Corrective Action Plans

Responsible Executive: CEO – Carmela Slivinski Implementation Status: Effective Immediately Full Implementation Date: No later than June 30, 2026 Finding — Compliance (Period of Performance) Significant Deficiency Condition: Auditor noted while testing period of performance, 1 of the 10 expenses recorded in June 2025 pertained to subsequent months outside of the contract period. Effect: One expense was included in the expenditure report under the incorrect grant period ending June 30, 2025. Cause: The Organization noted that this finding came about due to a clerical error. The bookkeeper inadvertently recorded a July invoice on June 30th and this led to an incorrect charge to the grant period ending June 30th. Recommendation: Auditor recommends management continue to perform a second review on the grant submission especially towards the end of the grant period. Management’s Response: Management concurs with the finding regarding deficiencies in grant period-of-performance compliance. Corrective Action Plan - Review existing Accounts Payable and Accounting Controls processes and revise as needed to ensure expenses are recorded as required. - Staff Training and Competency Development conducted annually to review accounting controls and ensure accounting personnel understand period of performance grant compliance requirements. - Ongoing Monitoring and Internal Compliance Review conducted periodically to ensure oversight of financial controls and grant compliance.

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Finance Director Phone: (787) 788-0404 Original Finding Number 2025-002 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: Objective of the plan: The objective of this Corrective Action Plan is to address the observations identified in the audit and establish preventive measures to avoid future recurrences. Corrective Actions: 1. Schedule restructuring: • Create a detailed calendar with clear dates to define intermediate delivery deadlines to avoid delays (collection of information, analysis, writing, review, and submission) 2. Implementation of alerts and reminders: • Set up automatic alerts and email reminders for key dates (for example, 3 days before each deadline) 3. Review and Quality Control: Establish an internal review of reports before final submission to ensure that the information reported is accurate and complete. The revision includes compliance with the requirements established by the agency. Compliance Monitoring: • Biweekly meetings: The team will have biweekly meetings to have updates regarding the progress and achievement of the deadlines. • Email notifications: Emails will be sent to document the timely submission of reports and when needed, waivers will be requested explaining situations that may have delayed the process to prepare accurate and complete reports on time. Evaluation: • Monthly evaluations will be performed to measure the compliance of the submission of the reports on the timeframe established by the agency. • Adjustments to the processes according to the response of the team. Implementation Date: Fiscal Year 2025-2026. Responsible persons: • Person responsible for the implementation: Mr. Carlos Flores, Federal Program’s Subdirector • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND OTHER MATTERS U.S. Department of Justice 2025-002 Department of Justice Second Chance Act Community-based Reentry Program – Assistance Listing No. 16.812 Recommendation: We recommend that TASC follow its established procedures for charging allowable expenses 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: Management will follow established procedure to make sure costs are recorded in the proper period. Management will review the procedure with all accounting staff. Name(s) of the contact person(s) responsible for corrective action: Roy Fesmire, CFO Planned completion date for corrective action plan: June 30, 2026

Reference Number: 2025-021 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Health and Social Services State Division: Division of Medicaid and Medical Assistance Federal Program: Children’s Health Insurance Program Assistance Listing Number: 93.767 Award Number and Period: SAI000005399 (10/1/2023 – 9/30/2024) Compliance Requirement: Period of Performance Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Recommendation: The Division should review and enhance its procedures and internal controls to ensure that it maintains documentation that expenditures charged to the program are incurred within an award’s allowable period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To prevent recurrence, we are implementing the following actions: 1. Enhanced Monitoring Controls o Establish a centralized tracking system for all awards, including start and end dates. 2. Staff Training and Accountability o Conduct mandatory training for program and finance staff on compliance with period of performance requirements. o Assign clear responsibility for monitoring award timelines to designated personnel. 3. Pre-Closeout Review Process o Introduce a formal pre-closeout review 60 days before the award end date to identify and resolve outstanding obligations. o Require certification from both program and finance leads confirming that all expenditures fall within the allowable period. 4. Post-Expenditure Review o Perform monthly reconciliation of expenditures against the period of performance. o Immediately flag and correct any discrepancies identified. Name(s) of the contact person(s) responsible for corrective action: Joel Riley – Program Integrity Chief Anthony Yeager – Fiscal Manager Planned completion date for corrective action plan: July 31, 2026

Grant Funds Spent After Award Ended The Division will complete the following corrective actions: •Continue cross-divisional meetings to strengthen grant oversight and fiscal monitoring. •Complete targeted training to support consistent application of requirements. •Update policies and procedures to reinforce verification that expenditures are incurred within the approved grant period and are supported by appropriate documentation prior to approval and payment. Anticipated Completion Date: June 30, 2026.

Corrective Action Plan: The Department will evaluate its current policies and procedures relating to the processing of expenditure transactions and update them, as necessary, to reasonably ensure compliance with period of performance requirements. Anticipated Completion Date for Corrective Action: June 2026 Contact Person Responsible for Corrective Action: Name: Daniel Schreiber Title: Deputy Chief, Budget Address: 77 South High Street, 27th Fl, Columbus, Ohio 43215 Phone Number: 614-466-2209 E-Mail Address: daniel.schreiber@development.ohio.gov

Corrective Action Plan: The Department evaluated and strengthened internal controls over its reporting process to reasonably ensure the information presented in the quarterly Performance and Expenditure Reports will be current, accurate, complete, and agree with support prior to submission to the Ohio Office of Budget and Management. The procedures will be periodically monitored to ensure they are working as intended. The Department cross trained employees so in the event of turnover or extended leave, the reporting process can continue without disruption or delays. Anticipated Completion Date for Corrective Action: Completed April 2025 Contact Person Responsible for Corrective Action: Name: Thomas Fitz Gibbon Title: Deputy Chief, Office of Division Support Address: 77 South High Street, Columbus, Ohio 43220 Phone Number: 614-466-0043 E-Mail Address: thomas.fitzgibbon@development.ohio.gov

March 25, 2026 Finding Number: 2025-002 Finding: (Significant Deficiency) AL#84.048: Career and Technical Education Basis Grants to States, U.S. Department of Education, Award No. V048A240016, Passed through the Kansas State Board of Education Contact Person: Taben Azad, Director, Budgeting Planned Corrective Action: The District acknowledges the finding. The Budget Department will implement a training process for all internal budget analysts as well as Career and Technical Education (CTE) program managers and business office staff on the requirements of 2 CFR 200.308 and 200.309, focusing on the “Period of Performance” and allowable cost principles. Additionally, the Budget Department will establish both a quarterly and year-end reconciliation process where the CTE assigned budget analyst will compare all expenditures against the authorized period of performance dates listed in the Perkins V Local Grant Handbook and specific grant award terms. Anticipated Completion Date: These processes will be implemented immediately.

Finding #2025-003 - Rent Reasonableness Criteria: HUD requires that recipients ensure that rent is reasonable compared to similar unassisted units and maintain documentation supporting the determination; rent paid with CoC leasing funds·may not exceed Fair Market Rent (FMR); and rent reasonableness determinations must be completed before providing assistance. Condition: During testing of rent reasonableness controls and documentation, the following exceptions were identified: • 4 of 4 rent reasonableness determinations lacked evidence of an independent review and approval. • There were 8 instances (2 units x 4 months) where rents exceeded HUD FMR limits. • 3 of 20 rent reasonableness determinations were not completed prior to the lease start date. Questioned Costs: $392. Cause: The Organization did not have sufficiently defined or consistently followed procedures for documenting independent review of rent reasonableness determinations, verifying rents against applicable FMR limits before authorizing payments, and ensuring determinations were complete prior to lease start dates. Effect: Units are approved and paid at non-compliant rent levels, federal funds are used for rents above allowable limits, and documentation does not meet HUD standards, potentially leading to questioned costs, required repayment, and findings in future monitoring or audits. Recommendation: We recommend that management establish a mandatory review and approval step for all rent reasonableness forms, require staff to verify current FMR limits before approving leasing amounts, and require rent reasonableness completion before any lease start date or payment authorization. Response: HALO's management concurs with this finding. HALO management will implement procedures to ensure compliance with rent reasonableness and FMR limits and train staff on those procedures. HALO will replace the current Rent Reasonableness form with the one on the HUD Exchange. Contact Person: Yvonne MacDonald Hames Anticipated Completion: June 30, 2026

Finding 2025‐001: Contact Person NAME: Julia Delgado PHONE: (503) 280-2600 E-Mail: jdelgado@ulpdx.org Explanation and Specific Reasons for Disagreement with the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned The Urban League of Portland is committed to an environment of continuous improvement. Further training shall be provided to Program Managers regarding the organizations’ documented internal controls and the importance of adhering to the established approval process. Urban League has currently hired a seasoned Controller and is in the process of hiring an experienced Accounting Manager. Tracking expiring grants more thoroughly and having further reviews in place to assure transactions are recorded within the grant’s agreed upon period of performance shall provide confidence expenses are recorded properly. Anticipated Completion Date May 1, 2024

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services [2025-041] (Period of Performance) Maternal and Child Health Services Block Grant to the States Assistance Listings: 93.994 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: For 5 of the 60 transactions tested, 1 had costs incurred before the period of performance date and 4 had program expenditures not obligated and expended in accordance with program requirements. This was the result of human error/misclassification during processing. We are reinforcing guidance with both program and budget staff to prevent similar errors in future reporting periods. Anticipated Completion Date: June 30, 2026 The contact persons responsible for corrective action: . Meredith Murphy, Director, Budgets & Financial Planning at 803-898-4222 . Danielle Wingo, Director, MCH Bureau at 640-649-9292

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Child Care and Development Fund (CCDF) Cluster – Assistance Listing No. 93.575, 93.596, and 93.489 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: The Department is in the process of closing grants within the accounting system to prevent system-generated payroll expenses from posting after the grant period of performance has ended. This control ensures that payroll charges are restricted to the allowable grant period. Anticipated Completion Date: December 31, 2026 Names of the contact persons responsible for corrective action: • Courtney Hogue, Controller at 803-898-7488 • Hiba Khalaf, Grants Accounting Manager at 803-898-7484

The Department of Environmental Services respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency Performance Partnership Grants – Assistance Listing No. 66.605 Disposition of Audit Finding: The Department of Environmental Services agrees with the audit finding. Corrective Action: There will be one staff member in Budgets that prepares the document and the JE and supporting documentation will be reviewed by another to ensure that the JE is not moving an expenditure onto a closed Federal grant. Anticipated Completion Date: Process began July 1, 2025, and will be ongoing. Simon Li will be responsible for corrective action: • Simon Li at 803-898-3443

Criminal Justice Academy respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Transportation State and Community Highway Safety & National Priority Safety Programs – Assistance Listing No. 20.600 & 20.616 Disposition of Audit Finding: The South Carolina Criminal Justice Academy (SCCJA) concurs with the audit finding. Corrective Action: Agency policy was previously amended to ensure adequate internal controls. Additional staff training has been conducted to ensure full understanding of the policy changes to prevent future errors. Anticipated Completion Date: 10/30/2025 Name of the contact person responsible for corrective action: • Lauren Wright at (803) 896-8115

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General concurs with the audit finding. The $2,571 finding was identified by the Agency prior to the audit. The Agency was only able make corrections to the grants which remained open (total of $1,421). The Agency was unable to make corrections for the remaining amount as those grants had been closed. Corrective Action: The Agency relies on SCEIS workflow approvals to verify and approve the period of performance. The Agency currently has three or four levels of approvals (depending on the specific grant) for each Shopping Cart. During this process, the Shopping Carts are reviewed and approved/disapproved by the Cooperative Agreement budget analyst, the Grants Department, the Procurement Department and the Budget & Finance Department. Annual reminders are sent to each Cooperative Agreement and email verification of disbursements are filed. Additional quarterly quality control checks will be added to the process. Anticipated Completion Date: 6/30/2026 Name of the contact person responsible for corrective action: Anita Ballington at 803-299-4294

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT United States Department of Homeland Security 2025-003 Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Disposition of Audit Finding: The South Carolina Emergency Management Division (SCEMD) of the Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency will refine its Public Assistance (PA) Reimbursement Review SOP and related Recovery Grants and Finance staff training to specify a requirement to validate that for projects under PA grants declared in 2018 and before, Direct Administrative Costs (DAC) were expended before the end of the project period of performance. In addition, the Recipient has submitted a time extension for the project period of performance but does not yet have approval from FEMA. Notes: • DAC was an eligible category of costs in PA projects under disaster grants through 2017 and optional for those declared August 1, 2017, through October 04, 2018 (opt-in). • Federal PA policy shifted to a management costs approach for projects under incidents declared on or after October 05, 2018. See attached FEMA Recovery Policy FP 104-11-2. Management costs are eligible for reimbursement up to 180 days after the subrecipient completes its last non-management cost project (p. 5). • Guidance regarding Direct Administrative Costs (see FEMA table attached) indicates that project closeout activities are eligible direct costs,which may have led to the Recipient considering DAC during the closeout period as eligible even when the project period of performance had ended. • The Federal Agency involved, FEMA, closed the project without noting an issue with reimbursement of these expenditures. Anticipated Completion Date: June 30, 2026 2 Name of the contact person responsible for corrective action: • Emily Bentley, SCEMD Chief of Mitigation and Recovery, at (803) 737-8774 • Antonio Johnson, SCEMD Grants and Finance Manager, at (803) 737-8606

Reference Number: 2025-016 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Agency of Human Services Federal Program: COVID-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Award Number and Year: 19NU50CK000520 (8/1/2019 – 7/31/2027) Compliance Requirement: Reporting – Financial Reports Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that financial reports are accurate and agree with supporting documentation. The reviewer should verify that reports are tied to supporting documentation before they are approved and submitted. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: For each required financial report, the Financial Administrator will prepare the appropriate information and review it with the PH Program Manager prior to submission to the CDC. Amounts reported by budget category will align with the budget category generated by the Department’s financial reporting system. Any changes made to the amounts reported by budget category will be discussed by the PH Program Manager and the Financial Administrator and documented in the report backup file. Once the financial information has been reviewed by both the Financial Administrator and the PH Program Manager, the PH Program Manager will submit the financial information into the CDCs reporting system. After the report has been submitted the PH Program Manager will save a screenshot or some other form of documentation verifying timely submission. A copy of the submitted report will be sent to the Financial Administrator who will perform a final review of the data submitted to the CDC. Copies of the backup file and final submitted report will remain in the business office federal grant records for the required retention period associated with the federal grant award. Scheduled Completion Date of Corrective Action Plan: January 1, 2026 Contacts for Corrective Action Plan: Mia Romeo, Financial Administrator, Vermont Department of Health, mia.romeo@vermont.gov Catie Markesich, PH Program Manager, Vermont Department of Health, catherine.markesich@vermont.gov Megan Hoke, Financial Director, Vermont Department of Health, megan.hoke@vermont.gov Peter Moino, Director of Internal Audit, Vermont Agency of Human Services, peter.moino@vermont.gov

Reference Number: 2025-007 Prior Year Finding: 2024-010; 2023-008: and 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) Compliance Requirement: Period of Performance Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that, prior to charging costs to the program, they are incurred within an award’s allowable period of performance and that payments are reviewed and approved by a supervisor who has knowledge of costs that are allowable under the program. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: The Department will review its procedures and internal controls and update as necessary to ensure that all expenditures incurred on an award fall within the allowable period of performance. Scheduled Completion Date of Corrective Action Plan: June 30, 2026 Contacts for Corrective Action Plan: Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

Audit Finding Reference: 2025-001 Improve Oversight Over Period of Performance of Federal Awards Planned Corrective Action: To address the material weakness regarding the period of performance, the Longmeadow Public Schools will implement the following actions: Procedure Revision: The Longmeadow Public Schools will update internal control procedures to require that all invoices charged to federal grants explicitly state the dates of service. Staff pro-cessing invoices against Federal grant funds will be instructed to verify these dates against the au-thorized period of performance listed on the Grant Award Notification before processing payment. Staff Training: The Town will conduct mandatory training for the Special Education Department and central office administrative support staff. This training will focus on 2 CFR §200.309, specif-ically emphasizing that costs are only allowable if incurred during the approved budget period, re-gardless of when the invoice is received or paid. Name of Contact Person: Thomas Mazza, Assistant Superintendent for Finance and Operations, Longmeadow Public Schools, tmazza@longmeadow.k12.ma.us Completion Date: Prior to July 1, 2026

Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (ASU) Responsible Official: Dr. Capetra Polk, Default Management Coordinator capetra@alcorn.edu Corrective Action Planned: Our prior corrective plan was to ensure that any post-withdrawal aid eligible for disbursement would be processed in a timely manner. Although corrective actions were implemented in response to the previous finding, the university unfortunately returned funds outside the required timeframe, resulting in the current finding. To address this issue, responsibility for the R2T4 process has been reassigned, and new staff have been trained and will assume these duties to prevent future oversights. Estimated Completion Date: June 30, 2026 Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (DSU) Responsible Official:Megan Smith, Director of Financial Aid (mlsmith@deltastate.edu) and Tammy Prather, Registrar (tprather@deltastate.edu) Corrective Action Planned: Delta State University understands that the spring break start date did not match the days of the break and have resolved the accuracy of those entries to policy. The Registrar and Director of Financial Aid will verify the input of the dates prior to processing withdrawals each year. Delta State University is implementing a weekly process to ensure all R2T4 reviews are conducted and funds returned within the required timeframe. Estimated Completion Date: June 30, 2026 Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (MVSU) Responsible Official: Angela Fant, Director of Financial Aid (Angela.Fant@mvsu.edu) and Jeffery Loggins, University Registrar (JLoggins@mvsu.edu) Corrective Action Planned: As part of ongoing corrective actions, the Office of Financial Aid will continue to verify the accuracy of data provided by the Registrar’s Office prior to processing and awarding aid. In addition, better coordination will be implemented to manage and ensure the submission of accurate data. Estimated Completion Date: June 30, 2026 Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (UMMC) Responsible Official: Davita Weary, Director Financial Aid (FinancialAid@umc.edu) Corrective Action Planned: To ensure accuracy, uniformity, and compliance across all UMMC schools, the following corrective actions will be implemented. All academic calendars must clearly state standardized semester start and end dates using the required language. In addition, standardized break and holiday language must be applied consistently for all holidays, recesses, and institutional closures. Oversight of the academic calendar will be provided by the UMMC Academic Affairs Council, and all academic calendars and associated verbiage must be submitted for review and approval by the Council. The Academic Affairs Council will conduct a full review prior to publication, provide feedback and required revisions during the review period, and return any non‑compliant submissions for correction. In addition to calendar requirements, Financial Aid Advisors will be required to participate in Return to Title IV (R2T4) training offered through the National Association of Student Financial Aid Administrators (NASFAA), and the Financial Aid Director will conduct periodic spot checks of R2T4 submissions throughout the year to ensure continued compliance. Estimated Completion Date: Immediately Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (USM) Responsible Official: David Williamson, Director of Financial Aid (david.williamson@usm.edu) Corrective Action Planned: The University of Southern Mississippi (USM) acknowledges the audit finding and agrees that controls surrounding Return of Title IV (R2T4) calculations must be strengthened to ensure full compliance with federal requirements. During the Spring 2025 semester, the institution experienced a two‑day weather‑related delay in the start of classes. As a result, the Registrar updated the academic calendar start date to align with the actual commencement of instruction. No in‑person or online classes were held, and no federal aid disbursements occurred prior to the revised start date. The Spring 2025 semester remained a standard academic term with at least 15 weeks of instructional time. While the institution believed the revised calendar reasonably reflected student attendance and instructional activity, the audit identified that the payment period start date used in Return of Title IV calculations did not align precisely with the approved term structure for purposes of federal aid calculations. This misalignment resulted in incorrect day counts for certain withdrawals. To address this issue and mitigate future risk, the University will implement the following corrective actions: •The Office of Financial Aid will formally coordinate with the Registrar prior to the start of each semester to confirm that academic calendar dates used for Title IV purposes align with approved payment periods and federal regulations. •Any future adjustments to the academic calendar regardless of instructional time impact will be reviewed for Title IV implications, and written guidance will be obtained from the U.S. Department of Education by contacting caseteams@ed.gov as appropriate. •Internal procedures for Return of Title IV calculations will be updated to require verification of calendar day inputs against the institution’s final, approved academic calendar prior to processing. These actions are intended to reinforce internal controls over compliance and ensure consistent application of federal requirements across all withdrawals. Estimated Completion Date: March 18, 2026

Special Education Cluster – Assistance Listing No. 84.173 Recommendation: We recommend that the Board strengthen internal controls over federal grant expenditure by implementing procedures to ensure costs are incurred within the approved period of performance prior to being charged to federal awards. This should include enhanced supervisory review, system controls where feasible, and training for staff responsible for grant accounting and compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To address this issue, the Board will implement the following corrective actions: 1. Enhanced Review Procedures: All payroll journal entries to reclassify expenditures charged to federal grants will be reviewed by Lead Staff Accountant and/or Budget Manager to verify that the time worked along with the transaction accounting date falls within the approved grant period of performance prior to posting. 2. System and Process Improvements: The Board will explore report customizations regarding payroll transactions to provide more visibility of the actual days worked regardless of the transaction accounting date. This system improvement will help prevent payroll journal entry reclassifications from being charged to grants outside of the approved period of performance. These procedures will strengthen internal controls over federal grant expenditures and help ensure compliance with federal regulations. Name(s) of the contact person(s) responsible for corrective action: Sherri Fisher-Davis Planned completion date for corrective action plan: March 2026

Finding 2025-002: Noncompliance with OMB Compliance Supplement; Period of Performance (H) for Assistance Listing Number (ALN) 93.958 Block Grants for Community Mental Health Services Criteria: The Code of Federal Regulations (CFR) Sections 200.308, 200.309, and 200.403(h) states “a non-Federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entities.” Costs incurred before or after the period of performance are unallowable unless explicitly approved. Condition: During our testing of expenditures charged to ALN 93.958, we identified 2 transactions out of a total sample of 15 totaling $192 that were incurred outside of the award’s period of performance. Corrective Action Plan: To ensure compliance and accurate reporting, we established internal control protocols for the formal review of service dates, verifying that all expenditures correspond to the appropriate period of performance. The Controller's signature on formal, documented month end checklists will serve as confirmation that all year-end invoices have been checked for appropriate period distribution. Responsible Person for Corrective Action Plan: Addy Hiles (Controller) Implementation Date for Corrective Action Plan: September 2025

2025-003 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing Number 21.027 Recommendation: We recommend procedures be strengthened to ensure that charges to the grant program are obligated and/or incurred within the period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City acknowledges the finding related to documentation supporting the period of performance for expenditures reported under the SLFRF revenue loss category. Because the City applied the standard allowance for revenue loss and did not track specific expenditures to the grant at the transaction level, some expenditures initially provided for testing were outside the period of performance, although sufficient eligible expenditures existed within the allowable period. To address this issue, the Finance Department will implement procedures to maintain supporting schedules identifying government service expenditures incurred within the applicable period of performance that support amounts reported under the revenue loss category. Finance will also implement a review process to verify that expenditures identified for compliance or audit testing meet applicable period of performance and obligation requirements. These procedures will strengthen documentation and ensure expenditures supporting SLFRF revenue loss are clearly identified and supported for compliance purposes. Name(s) of the contact person(s) responsible for corrective action: Michael Tucker, Deputy Finance Director Planned completion date for corrective action plan: Implemented immediately and effective for all current and future federal awards.

2025-002 Special Education Cluster - Assistance Listing Number 84.027, 84.173 Recommendation: We recommend procedures be strengthened to ensure that charges to the grant program are incurred within the period of performance included in the grant award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will implement procedures to ensure that expenditures charged to federal awards are incurred within the approved period of performance in accordance with 2 CFR §§ 200.308, 200.309, and 200.403. The School Department will enhance its grant monitoring procedures by maintaining a tracking schedule of grant periods of performance and reviewing invoices and payment requests for compliance with grant award dates prior to processing. School Department Finance staff will also provide guidance to departments administering grants to ensure expenditures are incurred and submitted within the allowable grant period. These procedures will strengthen internal controls and reduce the risk of expenditures being charged outside the approved period of performance. Name(s) of the contact person(s) responsible for corrective action: Brian Cisneros, Business Administrator Planned completion date for corrective action plan: Implemented immediately and effective for all current and future federal awards.

Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Period of Performance Finding (FY 2024) • Improved Internal Controls o Rensselaer Central and Cooperative School Services will implement additional review procedures to ensure all federal grant obligations occur within the allowable grant period and that vendor payments align with the original approved purchase orders. • Verification of Obligation Dates o Fiscal staff will verify that purchase orders, vendor invoices, and final payments reflect an obligatory date that occurs prior to the applicable grant deadline. • Staff Training o Rensselaer Central and Cooperative School Services Fiscal personnel involved in grant management will receive training on federal grant period of performance requirements and proper documentation of obligations. • Monitoring Procedures o Rensselaer Central and Cooperative School Services will conduct periodic reviews of federal grant expenditures to ensure ongoing compliance with grant timelines. • Statement of Isolated Occurrence o Rensselaer Central and Cooperative School Services reviewed the circumstances surrounding this finding and determined that the issue was isolated to fiscal year 2024. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.