Corrective Action Plans

This is the first year that Federal Grant funds in excess of $750,000 have been received and spent by the city of Kenton. For the current year, two people will be in charge of meeting deadlines for filing reports. Compliance with Federal Grant Guidelines will be more closely followed and attempts will be made to make a written policy for Federal Grant Procedures

F A 2O24-OO3 Strengthen Controls over Financial Reporting Compliance Requirement: Reporting lnternal Control lmpact: Material Weakness Compliance lmpact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education CFDA Numbers and Titles: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: S0104220010 (Year:2023), S010A230010 (Year.2024) Questioned Costs: $0.00 Repeat of Prior Year Finding: FA 2023-004, FA 2022-004, FA 2021-002, FA 2019-002 Description: The School District did not file accurate completion reports for the Title I Grants to Local Educational Agencies program. Corrective Action Plans: . CFO will make sure expenditures are correctly recognized on all completion reports . An independent CPA person has been hired and review completion reports before they are submitted Estimated Completion Date: Decembet 31, 2025 Contact Person:Torrence H. Freeman lll. CFO Telephone: 706-665-8577 Email:tfreeman@talbot.kl2 aus

Condition: One Education Stabilization Fund final financial report has not been submitted that is overdue. Corrective Action Planned: Upon review, the District confirmed that the grants identified in this finding have either already had their final financial reports submitted or were operating under approved late liquidation extensions, during which final reporting is not yet required. The District has verified all reporting statuses and updated its internal grant tracking to ensure documentation of late-liquidation approvals is consistently stored with each grant file. No further action is needed beyond maintaining the existing reporting calendar and reconciliation procedures now in place. Anticipated Completion Date: Procedures are already implemented. Contact: Liz Latoria, School Director of Finance and Operations

Condition: Two final financial reports were not filed in a timely manner for Special Education Cluster grants. Corrective Action Planned: The District experienced delays in filing final financial reports due to difficulties reconciling grant revenues in the Town’s accounting system, as certain receipts were not clearly identifiable during the grant closeout process. To address this, the District implemented a monthly reconciliation process with the Town and created an internal grant reporting calendar with secondary review to ensure timely submission. These procedures are now in place and will prevent future delays. Anticipated Completion Date: These procedures are currently in place. The District will complete the final financial reporting process for outstanding grants within 60-90 days, with all remaining reports finalized no later than March 31, 2026. Contact: Liz Latoria, School Director of Finance and Operations

Planned Corrective Action: Planned Action The City will implement a calendar based reminder system using Microsoft Outlook to send annual notifications to designated staff prior to the reporting deadline. Roles and Responsibilities o Budget & Finance Director: Accountable for preparing and filing the report with the Treasury. o Community Development Director: Provides programmatic information necessary for report completion upon request. o Deputy Auditor: Receives annual reminder notifications to ensure oversight. o Auditor’s Office: Will be notified upon submission of the report for independent verification. Implementation Timeline Outlook reminders will be established by April 1 annually to ensure timely notification ahead of the next reporting deadline. Monitoring The Auditor’s Office will verify timely submission annually and maintain documentation of compliance for audit purposes. Anticipated Completion Date: 12/12/2025 Responsible Contact Person: Amanda N. Perkowski, Budget & Finance Director

The Organization concurs with the finding and management will implement procedures to ensure appropriate internal control procedures are in place for period of performance and cutoff procedures related to grant expenditures. Management will implement additional internal controls at the end of the grant and the beginning of the grant to ensure accuracy of the salaries being posted are in the correct period of performance.

Views of Auditee and Corrective Actions: The Division of Special Education is currently reviewing the details of the finding in order to provide an adequate response and corrective action plan.

Condition: We identified several monthly vouchers which were submitted to the grantor later than fifteen days after the month end. In addition, we identified financial close-out rep01i s which were submitted to the grantor later than thirty days after the end of the performance period. Corrective Action Taken or Planned: Management plans to reiterate the financial reporting requirements to ensure that monthly vouchers and financial close out reports are submitted to the grantor timely. Anticipated Date of Completion: December 31, 2025 Name of Contact Person: Karen Reitan, President and Chief Executive Officer Management Response: Management concurs with the finding.

CORRECTIVE ACTION PLAN April 10, 2025 M.C. College Preparatory School of Wisconsin, Inc., respectfully submits the following corrective action plan for the year ending June 30, 2024. Walkowicz, Boczkiewicz & Co., S.C. 1800 East Main Street, Suite 100 Waukesha, WI 53186 AUDIT PERIOD: June 30, 2024 The findings from the June 30, 2024, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION MATERIAL WEAKNESS 2024-001 Elementary and Secondary School Emergency Relief Fund - COVID-19 – CFDA No. 84.425 Condition: During the audit of submitted claims, it was found that there was a lack of sufficient review procedures to ensure proper verification of costs. Specifically, several instances of duplicated expenditures were identified within the claims. The same costs were submitted more than once for reimbursement, resulting in questioned costs. Criteria: The Organization's internal controls should require that claims be thoroughly reviewed for accuracy and completeness before submission. This includes verifying that costs are not duplicated and ensuring proper documentation supports each expenditure. Additionally, the previously submitted claims included in the period of performance should be monitored to prevent duplication. Cause: The review process did not involve cross-checking with previous claims or documentation to identify and prevent the submission of duplicate costs. Effect: As a result of inadequate claim reviews, the organization has submitted claims containing duplicated costs. These duplicated expenditures have resulted in questioned costs, which may need to be refunded. The failure to detect and prevent such errors could lead to non-compliance with funding requirements. Questioned costs: $505,820 Auditor’s recommendation: It is recommended that the organization implement a more thorough review process for all submitted claims. This should include cross-checking current claims against previous claims to detect and prevent duplicated costs. A system should be implemented to track claims and associated costs more effectively, ensuring that no expenditure is claimed more than once. Action Taken: M.C. College Preparatory School of Wisconsin, Inc.’s Management has completed the transition to a new payroll system with enhanced process controls as of December 2024. This system enables the organization to isolate funding source allocations at the individual employee level, thereby preventing expenses from being attributed to more than one source. Final programming and control reviews are scheduled for completion prior to June 30, 2025. Further, Management has reviewed the questioned costs with the local education authority and has submitted qualified replacement expenses for all amounts initially submitted in error. As a result, no refund is required, and the applicable financial reserve will be released in the upcoming fiscal year. If the Department of Education has questions regarding this plan, please call Alfred Keith IV at 414-264-6000. Sincerely yours, Alfred Keith IV Chief Education Officer

Finding: Material weakness in internal control over period of performance Corrective action: Pacific Forum will incorporate policies into expense management and financial reporting guidelines to ensure all expenditure is completed within the period of performance and reviews by management are properly documented. Completion Date: February 1, 2026 Responsible Individual: Executive Director

Corrective Action Plan: The City of Charleston will implement internal controls and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts. Anticipated Completion Date: Fiscal Year 2025

California Department of Fish and Wildlife • The Accounting Services Branch (ASB) will document the process by updating the respective desk procedures to clearly direct staff to only approve vouchers with dates consistent with the Project ID start and end date as identified on the FI$Cal Crosswalk. • Ensure new staff within ASB are trained on the desk procedures before they begin approving vouchers in FI$Cal. Estimated Implementation Date: March 31, 2026 Contact: Jing Lin, Branch Chief, Accounting Services Branch California Department of Transportation The Division of Research, Innovation and System Information staff have developed the following corrective actions in response to the audit finding: TEC Charging Guidance and Training To ensure research project Contract Managers properly code a Travel Expense Claim (TEC), the following guidance and training actions will be implemented. • The Division’s Contract Manager Handbook and Training documentation will be updated to provide staff with guidance ensuring that TEC charging information aligns with the fiscal year (FY) in which the travel expenses occurred. • DRISI Contract Managers and their first- and second-line supervisors will be trained on the change and will receive the annual reminder. A record of attendance of training will be maintained. • New hires will receive TEC charging practices training within 30 days of their start date. Annual TEC Coding Reminder To ensure TECs are coded accurately to the correct Federal Project Number, an annual email reminder will be sent to DRISI staff beginning in the month of May for coding/charging TECs. • The reminder will instruct staff to code and charge TECs to the fiscal year and federal project number in which the expense was incurred. • A list of tasks and project IDs will be attached to the email to minimize errors and ensure consistency. In addition, the program will send a reminder to the TEC/Accounting Office to: • Charge and post TECs and non-encumbered Operating Expense (OE) charges to the fiscal year in which they were incurred. • This process will help avoid audit findings related to charges being posted to the incorrect fiscal year or federal award number. Estimated Implementation Date: March 31, 2026 Contact: Chief, Division of Research, Innovation and System Information

Finding 2024-001 Federal Agency Name: Department of Health and Human Services Program Name: Block Grants for Prevention and Treatment of Substance Abuse Federal Financial Assistance Listing Number: 93.959 Finding Summary: The Organization must establish and maintain effective internal controls over federal awards that provides assurance that the organization is managing the federal award in compliance with federal statutes, regulation, and conditions of the federal award. The Organization did not have documented review completed prior to invoice payments being made or reimbursement requests being submitted to ensure all costs incurred were allowed and in the correct period of performance under the program. Responsible Individuals: Carlie Stevens, Wellcome Manor Finance Manager; Karen Klabunde, Wellcome Manor Center Director Corrective Action Plan: On a monthly basis, the Finance Manager will provide the month’s expenditures, receipts, reimbursement requests, and recap spreadsheet to the Center Director. The Center Director will agree all items to the grant and sign the recap spreadsheet to document her review and approval. Anticipated Completion Date: December 31, 2025

Finding 2024-239: The Division does not have documented control procedures in place to ensure compliance with period of performance requirements for the Rehabilitation Services-Vocational Rehabilitation Grants to States. Related to Prior Finding: N/A Agency’s view: Agree 3.1 Corrective Action Plan: Document Control Procedures: Develop and implement formal, written procedures (Grants Management Manual Chapter) for verifying that expenditures are assigned to the correct period of performance in both Aware and Luma. 3.2 Training: Train IDVR team members on policies and procedures tied to Period of Performance. Anticipated Corrective Action Date: 04/01/2026 Responsible for Corrective Action: Eric Bjork, Fiscal Officer

Finding Number: 2024-032 Audit Type: Single Audit Finding Title: Delayed Final Reimbursement Due to Unresolved Agency Requests Related Finding: 2024-023 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will designate a grants coordinator to monitor agency requests and ensure timely responses. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will improve communication with funding agencies. 5. Status of Prior Year Finding This is a newt finding.

2024-006 – WATERSHED REHABILITATION PROGRAM – LACK OF CONTROLS AND IMPROPER PERIOD OF PERFORMANCE – WRD – ALN 10.916 – MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition Pembina County Water Resource District applied costs to the Watershed Rehabilitation Program after the period of performance, which shows a lack of internal controls. The total value of the expenses past the period of performance end date was approximately $170,468 which occurred through September 14, 2024, more than a month past the period of performance end date. Corrective Action Plan: We agree we will ensure costs are in the proper period of performance going forward Anticipated Completion Date: FY2025

Auditors Recommendation: CBPSC should ensure that its records are completed and reconciled in a timely manner, so that the single audit can be performed and completed on time, and the reporting package and data collections form can be submitted before the deadline. Corrective Action Plan: Management acknowledges that the reporting package and Data Collection Form for the 2023 audit were not filed by the required September 30, 2024 deadline. Management also acknowledges that this finding will appear for the next audit year, however to correct this and prevent recurrence of this issue the organization has implemented the following actions: Established external filing deadlines. Enhanced monitoring and tracking. Assignment of oversight responsibility. Improved coordination with external auditors. Staff Training. Anticipation Completion Date: These corrective actions were initiated in the 2025 fiscal year and will be fully in place for the 2025 audit cycle, ensuring timely submission by September 30. 2026 Management Statement: Management believes these corrective steps will ensure full compliance with federal reporting requirements going forward and prevent recurrence of late submissions. Responsible Individual: Managing Director, Fred Fogg

Finding 2024-002 Contact Person responsible for corrective action: Kevin Couey The corrective action planned: Strengthen our processes to ensure all grant expenditures are made within the authorized period of performance. The anticipated completion date (or starting date if ongoing): We immediately put new processes into action effective October 1, 2025 and will be validated at next audit in May 2026.

Finding 2024-010 – Period of Performance (Material Weakness) Finding: The Organization did not have good controls to ensure the period of performance requirements was met due to staff turnover. Management Response: Management concurs. Corrective action plan: •Implement a grant compliance checklist and training for staff by the end of 2025 to ensure expenditures are within the grant period. •Require pre-approval for all expenditures near grant end dates. •Quarterly compliance reviews. Responsible Party: CFO Completion Date/Status: Expected to be Implemented by end of 2025; ongoing review.

Federal Program Information Federal Agencies: Department of Health and Human Services (“HHS”) Pass-Through Entity: Virginia Department of Health; Not Applicable Pass-Through Entity Number: INORWB611-GY23; INORWB611-GY24; Not Applicable Awards: Assistance Listing 93.917 – HIV Emergency Relief Project Grants; Assistance Listing 93.918 – Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease Award Periods: April 1, 2023 to March 31, 2024; April 1, 2024 to March 31, 2025; May 1, 2023 to April 30, 2024; May 1, 2024 to April 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Description: Timely Application of Program Income Prior to Requesting Additional Cash Payments Recommendation: During the latter part of the fiscal year and as a result of prior year audit findings, IJP implemented various checkpoints in their monthly processes to ensure that program income was disbursed prior to requesting cash reimbursements. IJP should continue to assess existing policies and procedures to ensure the program income balance is spent timely. HRSA recommends that recipients and subrecipients strive to proactively secure and estimate the extent to which program income will be accrued. View of responsible officials: Management concurs with the finding and has implemented procedures to ensure appropriate and timely application of program income. Corrective Action Planned: Inova Grants Accounting and Inova Juniper Program (IJP) directors will work collaboratively to disburse funds available from program income prior to requesting additional cash payments from RWHAP funds. Inova implemented a Program Income from Sponsored Programs policy in February 2025. Inova will assess this written procedure and revise as necessary to ensure that program income is applied before requesting federal reimbursement. Inova will review federal grant requirements related to program income and identify sources of program income during kickoff meetings for new awards. Mandatory training will be conducted for program and finance staff responsible for the administration of these awards. (2 CFR 200.307 and 200.305) Inova will require a monthly reconciliation of program income earned and expenditures by grant. Program income tracking will also be included in monthly grant variance reports. Planned Completion Date for Corrective Action Planned: Ongoing with completion date of December 31, 2025.

This Finding is related to the failure to correctly report grant funds being expended and to the lack of a Department’s filing one quarterly report timely related to the SLFRF Funds. The Department has been contacted and is carefully reviewing guidance for all future remaining reports. Future Reports are expected to be filed correctly and timely, with future education being sought as needed.

We are working to change the standard for document retention and organization. This will help ensure all costs are properly approved before they are charged to federal programs, and that management understands the imperative nature for the record retention.

Audit Finding 2024-002 Reference: Expenses charged to federal awards outside the designated period of performance. (2 out of 40 sampled) ________________________________________1. Issue Summary The audit identified two instances where expenses were charged to a federal grant outside the approved period of performance. These expenses were tied to invoices that began within the period of performance and a portion extended beyond the performance period. The root cause was insufficient review of transaction timing and lack of controls to ensure compliance with Uniform Guidance requirements. ________________________________________ 2. Root Cause Analysis Lack of a formalized review process for validating transaction that span extended period dates that may extend past grant period of performance. ________________________________________ 3. Corrective Actions A. Implement a Formal Expense Review Protocol • Develop and document a standard operating procedure (SOP) for reviewing all grant-related expenses. • Require validation of invoice service dates and delivery dates before posting to federal awards • Include a checklist for SPF accountants to confirm alignment with the period of performance. B. Staff Training and Awareness • Conduct mandatory training sessions for all staff involved in grant accounting and expense processing. • Include guidance on: o Allowable costs under 2 CFR Part 200 o Period of performance compliance o Documentation standards ________________________________________ 4. Responsible Parties • Finance Director: Oversight and implementation of corrective actions • Sponsored Projects Finance Team: Execution of SOP and transaction reviews ________________________________________ 5. Timeline Action Item Target Completion Date Policy Development Already implemented Staff Training Completed initial training, additional will be ongoing

Finding 2024-003: Activiites Allowed or Unallowed & Allowable Costs/Cost Principles & Period of Performance (Clean Energy Demonstrations - ALN 81.255). Contact Person: Manny Citron, Chief Operating Officer. Recommendation: MACH2 should establish an internal control policy to ensure transactions are reviewed and approved prior to being charged to the grant and the approval should be documented for each transaction. Action: MACH2 has created and implemented written policies prior to execution of cooperative agreement regarding the review and approval of grant expenditures. These policies ensure transactions are reviewed with multiple approvals and for accuracy, allowability, allocability, and eligibility prior to being submitted for reimbursement. In addition, MACH2's policies are designed to demonstrate compliance with 2 CFR 200 by esbalishing internal controls that maintain documenation of approvals and ensuring segregation of duties so that no single individual has control of processing of transactions. Date of Completion: October 31, 2025.

Corrective Action Plan – Federal Funds Review and Processing Audit Finding Reference: Response to Finding 2024-002: Improvement Control Over Period of Performance for Federal Awards Name of Contact Person and Completion Date: Krystal De Gray, COO of Nashua School District 09-22-2025 Planned Corrective Action: The Nashua School District acknowledges the finding related to the control over the period of performance for federal awards (Finding 2024-002). In response, the district will develop and implement a formal internal procedure to ensure that all purchases funded by federal awards are both placed and received within the established period of performance. This procedure will include appropriate review, documentation, and oversight to maintain compliance with federal grant regulations. To further strengthen internal controls, the Nashua School District will implement a procedure limiting purchases to occur no later than 15 days prior to the grant’s end date. Additionally, all necessary services must be received and completed prior to the expiration of the grant period. Mario Andrade Krystal De Gray Superintendent Chief Operating Officer