Corrective Action Plans

Condition 1: The new FMIS includes built-in controls to monitor the period of performance, including tracking the last day for encumbrances and payments, ensuring timely and accurate financial management. Condition 2: In FY2025, all invoices with corresponding purchase orders are uploaded into the system by the Procurement & Supply Division. Once uploaded, the Accounting Division reviews and processes payments accordingly. Additionally, Accounting Management reinstated the pre- review of payment request vouchers with corresponding BRVs prior to payment issuance to strengthen controls and ensure compliance. Condition 3: A control process is currently in place whereby each Notice of Award (NOA) is assigned to a single, corresponding SPG account. Condition 4: NOAs and all relevant grant documents are required to be uploaded to Bisan at the time a new SPG account is created.

As part of the close-out process, all open purchase orders are now submitted to the Department of Finance for closure. The grant close-out process has been shifted to the OMB to ensure the grant is no longer available for transaction entries or liquidations. Additionally, a dedicated Fiscal Analyst is being integrated into the workflow to ensure compliance.

The Government concurs with the finding. OTAG enhanced grant setup, expenditure charging, and closeout controls to ensure costs are charged to the correct award and within the approved period of performance, including 90-day liquidation monitoring.

VIDE acknowledges the audit finding regarding the Child Nutrition Cluster Period of Performance and concurs with the recommendation. We recognize that while the cost was incurred during the valid period, the liquidation payment occurred 18 days past the allowable deadline. To prevent recurrence, VIDE will enforce strict protocols for grant closeout and liquidation. To achieve this, VIDE will establish an internal hard stop deadline for invoice submission, requiring that all invoices for expiring grants be submitted to the Fiscal Office no later than 45 days prior to the federal liquidation deadline to provide a necessary buffer to resolve vendor disputes and process payments before the federal cutoff. Additionally, the State Director of Special Nutrition Programs will implement a scheduled notification system to issue closeout alerts to relevant program staff and fiscal support personnel at 90, 60, and 30 days prior to the liquidation deadline, which will trigger the immediate review of open encumbrances and the expediting of pending invoices to ensure the internal hard stop deadline is met. Furthermore, for any valid expenditures remaining unpaid within 30 days of the liquidation deadline, the Fiscal Office will generate a priority payment list and transmit it to the Department of Finance with a high-priority flag to ensure these specific vouchers are processed before the grant period closes. Finally, the Federal Grants Director and the Deputy Commissioner of Fiscal and Administrative Services will review the Grant Expiration Report monthly to identify grants approaching their liquidation deadline and ensure the internal cut-off dates are being adhered to.

The City will work to ensure all reports for grant funding are completed.

• Strengthen monitoring controls to verify period of performance, including obligation/incurrence and liquidation timelines. • Collaborate with grantors to clarify and document allowable liquidation periods for drawdowns. • Implement systematic filing of supporting documents for easy retrieval. • Note: Drawdowns conducted in close collaboration with grantors, confirming compliance with agreed terms. 9/30/2026 Ms. Senny Phillip, Asst. Secretary of Investment & International Financing Email: senny.phillip@gov.fm

U.S. Department of Health and Human Services Period of Performance Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: We recommend that the Organization design, implement, monitor and maintain evidence over internal controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will assign responsibility for maintaining source documentation to a specific individual or team and develop a system for organizing and storing source documentation, such as a centralized electronic database. Monitoring and testing procedures will be implemented to ensure that source documentation is being maintained and is readily accessible. Lastly, there will be regular reviews and updates to the system for organizing and storing source documentation as needed to ensure ongoing effectiveness.

Condition: During the audit, it was identified that $247,000 in federal funds were expended outside of the authorized period of performance for the Emergency Shelter Grant Program under the CARES Act. These expenditures were deemed unallowable by HUD and required repayment. The issue resulted from the lack of an effective monitoring system to track grant performance periods and ensure compliance with federal requirements. Planned Corrective Action: 1. Implement a Grant Period Monitoring System: The organization will establish a formal process for tracking the start and end dates of each grant’s period of performance, including automated alerts and internal checklists. 2. Strengthen Internal Controls: Develop procedures to ensure all expenses are reviewed and approved based on the grant’s performance period before payment or reimbursement/ 3. Staff Training: Provide mandatory annual training for fiscal and program staff on Uniform Guidance cost principles, compliance requirements, and federal reporting standards. 4. Pre-Audit Reconciliation: Conduct quarterly reconciliations of grant expenses to verify compliance with the authorized periods and allowable cost principles. 5. Documentation Submitted to HUD: The organization has submitted supporting documentation and justifications to HUD to validate the expenditures incurred outside the contractual performance period. These expenditures were related to payroll and operational costs within the same program operation. The entity awaits HUD’s determination and will comply with any final resolution or additional corrective guidance provided.

Finding Number 2023-004 Period of Performance Corrective Action Plan (CAP) The State (DAS) will issue a memo requiring all departments to document the period of performance procedures performed. Additional training will be provided to ensure departments are complying. Anticipated Completion Date September 30, 2026 Responsible Person (Contact Details) Jonas M. Paul- Director (DAS) jpaulckdas@gmail.com Kayviann Hallers – Internal Control kayviannhallers@gmail.com

2023-010 – Material Weakness & Noncompliance, Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance: FEMA Disaster Grants (ALN 97.036) Corrective Action: Develop an improved detailed tracking system for force account labor and materials. Require contemporaneous documentation of payroll and invoices tied to FEMA projects. Grants Officer to oversee federal disaster recovery funds. Timeline: New procedures adopted October 2025; effective for any new FEMA claims. Responsible Party: Grants Officer in coordination with relevant departments

All expenditures will be verified prior to disbursement to ensure they are paid within the defined grant period.

Finding Number 2023-059 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425R; 84.425U) Planned Corrective Action Beginning with FY23, the ESSER Performance Report (formerly known as the ESSER Annual Reporting) data from LEAs has been collected in our Grants Management System (GMS). This has increased the accuracy of data reported annually to USDE. Anticipated Completion Date March-2024 Responsible Contact Person Tammy Smith

Finding Number 2023-101 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.027 Federal Program name: Coronavirus State And Local Fiscal Recovery Funds (CSLFRF) Planned Corrective Action The Oklahoma Office of Management and Enterprise Services – Grants Management Office (OMES-GMO) respectfully disagrees with this finding, specifically with the criteria from the Code of Federal Regulation utilized as the sole foundation for this finding, 2 CFR §200.303. This regulation states, in part that, “The Non-Federal entity must; (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” (emphasis added). For further clarity as to the standard for reasonableness, clarity can be found in 2 CFR § 200.1 Questioned cost, that states in part: Questioned cost means a cost that is questioned by the auditor because of an audit finding: … (4) where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. Findings bolstered by the reasonable prudent person standard in 2 CFR §200.303 must not rest on a perfect person standard, nor rest on an experienced auditor standard, but based on the care applied by the ordinary prudent person acting reasonably under the circumstances at the time of their review. From this perspective, the efforts of participants to obtain reasonable assurances included meetings, correspondence, and the gathering of documentation in support of work in furtherance of the program. If the determinations based on the documentation provided at the time satisfy reasonableness upon review, then subsequent documentation will not sustain the finding based on the criteria cited in 2 CFR §200.303. At the outset of the program, DHS was assessed as a low risk subrecipient in part due to its extensive experience with federal awards. Supporting documentation produced by the agency during the period associated with the finding reflected the breakout of the vendor’s hours and rate for the projects. Sustained communication and correspondence between the agencies and the vendor contributed to providing additional assurances that the work was consistent with the documentation in support. Agency-Specific Responses: The identified agency, DHS, provided the following independent response: OKDHS has the backup for each invoice submitted by its contractor, JGC, and reviews the invoices as the hours are reflected in the backup. OKDHS and the supplier keep detailed records and support for all activities related to CSLFRF. The Oklahoma legislation, HB 2884, effective 3/28/2023, appropriates $65 million from ARPA pandemic relief funds to OKDHS for use on 9 projects as approved by the Joint Committee on Pandemic Relief Funds. Without separating administrative costs per project, Section 13 of the bill provides that OKDHS may retain 2% of the funds appropriated in the bill for costs associated with administering the projects in the bill as a whole, "provided that no funds shall be retained that would be disallowable under the provisions of the American Rescue Plan Act of 2021". The total administrative allowance to implement HB2884 equates to $1,304,847.00. The American Rescue Plan Act of 2021 grant guidance for administrative fees at or lower than the accepted de minimis rate (10%) "does not require documentation to justify its use." Anticipated Completion Date N/A Responsible Contact Person OMES: Parker Wise DHS: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell

Finding Number 2023-092 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) disagrees with the report did include the demographic section, which is a required reporting element. Per the email titled 2025.03.24 Reporting download Issue OIG, page 7 of the pdf request verification the demographic data was received. On page 6 of the attachments a response states that the data for Q1, Q2 and Q3 2023 had been received. Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. Beginning with FY2025, OMES has taken the following measures: • Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience. • To ensure that the subrecipient agreement includes all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) have recently executed a Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies. See Attached – Grant Agreement Amendment. • OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed. • OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES- GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multi-layer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES- GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements. • Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMES-GMO conducts bi-weekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. • OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek

Finding Number 2023-108 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action The State agrees with this finding. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. Finally, OMES Finance has developed processes which provide for a more thorough coding of expenditures and proper review of expenditures when reporting on their GAAP Z. The State disagrees with the finding. The State had two Grant Award Notifications in place with the Boys and Girls Club which reflects the monies awarded to be used on the capital improvements and Club on the Go Mobile Clubhouses. This indicates the funds were obligated during the covered period. Per the email from the Keri for Jill Geiger Consulting, no signatures on the GANs were required and the Uniform Guidance does not require the GAN to be signed. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. OMESGMO’s internal control processes ensure subrecipient risk assessments are performed and that proper grant awarding documentation is provided to subrecipients. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

Finding Number 2023-035 Subject Heading (Financial) or AL no. and program name (Federal) #17.225 Unemployment Insurance Planned Corrective Action The agency concurs with the findings and agrees with the recommendation. The agency acknowledges our responsibility for program integrity and proper controls for the RESEA program. As we referenced in our response last year, the agency has undertaken modernization efforts to provide better solutions for the RESEA program. EmployOklahoma is the first result of this effort in the workforce employment area and it launched in January 2025 as the replacement for OKJM. The majority of the findings above were related to cases pulled for the period between July 2022 and December 2022; there was improvement in the period from January 2023 to June 2023. We anticipate continued progress and improvement going forward, but there will continue to be elevated risk for inaccuracies until the agency’s modernization efforts are successful in implementing solutions to address both the case management and data reporting requirements needed to fully resolve these findings. Anticipated Completion Date Ongoing until modernization of RESEA tools is complete Responsible Contact Person Tammy Wood, RESEA/TAA Program Manager

Finding Number: 2023-013 Finding Name: Unallowable Costs Charged to the SAPT Program Finding Condition(s): The Illinois Department of Human Services (IDHS) charged subrecipient expenditures to the Block Grants for Prevention and Treatment of Substance Abuse (SAPT) program which were incurred after the period of performance ended. Name of Contact Person(s): Christina Miller, Fund Disbursement Manager – Illinois Department of Human Services, Division of Substance Use, Prevention, and Recovery Corrective Action(s): The IDHS established a procedure to run billing data which will be filtered to determine if dates fall outside of the performance period of the grant. Additionally, the IDHS will ensure that any bills that fall outside of the performance period of the grant are paid as separate payments so as not to be paid out of incorrect funds. Proposed Completion Date: October 15, 2024 – Completed

Finding Number: 2023‐003 Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 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 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.

Corrective Action Plan: ALN 93.568: The LIHEAP program reports were submitted late and the obligations were reported on the Federal Financial Reports and Carryover/Allotment Report. The LIHEAP carryover/allotment report was late due to staff turnover. Person(s) Responsible: Deanne Bear Catches, LIHEAP Director Estimated Completion Date: December 31, 2025

Finding 2023-003: Reporting - Timely Submission of Financial Reports – Significant Deficiency in Internal Control over Compliance and Noncompliance Name of Contact Person: James Wilson, Borough Manager/Acting Finance Director Corrective Action Plan: The Borough is in the process of engaging additional stakeholders to expedite the completion of future financial reports. Completion Date: September 30, 2025

Consistent with Management’s Response to Audit Finding SA 2023-002, the City’s grant processes have been updated to ensure that grants administration and reporting are compliant with individual grant requirements and that there is interdepartmental coordination to ensure appropriate monitoring, reviews, and reporting. Training will also be provided to all departmental managers and Finance staff involved in grants administration, accounting, and reporting. Responsible Personnel Name and Position: Jill Taura, Interim Finance Director Expected Implementation Date of Corrective Action Plan: Fiscal year 2026

DSCEJ will enforce its existing month-end and year-end close procedures with accounting staff to ensure all expenses are consistently recorded in the correct accounting period.

Condition: No documentation of employee time approval by supervisors could be provided. The payroll clerk processes the payroll and 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 to 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 Manager providing the final approval within ADP once all items are confirmed. The entire process is fully documented, with approvals recorded within the ADP by employees and supervisors and the shared file drive where HR and Finance intimal off on the reviewed payroll times, ensuring a traceable record of the entire payroll approval process. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer. Anticipated Completion Date: Implemented.

Finding Number: 2023-002 Planned Corrective Action: City Auditor has confirmed the ARPA 3/31/24 and 3/31/25 Project and Expenditure Reports submitted agree to City Accounting records. Anticipated Completion Date: July 3, 2025 Responsible Contact Person: City Auditor Sherri Hess

The organization agrees with the finding. The organization will implement a method to ensure accrued vacation is appropriately adjusted and vacation costs are accurately recorded and allocated to grants. Completed in FY2023-2024