Corrective Action Plans

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.

Finding 2025-004 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: The Registrar prepares the program calendars with input from the programs on an annual basis. MSM has a diversity of programs with different start and end dates. We understand that this needs to be accurately reflected in our calendars and in the Banner system or other enrollment platform. Academic calendars will be reviewed by the Registrar and program staff on an annual basis. Any changes to the academic calendars will need to be communicated to all members of the team. Updated calendars will be posted annually on the website and in the student handbook. After the Registrar’s Office confirms the academic start date and academic end date, Student Fiscal Affairs will continue to input this information in our Student Information System Banner to allow accuracy in our student records sent to the Department of Education Common Origination and Disbursement. If there is a change in the academic start dates and/or academic end dates, the Registrar’s Office will notify Student Fiscal Affairs, Admissions, and Student Accounts to allow for updates within the institution. Anticipated Completion Date: March 1, 2026

Finding Number: 2025-002, Grant Closeouts Condition: The University did not complete full grant closeout procedures in a timely manner for 8 out of 40 grants that were tested with a period of performance that ended in the year ended June 30, 2025. Corrective Actions: Penn State will raise awareness of the late closeout issue at various committee, workgroup, and council meetings during Spring 2026, and enforce compliance with our existing policy. These meetings involve research leadership at all colleges, such as Associate Deans for Research, College Research Administration Officers, and College Strategic Financial Partners. Penn State will provide additional trainings throughout the year to educate colleges on the closeout process through the Financial Analysis and Compliance Office. Contact person responsible for corrective action: Jason Guilbeault, Assistant Vice President for Research – Post Award Contractual Compliance Anticipated Completion Date: March 31, 2026

Corrective action plan: HHSC will run quarterly expenditure reports for this grant to monitor administrative earmarking thresholds. Implementation date: July 31, 2026 Responsible person: Roderick Swan, Associate Commissioner, Behavioral Health Services Operations

Corrective action plan: ITS will: • Work with HR and Security to analyze and validate the size and scope of the late submission of access termination requests for separated employees. Communicate the analysis results and recommendations on or before May 1, 2026. • Work with the Information Security Office for continuation of periodic reconciliation of HR data and network accounts. Schedule for reconciliation to be established on or before May 1, 2026. • Work with Human Resources to establish a schedule of periodic reconciliation for HR data and case management application accounts. Schedule for reconciliation to be established on or before May 1, 2026. • Review existing business process for offboarding separated employees and provided recommendations to HR for training and communication for staff. Recommendations to be provided by May 1, 2026. • Determine what technology solution may be needed by August 31, 2026, with consideration of effectiveness of mitigation actions, as noted above. Implementation dates: See Corrective action plan Responsible person: Angie Lindemann, Deputy Chief Information Officer

Information on the federal program: Subject: Special Education Cluster (IDEA) – Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Period of Performance compliance requirements. Context: During fiscal year 2023-24, the School Corporation was a member of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01 and 22619-047-ARP grant awards, two exceptions were identified in the sample of five transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the two identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. This issue was isolated to fiscal year 2024. No costs incurred outside of the period of performance were identified in fiscal year 2025. Views of Responsible Officials and Corrective Action Plan: Management disagrees with part of the finding. The term “obligate” can be interpreted in various ways within our context. While we have a purchase order that was completed by September 30, we do agree that we changed vendors after September 30 and paid the non-public school directly. We agree with the finding that direct payment to a non-public school is not allowable. The purchase order is an internal written commitment to acquire the items/supplies, but it is not a binding written agreement to acquire “property” when we are purchasing supplies until it is provided to the vendor. The purchase order is authorization and approval to purchase the items/supplies. Once the purchase order is provided to the vendor, it is committed and is the binding written agreement. The invoice is an order to pay the obligation. 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. Sarah Claton, Cooperative School Services director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the cooperative on an ongoing basis.

U.S. Department of State U.S. Refugee Admissions Program - Assistance Listing No. 19.510 Recommendation: It is recommended that the Organization review controls in place to ensure expenses are approved and maintain evidence of approval. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is reviewing standard operating procedures with the program staff. All expenses will be supported with proper approvals. Management will perform periodic reviews to ensure expenses have evidence of approval. Name(s) of the contact person(s) responsible for corrective action: Christopher Paris, Senior Director of Finance Planned completion date for corrective action plan: June 30, 2025 and Ongoing

Incorrect Term Dates Used in R2T4 Calculations Auditor Description of Condition and Effect. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the percentage of the payment period completed. We further noted that the University used an incorrect term start date for all R2T4 calculations performed for the Fall 2024 semester. Specifically, the start date used in the calculation did not agree to the official academic calendar approved for the applicable term. As a result of this condition, the University performed R2T4 calculations that included inaccurate percentages of the payment periods completed, which lead to the improper calculation of Title IV funds earned and unearned. Auditor Recommendation. We recommend that the University implement a control requiring reconciliation of term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Additionally, management should review R2T4 calculations completed during the affected period to determine whether recalculations and any necessary adjustments or returns are required. Corrective Action. The University will establish formal procedures to review the term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026

Noncompliance with the 10-Day Rule (Repeat finding) Auditor Description of Condition and Effect. Of the 40 students tested, we noted 13 students that had funds distributed to them more than 10 days prior to the start of the semester, as a result of University personnel using the incorrect semester start dates. As a result of this condition, the University is not in compliance with federal guidelines. Auditor Recommendation. We recommend that the University implement a review process to ensure that all funds are distributed to students timely and within prescribed federal guidelines. Corrective Action. The University will implement a review process to ensure that all funds are distributed to students timely. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026

Research and Development Cluster— Assistance Listing Nos. Various Recommendation: We recommend that the University review its procedures around review and approval of R&D expenditures to ensure that only valid expenditures are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University does have existing internal control processes over its federal grants. The principal investigators code, approve, and submit expenditures for payment. In addition, principal investigators receive periodic grant reports which include the detail of all transactions charged to their grants for review. The University will add an additional control step to review coding of research and development payment requests in the ERP system prior to payment. Names of the contact persons responsible for corrective action: Gerri Stepanek and Carole Kampf Planned completion date for corrective action plan: September 1, 2025

Program: AL 93.575 – COVID-19 Child Care and Development Block Grant – Allowability Corrective Action Plan: In 2025, The Agency developed a subrecipient monitoring tool to ensure effective controls and processes are in place. The Agency will review all findings and take appropriate actions when warranted. Contact: Nicole Vint Anticipated Completion Date: June 30, 2026

Program: AL 93.575 – COVID-19 Child Care and Development Block Grant – Period of Performance Corrective Action Plan: N/A Contact: Heather Arnold Anticipated Completion Date: Complete

2025-001 Period of Performance Recommendation: We recommend that the Center implement specific controls around cut off for expenditures to ensure expenditures are recorded in the proper period in accordance with the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will monitor expenditures closely to ensure expenditures are recorded in the proper period. Name(s) of the contact person(s) responsible for corrective action: Greg Miller Planned completion date for corrective action plan: April 2026 If the U.S. Department of Health and Human Services has questions regarding this plan, please call Greg Miller at 309-323-6609.

Condition: Costs were charged to the grants for invoices with service dates prior to the start of the grant period and payroll and related benefits earned prior to the start of the grant period. Corrective Action Planned: We had budgeted the full cost of one teacher and four teaching assistances in the IDEA 240 grant for 2025. The approval process for the grant took longer than expected, our intent was always to comply, but we do realize we should have waited for the approval to be in place prior to charging the costs of these employees to the grant. In the future we will wait for the approval process to be complete and will then charge the employees there. Anticipated Completion Date: Completed Contact: Martin Anguelov, Chief Financial Officer for Nantucket Public Schools and Deb Gately, Director of Special Education for Nantucket Public Schools

Finding 2025-004 Supplanting Controls – Significant Deficiency Condition: Lack of controls to prevent supplanting in the Student Support and Academic Enrichment program; presumption of supplanting rebutted but controls not in place. Corrective Action Plan: Implement pre-award and annual budget review procedures to document that state/local funds are not used for activities proposed for federal funding and document any rebuttals in grant and budget records. Responsible Official: Holly Langan, Managing Officer for Financial Services Timeline: Implementation completed by June 30, 2026. 113

Name of Contact Person: Karen Gillis Corrective Action Plan: This finding remains an unusual situation for BSFA. BSFA has not previously been in a situation where BSFA funded a contractor in the absence of the federal government’s inability to enter into a contractual agreement (due to the Trump Administrations strict limitations on entering into contractual agreements). The inability to demonstrate that costs were incurred lies with the contractor wherein we were unable to obtain from them their spending down the funds provided as originally agreed upon. We do not anticipate another instance such as this though we will implement stronger controls over contract payments in the future so expenditures are supported by documentation showing costs were incurred within the approved period of performance. Proposed Completion Date: February 28, 2026

Grant Accounting Finding 2025-005 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the de minimis rates were appropriately billed as allowed under uniform guidance. Corrective Action Plan: CCSPM will adhere to uniform guidance specific to de minimis rates ensuring Indirect Expenses are no more than allowable percentage of eligible total expenses over the grant period. Adherence will be monitored as part of an expanded monthly secondary review process across Continuum of Care grants. Responsible Individuals: Mary Ammer, Senior Director of Accounting and Finance and Grant Accountants: Jen Goeppinger and Ashley Feldick. Anticipated Completion Date: Allowable de minimis rates will be met by the end of the current grant period or end of FY26 (6.30.26), whichever is sooner for each currently active Continuum of Care grant.