Corrective Action Plans

Audit Finding Reference: 2024-001 Description of Finding: The audit revealed that grant expenditures were incurred outside the authorized performance period, resulting in non-compliance with grant regulations and potential cost disallowance. Planned Corrective Action • Conduct a comprehensive assessment of existing procedures to identify gaps that led to noncompliance with grant regulations. • Ensure timely submission of grant applications. • Implement enhanced oversight and monitoring processes for all grant-related expenditures to ensure alignment with policy 2 CFR 200.1. • Maintain detailed documentation of all award dates and expenditures to provide a clear compliance record. • Ensure all documentation is easily accessible and systematically organized for audit purposes. • Ensure pre-award costs are allowable only to the extent they would have been allowable if incurred after the effective date and only with written approval from the Federal awarding agency (as per 2 CFR 200.458). • Establish a process for obtaining and documenting written approval for pre-award costs. • Provide comprehensive training on compliance with Uniform Grant Guidance to all relevant staff. • Review and update policies and procedures related to grant expenditures regularly to ensure they are current and compliant with federal regulations. • Assign accountability for monitoring and reporting compliance to specific roles within the organization. The Business Manager, Elizabeth Bouchard, will be responsible for implementing this plan beginning with the Fiscal Year 2026 grant cycle. As of September 2025, non-compliance issues have been identified and addressed, documentation has been maintained to track award dates, and training has been provided to designated roles within the District. In addition, procedures to maintain detailed documentation of all award dates and expenditures to ensure a clear compliance record have been shared with all District Administrators utilizing grant funds.

City of Aledo Program Specific Audit Recommendation 2024-001 We recommend that the Organization review the requirements of 2 CFR Section 200.302 to develop allowable cost, activity, and period of performance activities to be followed. Management Response: The organization recognizes the importance of having written policies and procedures to ensure cost are allowed and reasonable for the federal program. To address this finding, the agency has implemented the following corrective actions:  Review requirements of 2 CFR Section 200.302 as it relates to internal controls and financial management  Create documented policies and procedures that details how the grantee will review and approve invoices, cost allocation, efforts of personnel, fringe benefits and indirect charges for allowability, adherence to cost principles, accuracy, and completeness  Create documented policies and procedures that details how the grantee will review and approve invoices, cost allocations, efforts of personnel, fringe benefits and indirect charges to ensure they were incurred during the period of performance Responsible Staff: City Official Implementation Date: October 1,2025 90

Corrective Action Plan: Atrium Health CMHA management in the future will ensure that all correspondence, including notes from review meetings and approvals of key decisions, will be documented and retained as part of the support records for FEMA related awards. Proposed Completion Date: No further action is required until future needs arise for Atrium Health CMHA to obtain FEMA funding awards at which time management will ensure all documentation supporting the process and key decisions are retained.

Condition: An effective internal control system was not in place to ensure compliance with requirements related to the grant agreement and the Cash Management compliance requirements. Management's Corrective Actions: During 2025, Hamilton County Area Neighborhood Development, Inc. (HAND) hired a controller to assist with the preparation of the parent company and subsidiaries financials while instituting improved internal control policies. As such, HAND with the assistance of its controller will establish effective internal control systems to ensure the compliance with the requirements for grant agreements and cash management compliance requirements

Finding No. 2024-001: Obligation Requirement for Capital Fund Program Drawdowns (Significant Deficiency Corrective Action Plan: NBHA has reviewed its internal controls regarding the obligation requirement for CFP LOCCS and will implement additional monitoring procedures to ensure timely obligation of funds. This includes developing a tracking spreadsheet and assigning a staff member to review obligations quarterly. The Executive Director will receive quarterly reports to ensure compliance going forward. Responsible Person: Reginal Barner, Executive Director Expected Completion Date: December 31, 2025

With the addition of personnel, the finance team has been restructured to allow for a more streamlined month-end process. As part of the month-end process we have implemented more collaborative and robust communication between the grants management and finance teams to ensure accuracy in our grant management process.

Findings Reported by Uniform Guidance – The following steps have been taken or will be taken to address Finding 2024-005: • Heart City Health Center, Inc. will refine and change controls that deal with tracking of when expenses are incurred to confirm that no drawdown receipt is received before then or in the incorrect grant period

Management has updated its compliance responsibility procedures to clarify roles and responsibilities and to ensure accountabilities for all federal reporting requirements. Specifically: • A compliance calendar will be established to track all non-standard reporting deadlines (other than monthly or quarterly cost reimbursement grant request). • Responsibility for preparing and submitting DRGR reports has been formally assigned to Finance Department. • Verification procedures have been implemented to confirm that all reports are filed timely. • Periodic internal reviews will be conducted to ensure compliance with reporting requirements.

The Organization will continue efforts to obtain written confirmation from the Department of Commerce, compile all available email correspondence and notes from verbal conversations, and prepare a detailed timeline of authorization requests and responses. Further, the Organization will submit a formal response to the Department of Commerce regarding questioned costs, provide documentation supporting the allowability of expenses, and request a formal resolution of questioned costs. Person Responsible: Steve Sanders, Grant Manager, Tel: 207-249-8578 Estimated completion: December 2025

2023-002: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout procedures, consequently, the district will monitor closely all grants spending throughout each grant cycle. For both state-administered and direct grants, regardless of the period of availability, the District must liquidate all obligations incurred under the award Reports not later than 90 days after the end of the funding period unless an extension is authorized. These procedures are included in the Financial Procedures Manual (pages 226-230 under Section G— Timely Obligation of Funds) Key Control Key Actions Resources Needed Timeline Outcome Grants Management Use appropriate resources to mitigate any errors, omissions and ensure timely maintenance of records and reporting Grant Management Form Grant Award Letter Internal Controls Guide GEM$ Trainings FY24, FY25 ongoing Implementation of preventive controls for ALL grant funding Contacts: School Business Manager & Town Accountant Submitted by, Annette Colón, Business Manager MBA, MCPPO, Notary Public Clinton Public Schools 150 School St. Clinton, MA 01510 (978) 365-4200 x 12241 colona@clinton.k12.ma.us

Audit Finding Reference: 2024-001 (Reporting) Planned Corrective Action: NUL acknowledges the reporting requirements outlined in Article VI of the FY22 and FY24 CPF Grant Agreements with HUD. We respectfully note, however, that while we are fully aware of these reporting requirements, we were unable to submit the required reports because the Disaster Recovery Grant Reporting (DRGR) system was not available for submissions during the relevant periods. As such, even if we had attempted to file, submission could not have occurred due to the system’s unavailability. We were in contact with the administrators of HUD on a regular basis during the reporting period. Both HUD and NUL were fully aware of the DRGR system short falls. We emphasize that NUL maintains a strong record of timely and accurate federal reporting and does not typically experience issues with missed or late submissions. This instance is an isolated occurrence and is not reflective of our overall compliance practices. Once the DRGR system becomes available, NUL will promptly submit all required FY22 and FY24 reports to ensure compliance. To further strengthen our processes, NUL is committed to implementing a financial reporting calendar to supplement our existing internal controls and ensure continued timely compliance with all reporting obligations. This reporting calendar will be disseminated to all NUL departments that work with and are responsible for federal grant reporting.

The Agency agrees with the finding. We will provide training to program managers who are approving program expenditures to ensure proper allocation of costs to the appropriate grant cycles. We will also update our purchasing procedures to ensure that the proper allocation of costs is reviewed prior to supervisor's approval of the cost.

FINDING 2024-004 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Ann Stark Contact Phone Number and Email Address: 317-745-9315 / astark@co.hendricks.in.us Views of Responsible O􀆯icials: We concur with the findings. Description of Corrective Action Plan: The Grant Administrator will monitor all claims that will be used for the quarter and send them to the reporting agent to report after the quarter ends. She will be diligent to track any claims coming in outside of that quarter so that reporting is accurate. She will provide the reporting agent with all claims relevant to that quarter’s report. Anticipated Completion Date: This will be done quarterly starting with the quarter ending on September 30th, 2025. The Grant Administrator will submit these claims to the reporting agent one week after the quarter ends. The Financial Administrator will sign o􀆯 on the LOW report to verify the claims match.

Contact Person(s): Bridgette Zappacosta, CFO Corrective Action Planned: Management concurs with the finding. We acknowledge that expenditures were charged outside of the applicable award period due to timing of invoice receipt and data entry errors. The Organization has reviewed its internal controls and will strengthen procedures to ensure compliance with federal requirements. Specifically, we are revising our grant expenditure procedures, implementing new software which includes additional review controls and is specific to grant reporting, and providing targeted staff training on period of performance compliance. We will also perform quarterly monitoring of federal award expenditures to verify compliance. Anticipated Completion Date: December 31, 2025

Finding 2024-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Reporting Contact Person Responsible for Corrective Action: Cindy Poore Contact Phone Number and Email Address: 317-733-2809, cpoore@zionsville-in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Below is the process for submitting required grant reporting. 3. The Director will input the required information 4. Prior to submission of the report, the Director will have the Deputy Director verify the information that has been entered against the supporting documentation. 5. The Deputy Director will let the Director know if it is ok to submit the report. 6. The Director will submit and print a completed submission document that the Deputy Director will verify again. 7. The Deputy Director and Director will both sign and date the completed report. 8. This will be filed for audit purposes. Anticipated Completion Date: This is already taking place. The 2025 filing in April followed this process.

Finding 2024-004: Cutoff Procedures Issue: Previously, there were no formal cutoff procedures to ensure expenses were recorded in the correct period, which caused inconsistencies and required post-year-end journal entries to correct expense timing. • What's been done: Contracts are now recorded as prepaid or accrued expenses and are being expensed monthly. • Next steps: Salaries and benefits incurred before month-end will be accrued to grants at grant cutoff dates (e.g., September 30) and at year-end. Estimated monthly accruals for salaries will be implemented. • Timeline: Full implementation by the end of September 2025. • Responsible party: Finance manager with oversight by President

The Foundation immediately paid the vendor the full amount upon learning of this finding from the auditor and verified that the vendor received the payment. The recording of Grant Revenue/Accounts Receivable and Grant Expenses/Accounts Payable is now done for each grant expense immediately upon approval from the Foundation and submission to New York State for reimbursement. This was previously not done. The changes to the recognition of revenue and expenses are already in effect and should eliminate any future finding related to the non-payment of expenses that have been reimbursed through grants.

Finding 2024-001 Internal Control Deficiency over Allowable Costs Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036 Award Period of Performance: January 1, 2020 – July 1, 2022 Summary of Finding: Management did not consistently retain documentation evidencing the performance of internal controls in place to review and approve FEMA expenditures submitted to the FEMA Portal. Corrective Action Plan: Management implemented corrective action on December 31, 2024 to ensure evidence of controls is retained. Responsible Party: Wah-chung Hsu, Chief Financial Officer Completed Date: December 31, 2024

2024-004 FINDING: Period of Performance Responsible Officials: Daniel Ainslie, Finance Director, Jamie Toennies, Grants Division Manager Corrective Action Plan: Written communication will be sent to department directors and staff involved in grant administration addressing the compliance requirements associated with Period of Performance. This communication will specifically state that no federal funds will be spent outside of this time period without written approval by grantor and/or approved budget modification. In addition, the City’s Uniform Grant Guidance Polices/Procedures will be updated to include a section on Period of Performance compliance requirements. Anticipated Completion Date: December 31, 2025

Finding 2024-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over compliance it was noted that one expense charged to the 2023 Hi Quality Instructional Materials grant major program was not an allowable expenses. Criteria: Costs charged to the 2023 Hi Quality Instructional Materials grant major program should meet the requirements as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Context: During our review of expenses charged to the 2023 Hi Quality Instructional Materials grant it was noted that one expense that was charged to the grant whose service period was outside the period of performance and thus an unallowable cost. Effect: Town of Bellingham was not in compliance with the allowable costs/ cost principals requirement as set forth by the Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Questioned Costs: $2,170.00 Cause: The District utilized the FY2023 Hi Quality Instructional Materials grant to fund subscription(s) that support organizational assessment data results for Social & Emotional learning, with the understanding that the subscription started during the grant's timeframe but did not consider that the subscription would extend beyond the grant period. Identification as a Repeat Finding: N/A Recommendation: We recommend the Town of Bellingham follow procedures to ensure that expenditures charged to the grants are allowable costs as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles) Responsible for Corrective Plan: Director of Finance Estimated Completion Date: September 1, 2025 Action Taken: The District will not utilize grant funds to support subscriptions that span outside of the grant-funding timeframe.

FINDING 2024-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Wendy Marples Contact Phone Number and Email Address: 812-338-2142/ auditor@crawfordcounty.in.gov Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The County Auditor will ensure that any future ARPA funding will be reported correctly and broken out by project. This will also be verified with the ledger for the same period. Internal controls within the office will ensure the County Auditor reviews everything is correct prior to submission. Anticipated Completion Date: December 31, 2025

FINDING 2024-003: Finding Subject: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Toni Loper, Town Clerk-Treasurer Contact Phone Number and Email Address: 765-857-2377 / ridgevilleclerk@gmail.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In regards to the current finding over the reporting period under audit all pertinent issues will be corrected in the following annual project and expenditure report, due in April, 2026. The town will contract with Local Government Services to prepare the annual project and expenditure report, develop a procedure where the Clerk-Treasurer or any Town employee with proper training and knowledge will review the report prior to submission for accuracy and completeness before final filing. The Clerk-Treasurer or respective town employee who will review the report, will receive the proper training over the respective program. Any correspondence between Local Government Services and the Town of Ridgeville will be documented accordingly. Anticipated Completion Date: Policies and procedures to be documented and adopted by March 18, 2026. Full implementation and testing to be in place for the 2025 fiscal year reporting cycle.

Noncompliance with Period of Performance (Public Housing Capital Fund ALN 14.872) We will implement controls to ensure that the amounts reported in ELOCCS for obligations and expenditures are properly supported by an underlying contract or invoice. Date of completion: Ongoing

FINDING 2024-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-882-6426 clane@vincennes.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All reports will be prepared by the clerk’s treasurer’s office and will be reviewed by someone who is knowledgeable about the reporting requirements prior to submission. They will review reports for errors and omissions. After this additional review, the report will be submitted. Anticipated Completion Date: This corrective action plan will go into effect immediately.

Finding Number 2024-007: Period of Performance – Material Weakness in Internal Control over Compliance and Noncompliance Corrective Action: To ensure compliance with 2 CFR §200.344(b), Management will implement formal policies and procedures requiring that all financial obligations under federal awards be liquidated within 120 calendar days after the end of the period of performance. Grants Accounting will establish a documented review and tracking process to monitor grant deadlines, identify outstanding obligations, and ensure timely payments. These actions are intended to strengthen controls, ensure timely liquidation of expenditures, and prevent recurrence of prior year findings. Name of Responsible Individual(s): Jason Brenier, Shelly Courtois, Judy Bokhari, and Sandra Shannon Anticipated Completion Date: September 2025