Corrective Action Plans

Program Names/Assistance Listing Titles: Assistance Listing Numbers: Title I Grants to Local Educational Agencies 84.010 Education Stabilization Fund 84.425C Education Stabilization Fund 84.425D Education Stabilization Fund 84.425U Education Stabilization Fund 84.425W Contact Person: James Serbin, Chief Financial Officer Anticipated Completion Date: June 30, 2026 Planned Corrective Action: Since April 2025, Federal & State grant expenditures are verified to conform to the grant applications. Budget revisions are requested and approved before expenditures are made. After reconciling expenditures to the ADE approved grant detail, timely reimbursement requests are made. Journal entries are expected to contain adequate detail and justification and Grant personnel now report to the Business Manager and Chief Financial Officer where they receive ongoing support, training and supervision. The District intends to be in compliance with 2 CFR Part 200.303 during the 2026 fiscal year.

August 20, 2025 FINDING 2024-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Martha L. Arnold-Turner Contact Phone Number and Email Address: 812-275-3111, mturner@lawrencecounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The county corrective action plan will be designed to implement a proper system of internal controls that will ensure compliance with the Reporting requirements of the grant. - The County will implement internal controls that will prevent or correct noncompliance. For all Federal grants that require reports, after one person prepares the report, another person will review the report for accuracy and completeness prior to it being submitted. Anticipated Completion Date: 12/31/2025

The Methodist College Registrar has been working with NSC to get the college relinked to the correct college in their system, which was fixed 11/2023. The registrar redeveloped database query to pull the old data that had been deleted by NSC due to FERPA and began sending accurate file submissions to NSC in June 2024. Files generated and submitted under the College’s new processes are taking roughly one week to process from initial submission, through error correction, and finalization.

Management agrees with the finding and will establish the internal control recommendations outlined in the Schedule of Findings and Questioned Costs. Additionally, the Credit Union has corrected and resubmitted the PPR and UOA reports which were accepted by the CDFI in August 2025. Internal control procedures will be developed and implemented in December 2025 and the Credit Union has corrected and resubmitted the PPR and UOA reports which were accepted by the CDFI in August 2025.

Management’s Response/Corrective Action Plan: The City of Bangor’s Community Development Block Grant program receives direct oversight by the Community Development Officer, responsible for ensuring compliance with Federal regulations, including the determination of eligibility, allowability, and allocability of all financial expenditures. Previously, the City’s practice concerning CDBG funds provided to other departments allowed those project managers to directly charge the CDBG account through payroll, requisition or direct charges which are not first reviewed and approved by the Community Development Officer. The Community Development Officer has implemented the following procedural changes: 1. Executing Interdepartmental Subrecipient Agreements. This document establishes certain standards and expectations for CDBG-funded programs. In 2025-26, Agreements will create new procedural safeguards including submitting requisitions for all expenditures not contained in the approved budget, and to submit receipts or invoices to the Community Development office directly to back up all approved expenses. 2. The Community Development Officer must review and sign off on all expenses charged to the CDBG account by Community and Economic Development Staff, including “OK To Pay” charges, and requisitions. The Community Development Officer recommends the following changes: 1. The issuance of a separate credit card to be used exclusively for CDBG expenditures. The reconciliation process is very tedious and involves sifting through unrelated expenses, and some expenses which are allocated to CDBG which have not been initiated by the Community Development Division and were deemed ineligible by the Community Development Officer. This creates some challenges finding another account to charge to, often a month or more after the expense occurred. The CDBG program does a monthly drawdown for administrative costs, which requires the CDO to make adjustments for expenses that are discovered during the reconciliation process. 2. Eliminating the practice of providing CDBG account numbers to individual departments to directly charge expenses. This leaves the program particularly vulnerable, as when a department charged nearly $435,000 to the CDBG account, requiring reversal of charges that were not eligible. The CDO believes that this change should be initiated by the Finance department with cooperation by the CED. 3. Establishing a review process for personnel expense outside of Salary and Fringe Benefit. Many charges in SunGard related to 701 charges are not viewable as they are deemed privileged expenses. However, some charges for personnel expenses have required review and reversal, and in one case a charge for “travel” was discovered for a program that does not involve this activity. The Finance Department might consider a change to include review if necessary.

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of South Dakota Office of Emergency Management Assistance Listing Number: 97.039 Program Name: Hazard Mitigation Grant Program Finding Summary: Material expenditures were claimed for reimbursement with no documented formal review and approval. Corrective Action Plan: We will continue to have the approvals of material expenditures happen at the requisition level when the materials are ordered. If we must use material from our internal inventory stock, we will use a material charge out sheet that will provide the following information: work order number of project, name of work order, date, material item number (SBR#), quantity, charged by, approved by and posted by. This charge out sheet will then be posted in our IVUE system, and the paper copy will be scanned into vault for documentation. This same procedure will be used for salvage and credit material. For cash management, we will send the final summarized report to the Operations Manager for approval before it is sent to FEMA. Responsible Individuals: Mike Letcher, Operations Manager; Brendan Nelson, Operations Supt.; and Sanden Simons, Operations Supt.; Anticipated Completion Date: The anticipated date of completion is September 2025, as we have notified our employees of this change.

Federal program title - Local Assistance and Tribal Consistency Fund program (LATCF) CFDA 21.032 Recommendation: We recommend the County refine its understanding and interpretation of the standards and ensure that the County policies and procedures are consistent with that understanding and interpretation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The LATCF funds were reported on the SEFA under CFDA 21.032 by the CAO’s department because the funds were transferred from the CAO’s fund to the DOT fund, with the understanding it would be expended. However, DOT did not spend the funds within the same fiscal year in which they received the transfer due to a misunderstanding that the funds could not be used for prior year expense. As a result, the funds were recorded as unearned revenue in fiscal year 2023/24, and the related expenditures will be reported in the following fiscal year. Name(s) of the contact person(s) responsible for corrective action: Lisa McNeely Department of Transportation Business Manager & Christine Gaffney Auditor-Controller. Planned completion date for correcting action plan: Completed

FINDING 2024-003 (prior finding audit number 2023-002) Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Mindy Byers, Auditor Contact Phone Number and Email Address: 765-364-6401 mindy.byers@montgomerycounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: One person will complete the report and another will sign off on a full review. Anticipated Completion Date: April 1, 2026 (based on due date of the next report)

FINDING 2024-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Jessica Secrease, County Auditor Contract Phone Number and Email Address: 765-456-2804 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To prevent a recurrence of this issue in future audits, the County will implement a new internal control procedure. Specifically, the Auditor’s Office will require that both the Deputy Auditor and the County Auditor review and sign off on all Coronavirus State and Local Fiscal Recovery Fund reports prior to submission. This dual-review process will include a standardized checklist to verify data accuracy, consistency with supporting documentation, and compliance with federal reporting requirements. In addition, staff involved in the preparation of the reports will receive refresher training on the applicable guidance and reporting protocols to ensure a thorough understanding of expectations and requirements Anticipated Completion Date: September 2025

FINDING 2024-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Lori Elmore Contact Phone Number and Email Address: 317-325-1315 Lelmore@greenfieldin.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure an internal person reviews the items included in the Annual Project and Expenditure Report before the submission of the report, we will implement a system where communications are exchanged between the Clerk-Treasurer and the person reviewing the submission to verify the report has been reviewed by someone other than the preparer. The spreadsheet which tracks expenditures has been amended to separate the reporting periods. Anticipated Completion Date: By April 30th, 2026 when the next Annual Project and Expenditure Report is due to be submitted.

Communicate with the Budget Board regarding this finding. We have already introduced to the budget board, a form guideline called "Payne County Grant Administration Plan" to aid in proper documentation, repo1ting and proper spending of all grant awards, including creating a capital outlay sub account as recommended.

FINDING 2024-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Shelly Baucco, County Auditor Contact Phone Number and Email Address: (260) 563-0661 Views of Responsible Officials: We concur with the finding and submit the following corrective action plan. Description of Corrective Action Plan: 1. The Auditor will print reports in the date span of the reporting period. 2. The Auditor will fill out the SLFRF Compliance Report and print it out for review. 3. A Deputy Auditor will compare the report documents to the Compliance report from SLFRF with checkmarks, for date span and correct amounts reported. Then sign off when correct and completed. 4. The documentation will be filed in the Grant binder. Anticipated Completion Date: August 2025

FINDING 2024-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Dana Gault, Controller Contact Phone Number and Email Address: 765-382-3762 dgault@cityofmarion.in.gov Views of Responsible Officials: We concur with the finding. Explanation: While the City concurs with the finding that funds were reported as expended in the April 1, 2023 to March 31, 2024 program reporting period, while in fact, these funds were merely transferred from the City’s American Rescue Plan Act Local Fiscal Recovery Fund to accounts for the City’s Redevelopment Commission and Airport Authority, and were not actually expended during said program reporting period from the accounts to which they had been transferred. The City wishes to make it clear that the City made the relevant transfers appropriately and did so to advance permissible programs and projects under the Award Terms and Conditions of the City’s Local Fiscal Recovery Fund Program award. At all times, the City maintained awareness of the funds in question and the status of the programs and projects being undertaken by the Redevelopment Commission and Airport Authority, respectively. The only matter with which the City concurs is the finding that, for purposes of reporting in the City’s Project and Expenditure Report, these funds were in fact transferred to allow the Redevelopment Commission and Airport Authority, respectively, to expend the funds, and that this transfer was reported as an expenditure of such funds in error. Description of Corrective Action Plan: The Deputy Controller will prepare the report and the Controller and the Financial Advisor will review and approve the current reporting period dates and data are correct. We will update the INTERNAL CONTROL to require that the Deputy Controller, Controller and Financial Advisor will include in their preparation and review, identification of the specific expenditure underlying any report of expended funds to avoid future incidents of a transfer of funds being mischaracterized as an expenditure of funds. Anticipated Completion Date: December 31, 2025

August 26, 2025 CORRECTIVE ACTION PLAN Cognizant or Oversight Agency for Audit Trinity Academy for the Performing Arts respectfully submits the followinbg correction action plan for the year ended June 30, 2025 Name and address of independent public accounting firm: AAFCPAs 160 Federal Street 16th Floor Boston, MA 02110 Audit Period: July 1, 2023, thru June 30, 2024 The findings from June 30, 2024, schedul fo findings and questioned cost are discussed below. The findigns are numbered consistently with the numbers assgined in the schedule. FINDINGS - FINANCIAL STATEMENT AUDIT FINDINGS SIGNIFICANT DEFICIENCY 2024-001 Payroll Reccomendation: The Scheool implements a standardized checklist and conducts preiodic internal reviews of onboarding documentation to ensure all required forms are properly completed and retained in accordance with Federal Regulations.. Action Taken: The School is implementing a standardized onboarding checklist; all personnel folders will now included a printed version to ensure required forms, including Form I-9 and Form W-4 are completed in full a the time of hire. In addition, periodic interal review of personnel files are completed in full at the time of hire. In addition, periodic internal reviews of personnel files will be conducted to verify ongoing compliance. HR staff will also receive additional training to reinforce proper documentation procedures and retention requirements. We are committe to strengthening interal controls and ensuring full compliance moving forward. If there are any questions regarding this plan, please call Harold Sands at 401-432-7881. Sincerely yours, Harold Sands

FINDING 2024-001 Finding Subject: Contact Person Responsible for Corrective Action: Michael A. Watkins, Auditor Contact Phone Number and Email Address: 812-385-4927, mwatkins@gibsoncounty-in.gov Views of Responsible Officials: Finding 2024-001: We concur with the finding. Description of Corrective Action Plan: The Deputy Auditor will prepare the report from the financial information in LOW and the Auditor will review and approve it prior to submission with the U.S. Treasury. Moving forward the County Auditor will enhance internal controls procedures to be in compliance with 2 CFR 200.303. This includes protocols to communicate with the U.S. Treasury when system issues are identified that may affect timely or accurate reporting. Anticipated Completion Date: January 1, 2026

USAID Foreign Assistance for Programs Oversees – Assistance Listing No. 98.001 Recommendation: Management should review its existing control structure and ensure that there are adequate processes and controls to ensure only expenditures incurred during the period of performance are booked to Federal programs and that the correct program codes are charged, based on the underlying supporting documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Training on the Federal awards regulations to be provided to the country office. In addition, adjustments will be made to the review structure of expenditure to ensure full compliance. Follow up of the implementation status will be carried out by HQ finance. Name(s) of the contact person(s) responsible for corrective action: Florence Ruona Planned completion date for corrective action plan: September 30, 2025

Finding 2024-003 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2024 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: Management has requested that the auditor propose certain year-end adjustments to bring the financial statements into conformity with Generally Accepted Accounting Principles (GAAP). For example, cash to accrual adjustments, depreciation calculations and adjustments, adjustments to debt and interest expense, interest subsidy adjustments, etc. Management Response: Management has evaluated the risk that a material misstatement might occur and not be detected in the financial statements. Management believes that the risk of material misstatement is not significant for the following reasons: 1. The entries are standard entries required to be made each year. If an entry was not made it would be obvious in the financial statements. A calculation error that would be material to the financial statements would also be obvious. 2. Management reviews and approves both the proposed adjusting journal entries and the financial statements prior to release. Based upon management’s consideration of the risk of material misstatement, management believes the costs of hiring, training, and monitoring part-time accounting personnel far exceed any potential benefits from implementing additional controls. Status: In progress Anticipated Completion Date: Estimated 2025

Finding 2024-001 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2024 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

FINDING 2024-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Federal Agency: Department of Treasury Contact Person Responsible for Corrective Action: Elizabeth Modesto Contact Phone Number and Email Address: 219-841-6326 Emodesto@portage-in.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: A new process of tracking grants for the City has been implemented; however, it should be noted that the previous Clerk-Treasurer prepared and submitted the report 2022. The report for 2024 was submitted in a timely fashion as required based on the fund activity in 2024. The report due and submitted in April 2025 was done similarly. Future reporting activities will not be necessary for this grant as it was completed in 2024. Anticipated Completion Date: New process will be completed prior to the preparation of the Annual Financial Report that will be submitted by March 1st of 2026 for all active federal awards.

Accounting has reviewed all projects and Ordinances related to ARPA and has updated reports and records to fully account for ARPA funding. From the Chief Administrative Officer (CAO) and the department responsible for a specific project that has multiple funding sources, confirmation was obtained on what amounts were obligated ARP funds. This strengthens the controls over the report submission process to ensure the reported amounts are accurate and reconciled properly. Person Responsible: Sheila Faour, CFO Anticipated Completion Date: Immediately

FINDING 2024-002 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Valeriano Gomez, City Controller Contact Phone Number and Email Address: (219) 391-8220, vgomez@eastchicago.com Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: To ensure proper implementation of the policies and procedures in place related to SLFRF reporting, in the future, no submittal of reports will be approved without the City Controller and a Senior Staff Accountant reviewing and approving the P&E reports. This will ensure policies and procedures are followed and possibly added to, if needed, to ensure compliance over SLFRF reporting. Anticipated Completion Date: Corrective action is now in effect as of August 18, 2025.

Continuum of Care Program – Assistance Listing No. 14.267 Recommendation: We recommend the Organization evaluate its procedures and implement an additional control to ensure costs are charged to the grant during the period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Prior to 2023-2024, we only had one primary HUD contract that we were solely responsible for spending and contract timelines. With the addition of three more COC grants, with different, yet close together end dates, we needed to develop a more formalized process to ensure all expenses are billed to the correct contract for the correct dates. Avivo will implement oversight check-in meetings at least one month prior to each contract end and at least one more before final grant submissions. This meeting will include program leadership, RAA, Director of Housing Compliance, and our Contracts Accountant who oversees eLOCCS pulls. We will discuss all final expenditures and any upcoming expenses that may near the end of the grant term, including staff expenditures like mileage reimbursement. We will create an oversight document that highlights all areas to consider and breaks down roles and responsibilities to drive these meetings ongoingly. Accounting and program leadership will closely monitor spending via Papersave, credit card submission and through Paycom falls within the correct payment periods. Additionally, the RAA and Program Managers in the last quarter of the grant cycle, will meet monthly to work to resolve any outstanding rent balances and oversee any staff reimbursement or other charges that may need to be accounted for. Name(s) of the contact person(s) responsible for corrective action: Courtney Knoll & Lyssa Westling. Planned completion date for corrective action plan: December 2025

The Town is in the process of reviewing Policies and Procedures as they relate to Federal Awards.

FINDING 2024-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The City submitted four P&E reports during the audit period; however, the controls in place were not effective to prevent, or detect and correct, errors. As a result, errors in reporting were identified. The current period and cumulative expenditures reported consisted of the amounts expended by the beneficiaries who were awarded funds from the City, rather than total amounts expended to the beneficiaries, resulting in current period expenditures and cumulative expenditures being incorrectly reported on all four reports as follows:  Quarterly Report: October 1, 2023 to December 31, 2023 Current period expenditures were overstated by $666,417. Cumulative expenditures were understated by $964,879.  Quarterly Report: January 1, 2024 to March 31, 2024 Current period expenditures were overstated by $860,312. Cumulative expenditures were understated by $104,567.  Quarterly Report: April 1, 2024 to June 30, 2024 Current period expenditures were overstated by $104,567. Contact Person Responsible for Corrective Action: Linda Moeller Contact Phone Number and Email Address: 812-948-5333 and lmoeller@cityofnewalbany.com Views of Responsible Officials and Explanation and Reasons for Disagreement:  We concur with the finding.  However, the issue and non-compliance deals with the interpretation of the federal rules regarding the appropriate amounts to report and when to report them by subrecipients of the monies.  The non-compliance is not related to policies or controls not being effective to prevent, detect or correct errors. In fact, the reporting system initially implemented by the City and put in the federal reports provided the actual expenditures for those periods by recipients of the grants.  However, the City does agree that after full examination and review of the federal rules the initial full amount of funds provided to the subrecipients should have been reported in full versus the actual expenditures during the periods. Description of Corrective Action Plan:  Current period and cumulative expenditures reported will consist of the amounts advanced to subrecipients. Anticipated Completion Date:  The City has already made this correction in its Quarterly Report July 1, 2024 to September 30, 2024.

County department personnel changes have been implemented, which address this deficiency. Additional training from the Auditor’s Office and state grantors has occurred for newer staff in certain departments with large amounts of federal and state awards.