Corrective Action Plans

VIEWS OF RESPONSIBLE OFFICIALS As part of our outreach initiatives, we have partnered with other agencies and organizations while creating events that maximize our resources. On February 12, 2026, the Local Area held a regional youth-centered fair that took place at the Tomás Dones Coliseaum, impacting over 600 individuals, both in school and out of school. Our Local Board, as part of their efforts, also approved the implementation of smaller educational fairs brought to every town focused on their in school and out school individuals and their specific needs and challenges. IMPLEMENTATION DATE June 2027 RESPONSIBLE PERSONS Executive Director Director of Programmatic Services Title I-B Director

Responsible Person(s): Rebecca Ullrich, Associate Director of Early Childhood Policy and Innovation Corrective Action Planned: Mitigating Information: -DOE identified incorrectly coded transactions at the end of SFY2025 and had begun correcting some entries prior to the APA audit. -DOE Finance and Early Childhood Divisions are developing strategies to ensure alignment of project codes with appropriate grant awards each federal fiscal year. These strategies will be in place no later than September 1, 2026. -General ledgers adjustments have been posted for the identified ARP grant transactions. DOE is in the process of returning those ineligible funds to the federal government. All funds were returned on February 5, 2026. Estimated Completion Date: 9/1/2026

Responsible Person(s): Fernanda Crandol, Chief Financial Officer Corrective Action Planned: DARS’ Finance Division will develop agency-specific payroll policies and procedures governing all critical payroll processes, including payroll reconciliations and payroll certifications. Additionally, the Finance Division will ensure that payroll reconciliations are completed each pay period so that payroll transactions are accurate, complete, and properly reviewed. Estimated Completion Date: 5/31/2026

U.S. DEPARTMENT OF EDUCATION 2025-002 Special Education Cluster Grants – ALN’s 84.027 & 84.173 Recommendation: We recommend procedures be implemented 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: We have reviewed the finding and have since implemented controls to ensure that expenditures are charged to a grant only after final approval has been issued in the grant portal. Name(s) of the contact person(s) responsible for corrective action: Aisha Oppong, Executive Director of Business and Support Services Planned completion date for corrective action plan: January 12, 2026.

The Department agrees with the recommendation. The Center for Accounting (CFA) and the Office of Transportation Safety (OTS) have coordinated to implement updated reviews and controls. This implementation involves reviewing current processes to ensure supporting documentation is vetted and grant compliance is verified prior to payment. It also includes assessing the need for increased monitoring to ensure initial program reviews are complete and accurate. This remediation effort was finalized on June 30, 2025, following the September 2024 transaction in question. Additionally, the Department plans to review the remediation plan with all relevant staff again this season. This will ensure that all supporting documentation is thoroughly vetted and that expenditures comply with the applicable award period of performance.

The Colorado Department of Transportation (CDOT) agrees with the recommendation. The Center for Accounting (CFA) and the Office of Transportation Safety (OTS) have coordinated on its implementation. The Department has assessed and updated training for staff responsible for reviewing and approving invoices for Highway Safety Cluster grants, with a specific focus on the period of performance. This training plan will be revisited and reviewed with all staff involved by April 2026.

Views of Responsible Officials and Corrective Action Plan We concur. Management has formed an Academic Calendar Committee for pre-year review, as well as implemented automated short-term date detection in SIS and instituted a secondary review process for all R2T4 calculations.

here is no disagreement with the audit finding. Action taken in response to finding: In fiscal year 2025, Start Early used a payroll system that, after a pay period was locked for processing, would not allow supervisors who missed timecard approvals to go back and approve after the period was locked. As a result, Start Early used a manual, time-consuming process to receive these approvals outside of the payroll system. While all approvals were received via this process, due to the manual nature, not all approvals were received timely. In early fiscal year 2026, Start Early changed to a new payroll system which allows for supervisors to go back to prior periods for their sign offs. Start Early will implement a process to, no less than monthly, remind supervisors that had previously missed their timecard approvals to go back and approve to ensure timeliness. Name(s) of the contact person(s) responsible for corrective action: David Paul, Controller Planned completion date for corrective action plan: The corrective action plan detailed above is being implemented by June 30, 2026.

Corrective Action Plan: The University is committed to ensuring compliance with all federal, institutional, and programregulations. The University continues to enhance its internal controls, policies and procedures toensure the appropriate documentation to support is maintained. Primary Control Enhancements. During the next Annual Performance Report (APR) reporting cycle, the AVP for Student Affairs, TRIO and Well-being as well as the respective TRIO program director will correct the inaccurately reported Project Entry Date and First Date of Postsecondary Enrollment for affected participants. These data elements are editable within the APR system and will be updated to align with official institutional and program records. Supporting Controls and Training. To support ongoing compliance, the Federal TRIO Programs have strengthened internal controls and will continue to conduct annual reviews of policies, procedures, and internal controls to ensure alignment with federal regulations and grant administration best practices. To ensure consistent implementation, monthly staff trainings are conducted using the TRIO General Guidelines. In addition, TRIO staff will continue to participate in local and national professional development opportunities to enhance grant management knowledge and standardize practices related to program administration and federal reporting. To ensure all APR reports are accurate moving forward, all APR reports will be completed prior to the deadline and the TRIO staff along with GSPAR will review for accuracy and completeness. Monitoring and Quality Assurance. To further strengthen compliance efforts, the AVP for Student Affairs, TRIO, and Well-being developed a comprehensive TRIO General Guidelines resource for program personnel. The TRIO General Guidelines will be updated to include new JCSU policies that relate to TRIO program management. Informed by Johnson C. Smith University institutional policies, federal TRIO regulations, and best practices from peer institutions, the guide addresses grant administration, record-keeping, participant eligibility, program services, fiscal management, personnel, and travel. TRIO personnel, in collaboration with the Assistant Vice President (AVP) for Student Affairs, TRIO, and Well-being, will continue to conduct regular reviews of participant files and program records to verify data accuracy and regulatory compliance prior to federal reporting. Sustained Oversight. The university will engage in continuous monitoring and evaluation to assess the effectiveness of these corrective actions, identify opportunities for improvement, and maintain full compliance with all applicable regulatory requirements. Anticipated Completion Date: June 2026

Corrective Action Plan: To address the deficiencies identified in Finding 2025-002, the University has implemented and is continuing to formalize a comprehensive corrective action strategy focused on strengthening disbursement scheduling, improving system integration, institutionalizing reconciliation and quality assurance processes, and enhancing cross-functional oversight of COD reporting. Primary Control Enhancements. A standardized disbursement and reporting calendar has been established, and system integration between Ellucian Colleague and Jenzabar has been strengthened to improve consistency of cost-of-attendance and disbursement data transmitted to COD. For the 2025–2026 academic year, the Office of Financial Aid and the Office of Student Accounts are disbursing Title IV aid on the second and fourth Tuesday of each month. This schedule has been jointly approved and will continue to be followed by both departments to ensure consistency between disbursement activity and COD reporting. Supporting Controls and Training. Staff participate in targeted training related to COD reporting and cash management through NASFAA and FSA to reinforce knowledge of reporting timelines and requirements. Monitoring and Quality Assurance. A formal financial aid compliance calendar has been developed and institutionalized, outlining required quality assurance (QA) reviews by month, identifying responsible departments, and requiring documented supervisory sign-off. Reviews of COD reporting timelines are conducted twice per semester, and any discrepancies identified are documented, reviewed, and resolved in a timely manner. A systematic monthly reconciliation process has been instituted and is maintained involving the Office of Financial Aid, the Office of Student Accounts, and Budgets & Grants Accounting to ensure consistency across internal systems and COD reporting. Sustained Oversight. Any discrepancies identified through reconciliation are documented, communicated to relevant departments, and resolved, with formal supervisory sign-off required from the Assistant Director of Financial Aid and the Director of Budgets & Grants Accounting. In addition, Financial Aid maintains standing bi-weekly coordination meetings with Student Accounts and Business Office staff to support ongoing alignment related to Title IV disbursement activity and COD reporting timelines. Anticipated Completion Date: June 2026

Contact Person(s): Sandy Fabre, CFO Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement Corrective action planned: Management will complete a two-step review process to ensure expenses are being validated correctly. Additionally, a selective self-audit program will be developed to verify that recordkeeping is complete and effective. Anticipated completion date: 05/01/2026

Condition: During testing of the enrollment reporting, we identified the following errors: 􀁸 The change in status was not reported at the program level. 􀁸 The program begin date reported to NSLDS does not match the program begin date per the college’s records. Recommendation: The College should evaluate their procedures and policies related to reporting status changes and program begin dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have researched the issue and found that it goes back to the June 2022 purging of the archive file within our student information system in order to get the NSC reports to pull from the system. We no longer purge the archive file, so these issues will only happen on some older records where students return to the college. Name(s) of the contact person(s) responsible for corrective action: Katrina Dumont, Institutional Effectiveness Planned completion date for corrective action plan: We will monitor the Spring 2026 NSC enrollment files to make sure the issue is not getting worse.

Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the reporting errors identified in certain student origination records submitted to the Common Origination and Disbursement (COD) System, specifically related to cost of attendance and academic end date data elements. To address this finding, the College will enhance internal controls and oversight over federal aid reporting by implementing the following corrective actions: • Establish a documented secondary review process for all origination records prior to submission to COD, with verification of key data elements including cost of attendance, academic start and end dates, enrollment status, and award amounts. • Implement a standardized review checklist to ensure accuracy and completeness of required data fields. • Strengthen reconciliation procedures between the student information system and COD to identify and resolve discrepancies timely. • Conduct periodic internal quality assurance reviews of origination and disbursement records. • Provide additional staff training on federal reporting requirements. Anticipated Completion Date: This process has already been implemented.

Noncompliance/Material Weakness in Internal Control over Compliance: • Provide grants management training to all financial staff and management, covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. • Develop and implement policies and procedures that ensure: 1) all staff are aware of the period of performance for each federal award; 2) the financial management records and systems include the ability to monitor and track the status of each federal award throughout its period of performance, especially for one-time funding awards. • Return H8F funds, including interest, to the Federal grantor agency.

Views from Responsible Officials and Corrective Action Plan BCFS Health and Human Services For the Year Ended August 31, 2025 Finding Number: 2025‑001 and 2025-002Federal Program: Crime Victim Assistance – AL 16.575 (Common Thread – Texas) Pass‑Through Entity: Texas Office of the Governor Award Number: 3853406 Questioned Costs: $853,982 Responsible Person: Rosa Baez, President BCFS Health and Human Services Views of Responsible Officials: Management concurs with the finding. BCFS Health and Human Services’ (BCFS HHS) in-kind match plan includes the use of exempt personnel performing after-hours "on-call" volunteer duties, such as answering phones or undertaking responsibilities outside their standard work roles. BCFS HHS did not meet the in-kind match requirements, as the former Program Executive Director deviated from the in-kind match plan, as approved by the funder. The former Program Executive Director did so by hiring full-time personnel to perform the same duties as the on-call volunteers and including them as part of the in-kind match. In 2022, during the COVID pandemic, the funder waived match requirements; during this period, the prior Program Executive Director hired full-time overnight on-call personnel, in response to increased call volume driven by restrictions on face-to-face services due to concerns of exposure. The match waiver was discontinued with the grant awarded for October 2024 through September 2025, and BCFS HHS was required to meet their match obligations. The former Program Executive Director failed to reassign the On-Call workers resulting in a significant deviation from the approved match plan and contributed to the noncompliance of in-kind match requirements. Immediately upon the issuance of the monitoring report regarding match requirements, BCFS HHS’ President has been actively working with Office of the Governor (OOG) to rectify the match requirements per the grant. Management has recorded an accrual for the estimated adjustment and has implemented the corrective action plan outlined below. Page 2 of 3 Corrective Action Plan Upon receiving the preliminary monitoring report from the OOG, management promptly initiated an internal review with the OOG and began collaborating with OOG to address and resolve the findings identified. Effective immediately, BCFS HHS has established new protocols to ensure compliance with match requirements for the Common Thread Texas program. BCFS HHS will undertake the following corrective actions: 1. Revised In-Kind Volunteer Hotline Process A protocol has been implemented to manage the volunteer hotline for the Common Thread Program during after-hour operations. The hotline provides callers with program information, resources, referrals, and transfers calls as appropriate, including crisis response or intake services. The volunteer hotline is managed by volunteers that include exempt employees (working outside their regular duties), interns, and other approved community volunteers. Volunteers must complete training prior to being scheduled. The protocol guidelines include: •A designated volunteer timesheet. •A signed attestation certifying that hours listed are an accurate record ofvolunteer service. •Confirmation that the volunteer work is not required by their employment andis different and separate from their regular job duties. These measures provide robust supporting documentation and ensure that match activities are voluntary, allowable, and compliant. The Volunteer Hotline Protocol was reviewed and approved by the Office of the Governor (Public Safety Office and Office of Compliance and Monitoring). Target completion: Completed January 2026 2. Strengthen Match Documentation Processes Volunteer Attestation and Timesheet- Volunteers are required to sign a timesheet and an attestation affirming that the recorded hours accurately reflect their service with the Common Thread Volunteer Hotline. Additionally, if applicable, volunteers must confirm that this service is not mandated by their employment and is distinct from their regular job responsibilities. Monthly Match Meetings: These meetings will review the reported match activities against the approved match plan. Additionally, the meetings provide an opportunity to evaluate current needs and trends, and to ensure match obligations are met. Page 3 of 3 Target completion: Completed January 2026. 3. Correct and Reclassify Previously Reported Match BCFS HHS excluded the disallowed match activities and included permissible methods such as unrecovered indirect costs, reductions in billed expenditures, including personnel and training—and additional adjustments approved by OOG. All necessary changes are incorporated in the final Financial Status Report (FSR) submitted on January 29, 2026. Target completion: Completed. 4. Staff Training and Ongoing Compliance Monitoring BCFS HHS will provide Common Thread leadership training on uniform guidance match requirements, OOG-specific guidance, and the Volunteer Hotline Protocols. Weekly Audits- The BCFS HHS Director of Support Services, or designee, will conduct weekly audits to ensure protocol adherence. This will encompass a review of the hotline volunteers’ timesheets, and schedules. Results will be discussed in the monthly match meetings. Use of U.S. Bureau of Labor Statistics wage data- All volunteer and intern hours are valued using OOG‑approved labor categories. Target completion: Training will be completed by February 28, 2026; monitoring process will be implemented February 1, 2026. Sincerely, Rosa Baez, President BCFS Health and Human Services

CORRECTIVE ACTION: Management is in agreement with the auditor’s recommendations and has already implemented procedures to correct the issue. The prior executive director’s contract was not renewed and a new executive director has been hired. If there are questions regarding this corrective action plan, please contact Ms. Betsy Soto, Executive Director at (860) 379-4573.

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 Significant Deficiency and Nonmaterial Noncompliance – Child Support Non-Cooperation Finding 2025-008 Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each sanction for noncooperation. Condition: a) There was one (1) instance out of two (2) sanctions tested where the required form to be sent was dated after the sanction start date. b) There was one (1) instance out of two (2) sanctions tested where the sanction was not properly documented. Questioned Costs: None of the nonmaterial noncompliance items resulted in questioned costs. Effect: When required sanction notifications are not issued prior to the sanction start date and sanctions are not properly documented, there is an increased risk that clients may not be properly informed of program actions and that the County may not comply with program requirements. Cause: The County did not have adequate procedures in place to ensure that required sanction notifications were issued prior to the sanction start date and that all sanctions were properly documented in accordance with program requirements. Recommendation: The County should implement procedures to ensure all required sanction notifications are issued prior to the sanction start date and that sanctions are properly documented in accordance with program requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this, which is further discussed in the Corrective Action Plan. Corrective Action Plan: Performance Improvement Strategy: Collaborate with Child Support Services to improve understanding of their processes and ensure accurate case handling. Responsible Individuals: Sarah Carter, Tatyenne Rone, Karl Parisien, Denize Cuff (Sr. Quality and Training Specialist), Danisa Concepcion (Quality and Training Supervisor), Staphon Snelling (Training and Development Manager), Scott Fritz (Social Services Manager), Program Supervisors Training: Non-Cooperation Sanction Training Anticipated Completion Date: To be completed quarterly. Responsible Individuals: Sarah Carter, Tatyenne Rone, Karl Parisien, Denize Cuff (Sr. Quality and Training Specialist). Danisa Concepcion (Quality and Training Supervisor), Staphon Snelling (Training and Development) Anticipated Completion Date: Completed by January 2026.

Audit Finding: The Authority did not have sufficient internal controls to ensure that payroll expenditures submitted to FEMA were incurred within the applicable period of performance prior to submission of the project worksheet. Recommendation: The Authority’s policy and procedures should be designed to strengthen the internal controls over the review of the submissions to ensure accurate reporting as required by the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 1. Enhanced Review of Period of Performance (POP): The Authority will implement a formal verification step requiring the Finance Department to confirm that all costs included in FEMA project worksheets were incurred within the approved period of performance prior to submission. This verification will specifically address payroll costs that span multiple pay periods. 2. Payroll Cost Allocation Controls: Payroll expenditures that cross fiscal periods or project periods of performance will be allocated based on actual days worked within the applicable period. Payroll reports will be reviewed to ensure that only eligible dates are included in each FEMA project. 3. Secondary Review: The Authority will require a secondary review by a finance staff member not involved in the initial preparation of the FEMA project worksheet to ensure accuracy, completeness, and compliance with FEMA eligibility requirements. 4. Correction of Identified Error: Management has corrected the duplicated payroll costs of $104,434 by removing them from the project ending June 30, 2022 and ensuring they are only reported in the project beginning July 1, 2022. Total FEMA expenditures reported on the Schedule of Expenditures of Federal Awards were adjusted accordingly. In addition, VCUHSA has voluntarily prepared a letter to VDEM to alert them of the identified issue and request assistance on next steps to return the funds that were received in error. The letter will be followed up by an email. The Finance team has also notified the CFO of both the findings of the audit and the related corrective actions. Name(s) of the contact person(s) responsible for corrective action: Min Cummings, VP of Finance and Accounting, 804-827-0545 Planned completion date for corrective action plan: Notification of error to be sent to VDEM within 60 days of audit completion. All other planned actions to be implemented immediately for any future costs and expenditures.

--Corrective Action Plan: Management has prepared a written procedure for the process used to bill payroll and related costs to the federal award programs. This process will be followed in the future to ensure this same mistake is not made. Once it was brought to management’s attention, they adjusted their process to get back “on track”, such that the correct two-week period is being billed each time and none are being repeated. Further, management will implement a more robust review of this process in case similar errors still exist. --Person Responsible: Phoebe Benjamin, Associate Finance Director --Date Implemented: 1/1/2026

Planned Corrective Action: The district will implement controls for monitoring reporting grant requirements and grant expenditures to ensure compliance with reporting and period of performance requirements for federal grants. Anticipated Completion Date: 6/30/26 Responsible Contact Person: Hiwot Abraha

12/7/2026 Cognizant or Oversight Agency for Audit, Codman Academy Charter Public School and Affiliate (the School) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm : AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: July I, 2024 - June 30, 2025 The finding from the June 20, 2025 Schedule of Findings and Questioned Costs is discussed below. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2025-001 Required Payroll Forms Recommendation: AAFCPAs recommends the School implement a standardized checklist and conduct periodic internal reviews of onboarding documentation to ensure all required forms are properly completed and retained in accordance with Federal regulations. Action Taken: As of January, 2026 the staff member responsible for staff on boarding and payroll processing is no longer employed at the School. Codman, with a new staff person in charge of these tasks has instituted a standardized checklist for on boarding, has performed a backward looking audit of employee files and will conduct internal periodic reviews for completeness and accuracy. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please tell Derrick Cielsa, Executive Direct as 617-287-0770 Sincerely yours, Derrick Ciesla Excutive Director

Finding 2025 – 002- Allowable Costs & Period of Performance (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. To strengthen policies and procedures surrounding grant disbursements and ensure expenses are properly approved and allowable under the specific grant budget, the Fiscal Service Office along with the Human Resources Department will implement a process to properly document, review, and approve all allowable grant pay rates and salaries.

Material Weakness Item 2025-003 - Period of Performance - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8/-ICS46163-03-01 During our audit, we noted that LBUCC drew down $190,688 of federal grant funds under the Section 330 program for the budget period beginning June 1, 2024 to reimburse salary expenses incurred in May 2024. Recommendation: We recommend that LBUCC implement procedures to ensure that all drawdowns are supported by expenses incurred strictly within the grant's approved period of performance and train staff on grant compliance requirements. Action Taken: A change in the process to draw down funds has been implemented to determine that the funds were incurred in the proper funding period rather than the period it was paid. Effectivity Date: Process change was implemented 12/1/2025.

State Agency: State Education Department Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Maria Stamoulis Title: Audit Manager Telephone: (518) 473-2810 E-mail Address: Maria.Stamoulis@nysed.gov Audit Report Reference: 2025-003 Anticipated Completion Date: 12/31/2026 Corrective Action Planned: New York State Education Department (SED) has updated the payment procedures to require additional review prior to processing and will provide training to staff involved in preparing or processing payment forms to understand the appropriate application of cost centers to align with the Period of Performance for Federal awards, including the Vocational Rehabilitation grant. Additional controls planned include the alignment of purchase orders with the Federal fiscal year to ensure cost centers are appropriately assigned to services.

State Agency: State Education Department Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Maria Stamoulis Title: Auditor 3 Telephone: (518) 473-2810 E-mail Address: Maria.Stamoulis@nysed.gov Audit Report Reference: 2025-002 Anticipated Completion Date: 12/31/2026 Corrective Action Planned: New York State Education Department (SED) ACCES-VR began doing quarterly data validation reviews prior to RSA 911 submission in early 2025. ACCES-VR is also working on updating the RSA 911 Reporting Data Validation policies and procedures to address this request from the RSA monitoring visit in 2024.