Corrective Action Plans

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

Finding Number 2024-004: Period of Performance and Allowable Costs/Cost Principles – Significant Deficiency in Internal over Compliance Corrective Action: Management will enhance oversight of payroll allocations and rental assistance charges, update written procedures, and train Grants Accounting staff on period of performance requirements, cost allowability, documentation, and grant closeout. Monthly meetings with grantors have been initiated to monitor spenddown, address processing issues, and ensure proper cut-off. Management will also collaborate with the Payroll Service Provider to improve allocation accuracy and reduce manual errors. A documented review and approval process at period-end will further ensure costs are charged to the correct funding period and comply with federal requirements. Name of Responsible Individual(s): Jason Brenier, Judy Bokhari, Luz Gonzales-Toscano Anticipated Completion Date: January 2025 – immediate term and December 2026 software implementation.

FINDING 2004-006 Finding Subject: COVID-19-Coronavirus State and Local Fiscal Recovery Funds Reporting Contact Person Responsible for Corrective Action: Celita Green, City Controller Contact Phone Number and Email Address: 219-881-5085 Views of Responsible Officials: We concur with the finding that Total Cumulative Expenditures reported for Quarter 2 report (April 1, 2024 to June 30, 2024) and Quarter 3 report (July 1, 2024 to September 30, 2024) were understated. However, there is no mechanism to file corrective to the State and Local Fiscal Recovery Funds (“SLFRF”) Compliance Quarterly Reports with the Treasury reporting system once they are submitted. The City did make cumulative adjustments in the Quarter 4 report (October 1, 2024 to December 31, 2024) to agree with Cumulative Expenditures in the Report with the City’s accounting records, once the City determined the cumulative totals were inaccurate prior to being audited. Description of Corrective Action Plan: As stated above, the City did make cumulative adjustments in the Quarter 4 report (October 1, 2024 to December 31, 2024) to agree with Cumulative Expenditures with the City’s accounting records, in accordance with the periodic updates to the “Compliance and Reporting Guidance for State and Local Fiscal Recovery Funds” issued by the U.S. Department of the Treasury, which indicates how to make cumulative adjustments in the current quarter’s report. Since the 4th Quarter 2024 Compliance Report, the City’s totals agree with Treasury Quarterly Reports to date. . Anticipated Completion Date: Actions were completed on January 30, 2025

Condition: The Organization’s expenditure reports filed with the grantor for the cost reimbursement-based grant were overstated, and the Organization was overpaid by $182,167, of which $26,730 was received after yearend. The overpayment has not yet been refunded back to the grantor, over a year after the performance period of the grant had ended. Recommendation: The Organization should coordinate with the grantor the return of the unspent funds. The Organization should reevaluate its grant expenditure reporting procedures to better mitigate the risk of inaccurate filing and improper reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and recommendation. The anticipated completion date for the corrective action is October 30, 2025.

Finding 2024-005: PERIOD OF PERFORMANCE Description of Finding: Capital Funds identified in the PHA's CFP 5-Year Action Plan to be transferred to operations are obligated by the PHA once the funds have been budgeted and drawn down by the PHA. Capital Funds transferred to operations (BLI 1406) are not considered obligated until the PHA has budgeted and drawn down the funds. To meet this requirement, the funds must be budgeted in line BLI 1406 (Operations) and the PHA must submit the voucher request in LOCCS. (24 CFR Section 905.314(I)). Statement of Concurrence or NonConcurrence: The Authority had obligated capital funds related to operations (BLI 1406) for Capital Fund years 2020 and 2022 prior to the voucher request date for these draws. The Authority had six open capital fund grants during fiscal year 2024 (Capital Fund years 2019-2024). The Authority obligated the BLI 1406 funding for Capital Fund 2020 in March 2024 and Capital Fund 2022 in May 2024. The Authority submitted the voucher requests in February 2025. Corrective Action: Funds in 1406 will be drawn down directly after obligation. Name of Contact Person: Cheryl Thibeault Projected Completion Date: 09/30/2025

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2024 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2024-004 – Period of Performance Description of Finding: There was no evidence, such as a signature, evidencing review and approval by a direct supervisor of the timesheets. Time and effort reports were not done. Statement of Concurrence: We concur with the finding above. Corrective Action: BCHN has put together a training program for employees to ensure that timecards are reviewed and approved by both the employee and the supervisor on a bi-weekly basis. Before payroll is processed, approvals by employees and supervisors will be checked. HR will provide a monthly time and effort report to the finance team. This report will provide total number of hours worked by each employee for each assigned cost center. Completion Date: October 2024. Name of Contact Person: Alicia Tenny Chief Financial Officer Tel. No.: (917) 364-1156 E-mail: atenny@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call Alicia Tenny at (917) 364-1156. Sincerely yours, _________________________ Alicia Tenny Chief Financial Officer

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Cheney January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The City did not have adequate internal controls for ensuring compliance with federal allowable costs, matching and reporting requirements, and it did not comply with federal allowable costs and matching requirements. Name, address, and telephone of City contact person: Cindy Niemeier, Finance Director 609 2nd Street Cheney, WA 99004 509-498-9215 Corrective action the auditee plans to take in response to the finding: The City of Cheney recognizes the error in classifying a grant received from the Washington State Department of Commerce as a state grant rather than a federal pass­ through grant, which makes this funding source ineligible as matching funds in the funding awarded from the Department of Reclamation. The City has contacted the Department of Reclamation federal program to disclose the error and determine the required corrective action. The City of Cheney has proposed replacing the submitted reimbursement requests with City expenses as allowable matching expenses. The City is currently waiting on the Department of Reclamation for direction. The 2024 reporting error was corrected in 2025. Future projects with multiple funding sources will continue to be managed by the individual departments. The additional internal control will require the departments to meet quarterly with Finance to conduct internal audits of the reimbursement requests and completed reporting. Anticipated date to complete the corrective action: December 31, 2025

Program Names/Assistance Listing Titles: Assistance Listing Numbers: Title I Grants to Local Educational Agencies 84.010 Education Stabilization Fund 84.425C Education Stabilization Fund 84.425D Education Stabilization Fund 84.425U Education Stabilization Fund 84.425W 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 ADE approved 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.

August 20, 2025 FINDING 2024-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Martha L. Arnold-Turner Contact Phone Number and Email Address: 812-275-3111, mturner@lawrencecounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The county corrective action plan will be designed to implement a proper system of internal controls that will ensure compliance with the Reporting requirements of the grant. - The County will implement internal controls that will prevent or correct noncompliance. For all Federal grants that require reports, after one person prepares the report, another person will review the report for accuracy and completeness prior to it being submitted. Anticipated Completion Date: 12/31/2025

The Methodist College Registrar has been working with NSC to get the college relinked to the correct college in their system, which was fixed 11/2023. The registrar redeveloped database query to pull the old data that had been deleted by NSC due to FERPA and began sending accurate file submissions to NSC in June 2024. Files generated and submitted under the College’s new processes are taking roughly one week to process from initial submission, through error correction, and finalization.

Management agrees with the finding and will establish the internal control recommendations outlined in the Schedule of Findings and Questioned Costs. Additionally, the Credit Union has corrected and resubmitted the PPR and UOA reports which were accepted by the CDFI in August 2025. Internal control procedures will be developed and implemented in December 2025 and the Credit Union has corrected and resubmitted the PPR and UOA reports which were accepted by the CDFI in August 2025.

Management’s Response/Corrective Action Plan: The City of Bangor’s Community Development Block Grant program receives direct oversight by the Community Development Officer, responsible for ensuring compliance with Federal regulations, including the determination of eligibility, allowability, and allocability of all financial expenditures. Previously, the City’s practice concerning CDBG funds provided to other departments allowed those project managers to directly charge the CDBG account through payroll, requisition or direct charges which are not first reviewed and approved by the Community Development Officer. The Community Development Officer has implemented the following procedural changes: 1. Executing Interdepartmental Subrecipient Agreements. This document establishes certain standards and expectations for CDBG-funded programs. In 2025-26, Agreements will create new procedural safeguards including submitting requisitions for all expenditures not contained in the approved budget, and to submit receipts or invoices to the Community Development office directly to back up all approved expenses. 2. The Community Development Officer must review and sign off on all expenses charged to the CDBG account by Community and Economic Development Staff, including “OK To Pay” charges, and requisitions. The Community Development Officer recommends the following changes: 1. The issuance of a separate credit card to be used exclusively for CDBG expenditures. The reconciliation process is very tedious and involves sifting through unrelated expenses, and some expenses which are allocated to CDBG which have not been initiated by the Community Development Division and were deemed ineligible by the Community Development Officer. This creates some challenges finding another account to charge to, often a month or more after the expense occurred. The CDBG program does a monthly drawdown for administrative costs, which requires the CDO to make adjustments for expenses that are discovered during the reconciliation process. 2. Eliminating the practice of providing CDBG account numbers to individual departments to directly charge expenses. This leaves the program particularly vulnerable, as when a department charged nearly $435,000 to the CDBG account, requiring reversal of charges that were not eligible. The CDO believes that this change should be initiated by the Finance department with cooperation by the CED. 3. Establishing a review process for personnel expense outside of Salary and Fringe Benefit. Many charges in SunGard related to 701 charges are not viewable as they are deemed privileged expenses. However, some charges for personnel expenses have required review and reversal, and in one case a charge for “travel” was discovered for a program that does not involve this activity. The Finance Department might consider a change to include review if necessary.

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of South Dakota Office of Emergency Management Assistance Listing Number: 97.039 Program Name: Hazard Mitigation Grant Program Finding Summary: Material expenditures were claimed for reimbursement with no documented formal review and approval. Corrective Action Plan: We will continue to have the approvals of material expenditures happen at the requisition level when the materials are ordered. If we must use material from our internal inventory stock, we will use a material charge out sheet that will provide the following information: work order number of project, name of work order, date, material item number (SBR#), quantity, charged by, approved by and posted by. This charge out sheet will then be posted in our IVUE system, and the paper copy will be scanned into vault for documentation. This same procedure will be used for salvage and credit material. For cash management, we will send the final summarized report to the Operations Manager for approval before it is sent to FEMA. Responsible Individuals: Mike Letcher, Operations Manager; Brendan Nelson, Operations Supt.; and Sanden Simons, Operations Supt.; Anticipated Completion Date: The anticipated date of completion is September 2025, as we have notified our employees of this change.

Federal program title - Local Assistance and Tribal Consistency Fund program (LATCF) CFDA 21.032 Recommendation: We recommend the County refine its understanding and interpretation of the standards and ensure that the County policies and procedures are consistent with that understanding and interpretation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The LATCF funds were reported on the SEFA under CFDA 21.032 by the CAO’s department because the funds were transferred from the CAO’s fund to the DOT fund, with the understanding it would be expended. However, DOT did not spend the funds within the same fiscal year in which they received the transfer due to a misunderstanding that the funds could not be used for prior year expense. As a result, the funds were recorded as unearned revenue in fiscal year 2023/24, and the related expenditures will be reported in the following fiscal year. Name(s) of the contact person(s) responsible for corrective action: Lisa McNeely Department of Transportation Business Manager & Christine Gaffney Auditor-Controller. Planned completion date for correcting action plan: Completed

FINDING 2024-003 (prior finding audit number 2023-002) Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Mindy Byers, Auditor Contact Phone Number and Email Address: 765-364-6401 mindy.byers@montgomerycounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: One person will complete the report and another will sign off on a full review. Anticipated Completion Date: April 1, 2026 (based on due date of the next report)

FINDING 2024-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Jessica Secrease, County Auditor Contract Phone Number and Email Address: 765-456-2804 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To prevent a recurrence of this issue in future audits, the County will implement a new internal control procedure. Specifically, the Auditor’s Office will require that both the Deputy Auditor and the County Auditor review and sign off on all Coronavirus State and Local Fiscal Recovery Fund reports prior to submission. This dual-review process will include a standardized checklist to verify data accuracy, consistency with supporting documentation, and compliance with federal reporting requirements. In addition, staff involved in the preparation of the reports will receive refresher training on the applicable guidance and reporting protocols to ensure a thorough understanding of expectations and requirements Anticipated Completion Date: September 2025