Corrective Action Plans

The Fiscal Officer will improve tracking and reporting procedures by requesting a clear outline from all funding and liaising parties at the start of all future projects. As well as making sure all reporting and procedures are adhered to by those parties.

Management has registered with Sam.gov and obtained a Unique Entity ID (UEI) for the submission of the single audit report for the fiscal year ended June 30, 2024. The UEI does not expire and is therefore addressed for future single audits.

U.S. Department of Health and Human Services • Material Weakness in Internal Control over Compliance Community Service Block Grant – Assistance Listing No. 93.569 Condition: During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/23/23 - 1/5/24, which the first nine days were prior to the start of the period of performance. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization will strengthen internal controls over the recording of grant-related invoices and payroll expenditures by requiring expenses to be recorded based on the actual date services are incurred rather than invoice date or payroll period end date. Finance staff will be retrained on period-of-performance requirements for federal programs, and a secondary review will be implemented for all federal grant postings to verify proper timing prior to submission for reimbursement or drawdown. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.

Management agrees with the finding and has implemented corrective actions to improve documentation, grant tracking, and compliance processes. Grant transactions are now recorded and tracked within Sage Intacct using appropriate invoice dates and general ledger posting dates to ensure that expenses are recorded within the correct period of performance for each grant. Sage Intacct provides detailed grant reporting capabilities, allowing the organization to generate transaction‐level reports for individual grants. Documentation procedures have also been strengthened. Supporting documentation for expense transactions is attached directly to transactions within Sage Intacct and is also stored in organized files on Porchlight’s internal server to ensure documentation is readily available for review and audit purposes. Procurement approvals and related documentation are retained within Sage Intacct on a transactional level, archived email records, and internal file storage, ensuring that approvals are documented and accessible. The Financial Director is currently responsible for preparing and submitting grant performance reports. Porchlight is also in the process of recruiting a staff Grants Manager to further strengthen grant management, monitoring, and reporting responsibilities. Porchlight maintains a grant reporting calendar and tracking system, which is maintained electronically on the organization's internal server to ensure that all reporting deadlines are monitored and met. Grant documentation is now maintained in centralized and organized compliance files on the internal server, allowing staff and auditors to easily access grant documentation and supporting records. Management will continue to monitor grant compliance processes and documentation procedures to ensure ongoing compliance with funding requirements and reporting obligations. Person(s) Responsible: Halle Pollay Timing for Implementation: In process

Now that Treasury Portal is updated with all obligations the County will utilize Oracle reporting to input all remaining expenditures in the applicable quarterly report.

The Sheriff’s Office has separated from the person who oversaw these grants. New procedures have been implemented, and the Chief Deputy is now involved in overseeing these grants as well.

The Municipal Court Probation Department took corrective action on March 6, 2025 by enacting a grant reporting policy applicable to all grants in which they administer. The Sheriff’s Office has separated from the person who oversaw these grants. New procedures have been implemented, and the Chief Deputy is now involved in overseeing these grants as well.

Finding 2024-007 – Education Stabilization Fund – ESSER III AL No. 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over compliance it was noted that there was an expenditure charged to the Education Stabilization Fund – ESSER III for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Criteria: The Period of Performance for the Education Stabilization Fund – ESSER III was October 4, 2021 through September 30, 2024. Context: During our test of expenditures and review of the general ledger against the Education Stabilization Fund – ESSER III grant as it is related to compliance it was noted that the School paid in full a four year lease from 3/1/23 to 2/28/27 and charged 10/1/23 to 2/28/27 to the Education Stabilization Fund – ESSER III grant in the amount of $190,869 and thus the period from 10/1/24 to 2/28/27 would be outside the period of performance and thus would not be an allowable cost. Unallowable costs for this period was $52,426. Effect: Assabet Valley RTHS was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education. Questioned Costs: Questioned cost charged to the Education Stabilization Fund – ESSER III grant whose service period was beyond the grant end date of September 30, 2024 was in the amount of $52,426. Cause: Grant should have been amended. Identification as a Repeat Finding: 2023-003 Recommendation: We recommend the Assabet Valley RTHS follow procedures to ensure that expenditures charged to the grant is within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Responsible for Corrective Plan: Maria Silva Estimated Completion Date: 2024 Action Taken: Grant has since been corrected and funds where moved to the correct account in our general ledger. Assabet staff is aware that leases cannot be past or before a grants end/start date.

Finding 2024-004 – Special Education Cluster – AL No. 84.027 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the School is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the major program were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the program, the employees tested were for pay periods outside the period of performance and were found to not have time and effort certifications for the pay periods tested. Cause: We did not have a full-time payroll staff member or a grant manager. Context: During our test of payroll transactions charged to the Special Education Cluster it was noted that Payroll transactions were charged to the FY 24 Special Education PL94-142 grant were for services prior to the grant start date of 8/28/23 in the amount of $24,196.32. Additionally, the same payroll transactions were not supported with Time and Effort certifications for payroll charged to the FY 24 Special Education PL94-142. Effect or Potential Effect: Due to the material weakness and noncompliance in internal controls noted above, there is a risk of unallowable expenditures being charged to the federal grant. Identification as a Repeat Finding: This is not a repeat finding. Questioned Costs: Total questioned costs for the payroll charged to the grant that was outside the period of performance and not supported with Time and Effort certifications totaled $24,196.32. Recommendation: The Assabet Valley Regional Technical High School should improve the internal controls over Allowable Costs by ensuring employee’s payroll charged to the federal grant is within the period of performance and supported with Time and Effort certifications. Responsible for Corrective Plan: Sabrina Howley Estimated Completion Date: 11/5/25, Ongoing Action Taken: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Also at the same time we had no trained payroll staff to verify the salaries where paid out of the correct account line. We are double checking that the staff is paid correctly and not before a grant begins or ends. Also all staff will have signed a time and effort sheet for any pay periods they are paid out of grants.

Finding Number: 2024-005 Anticipated Completion Date: March 31, 2026 Responsible Contact Person: Brad McCain, Chief Financial Officer Planned Corrective Action: Management is strengthening controls over tracking, documenting, and reconciling federal grant expenditures to ensure compliance with period of performance requirements. Actions include implementing improved grant-level tracking within the financial system, reconciling general ledger activity to reimbursement invoices and the SEFA on a routine basis, and retaining documentation to support the allowability and timing of costs charged to federal programs. Management will also formalize procedures for payroll reallocations across programs to ensure traceability and compliance with grant requirements. Documentation will be required to be attached to all journal transactions demonstrating the linkage between the underlying payroll records to the correct grant programs.

U.S. Department of Health and Human Services Department of Human Services respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 - June 30, 2024 The findings from the 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 Human Services Low-Income Home Energy Assistance Program – Assistance Listing No. 93.568 Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Explanation of disagreement with audit finding: No disagreement. Action taken in response to finding: The Department has made changes in the Office of Budget and Finance Leadership team and continues to do so at every level. The Department will review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Currently, expenditures are recorded in the State’s Financial Management Information System (FMIS) with program cost accounting codes used to identify the funding source(s) for each activity. The system-generated report summarizes the information and includes the effective date of the activity. In turn, this same report is used to run the cost allocation to properly charge the exact costs to the funding source. Currently information is manually inputted into multiple spreadsheets to prepare the federal reports resulting in the possibility for errors. This significantly impedes the accuracy of the data being reported to federal grants and the provision of supporting documentation. As such, the Department will partner with external consultants to develop a better and more seamless recording structure for grant expenditures to the general ledger. This structure will require quarterly review by the Deputy Cost Allocation Revenue Management Director (CARM), the Cost Allocation Revenue Management Director, and the Deputy Chief Financial Officer. The Department will create a database and document repository to track the submission and reconciliation for federal grant reporting. The document repository will include the FMIS generated report and the cost allocation results table. Upon submission to the federal grant

U.S. Department of Education (USDE) Maryland State Department of Education respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023-June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. Finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Maryland State Department of Education 2024-023 Special Education Cluster– Assistance Listing No. 84.027, 84.173 Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MSDE will review and enhance its Standard Operating Procedures (SOPs) and internal controls to ensure that it charges expenditures (including accounts payable and payroll) to Federal programs that are incurred within an award’s allowable period of performance. Name(s) of the contact person(s) responsible for corrective action: Neeta Gandhi Executive Director Office of Program Fiscal Operations and Local Strategic Finance Jenna Meinl Director Office of Procurement and Contract Management Planned completion date for corrective action plan: June 30, 2025 If the USDE has questions regarding this plan, please call Patricia Ramallosa at 410- 767-0103. Page 2 Approval of Response to the CLA Findings and Recommendations: Document Version Approval Date Approved by Signature 1.0 Mar 29, 2025 Neeta Gandhi, Executive Director-Office of Program Fiscal Operations & Local Strategic Finance Mar 29, 2025 Jenna Meinl, Director-Office of Procurement and Contract Management Mar 29, 2025 Donna Gunning, Assistant Superintendent of Financial Policy, Planning, Operations & Strategy Mar 29, 2025 Shawn Rushing, Assistant Superintendent of Administration Mar 29, 2025 Krishnanda Tallur, Deputy Superintendent of Finance and Operations

Department of Labor (DOL)Financial Statement Preparationinancial Statement Preparation. Unemployment Insurance – Assistance Listing No. 17.225 Recommendation: We recommend the Department implement procedures and internal controls to ensure that it complies with program requirements, that it maintains documentation, and that documentation is readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Recommendation: We recommend the Fund establish procedures to ensure that financial reporting is performed in a timely manner and provide accurate and relevant information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The team that was assembled to work through the audit has also been enlisted to redesign the process and build new tools to create UI Trust Fund financial statements every month. While this is still in development, we plan to have it functioning accurately by May of 2025. Name(s) of the contact person(s) responsible for corrective action: John Fahnbutu. Planned completion date for corrective action plan: 5/30/2025 Recommendation: We recommend the Fund establish procedures to ensure that financial reporting is performed in a timely manner and provide accurate and relevant information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The team that was assembled to work through the audit has also been enlisted to redesign the process and build new tools to create UI Trust Fund financial statements every month. While this is still in development, we plan to have it functioning accurately by May of 2025. Name(s) of the contact person(s) responsible for corrective action: John Fahnbutu. Planned completion date for corrective action plan: 5/30/2025 Maryland Department of Labor- Unemployment Insurance Trust Fund (the Fund) respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023-June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS

1. The Maryland Military Department respectfully submits the following corrective action plan for the year ended June 30, 2024.Projects – Assistance Listing No. 12.401 (1) Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award's allowable period of performance. (2) Explanation of disagreement with audit finding: There is no disagreement with the audit finding. (3) Action taken in response to finding: The Department will carefully exam and allocate expenses to the fiscal year in which they are incurred, ensuring proper period assignment when expenses span multiple fiscal years. This will confirm accurate costs charged to the programs. 2. Audit period: July 1, 2023-June 30, 2024 3. The findings from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. 4. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS: a. Finding 2024-011: National Guard Military Operations and Maintenance (O&M

Finding 2024-002: Significant Deficiency Activities Allowed or Unallowed and Allowable Cost/Cost Principle (Payroll) Responsible Official’s Response and Corrective Action Plan We concur with the finding related to deficiencies in our time tracking Process. Starting in the fourth quarter of fiscal year 2025, a time tracking system using Paychex Time & Attendance was implemented. This system is designed to accurately capture, and record employees’ hours worked by project/grant. Comprehensive training sessions have been conducted for all affected employees to ensure they are proficient in using the new time tracking system. Supervisors have received additional training on monitoring and verifying time entries. Planned Implementation Date of Corrective Action Plan October 2025 Person Responsible for Corrective Action Plan Natésha Johnson, Director of Finance and Administration Dr. Felecia Nave, President and Chief Executive Officer

Finding 2024-003: Reporting - Timely Submission of Financial Reports – Noncompliance and Significant Deficiency in Internal Control over Compliance Name of Contact Person: Courtney Hoiby, Interim Finance Director Corrective Action Plan: The Borough has engaged accounting resources and staff with the appropriate time and expertise to expedite the completion of future financial reports. Completion Date: September 30, 2026

Finding: 2024-002 Material Weakness in Internal Control Over Period of Performance – Health Center Program, WIC Special Supplemental Nutrition Program for Women, Infants, and Children, and Immunization Cooperative Agreements (93.224, 10.557, 93.268) Corrective Action: The District is in the process of developing a comprehensive year-end closing checklist and has already streamlined many of the procedures that caused reconciliation issues. In addition, we will perform spot checks on transactions to ensure that payroll and nonpayroll expenditures are recorded in the proper period. We will also provide additional training to ensure that personnel only record expenditures when confirmation has been received of receipt of goods or services. Proposed Completion Date: February 28, 2026 Name of Contact Person: Tomiko Fisher, Chief Operating Officer

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.