Corrective Action Plans

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Corrective Action Plan: In response to the FY21 Corrective Action Plan, CFSC implemented a Subrecipient Monitoring Policy in June 2024 to ensure compliance with the Uniform Guidance for monitoring subrecipients of federal funding, including audit requirements and the verification of suspension and debarment status. To further strengthen compliance and ensure timely verification, CFSC will implement the following actions: 1. Mandatory Pre‐Award Verification Timing & Documentation: a. Suspension and debarment status must be verified on SAM.gov by the assigned Grant Specialist before the execution of any subaward agreements. b. The verification data and results will be documented by the assigned Grant Specialist and included in the Risk Assessment process prior to award issuance. c. Any subrecipients flagged as high risk due to past audit findings will undergo enhanced pre‐award due diligence before subaward execution to be carried out by the assigned Grant Specialist. 2. Grant Compliance Oversight & Approval: a. The Grants Manager (or designee) will review and approve all subrecipient compliance checks before final award execution. b. Any exceptions or delays in verification must be documented and approved by the CFAO & Deputy Director before proceeding. 3. Quarterly Compliance Audits: a. The Grants Manager (or designee) will conduct quarterly internal audits of subrecipient monitoring files to confirm that suspension & debarment verification was completed timely before subaward execution. b. The Grants Manager will be responsible for reporting any identified deficiencies to senior management and ensuring timely correction for policy reinforcement. Anticipated Completion Date: CFSC has implemented corrective actions regarding mandatory Pre‐award verification & documentation (action item 1) and grant compliance oversight & approval (item 2). CFSC has begun to implement the quarterly compliance audits (item 3) and will have this fully implemented by the end of FY25.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Corrective Action Plan: In response to the FY21 Corrective Action Plan, CFSC implemented a Subrecipient Monitoring Policy in June 2024 to ensure compliance with the Uniform Guidance for monitoring subrecipients of federal funding, including audit requirements and the verification of suspension and debarment status. To further strengthen compliance and ensure timely verification, CFSC will implement the following actions: 1. Mandatory Pre‐Award Verification Timing & Documentation: a. Suspension and debarment status must be verified on SAM.gov by the assigned Grant Specialist before the execution of any subaward agreements. b. The verification data and results will be documented by the assigned Grant Specialist and included in the Risk Assessment process prior to award issuance. c. Any subrecipients flagged as high risk due to past audit findings will undergo enhanced pre‐award due diligence before subaward execution to be carried out by the assigned Grant Specialist. 2. Grant Compliance Oversight & Approval: a. The Grants Manager (or designee) will review and approve all subrecipient compliance checks before final award execution. b. Any exceptions or delays in verification must be documented and approved by the CFAO & Deputy Director before proceeding. 3. Quarterly Compliance Audits: a. The Grants Manager (or designee) will conduct quarterly internal audits of subrecipient monitoring files to confirm that suspension & debarment verification was completed timely before subaward execution. b. The Grants Manager will be responsible for reporting any identified deficiencies to senior management and ensuring timely correction for policy reinforcement. Anticipated Completion Date: These corrective actions will be fully implemented by the end of FY25, with ongoing monitoring and enforcement thereafter.

July 25, 2025 The Blackstone – Millville Regional School District respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Robert E. Brown II, CPA Certified Public Accountant 25 Cemetery Street P.O. Box 230 Mendon, Massachusetts 01756 Audit period: The finding from the June 30, 2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule of expenditures of federal awards. Finding 2024-001 – Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Expenditures charged to the Special Education Cluster major program must be within the period of availability of the individual grants that are part of the major program cluster. The Period of Availability for the SPED PL 94-142 Grant was October 2, 2023 through September 30, 2025, ARPA IDEA September 29, 2021 through September 30, 2023, 21st Century Enhanced Programs for Students with IEP’s September 1, 2023 through August 31, 2024, and 21st Century Community Learning September 1, 2023 through June 30, 2024. Condition: During our test of controls over compliance it was noted that there are expenditures charged to these various programs, the SPED PL 94-142 Grant was October 2, 2023 through September 30, 2025, ARPA IDEA September 29, 2021 through September 30, 2023, 21st Century Enhanced Programs for Students with IEP’s September 1, 2023 through August 31, 2024, and 21st Century Community Learning September 1, 2023 through June 30, 2024 that are for services outside of the period of availability as set forth by the Massachusetts Department of Elementary and Secondary Education. Context: During our test of expenditures and the review of the general ledger we noted the follow: • SPED PL 94-142 Grant as it is related to compliance it was noted that 3 vendor invoices charged to the grant were for services prior to the grant start date of October 2, 2023 and thus would be outside the period of performance and thus would not be allowable costs. • ARPA IDEA Grant as it is related to compliance it was noted that 1 vendor invoice charged to the grant was for 11 months of service that extended beyond the grant end date of September 30, 2023 and thus would be outside the period of performance and thus would not be allowable costs. • 21st Century Enhanced Programs for Students with IEP’s Grant as it is related to compliance it was noted that 1 payroll transaction charged to the grant was for services prior to the grant start date of September 1, 2023, and thus would be outside the period of performance and thus would not be allowable costs. • 21st Century Community Learning Grant as it is related to compliance it was noted that 3 payroll transaction charged to the grant were for services prior to the grant start date of September 1, 2023 and thus would be outside the period of performance and thus would not be allowable costs. Effect: The School District was not in compliance with the period of availability requirement as set forth by the Massachusetts Department of Elementary and Secondary Education. Questioned Costs: Questioned costs for the expenses charged to the major program that are outside the period of availability is $24,840.55. Cause: The absence of a Director of Finance and Operations led to a lack of centralized oversight for grant expenditures. As a result, submissions were not consistently reviewed for compliance with grant award timelines and allowable use criteria. Identification as a Repeat Finding: N/A Recommendation: We recommend the School District follow procedures to ensure that expenditures charged to the grant are within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Managements Response: 1. Hiring of Key Personnel: In April 2024, the district hired a new Director of Finance and Operations, who now oversees all financial and grant-related activities to ensure full compliance with state and federal requirements. 2. Reinforced Review Procedures: All grant expenditures must now be submitted through a centralized review process, which includes validation of budget alignment and period of availability before approval. 3. Staff Training: All staff responsible for grant management have completed training on federal and state grant compliance requirements, including proper expenditure coding and allowable use of funds. 4. Internal Monitoring: Monthly reviews of all active grants are now conducted by the Business Office to identify and correct any discrepancies proactively. Expected Outcome: These corrective actions will ensure that all grant expenditures are compliant with award requirements and period of availability. The presence of a qualified Director of Finance and Operations and the implementation of new procedures will prevent recurrence of this issue in future fiscal years. Responsible for Corrective Plan: Director of Finance and Operations Estimated Completion Date: Complete as of September 2025 Action Taken: See Management Response above

2024-105 Lack of Payroll Review and Approval Condition: No documentation of employee time approval by supervisors could be provided. The payroll clerk processes the payroll, and the finance director approves through the releasing of the payroll. However, there is no formal documentation of the overall review of the payroll process and the supervisors’ approval of time recorded by employees. Corrective Action Planned: The Organization has implemented a new payroll process using the ADP system. Employees are now required to approve their own time within the ADP portal, and this approval is documented. Following this, supervisors review and approve their employee's time, which is also documented in the portal. Human Resources then prepares the payroll, reviewing all entries and initialing a shared file of payroll items and providing backup for changes. Once HR confirms accuracy, they notify Finance. Finance then reviews the payroll, with the Finance Manger providing the final approval within ADP once all items are confirmed. This entire process is fully documented, with approvals recorded within the ADP by employees and supervisors and the shared file drive where HR and Finance initial off on the reviewed payroll items, ensuring a traceable record of the entire payroll approval process Person Responsible for Corrective Action: Robert Thompson, Chief Executive Officer Anticipated Completion Date: Implemented

Identification of the federal program: Federal Agency: U.S. Department of Homeland Security (DHS) Assistance Listing: 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 7/1/2022-4/30/2023 Summary of Finding: The Personal Protective Equipment (PPE) and other COVID related supplies were not used within the period of performance outlined within the project worksheet. There were three FEMA obligations during FY 2024. An overstatement of expenditures in one of the projects (project 10) was identified with an obligation amount of $6,732,507. The period of performance as specified within the project 10 application is July 2, 2022 to April 30, 2023 and $1,077,759 of costs were not used by April 30, 2023. The overstatement represents approximately 16% of the amounts reported in the project 10 application and 14% of the total FEMA obligations in FY 2024. The total federal expenditures for FEMA for FY 2024 were $7,795,530. Corrective Action Plan: Management agrees that a thorough review of the claim was not completed prior to submitting the Request for Reimbursement to the State of Michigan, thus causing a control deficiency. In the future management will perform, document, and sign off on a thorough claim review to validate that all final adjustments have been submitted prior to submitting the Request for Reimbursement to the State. Individuals responsible for corrective action: Brittany Kruse, Vice President Finance and Assistant Controller Cindy Brink, Director, System Accounting and Reporting. Timing of corrective action: September 1, 2025 and going forward.

FINDING 2024-005 Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor will have the Deputy Auditor start signing off on all reports to verify the dates are correct for the reporting period. Anticipated Completion Date: August 30, 2025

FINDING 2024-003 Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number: 317-392-6310 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor or Department head will review and document their review for all Federal Grant disbursements for applicable grant requirements and Federal regulations. Anticipated Completion Date: August 30, 2025

FINDING 2024-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Reporting Contact Person Responsible for Corrective Action: Heather Huff Contact Phone Number and Email Address: 812-265-8907 heather.huff@jeffersoncounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Auditor’s Office will collect dual signatures on all submissions for reporting requirements. The Auditor’s Office will also have additional employees verify submissions to ledgers for accuracy. Anticipated Completion Date: Completion is anticipated for all reports due after 12-31-2025.

Management will ensure Federal expenditures are obligated during proper period and reported appropriately.

Views of Responsible Officials: Management concurs with the recommendation and has implemented procedures to ensure that

future SEFA reporting aligns with applicable period of performance requirements.

2024-003 – Reporting – Significant Deficiency Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758 Condition/Context: The Organization identified during the preparation of its second quarter 2024 expenditure report approximately $25,000 in costs incurred during November 2022 that had not previously been included in a submitted expenditure report to PCCD and which were included in the second quarter 2024 expenditure report. While such costs were incurred during the overall program performance period and were allowable and attributable to the program, such costs were not timely identified and reported on the correct expenditure report. Corrective Action Plan: To strengthen our internal controls and ensure full compliance with grantor reporting requirements, we are implementing the following corrective measures: 1. Review and Update of Reporting Procedures: o We will review and revise our existing grant expenditure reporting procedures to ensure that all expenditures are properly captured, reviewed, and reconciled before submission to the grantor. o Revised procedures will clearly define roles and responsibilities for program staff, grants management, and accounting. 2. Monthly Reconciliation Process: o A monthly reconciliation process will be implemented to match recorded expenditures in the general ledger with grant budgets and program activity. o Variances will be reviewed and resolved in advance of quarterly reporting deadlines to prevent errors in submitted reports. 3. Dual Review and Approval: o All quarterly expenditure reports will be subject to dual review by the grant’s accountant and the accounting operations manager prior to submission. o This control will ensure that reports are complete, accurate, and supported by accounting records. 4. Training and Communication: o Finance and program staff involved in grant administration and reporting will receive training on updated procedures and internal control expectations. o Ongoing communication between departments will be encouraged to ensure awareness of allowable costs, budget constraints, and reporting timelines. 5. System Enhancements: o We are evaluating our current financial system and looking for a system that will allow better tracking of grant-specific expenditures, including improved reporting functionality and coding accuracy.

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.

FINDING 2024-004 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Christy Smiley Contact Phone Number and Email Address: 812-663-2570, auditor@decaturcounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: INDIANA STATE BOARD OF ACCOUNTS 27 At least 2 people will look over the report and check all receipts and expenditures when the next P&E report is submitted to prevent and detect any errors. Prior P&E report had already been submitted before the prior audit was complete and we were made aware of the issue and then the Auditor changed in 2025. Control will not be in place until the 2026 P&E report is submitted. Anticipated Completion Date: Submission of next ARPA report, April 2026.

2024-003 Period of Performance - Community Development Block Grants/Entitlement Grants Cluster Assistance Listing Number 14.218 Grant Period - Year Ended December 31, 2024 Condition Found The City did not meet program timeliness spending requirements. The City’s unexpended balance at December 31, 2024 of $2,548,256 is more than 1.5 times the $1,319,714 entitlement grant for the current year. We consider this to be an instance of non-compliance relating to the Period of Performance Compliance Requirement. Corrective Action Plan The City of Decatur received the 2023 Management Letter on May 15, 2025 with this same instance of non-compliance, after most of the 2024 financial audit was completed and the 2024 fiscal year had ended. The City of Decatur Economic & Community Development Department is under new leadership with Lacie Elzy as Acting Economic & Community Development Director. Director Elzy will be reviewing all grant programs and duties in the department and ensuring that grant requirements are met. As of the date of this letter, timeliness spending requirements have been met and the City is compliant. Responsible Person for Corrective Action Plan Lacie Elzy, Acting Economic & Community Development Director Implementation Date of Corrective Action Plan December 31, 2025

One of the four CMF funded projects, Barry Farm, is a two-phase project. The construction start was delayed due to local permitting challenges and COVID-related issues which resulted in the project not being completed by the original Project Completion date of March 27, 2024. Management informed CDFI Fund of the delays in the project and on May 16, 2024, CDFI Fund provided a one-year cure period to March 31, 2025. At that time, Management informed CDFI Fund that the second phase of the Barry Farm project would require a longer cure period due to a 30-month delivery schedule, driven by the incorporation of a large geothermal system, with delivery set for late 2026. CDFI Fund directed Management to report on the second phase’s progress with a new cure period request annually until project completion. During the cure period, Barry Farm’s first phase was completed, and is now leased up and operating. In March 2025, Management informed CDFI of the project status for phase two which is now 24% complete and remains on schedule for completion in November 2026. CDFI Fund provided a one-year cure period until March 31, 2026. Management has otherwise significantly exceeded the grant’s performance targets and will request cure period extensions until project completion.

Finding Number: 2024-001 Condition: The expenditures were reported for the Capital Magnet Fund throughout the award period from the year ended June 30, 2019 to the year ended June 30, 2024 on the schedule of expenditures of federal awards (SEFA) but did not accurately report the amount of administrative expenditures incurred during the performance period, and, therefore, the SEFA was not complete and accurate for the year ended June 30, 2019 to the year ended June 30, 2024. Planned Corrective Action: Management has implemented procedures and controls to ensure reports are reviewed prior to submission and distributed funds are reported properly and in the correct period. Contact person responsible for corrective action: Lindsey Dehring, Vice President of Financial Planning & Analysis Anticipated Completion Date: July 31, 2025

Recommendation We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date.

The Department of Family and Support Services (DFSS) will review its budget and monitoring process for the Emergency Solutions Grant (ESG) Program to ensure grant funds are prioritized for spending in accordance with the program requirements. Monthly expenditure reports will be reviewed by the Director of Homeless Prevention Policy & Planning to assess spending progress and to follow up on any delays in vouchering by subrecipients. Specifically: 1. The Director will review monthly expenditure reports provided by the Department of Family and Support Services (DFSS) Finance team by the 10th of each month for all ESG grant awards. 2. The Homeless Services Division will send notices to agencies with expenditures below contracted expenditure expectations on ESG awards on at least a quarterly basis. The notice will include the current expenditure rate, a reminder on expectations to voucher on a monthly basis within 15 calendar days of the end of the month, and a request for the agency’s plan to improve expenditure rates in line with contract expectations, which are as follows: a. First quarter 25% b. Second quarter 50% c. Third quarter 75% d. Fourth quarter 100% 3. Any unspent ESG funds in the first 12 months of the grant will be reallocated in the second 12 months of the grant to maximize expenditures. Director of Homeless Prevention Policy & Planning Howard at the Department of Family and Support Services will be responsible for ensuring the implementation of this corrective action plan by December 31, 2025. The Voucher Audit and Tracking Unit (VATS) within the Department of Finance, Grant and Project Accounting Division will closely monitor the daily report of accumulated subrecipient (delegate agency) vouchers and prioritize aged vouchers. The goal is to issue payment for aged subrecipient vouchers within 15 calendar days. If the supporting documentation for the vouchers is incomplete or requires additional follow-up information, VATS will hold the vouchers for 2 business days pending the additional supporting documentation/information from the delegate agency. If the supporting documentation is not received within 2 business days, then VATS will reject the vouchers and provide an explanation for the rejection. The delegate agency will be allowed to re-submit the voucher(s) with the required supporting documentation. Chief Voucher Expediters Mendez and Vargas at the Department of Finance, Grant and Project Accounting Division, Voucher Audit and Tracking Systems (VATS) Unit will be responsible for ensuring timely payments to subrecipients and for the implementation of this corrective action plan by July 31, 2025.

Finding 2024-002 – Significant Deficiency Award No.: Assistance List (AL) No. 15.555 and No. 15.704 Federal Grantor: U.S. Department of the Interior, Bureau of Reclamation. AL No. 15.074 Passed-through the Del Puerto Water District Compliance Requirement: Other compliance requirements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was not complete, and expenditures reported on the SEFA were revised during the single audit. Criteria2 CFR Part 200, Subpart F (Uniform Guidance) Section 200.502 states, “The auditee should prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee’s financial statements.” Internal controls over preparation of the SEFA should be in place to ensure accrual basis expenses incurred under each federal program are properly reported as expenses on the SEFA and are properly reported as revenue in the financial statements prior to the start of the single audit. Cause: SEFA was not fully reconciled and finalized until after the single audit began. Effect: Expenses were omitted from the SEFA that should have been included and other expenses were included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of the audit. This delayed the audit testing and major program determination process and could have resulted in the wrong programs being tested as major programs and the single audit not complying with the Uniform Guidance. Context: The District’s Finance Department was not informed of grant amendments that changed the amount of federal funding available. The expenses reported on the SEFA were revised during the single audit as follows. • AL No. 15.555 San Joaquin River Restoration Program Poso Canal Bridge Replacement: The District estimated additional reimbursable costs of $30,335 existed for the Poso Canal Bridge Replacement grant under a potential new $990,000 grant amendment that was to be signed by the USBR in 2025. The amendment was not approved for the Poso Canal Bridge Replacement but the District included the additional reimbursable expenses on the SEFA. The expenses on the SEFA had to be reduced to reflect the eligible federal grant maximum reimbursable expenses under the approved grant agreement at year-end. • AL No. 15.704 Small Surface Water and Groundwater Storage Projects Orestimba Creek Recharge and Recovery Expansion: An additional grant amendment was identified during the single audit that authorized an additional $1,262,928 of federal funding. The District had eligible expenses during the period of performance to fully claim the additional funding, but did not include the expenses on the SEFA. Recommendation: We recommend additional review procedures be implemented to ensure the SEFA is complete and accurate when the single audit begins, which includes working with program managers to identify each grant awarded, obtain current executed grant agreements and amendments, reconciling all expenses incurred under each federal awards down to the invoice, payroll check and lowest level of any other costs claimed, cutting-off each expense at year-end and claiming the reconciled qualifying expenses within 45 days after quarter end. At year-end, programs should be reviewed for cost adjustments, extensions, and other changes that should be reflected on the SEFA when reconciling expenses for the SEFA. Separate general ledger program codes should be used for each grant on the SEFA that summarizes expenses down to the individual invoice level that should be provided to the auditor for the single audit. If overclaimed amounts are identified, the grantor and/or pass-through agency should be contacted to determine whether to return the funds or apply the overclaimed amounts to future claims. Views of Responsible Officials and Planned Corrective Actions: Prepare a summary of grant expenses to reconcile to claims with performance periods included. Staff has prepared an expense summary for Orestimba Creek Recharge and Recovery project and will be updated moving forward. A similar file will be created for each grant received. Estimated Completion Date of Corrective Action: File started for Orestimba Creek.

Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles   Contact: Chad Bender   Title: Controller  Phone Number: 202-785-0072 Estimated Completion Date – ongoing  Corrective Action  The results of the 2024 audit will be shared with appropriate staff and reiterated in training to ensure that adequate attention and guidance is provided on recording expenses within the correct accounting period. PSI delivers in person training to its global finance and program staff and will continue to offer training during 2025 to address such issues.

Internal Controls over Compliance and Compliance with the Period of Performance Compliance Requirement     Contact: Chad Bender  Title: Controller  Phone Number: 202-785-0072  Estimated Completion Date – done  Corrective Action  The results of the 2024 audit will be shared with appropriate staff and reiterated in training to ensure that adequate attention and guidance is provided on the allowability of trailing costs and the unallowability of newly incurred costs. PSI delivers in person training to its global finance and program staff and will continue to offer training during 2025 to address such issues.

We will obtain written documentation of the period of performance for all applicable projects to ensure compliance.

As with Finding 2024-002, employees will now use the time tracking software to log fleet assets with time entries. All submissions will be reviewed and approved by someone other than the submitter or Line Foreman.

We have implemented a time tracking software feature allowing employees to associate fleet assets with their time entries. Entries will be submitted by the employee or Line Foreman, then reviewed and approved by a separate supervisor or manager.