Corrective Action Plans

Finding Reference Number: 2025-002 – Internal Control over Compliance in Relation to Period of Performance Requirements Description of Finding: This is a new finding. For four of the seven projects reported under the Federal Program COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (SLFRF), totaling $204,862, documentation that the signed and accepted quote was sent back to the vendor by the program obligation deadline of December 31,2024 could not be located. Statement of Concurrence or Nonconcurrence: Nonconcur. Corrective Action: For each of these projects, fully detailed quotes incorporating specific scopes of work, pricing, and binding terms and conditions were executed (signed) by authorized Town officials on or before the December 31, 2024 obligation deadline. Additionally, work or deliverables were performed in accordance with these signed terms without dispute from either party, further proving mutual intent and the existence of a binding agreement. the existence of a binding agreement.

We have established a process to calculate program income semi-annually and will keep in place until this grant is officially closed. The program income calculated will be added back to this award. We will invest those dollars back into our houses and track and report this activity as part of our semi-annual reporting to HUD.

The County will work with Rehmann to develop policies and procedures sufficient to satisfy the rules of the uniform guidance.

Condition: The Town incurred and charged expenditures totaling $30,826 to a FEMA Public Assistance project after the approved period of performance ended on October 31, 2024. The Town submitted a formal request to extend the period of performance on September 8, 2025. As of March 19, 2026, FEMA had communicated that the extension request has been denied. However, FEMA reimbursed the Town for the expenditures incurred after October 31, 2024. As of the date of this audit report, FEMA has not indicated whether the reimbursement will ultimately be retained or subject to recovery. Corrective Action Plan Corrective Action Planned: The Town will implement a grant expenditure review checklist requiring pre-approval for any costs beyond the approved period; train all grant staff on compliance requirements; update internal controls. The Town will also document all correspondence whether that be by phone, email or written correspondence with FEMA when it comes to deadline extensions. The Town’s FEMA-funded recovery projects are complex, multi-year projects associated with rebuilding the community. Many projects have extended beyond their original completion dates due to factors including the pandemic, supply-chain and world trade impacts, weather, labor availability, construction timelines, and contract procurement requirements. In addition, frequent turnover among FEMA personnel assigned to the Town’s recovery projects has at times resulted in changes in points of contact, delays in responses, and extended processing times for approvals, determinations, and extension requests. These circumstances have contributed to the length and complexity of administering projects that already require significant coordination over multiple years. The Town has continued to work closely with FEMA throughout this process and has received approvals for extensions on recovery projects. In this instance, the expenditures identified in the finding occurred after the original October 31, 2024 period and were ultimately reimbursed by FEMA. Name(s) of Contact Person(s) Responsible for Corrective Action: Aimee Beleu, Finance Director Anticipated Completion Date: The corrective action will be implemented to take effect for the audit of the FY 2025-26 financial statements.

#2025-003 - Accounts Payable Cut-Off/ Period of Performance Corrective Action Planned: Certain grants - particularly at the Center for Adult College Success - were prepaid by the funder in order to disburse funds quickly, with grant conditions permitting continued work beyond the nominal completion date. TalentFirst closed these grants out in the accounting records before the full period of performance had concluded, resulting in expenses recorded in the wrong period. Management has implemented a contract timeline document that tracks each grant and contract's actual period of performance and governs when a grant is closed out in the accounting records - grants are no longer closed out until the full period of performance has concluded. Management is also moving away from structuring large prepaid contracts, in part to ease the cash flow pressure that structure creates. Anticipated Completion Date: Already implemented. Responsible Party: Finance Manager, with oversight by the President.

Management will revise grant setup and expenditure review procedures to ensure grant cost centers are not activated prior to the authorized period of performance. A documented review will be implemented to verify that expenditures charged to federal awards were incurred within the applicable period of performance before reimbursement requests are submitted. Initial grant expenditures and reimbursement requests will be subject to supervisory review and approval. Grants and finance personnel will also receive periodic training regarding Uniform Guidance requirements related to allowable costs and period-of-performance compliance. An entry will be made for FY26 to adjust the expenditures.

FINDING 2025-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Sandra L Morton Contact Phone Number and Email Address: 812-481-7000 slmorton@duboiscountyin.org Views of Responsible Officials: We disagree with the finding that the 2025 Annual P & E report current obligations were overstated by $8,300,967, which was the amount of cumulative obligations. Explanation and Reasons for Disagreement: We do not believe there was a systemic lack of effective internal controls or noncompliance throughout the audit period. We determined that the funds were fully obligated and reported the amount based on that interpretation, as was done on the previous reports submitted.

SAMARITAS AND SUBSIDIARIES Management’s Corrective Action Plan For the Year Ended December 31, 2025 Finding 2025-001 Contact Person(s): Bridgette Zappacosta, Chief Financial Officer Corrective Action Planned: Management concurs with the finding. During the period under review, the Finance Department was transitioning to a new accounting system. The identified exceptions occurred prior to the implementation of the new system and related processes. As part of the transition to Blackbaud Financial Edge NXT, Samaritas has implemented controls designed to prevent expenditures from being charged outside of a federal award's period of performance. Grant records within the system now include defined start and end dates that prevent expenditures from being applied to awards outside the authorized grant period. In addition, Samaritas enhanced its invoice approval process by adding a required custom field to identify the service period associated with each invoice. This information is reviewed during the monthly close process to identify invoices received before or after a grant period and to ensure expenditures are recorded in the appropriate award period. The Finance Department completed training on these revised procedures in July 2026. Management will continue to monitor compliance with these controls as part of its monthly grant and financial review processes. Anticipated Completion Date: Implemented July 2026; ongoing monitoring procedures are in place.

County department personnel changes have been implemented which address this deficiency. Additional training from the Auditor’s office and state grantors has occurred and will continue for staff in departments that receive federal and state awards.

FINDING 2025-002 Sherry Lockard, 812-283-1500, slockard@townofclarksville.com A. Coronavirus State and Local Fiscal Recovery Funds The Town concurs with the finding. The Town was not aware contracts had to be signed by December 2024 for all “obligations”. The Town was under the impression the obligations were submitted on the annual SLRF report, and that only the funds had to be spent for submitted obligations on the SLRF page by December 31, 2026. The Town was not able to obtain a contract that far in advance of the work to start, let alone be completed. At this time, we will await instructions from the Federal Agency as to what the Town needs to do regarding the expenses made after the ambiguous “obligation deadline”. For all future grants, the Town will designate the staff member who is in charge of that specific grant to create a checklist of requirements and to maintain that list until the grant is complete. (ATTACHMENT A)

Period of Performance California Governor’s Office of Emergency Services In July of 2024, Cal OES implemented EMPOWER, a new electronic time reporting system. EMPOWER captures employees' daily time worked, and activities identified with service locations (funding code) by cost category. The established EMPOWER Standard Operating Procedure instructs Cal OES Administrative Services staff on how to set the service location incident period start date, which creates system controls to not allow any activities to be entered prior to the start date. To address the transaction identified by CLA and prevent recurrence, Cal OES is troubleshooting and testing potential solutions to develop a systematic fix in EMPOWER. In addition, Cal OES will provide refresher training for all first-line managers to improve their oversight of funding codes and cost categories and ensure their staff submit time entries accordingly. Cal OES Administrative Services will also integrate a resource checklist into its monthly pre-labor review and posting process to add an extra layer of transaction oversight. Currently, Cal OES Administrative Services reviews and reconciles all cost category claims and supporting documentation before submitting to FEMA for obligation. This continuous review ensures Cal OES flags and corrects ineligible or out-of-period transactions before requesting reimbursement. Furthermore, Cal OES will review and correct the identified transaction. Estimated Implementation Date: October 2026 Contact: - Mary Rucker, Assistant Director Administrative Services, Finance & Logistics Administration

Period of Performance California Department of Social Services CDSS agrees with this finding. State operations costs incurred from July through September 2024 were incorrectly charged to FFY 2025 when the federal drawdown was processed in October, rather than being charged to FFY 2024. The issue identified in the audit period has been corrected in the ACF-696 report submitted on April 30, 2026. Upon identifying the error, CDSS provided additional training to staff and added a second level of supervisory review to ensure the appropriate federal fiscal year is applied when processing drawdowns that cross both the state and federal fiscal years. These corrective actions are intended to prevent similar misclassifications and strengthen compliance with federal reporting requirements. Estimated Implementation Date: July 2026 Contact: - Rosali Bautista, Chief, Accounting and Reporting Bureau, Accounting and Fiscal Systems Branch, Finance and Accounting Division

Period of Performance Employment Development Department Employment Development Department (EDD) agrees that it did not have documented procedures or formal ongoing monitoring activities to adequately ensure that payroll charges to Federal awards fell within the authorized award dates before costs were charged to the grant. As a result, payroll costs were incurred outside of the approved period of performance and were not prevented or detected in a timely manner. EDD’s Unemployment Insurance Branch (UIB) established the procedures to be overseen by the UIB Budget Unit to ensure proper controls are in place moving forward and costs are appropriately charged to current and future grants. See artifacts titled ‘Project-Activity Code Establishment Procedure for DUA Revised 7.6.26’ and ‘UIAN DUA Template for Code Release Instructions’. To address the 25 instances where payroll hours were charged to a grant after the approved period of performance end date of May 22, 2025, the Department identified and removed those expenditures from the federal grant and reallocated them to an appropriate state funding source via ledger adjustments. Adjustments were processed during the month end closing process for May and June. As a result, all expenditures outside of the grant’s period of performance have been identified and appropriately removed from the federal grant. Estimated Implementation Date: Currently implemented Contact: - Diane Underwood, Division Chief, Unemployment Insurance Branch

FINDING 2025-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Angela Hamrick Contact Phone Number and Email Address: 260-748-7012 ahamrick@newhaven.in.gov Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: When completing the Annual P & E report I will add an internal control of a separate employee reviewing the information to make sure the correct expenditures are listed within the correct period. We will have each employee who reviews the information to sign the completed report. Anticipated Completion Date: 6/24/26 INDIANA STATE

CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: COVID-19- Coronavirus State and Local Fiscal Recovery Funds Contact Person Responsible for Corrective Action: Valeriano F. Gomez Contact Phone Number and Email Address: 219-391-8220 Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: Previous corrective action read as follows: To ensure proper implementation of the policies and procedures in place related to SLFRF reporting, in future, no submittal of reports will be approved without the City Controller and a Senior Staff Accountant reviewing and approving the P & E reports…… issue arose when City Departments responsive for entering data in P & E reports and Staff Accountant documentation differed , adding to issue both groups were not together in same room to assist each other with reporting . Corrective Action Plan: 1. All future SLFRF Quarterly reports shall require advance meetings before the data entering day; to ensure correct reporting. Meetings shall include all personnel reviewing and entering information (City department personnel and Controllers office personnel, to include two from the Controller’s Office; Controller, or Deputy City Controller and Senior City Accountant. 2. These Staff meeting shall address any differences in reporting documentation, and prepare for any editing and revising data to correct issues from previous P & E reporting, in next available report (Sec. V. Editing and Revising Data P & E Report User Guide) 3. No data shall be entered / submitted on entry day for future Quarterly P & E reports without Controller personnel present and having reviewed and confirmed data. Anticipated Completion Date: Controllers Office and City Departments involved in reporting are presently working to address and correct issues in past reporting, completion is anticipated when upcoming 2nd Quarterly Report for 2026 is opened and issues are addressed.

Bang on a Can, Inc. will adopt written policies, procedures and standards of conduct as required by 2 CFR 200, Subparts D and E.

Condition: The County approved to purchase generators for the Village of Taylor Springs on June 11, 2024 with Ordinance 2024-12. However, due to unavailability, these generators were not purchased until June 2025. Approving an ordinance does not fall under the definition of obligating funds under ARPA. Plan: We recommend that applicable County employees and board members research all procurement compliance requirements when grants are received. Name of Contact Person: Nikki Lohman, Treasurer Management Response: Due to the generator not being available at the time of ordinance, it was an oversight that the actual obligation was incurred after the period of performance. The County did try in good faith to order the generator before the deadline. Anticipated Date of Completion: March 2026, anticipated date of ARPA funds being fully expensed.

Lima City Schools will prepare and complete the time and effort certifications each school year. Procedures have been put in place to verify that all employees charging salaries and benefits to federal grants will have completed semi-annual certifications, signed and verified.

EOHHS understands that this finding stems from two items. 1. Current limitations of the MMIS and the volume of manual transactions, including retroactive capitation adjustments and corrective journal entries related to CHIP funding 2. Lack of internal controls regarding CHIP draw downs and reporting. Management’s correction action plans for each item are below. 1. EOHHS will improve SOPs to include additional review of source data, collation of source data, and review of formula calculations for manual adjustment activities. These steps will be built into analyst training, and measures have been taken to include training and the creation/improvements of internal SOPs before the upcoming SFY 2026 closing activities occur. EOHHS will include within its forthcoming procurement of specific MMIS modules requirements to reduce the number of manual calculations and related entries. 2. Medicaid finance has and will take the following actions. a. Staff training. i. In May 2026, Medicaid Finance sent two employees to internal control training, which was sponsored by the Office of the Auditor General (OAG) ii. In July 2027, these two employees will train all Medicaid finance staff members on the importance of risk and internal controls using material from the OAG sponsored training. b. SOP tracker and dedicated work time i. Medicaid finance created an inventory of all finance-related SOPs to track assignments to ensure timely completion of high priority SOPs. ii. The Associate Director (Financial Management) has weekly worktime dedicated to the completion of high priority SOPs. iii. Each fiscal close, one staff member has been assigned to work with analysts to draft six SOPs (two from each finance unit—fee for service, managed care, and federal reporting) to continue to document all year end closing procedures. c. Post FFY-quarter end reconciliations i. Beginning in FFY 2026, the Associate Director (Financial Management) completes a post-quarter reconciliation of Medicaid draw down accounts (benefits, administrative claiming, and CHIP). ii. Staff email the Associate Director (Financial Management) after each federal draw down and include verification of the PMS draw down amount and account. iii. The Associate Director (Financial Management) enters this into a tracking sheet to ensure sufficient federal funds remain in each account during the quarter. Should additional funds be needed, Medicaid finance submits a supplemental budget request to CMS to prevent the shifting of funds between federal accounts benefits, administrative claiming, and CHIP accounts. iv. Shortly after the end of each FFY year quarter close, the Associate Director (Financial Management) completes the following: 1. Receives staff-run reports form the PMS system showing all draw downs in the previous quarter. 2. Checks that Medicaid Finance internal trackers (high level and detail trackers) accurately capture correct federal accounts and amounts. If variances, research is completed to reconcile to PMS. v. Associate Director (Financial Management) ensures that all CMS adjustments, such as Parts A, B, and D adjustments and TPL/AOR adjustments are included in the high-level fund tracker to match and verify CMS’ quarterly account balances. d. EOHHS acknowledges that many of the new checks and reviews implemented have not been formally codified. It will work to codify controls to document these reviews and checks. Anticipated Completion Date: Additional SOP and internal control development is ongoing and the date of procurement/implementation of the MMIS Finance module is still be determined. Contact Persons: Storm Lawrence, Chief of Strategic Planning, Monitoring & Evaluation, Executive Office of Health and Human Services storm.lawrence@ohhs.ri.gov Dezeree Hodish, Associate Director (Financial Management), Executive Office of Health and Human Services dezeree.hodish@ohhs.ri.gov

i. Comments on the Finding and Each Recommendation – We acknowledge the finding. The Organization utilized an informal practice to address processing timing di􀆯erences for rental assistance payments; however, the practice was not formally documented and was not applied consistently. Management recognizes the need for written policies and adequate supporting documentation when adjustments are made a􀆯ecting the timing of rental assistance payments and will review and revise its current policies and procedures to ensure appropriate documentation when future programs of similar nature exist. Additionally, this federal funding program has come to an end. ii. Actions Taken on the Finding – We will review our internal processes and procedures to ensure adequate and consistent processes and procedures are followed for programming and appropriate supervisory review exists across program areas.

2025-003: Period of Performance Compliance Action Taken/Planned: Management acknowledges the instances identified in which disbursements were processed after the award's period of performance. While no questioned costs were noted, the University recognizes that timely processing of expenditures and drawdowns is critical to ensuring compliance with federal requirements governing grant periods. To Strengthening Grant Closeout Procedures management will establish a formal grant closeout timeline to begin 90 days prior to the award end date, require principal investigators (PIs) and grant administrators to review all outstanding obligations and ensure timely submission of final expenses and implement a standardized closeout checklist to confirm all costs are recorded within the allowable period To Enhanced Monitoring of Grant Periods management will develop and maintain a centralized tracking system for all federal awards, including start and end dates, generate monthly reports identifying grants nearing expiration (within 90, 60, and 30 days) and distribute reports to Pis, Grants Accounting, and Finance leadership for proactive management. For timely processing and drawdown controls management will require all invoices and expenditures to be submitted within a defined timeframe (e.g., within 30 days of service or project completion), establish internal deadlines for processing disbursements and drawdowns prior to the grant end date and implement a review step within Grants Accounting to verify that expenses fall within the period of performance before payment is released. The grants department will conduct mandatory training for PIs, grant managers, and finance staff on period of performance requirements and federal compliance expectations and reinforce accountability for timely submission and processing of expenditures Management will also put in place for any costs identified outside the period of performance will require, documented justification, review and approval by the Director of Grants Accounting and CFO, and verification of allowability under award terms or sponsor approval, if applicable. Anticipated Completion Date/Date Completed: This will be implemented immediately with an anticipated completion date of June 30, 2026

Finding 2025-001 – Internal control deficiency over Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Reporting, and Special Tests and Provisions. Condition: Management did not design effective internal controls to retain documentation to evidence the operating effectiveness of the internal controls over the project and related expenses submitted to FEMA for reimbursement. Resolution: Management will develop and implement additional internal controls to ensure that adequate documentation is retained to evidence the design and operating effectiveness of controls over FEMA-related expenditures. These internal controls will be designed to ensure that expenses included in FEMA grant applications are complete, accurate, and allowable in accordance with program requirements. Specifically, management will implement a reconciliation process comparing detailed application expenses to the corresponding final paid invoices or payroll expenditures. As part of this process, each expense will be reviewed and annotated to confirm its allowability under FEMA guidelines. The reconciliation will be subject to review and approval by the Cottage Health Vice President of Finance prior to submission of the FEMA application. Evidence of this review and approval will be formally documented and retained. Contact Person: Lawrence Thomas, Vice President of Finance Anticipated Completion Date: December 31, 2026 (The entity has not incurred expenditures under the FEMA program subsequent to the period under audit. Accordingly, the corrective actions described above will be implemented on a prospective basis, contingent upon the entity incurring future FEMA-related expenditures).

Internal Controls over Compliance and Compliance with the Period of Performance Compliance Requirement Contact: Katie Queen Dossinger Title: Chief Operating Officer Phone Number: 202-785-0072 Estimated Completion Date: Ongoing Corrective Action The results of the 2025 audit will be shared with appropriate PSI and EGPAF staff and reinforced through training to ensure adequate attention and clear guidance on the allowability of trailing costs and the unallowability of newly incurred costs.

The Finance Department staff will review all items prior to completing the report. Personnel responsible for implementation: Carmen Tsui, Grant Accountant Completion Date: June 30, 2026

Finding 2025-002 – Significant Deficiency and Noncompliance - Lack of Required Uniform Guidance Policies and Procedures Condition: The City did not update their federal policies and procedures to be in full compliance with Uniform Guidance. Corrective Action: The City is in the process of updating and adopting written policies and procedures that are in compliance with Uniform Guidance. Anticipated Completion Date: December 31, 2026 Responsbile Official: John Szymanski, City Manager