Corrective Action Plans

Planned Corrective Action: The district will implement controls for monitoring reporting grant requirements and grant expenditures to ensure compliance with reporting and period of performance requirements for federal grants. Anticipated Completion Date: 6/30/26 Responsible Contact Person: Hiwot Abraha

12/7/2026 Cognizant or Oversight Agency for Audit, Codman Academy Charter Public School and Affiliate (the School) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm : AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: July I, 2024 - June 30, 2025 The finding from the June 20, 2025 Schedule of Findings and Questioned Costs is discussed below. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2025-001 Required Payroll Forms Recommendation: AAFCPAs recommends the School implement a standardized checklist and conduct periodic internal reviews of onboarding documentation to ensure all required forms are properly completed and retained in accordance with Federal regulations. Action Taken: As of January, 2026 the staff member responsible for staff on boarding and payroll processing is no longer employed at the School. Codman, with a new staff person in charge of these tasks has instituted a standardized checklist for on boarding, has performed a backward looking audit of employee files and will conduct internal periodic reviews for completeness and accuracy. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please tell Derrick Cielsa, Executive Direct as 617-287-0770 Sincerely yours, Derrick Ciesla Excutive Director

Finding 2025 – 002- Allowable Costs & Period of Performance (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. To strengthen policies and procedures surrounding grant disbursements and ensure expenses are properly approved and allowable under the specific grant budget, the Fiscal Service Office along with the Human Resources Department will implement a process to properly document, review, and approve all allowable grant pay rates and salaries.

Material Weakness Item 2025-003 - Period of Performance - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8/-ICS46163-03-01 During our audit, we noted that LBUCC drew down $190,688 of federal grant funds under the Section 330 program for the budget period beginning June 1, 2024 to reimburse salary expenses incurred in May 2024. Recommendation: We recommend that LBUCC implement procedures to ensure that all drawdowns are supported by expenses incurred strictly within the grant's approved period of performance and train staff on grant compliance requirements. Action Taken: A change in the process to draw down funds has been implemented to determine that the funds were incurred in the proper funding period rather than the period it was paid. Effectivity Date: Process change was implemented 12/1/2025.

State Agency: State Education Department Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Maria Stamoulis Title: Audit Manager Telephone: (518) 473-2810 E-mail Address: Maria.Stamoulis@nysed.gov Audit Report Reference: 2025-003 Anticipated Completion Date: 12/31/2026 Corrective Action Planned: New York State Education Department (SED) has updated the payment procedures to require additional review prior to processing and will provide training to staff involved in preparing or processing payment forms to understand the appropriate application of cost centers to align with the Period of Performance for Federal awards, including the Vocational Rehabilitation grant. Additional controls planned include the alignment of purchase orders with the Federal fiscal year to ensure cost centers are appropriately assigned to services.

State Agency: State Education Department Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Maria Stamoulis Title: Auditor 3 Telephone: (518) 473-2810 E-mail Address: Maria.Stamoulis@nysed.gov Audit Report Reference: 2025-002 Anticipated Completion Date: 12/31/2026 Corrective Action Planned: New York State Education Department (SED) ACCES-VR began doing quarterly data validation reviews prior to RSA 911 submission in early 2025. ACCES-VR is also working on updating the RSA 911 Reporting Data Validation policies and procedures to address this request from the RSA monitoring visit in 2024.

State Agency: Office of Children and Family Services Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Bonnie Hahn Title: Audit Liaison Telephone: (518) 486-1034 E-mail Address: Bonnie.hahn@ocfs.ny.gov Audit Report Reference: 2025-001 Anticipated Completion Date: 3/31/2026 Corrective Action Planned: The New York State Commission for the Blind (NYSCB) opens and maintains cases of blind and visually impaired individuals who apply for vocational rehabilitation and low vision services. Participants can apply and receive services multiple times, which can result in reporting more than one cycle on the RSA-911. In some cycles, the cases were open for more than 10 years, so the original application date is reflected on the RSA-911. These instances resulted in missing signatures on applications or Individualized Plans for Employment (IPE). The NYSCB has implemented a process that requires each Senior Vocational Rehabilitation Counselor (SVRC) to select 5 cases per month to complete an internal case review. There are two Internal case review forms used- one is for the case to be reviewed at IPE development or re-development and the other form is for the case to be reviewed at placement/case closure. If the SVRC finds documentation or signatures missing, they will notify the Vocational Rehabilitation Counselor (VRC) of the missing information by providing the completed form with their comments and follow up required. This process will continue. NYSCB will be providing further training to VRCs who complete applications and develop IPEs to emphasize the importance of having the participants sign the required forms. In addition, NYSCB will be providing training to the supervisors (including SVRCs and District Managers) in each district office when applications are taken by telephone to provide reasonable accommodations to our blind participants. Senior management will develop a written protocol which each district will be required to follow for how to manage accepting applications and signatures when cases are assigned to VRCs.

2025-001 Costs Incurred Beyond the Period of Performance Criteria: According to 2 CFR §§200.1, 200.308, 200.309, 200.344, and 200.403(h), a non-Federal entity may only charge allowable costs incurred during the approved budget period of the Federal award’s period of performance, and any costs incurred before the Federal award was made that were authorized by the Federal awarding agency or pass-through entity. All financial obligations incurred under the Federal award must be liquidated within the required time period. Costs incurred outside the approved period of performance are unallowable and constitute questioned costs. Client’s Response: During the grant cycle, the Organization submitted for an extension but did not receive confirmation of said extension. During the current fiscal year, the Organization has implemented additional controls to ensure that all grant funding is expended within the timeframe allotted. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444

2025 – 001: Period of Performance Federal Program CFDA # 14.872 Capital Fund Program Type of Finding: Material Weakness in Internal Control over Compliance Recommendation: Recommendation: It is recommended the Authority review all of the policies in place relating to the obligation of capital programs to ensure that funding is properly obligated and expended within the required time frame. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in response to finding: The PHA will proactively seek clarification from HUD when guidance is unclear or when operational challenges arise. The PHA remains committed to full compliance with HUD requirements and values its collaborative relationship with HUD. The Authority appreciates the guidance and technical assistance provided and will continue to work proactively to ensure clarity, transparency, and accountability moving forward. Name of the contact person responsible for corrective action: Jacque Sikes, Executive Director Planned completion date for corrective action plan: January 2026

Western Wyoming Community College experienced a transition in leadership within the Financial Aid Office, resulting in a change in the Director of Financial Aid position. This transition caused disruptions in communication and process continuity between the Financial Aid, Registrar, and Institutional Effectiveness offices. As a result, inconsistencies were identified in the timing and accuracy of enrollment reporting to the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS). Corrective Action Plan 1. Leadership and Process Realignment a. A new Director of Financial Aid has been appointed and is collaborating with the Institutional Effectiveness Office and the Registrar to define clear processes and timelines for Records & Registration and Financial Aid operations. b. The Director of Financial Aid and Registrar will maintain continuous communication to ensure timely and accurate enrollment reporting and prompt correction of any identified discrepancies. c. The Director of Financial Aid and Registrar will work together to develop a Standard Operating Process (SOP) to ensure if any future attrition occurs in either department that anyone else in those departments will be able to step in and continue processing without interruption ensuring timely and accurate enrollment reporting continues. 2. Implementation of Controls for Third-Party Reporting a. Recognizing the benefits and responsibilities of using the National Student Clearinghouse (NSC) for enrollment reporting, the institution has implemented controls to verify the accuracy of data transmitted through this third-party servicer. b. The Assistant Director (or the Director of Financial Aid in the Assistant Director’s absence) will generate the Summary Return of Funds Report (ROFS) from Colleague each term and provide a copy to the Registrar for enrollment verification and reconciliation. 3. Quarterly Reconciliation and Internal Review a. The Financial Aid Office will conduct a quarterly comparison between Colleague and NSLDS records to ensure consistency of enrollment and status dates. b. Any discrepancies identified will be communicated to the Registrar for prompt resolution. c. Results of the quarterly reviews will be documented and used for internal compliance monitoring and training. 4. Updated End-of-Term Procedure To ensure ongoing accuracy and compliance, the following revised steps will be followed each term: a. The Director or Assistant Director of Financial Aid will run an All F Report after final grades are posted. b. The Director and Assistant Director of Financial Aid will jointly calculate Return to Title IV (R2T4) funds. c. The Return of Funds Report (ROFS) will be provided to the Registrar monthly to verify last date of attendance and withdrawal dates against Colleague records. d. The Registrar will verify subsequent semester enrollments and continuously monitor student enrollment, reporting any changes to Financial Aid leadership. e. The Registrar will submit end-of-term enrollment data to the National Student Clearinghouse as usual, and one week before the next term begins, will submit the end-of-term R2T4 list to prevent overwriting by subsequent semester reporting. 5. Training and Internal Audit Enhancement a. The Financial Aid and Registrar’s Offices will use findings from this audit to develop staff training on identifying and correcting data discrepancies during the quarterly reconciliation process. b. The Director of Financial Aid will review 80% of R2T4 files during each semester for accuracy in reporting and documentation. 6. Graduation Data Accuracy a. The Registrar’s Office utilizes the Update Academic Credentials File (UACF) in Colleague to batch post student degrees and certificates three times per year (end of spring, summer, and fall terms). b. It was determined that the automatic graduation date populates correctly only when students have a single program with no changes. For students with multiple programs or program changes, the graduation date must be entered manually to ensure accuracy. c. The Registrar will oversee the upload of graduates and verification of accurate credential dates, ensuring these dates are correctly reflected in NSC and the Director or Assistant Director of Financial Aid will make sure the dates are correctly reflected in the NSLDS system. d. The Registrar and Director of Financial Aid will conduct joint reviews to verify that all graduation and enrollment data are reported correctly. Anticipated Completion Date: June 30, 2026 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, and Kayla Miller, Registrar

SIGNIFICANT DEFICIENCY 2025-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV Condition Of the 37 students tested for Return to Title IV procedures, 2 were determined to have had errors in their calculation. Recommendation We recommend that the College review and update its policies to ensure that accurate Return to Title IV calculations are completed. Comments on the Finding For the issue with an institutional charge incorrectly considered in the R2T4 calculation, this was due to a Federal Direct Parent PLUS Loan that was processed and a refund to the parent. Only seven of these loans were processed in the aid year of 2024-25, and there were no other R2T4 situations that involved a Federal Direct Parent PLUS Loan. The refund to the parent was shown at the top of the Banner form while student refunds show at the bottom of the Banner form. Due to the rarity of these loans being included in the calculation and the variation of where this charge is shown in Banner, this was missed. Barton personnel are now aware of where to look for this in these very rare cases. For the situation where the incorrect starting date was identified, there was human error when that was entered. Barton does have a quality assurance process to double check all dates on the Banner withdrawal form, and the R2T4 calculation spreadsheet, however, this review will now extend to checking the enrollment dates in a second Banner form. Action Taken Since the 2024-25 aid year was still open, both instances were corrected. Barton’s Director of Financial Aid has made all personnel aware of the issues and has revised the quality assurance review to watch for these issues.

Funds were drawn outside of the approved grant period because construction began before the grant start date. A reimbursement request was submitted and approved erroneously by the Environmental Protection Agency (EPA) for work completed prior to the eligible period. To correct this, the City is working with the EPA and has submitted a corrective request for reimbursement that will apply the funds already received to eligible work performed within the grant period. No additional funds will be transferred, as the total eligible amount in the corrective request will equal the amount previously received, ensuring all reimbursements align with allowable costs. To prevent recurrence, the City will avoid beginning construction before the official grant period begins and will ensure future grant budget periods include adequate contingencies for early project start dates. Additionally, all future reimbursement requests will undergo a thorough internal review to verify that costs were incurred within the approved grant period, rather than relying solely on federal approval.

Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding. The College experienced some turnover during the year. The new director was unaware that the Cost of Attendance was not being updated when a change in the award was submitted COD due to a change in the student’s schedule. The director is now aware that these changes must be updated manually in COD and has implemented procedures to ensure that the COA is reviewed whenever a revision to the student award is submitted to COD. The college will also confer with the software vendor to determine if any settings in the student information need to be corrected for this update to be automated. The new director of financial aid has been through substantial training in the last six months to better understand how the college’s software communicates with COD and has implemented procedures to ensure the timely submission of disbursements to COD after the disbursements have been made in the student information system. Anticipated Completion Date: Prior records with issues were corrected on September 1, 2025 and ongoing monitoring is taking place

Finding 2025.004 – Period of Performance Federal Program Name: Continuum of Care Federal Assisted Listing Number:: 14.267 Recommendation We recommend that management implement additional controls and policies over period of performance. Staff who purchase items with grant funds should have additional training on period of performance requirements. Planned Corrective Action: TVCCA is strengthening its period of performance controls through the following actions: 1. Training – All employees with purchasing power will be trained on the deadlines of the grants they are responsible for. This training includes what the definition of obligation truly is, as well as allowable spend down period of their grants. Finance staff will also be trained on the timing and definitions of obligations. 2. Revised internal controls and workflow – Cutoff testing will be performed and added to the month close checklist on a quarterly basis to align with grant closing schedules. 3. Monitoring – Cutoff testing will be monitored on a quarterly basis in association with quarter ending checklist. Name of Contact Person: Max Logan, CFO, 860-425-6506, mlogan@tvcca.org Anticipated Completion Date: March 31, 2026

The Administrative Services Office and the Student Affairs Office, or the Grant Manager/Principal Investigator responsible for any specific grants going forward, will work closely with the granting agency to ensure that any unanticipated changes/reductions in funding periods are communicated in time to allow the College to effectively close out the grant, or to obtain permission for funding of expenditures that will not be incurred/and or liquidated timely. Anticipated Completion Date: N/A Contact Person(s): Willie Noseep, Vice President for Administrative Services Coralina Daly, Vice President for Student Affairs

Management agrees with the auditor’s finding and their recommendation. The School returned $37 of Pell Grant Funds on November 25, 2025. Communication will be improved between the financial aid office and the registrar. Procedures will be improved to ensure that R2T4s are calculated correctly. Anticipated Completion Date: The corrective action was completed on November 25, 2025. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

Finding 2025-002 - Accounting Controls - capital Fund Grant Management (Cash Management)-ALN 14.872 Public Housing capital Fund - Noncompliance and Significant Deficiency Corrective Action Plan: AHC has assigned two Senior Managers with eloccs secure system) access. Person Responsible: Shlrley Henderson, Deputy Director, Arnesha Nuniss and Abe Singh, Ex. Dir. Who is waiting for his eloccs access Anticipated Completion Date: September 10, 2025.

Research and Development Cluster— Assistance Listing Nos. Various Recommendation: We recommend that the University review its procedures around review and approval of R&D expenditures to ensure that only valid expenditures are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University does have existing internal control processes over its federal grants. The principal investigators code, approve, and submit expenditures for payment. In addition, principal investigators receive periodic grant reports which include the detail of all transactions charged to their grants for review. The University will add an additional control step to review coding of research and development payment requests in the ERP system prior to payment. Names of the contact persons responsible for corrective action: Gerri Stepanek and Carole Kampf Planned completion date for corrective action plan: September 1, 2025

Finding 2025-001 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2025 Federal agency: United States Department of Agriculture Compliance Requirement: Activities allowed or unallowed, allowable costs/ cash management, eligibility, equipment, period of performance, procurement, program income, reporting, special tests Questioned Costs: None Name of contact person and title: Pat Bishop, President Condition and Context: The auditee did not submit the required audit reports to the Federal Audit Clearinghouse (FAC) and Rural Development (RD) in a timely manner. Specifically:  The 2023 Audit Report was not submitted to the FAC as required under 2 CFR Part 200, Subpart F.  The 2024 Audit Report was submitted past the regulatory deadline to both the FAC and RD. Management Response: Management plans to develop and implement an internal audit compliance calendar with clearly defined submission deadlines for all audit-related deliverables, including due dates for the FAC and RD and Create an internal checklist and sign-off process to confirm that each audit deliverable has been submitted to all required agencies and portals. Status: In progress Anticipated Completion Date: Estimated 2025

Management agrees with the finding and will establish the internal control recommendations outlined in the Schedule of Findings and Questioned Costs. Internal control procedures will be developed and implemented by September 2025.

The College acknowledges the finding and has strengthened its internal controls over federal reporting by piloting the new Jenzabar Financial Aid (JFA) system during SY 2024–2025. The system is designed to reduce manual processing and minimize errors previously encountered in reporting student award amounts, cost of attendance, and disbursement records. JFA, together with SONIS, will improve the accuracy of student information, streamline the review and updating of COD records, and strengthen compliance with federal reporting requirements.

Management concurs with the finding and recommendation. The Organization recognizes the importance of maintaining complete and accurate documentation supporting expenditures reported under federal awards and ensuring that amounts reported to the grantor reconcile to the underlying accounting records. Management has strengthened its procedures for preparing and reviewing ARPA and other grant-related financial reports. The Partnership corrected the reporting discrepancy through its March 2024 Q1 report to the City of College Park, with all subsequent reports reflecting the correction. The final report to the City, submitted on May 16, 2025, as part of the grant closeout, provided a complete accounting of the grant funds expended and their intended purposes, together with bank statements and supporting documentation. The City did not identify any additional concerns with the corrected or subsequent reports following the December 2023 Q4 report. The Partnership has also implemented broader improvements including a redesigned chart of accounts, grant specific project records within QuickBooks, a centralized grant tracker, reorganized electronic files centered on individual grant awards, and a regular review meeting between the Partnership and TCG. These improvements provide clearer grant level accounting, reporting, deadline tracking, and supporting documentation. In addition, since the period under audit, the Partnership has already implemented adjustments to grant reporting. Management maintains a reconciliation between cumulative expenditures reported to the grantor and cumulative expenditures recorded in the general ledger. Management is finalizing written grant administration and reporting policies and procedures as part of the financial policies and procedures updates – outlining requiring grant specific reconciliations to the general ledger and supporting documentation, documented explanations for adjustments and corrections, management review and approval before submission,complete grant reporting files, and period review of reporting and closeout requirements by grantor. Management anticipates competing and formally implementing these policies and procedures by November 30, 2026. Once established, the Finance Committee will receive periodic updates on grant reporting controls and the status of related corrective actions. The Partnership will retain the reports and supporting documentation associated with the $3,86 identified by the auditors and will provide additional information if requested by the City or the federal awarding agency. If a management decision requires additional action, the Partnership will respond withing the timeframe identified in that decision.

Pohnpei has agreed to the findings and is committed to implementing the recommendations. Ongoing Director of Treasury and Administration Sihna N. Lawrence sihna.lawrence@pohnpeidota.fm

AUDIT FINDINGS 2024-001: In one of 25 selections for testwork over period of performance, expenditures related to contract labor were submitted for reimbursement to the Federal Emergency Management Agency (FEMA) that were outside of the project period. Further, the review performed over expenditures was not completed appropriately to identify this error, this is an instance of the District’s internal control not operating as designed. Name of Contact Person: Daria Heimerman, Director of Financial Reporting, dtheimerman@evergreenhealthcare.org Corrective Action Planned: Assess process and controls for improvements to identify expenditures incurred outside of the designated project period. Anticipated Completion Date: August 2025 Statement of Concurrence or Nonconcurrence: Management concurs with audit finding 2024-001.

Person responsible for corrective action plan: Stacey Mike, Interim Tribal Chair Marjianne Yonge, Tribal Treasurer PO Box 747 Lone Pine, CA 93545 (760) 876-1036 Condition: During testing, we noted the following: 21.027 • The Tribe was unable to provide documentation demonstrating that the required Annual Project and Expenditure Report was prepared and submitted. Additionally, the Tribe was unable to provide documentation supporting the calculation of revenue loss used to support expenditures reported under the revenue replacement provision. Corrective Action: Documentation shall be kept to verify timely submission of the Annual Project and Expenditure Report as well as the supporting calculations. Anticipated date of completion: November 30, 2026.