate any errors, omissions and ensure timely maintenance of records and reporting Grant Management Form Grant Award Letter Internal Controls Guide GEM$ Trainings FY24, FY25 ongoing Implementation of preventive controls for ALL grant funding Contacts: School Business Manager & Town Accountant Submitted by, Annette Colón, Business Manager MBA, MCPPO, Notary Public Clinton Public Schools 150 School St. Clinton, MA 01510 (978) 365-4200 x 12241 colona@clinton.k12.ma.us