Corrective Action Plans

Views of Responsible Officials: Management concurs with the recommendation and has implemented procedures to ensure that

future SEFA reporting aligns with applicable period of performance requirements.

2024-003 – Reporting – Significant Deficiency Federal Program: Assistance Listing #16.812 Second Change Act Reentry Initiative, Passed Through Pennsylvania Commission on Crime and Delinquency, Pass-Through Entity Identifying Number: 36758 Condition/Context: The Organization identified during the preparation of its second quarter 2024 expenditure report approximately $25,000 in costs incurred during November 2022 that had not previously been included in a submitted expenditure report to PCCD and which were included in the second quarter 2024 expenditure report. While such costs were incurred during the overall program performance period and were allowable and attributable to the program, such costs were not timely identified and reported on the correct expenditure report. Corrective Action Plan: To strengthen our internal controls and ensure full compliance with grantor reporting requirements, we are implementing the following corrective measures: 1. Review and Update of Reporting Procedures: o We will review and revise our existing grant expenditure reporting procedures to ensure that all expenditures are properly captured, reviewed, and reconciled before submission to the grantor. o Revised procedures will clearly define roles and responsibilities for program staff, grants management, and accounting. 2. Monthly Reconciliation Process: o A monthly reconciliation process will be implemented to match recorded expenditures in the general ledger with grant budgets and program activity. o Variances will be reviewed and resolved in advance of quarterly reporting deadlines to prevent errors in submitted reports. 3. Dual Review and Approval: o All quarterly expenditure reports will be subject to dual review by the grant’s accountant and the accounting operations manager prior to submission. o This control will ensure that reports are complete, accurate, and supported by accounting records. 4. Training and Communication: o Finance and program staff involved in grant administration and reporting will receive training on updated procedures and internal control expectations. o Ongoing communication between departments will be encouraged to ensure awareness of allowable costs, budget constraints, and reporting timelines. 5. System Enhancements: o We are evaluating our current financial system and looking for a system that will allow better tracking of grant-specific expenditures, including improved reporting functionality and coding accuracy.

AUDIT FINDINGS 2024-001: In one of 25 selections for testwork over period of performance, expenditures related to contract labor were submitted for reimbursement to the Federal Emergency Management Agency (FEMA) that were outside of the project period. Further, the review performed over expenditures was not completed appropriately to identify this error, this is an instance of the District’s internal control not operating as designed. Name of Contact Person: Daria Heimerman, Director of Financial Reporting, dtheimerman@evergreenhealthcare.org Corrective Action Planned: Assess process and controls for improvements to identify expenditures incurred outside of the designated project period. Anticipated Completion Date: August 2025 Statement of Concurrence or Nonconcurrence: Management concurs with audit finding 2024-001.

FINDING 2024-004 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Christy Smiley Contact Phone Number and Email Address: 812-663-2570, auditor@decaturcounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: INDIANA STATE BOARD OF ACCOUNTS 27 At least 2 people will look over the report and check all receipts and expenditures when the next P&E report is submitted to prevent and detect any errors. Prior P&E report had already been submitted before the prior audit was complete and we were made aware of the issue and then the Auditor changed in 2025. Control will not be in place until the 2026 P&E report is submitted. Anticipated Completion Date: Submission of next ARPA report, April 2026.

2024-003 Period of Performance - Community Development Block Grants/Entitlement Grants Cluster Assistance Listing Number 14.218 Grant Period - Year Ended December 31, 2024 Condition Found The City did not meet program timeliness spending requirements. The City’s unexpended balance at December 31, 2024 of $2,548,256 is more than 1.5 times the $1,319,714 entitlement grant for the current year. We consider this to be an instance of non-compliance relating to the Period of Performance Compliance Requirement. Corrective Action Plan The City of Decatur received the 2023 Management Letter on May 15, 2025 with this same instance of non-compliance, after most of the 2024 financial audit was completed and the 2024 fiscal year had ended. The City of Decatur Economic & Community Development Department is under new leadership with Lacie Elzy as Acting Economic & Community Development Director. Director Elzy will be reviewing all grant programs and duties in the department and ensuring that grant requirements are met. As of the date of this letter, timeliness spending requirements have been met and the City is compliant. Responsible Person for Corrective Action Plan Lacie Elzy, Acting Economic & Community Development Director Implementation Date of Corrective Action Plan December 31, 2025

One of the four CMF funded projects, Barry Farm, is a two-phase project. The construction start was delayed due to local permitting challenges and COVID-related issues which resulted in the project not being completed by the original Project Completion date of March 27, 2024. Management informed CDFI Fund of the delays in the project and on May 16, 2024, CDFI Fund provided a one-year cure period to March 31, 2025. At that time, Management informed CDFI Fund that the second phase of the Barry Farm project would require a longer cure period due to a 30-month delivery schedule, driven by the incorporation of a large geothermal system, with delivery set for late 2026. CDFI Fund directed Management to report on the second phase’s progress with a new cure period request annually until project completion. During the cure period, Barry Farm’s first phase was completed, and is now leased up and operating. In March 2025, Management informed CDFI of the project status for phase two which is now 24% complete and remains on schedule for completion in November 2026. CDFI Fund provided a one-year cure period until March 31, 2026. Management has otherwise significantly exceeded the grant’s performance targets and will request cure period extensions until project completion.

Finding Number: 2024-001 Condition: The expenditures were reported for the Capital Magnet Fund throughout the award period from the year ended June 30, 2019 to the year ended June 30, 2024 on the schedule of expenditures of federal awards (SEFA) but did not accurately report the amount of administrative expenditures incurred during the performance period, and, therefore, the SEFA was not complete and accurate for the year ended June 30, 2019 to the year ended June 30, 2024. Planned Corrective Action: Management has implemented procedures and controls to ensure reports are reviewed prior to submission and distributed funds are reported properly and in the correct period. Contact person responsible for corrective action: Lindsey Dehring, Vice President of Financial Planning & Analysis Anticipated Completion Date: July 31, 2025

Recommendation We recommend the Organization update their method of allocating expenditures to federal awards based on the incurred date, rather than paid date.

The Department of Family and Support Services (DFSS) will review its budget and monitoring process for the Emergency Solutions Grant (ESG) Program to ensure grant funds are prioritized for spending in accordance with the program requirements. Monthly expenditure reports will be reviewed by the Director of Homeless Prevention Policy & Planning to assess spending progress and to follow up on any delays in vouchering by subrecipients. Specifically: 1. The Director will review monthly expenditure reports provided by the Department of Family and Support Services (DFSS) Finance team by the 10th of each month for all ESG grant awards. 2. The Homeless Services Division will send notices to agencies with expenditures below contracted expenditure expectations on ESG awards on at least a quarterly basis. The notice will include the current expenditure rate, a reminder on expectations to voucher on a monthly basis within 15 calendar days of the end of the month, and a request for the agency’s plan to improve expenditure rates in line with contract expectations, which are as follows: a. First quarter 25% b. Second quarter 50% c. Third quarter 75% d. Fourth quarter 100% 3. Any unspent ESG funds in the first 12 months of the grant will be reallocated in the second 12 months of the grant to maximize expenditures. Director of Homeless Prevention Policy & Planning Howard at the Department of Family and Support Services will be responsible for ensuring the implementation of this corrective action plan by December 31, 2025. The Voucher Audit and Tracking Unit (VATS) within the Department of Finance, Grant and Project Accounting Division will closely monitor the daily report of accumulated subrecipient (delegate agency) vouchers and prioritize aged vouchers. The goal is to issue payment for aged subrecipient vouchers within 15 calendar days. If the supporting documentation for the vouchers is incomplete or requires additional follow-up information, VATS will hold the vouchers for 2 business days pending the additional supporting documentation/information from the delegate agency. If the supporting documentation is not received within 2 business days, then VATS will reject the vouchers and provide an explanation for the rejection. The delegate agency will be allowed to re-submit the voucher(s) with the required supporting documentation. Chief Voucher Expediters Mendez and Vargas at the Department of Finance, Grant and Project Accounting Division, Voucher Audit and Tracking Systems (VATS) Unit will be responsible for ensuring timely payments to subrecipients and for the implementation of this corrective action plan by July 31, 2025.

Finding 2024-002 – Significant Deficiency Award No.: Assistance List (AL) No. 15.555 and No. 15.704 Federal Grantor: U.S. Department of the Interior, Bureau of Reclamation. AL No. 15.074 Passed-through the Del Puerto Water District Compliance Requirement: Other compliance requirements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was not complete, and expenditures reported on the SEFA were revised during the single audit. Criteria2 CFR Part 200, Subpart F (Uniform Guidance) Section 200.502 states, “The auditee should prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee’s financial statements.” Internal controls over preparation of the SEFA should be in place to ensure accrual basis expenses incurred under each federal program are properly reported as expenses on the SEFA and are properly reported as revenue in the financial statements prior to the start of the single audit. Cause: SEFA was not fully reconciled and finalized until after the single audit began. Effect: Expenses were omitted from the SEFA that should have been included and other expenses were included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of the audit. This delayed the audit testing and major program determination process and could have resulted in the wrong programs being tested as major programs and the single audit not complying with the Uniform Guidance. Context: The District’s Finance Department was not informed of grant amendments that changed the amount of federal funding available. The expenses reported on the SEFA were revised during the single audit as follows. • AL No. 15.555 San Joaquin River Restoration Program Poso Canal Bridge Replacement: The District estimated additional reimbursable costs of $30,335 existed for the Poso Canal Bridge Replacement grant under a potential new $990,000 grant amendment that was to be signed by the USBR in 2025. The amendment was not approved for the Poso Canal Bridge Replacement but the District included the additional reimbursable expenses on the SEFA. The expenses on the SEFA had to be reduced to reflect the eligible federal grant maximum reimbursable expenses under the approved grant agreement at year-end. • AL No. 15.704 Small Surface Water and Groundwater Storage Projects Orestimba Creek Recharge and Recovery Expansion: An additional grant amendment was identified during the single audit that authorized an additional $1,262,928 of federal funding. The District had eligible expenses during the period of performance to fully claim the additional funding, but did not include the expenses on the SEFA. Recommendation: We recommend additional review procedures be implemented to ensure the SEFA is complete and accurate when the single audit begins, which includes working with program managers to identify each grant awarded, obtain current executed grant agreements and amendments, reconciling all expenses incurred under each federal awards down to the invoice, payroll check and lowest level of any other costs claimed, cutting-off each expense at year-end and claiming the reconciled qualifying expenses within 45 days after quarter end. At year-end, programs should be reviewed for cost adjustments, extensions, and other changes that should be reflected on the SEFA when reconciling expenses for the SEFA. Separate general ledger program codes should be used for each grant on the SEFA that summarizes expenses down to the individual invoice level that should be provided to the auditor for the single audit. If overclaimed amounts are identified, the grantor and/or pass-through agency should be contacted to determine whether to return the funds or apply the overclaimed amounts to future claims. Views of Responsible Officials and Planned Corrective Actions: Prepare a summary of grant expenses to reconcile to claims with performance periods included. Staff has prepared an expense summary for Orestimba Creek Recharge and Recovery project and will be updated moving forward. A similar file will be created for each grant received. Estimated Completion Date of Corrective Action: File started for Orestimba Creek.

Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles   Contact: Chad Bender   Title: Controller  Phone Number: 202-785-0072 Estimated Completion Date – ongoing  Corrective Action  The results of the 2024 audit will be shared with appropriate staff and reiterated in training to ensure that adequate attention and guidance is provided on recording expenses within the correct accounting period. PSI delivers in person training to its global finance and program staff and will continue to offer training during 2025 to address such issues.

Internal Controls over Compliance and Compliance with the Period of Performance Compliance Requirement     Contact: Chad Bender  Title: Controller  Phone Number: 202-785-0072  Estimated Completion Date – done  Corrective Action  The results of the 2024 audit will be shared with appropriate staff and reiterated in training to ensure that adequate attention and guidance is provided on the allowability of trailing costs and the unallowability of newly incurred costs. PSI delivers in person training to its global finance and program staff and will continue to offer training during 2025 to address such issues.

We will obtain written documentation of the period of performance for all applicable projects to ensure compliance.

As with Finding 2024-002, employees will now use the time tracking software to log fleet assets with time entries. All submissions will be reviewed and approved by someone other than the submitter or Line Foreman.

We have implemented a time tracking software feature allowing employees to associate fleet assets with their time entries. Entries will be submitted by the employee or Line Foreman, then reviewed and approved by a separate supervisor or manager.

Description: The SEFA schedule included unallowable costs. Planned Corrective ActionL CGS will revise its SEFA preparation procedures to ensure that only allowable and properly reimbursable expenditures on federal awards are reported. Additional training will be scheduled for those responsible staff members to ensure that this error does not happen in the future. Anticipated Completion Date: October 1, 2025 Responsible Person: Keith Peregonov, VP for Finance, Human Resources and Operations

The City will continue to work with all agencies receiving HOPWA to complete their annual CAPER correctly and in a timely manner. This emphasis will be reiterated throughout the awarding process and will be subject to regular status updates to ensure compliance and accuracy. Further, the City will work with HUD to establish a correct methodology in reporting consistency with IDIS.

Unaccompanied Children Program Assistance Listing No. 93.676 Recommendation: We recommend LSI design controls to ensure an adequate review process is in place for all disbursements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review all timesheet approvals are completed monthly. Name(s) of the contact person(s) responsible for corrective action: Roni Knief Planned completion date for corrective action plan: Complete and ongoing

2004-002: Controls over Allowable Costs, etc. St. Jude’s Ranch for Children (the parent entity of HSB Holding Company) acknowledges that weaknesses in the financial oversight process contributed to this finding. Specifically, limited knowledge of Generally Accepted Accounting Principles (GAAP) and federal cost principles by key financial personnel led to misclassification of costs and errors in reimbursement requests in a new type of grant unfamiliar to the accounting team. In response, the organization is restructuring its finance department to ensure that individuals with appropriate qualifications and experience in nonprofit GAAP and federal grant compliance are responsible for reviewing accounting records and reimbursement requests. This includes a new Chief Financial Officer with demonstrated experience in federal grant accounting and compliance and a dedicated grants manager to prepare all reimbursement submissions under the oversight of the CFO.

Identifying Number: 2024-007 Corrective Actions Taken or Planned: Finding: 2024-007 Agency: internal Name of contact person and title: Keith Olson, Central Accounting Manager Anticipated completion date: Effective immediately / June 2025 Agency’s response: Concur: We agree with this finding. This grant has ended as of 6/30/25. In the future if we have fiscal agency services, we will ensure the that the program is being properly reviewed and administered.

Tuerk House, Inc. recognizes the importance of maintaining compliance with federal grant requirements related to allowable costs and documentation standards. The Organization acknowledges the deficiencies identified in the areas of time and effort reporting and supporting documentation for expenditures charged to grant programs. To address this finding, Tuerk House is taking the following corrective actions: ·Implementing a formal time and effort certification process that requires employees to certify actual time worked on federal grant activities on a regular basis, rather than relying on budgeted allocations. ·Developing a standardized cost allocation methodology that aligns with actual grant activity and is supported by verifiable documentation. ·Requiring that all expenditures charged to federal awards be supported by complete and accurate source documentation, including vendor invoices, timesheets, and approvals. ·Establishing a document retention policy consistent with 2 CFR § 200.334 to ensure all supporting records are retained for the required period and readily accessible for audit or review. Training sessions for program and finance staff will be conducted to ensure consistent understanding and application of these updated policies and procedures. Organization Contact Person Responsible for Corrective Action – Joseph Koehler, Director of Finance Anticipated Completion Date – June 30, 2025

FINDING 2024-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Scott Wagner Contact Phone Number: 260-248-3121 Ext 5 swagner@whitleygov.com Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Whitley County Health Department has developed and implemented a policy that will establish and maintain effective internal control for invoices for State and Federal Grants received by the Department. The Director of the department will review all compiled data and sign the invoice along with the employee who compiled the invoice data. In cases where the Director is the employee compiling the data, the office administrator will also sign the invoice to verify the data is correct. Anticipated Completion Date: Immediately

Finding Reference Number: 2024-003 – Period of Performance Federal Program: AL 20.237 High Priority Grant — FMCSA Cluster Name of Contact Person: Tim Adams, CEO Views of Responsible Officials: IRP acknowledges the finding and concurs with the recommendation. Planned Corrective Action: Grant management procedures have been revised to verify that services are received and costs incurred within the authorized period of performance in accordance with 2 CFR § 200.403 before the costs are charged to a federal award. Staff involved in grant management will receive targeted training on 2 CFR requirements related to period-of-performance compliance and allowable cost timing. Anticipated Completion Date: September 30, 2025

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will implement a system of internal controls to ensure that expenses submitted for reimbursement under federal awards, especially personnel costs, are reviewed for compliance with regard to the period of performance requirements.