Corrective Action Plans

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a rigorous compliance framework to ensure all grant funds are timely obligated and expended in accordance with 45 CFR §96.14. We will achieve this by integrating strict monitoring protocols into our operations, ensuring that the risk of Non-Compliance is identified and escalated to the federal agency in writing as required. Action Steps: 1. Protocol Development & Review – Develop new "Period of Performance Management Protocols" and conduct a comprehensive review of all existing financial reporting procedures to ensure alignment with 45 CFR §96.14. 2. Implement a Warning System – that alerts management 90 days before the end of the obligation period if funds remain unobligated, triggering an immediate internal review. 3. Automated ERP Obligation Tracking – Configure the new Government ERP system to track obligation deadlines at the grant and activity level, providing real-time visibility into the availability of funds and pending commitments. 4. Communication & Escalation SOP – Establish a formal SOP requiring that any anticipated non-compliance be communicated to the federal awarding agency in writing at least 60 days prior to the expiration of the obligation period, with all approvals archived centrally. 5. Segregation of Duties 6. Staff Training – Conduct mandatory training for all staff responsible for grant management on the Period of Performance requirements, including the legal consequences of unauthorized report amendments. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Nesvia Fontanez Marín Principal Accountant Federal Reports Rodolfo Ayala Muñoz Cash Management

FINDING 2024-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Burzynski Thaddeus Contact Phone Number and Email Address: 219-755-3200, burzytx@lakecountyin.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The County will develop and implement a proper system of internal controls and segregation of duties. This will ensure accuracy and correctness of all quarterly P & E Reports in the future. Anticipated Completion Date: December 2026

Mansfield Foundation Corrective Action Plan Summary Reviewed and Approved: Frank Jannuzi, Sara Harriger, Lisa Hosegood May 28, 2026 Action 1: Relevant to single audit finding 2024-001: Use external controller services support to ensure timely submission of Required Federal Financial Reports. Planned Implementation An external accounting/controller firm has been engaged to provide oversight and ensure that all bookkeeping and reporting tasks are completed on time. They report to the Vice President and President and work directly with the Director of Finance. They will provide weekly and monthly monitoring of financial procedures, regular financial reporting to management, and track grant reporting deadlines. This arrangement will continue for the foreseeable future. Responsible Party Outsourced CFO; Director of Finance Target Completion Ongoing Action 2: Relevant to single audit finding 2024-001: Apply an internal tracking system to ensure timely submission of Required Federal Financial Reports. Planned Implementation A reporting calendar will be established and maintained by the Director of Programs, with deadlines flagged 30 days in advance. Automated reminders will be circulated to responsible staff one month, two weeks, and one week prior to each filing deadline Responsible Party Outsourced CFO; Director of Finance, Director of Programs Target Completion Implement within three months Action 3: Relevant to single audit finding 2024-001: Implement a management review system to ensure timely submission of Required Federal Financial Reports. Planned Implementation The Vice President will verify completion of each report prior to submission. The President will receive confirmation that the report was submitted on or before the required deadline. Responsible Party President, Vice President, Director of Finance Target Completion Implement within three months Action 4: Relevant to single audit finding 2024-001: Implement a regular briefing to leadership to ensure compliance and monitor timely submission of Required Federal Financial Reports. Planned Implementation Twice annually, the Director of Finance will brief leadership on the status of required reports and confirm compliance. Responsible Party Outsourced CFO, Director of Finance Target Completion Implement within three months Action 5: Relevant to single audit finding 2024-001: Assign clear lines of responsibility to ensure timely submission of Required Federal Financial Reports. Planned Implementation The President and Vice President are ultimately accountable for submission of timely reports and will provide adequate resources and support, monitor regular bookkeeping and grant deadlines, and hold staff accountable for preparation of the reports. The Directors of Programs and of Finance will be the primary lead for monitoring deadlines, gathering information, and effectuating the timely preparation and submission of all financial reports. Responsible Party President, Vice President, Director of Programs, Director of Finance Target Completion Ongoing Action 6: Develop and formally document a standardized month‑end and year‑end close checklist, including required reconciliations, review sign‑offs, and reporting deadlines. Planned Implementation Management will implement a formal month‑end and year‑end close checklist that outlines key close activities, required account reconciliations, documentation standards, review and approval sign‑offs, and established reporting timelines. The checklist will clearly assign responsibility for each task to designated finance personnel to ensure accountability and consistency in execution. Responsible Party Outsourced CFO; Director of Finance Target Completion Implement for the next fiscal quarter close Action 7: Establish documented review procedures for key balance sheet accounts, including independent review of reconciliations and journal entries. Planned Implementation Management will implement formal, documented review procedures requiring monthly balance sheet reconciliations for all accounts, prepared on a timely basis and reviewed by appropriate Finance lead. In addition, management will require review and approval of journal entries associated with period‑end close activities to strengthen oversight and reduce the risk of error or misclassification. These review procedures will be integrated into the month‑end and year‑end close process and retained as part of the Foundation’s accounting records. Responsible Party Outsourced CFO; Director of Finance Target Completion Ongoing Action 8: Implement a formal budget‑to‑actual review process with documented explanations and periodic reporting to the Board of Directors Planned Implementation Management will establish a standardized budget‑to‑actual review process to be performed on a recurring Quarterly basis. This process will include preparation of variance analyses with documented explanations for significant differences between actual results and the approved budget. These reviews will be completed timely and used as a monitoring control to identify unexpected trends or potential misstatements requiring further review. Responsible Party Outsourced CFO; Director of Finance, Director of Programs Target Completion Implement within three months Action 9: Implement a structured system for tracking grants and contributions, including documentation of donor intent, restriction classification, and release schedules Planned Implementation Management will implement formal grant and contribution tracking procedures designed to document donor and grantor restrictions at the time of receipt and to monitor those restrictions throughout the life of the award. These procedures will support appropriate classification of net assets with and without donor restrictions and timely recognition of releases from restriction in accordance with donor intent and applicable GAAP rules. Responsible Party Outsourced CFO; Director of Finance Target Completion Implement within three months Action 10: Establish procedures for timely identification and release of donor‑restricted funds in accordance with donor and grantor requirements Planned Implementation Management will implement documented procedures to ensure that donor‑imposed restrictions and grantor requirements are identified at the time of receipt and tracked throughout the life of the contribution or grant. These procedures will include quarterly review of restricted net asset balances to ensure that restrictions are released in a timely manner when the applicable purpose or time requirements are satisfied. Responsible Party Outsourced CFO; Director of Finance Target Completion Ongoing Action 11: Strengthen technical accounting review through training, cross‑training, and use of qualified external resources as needed. Planned Implementation To address this recommendation, management has engaged an outsourced accounting team to provide technical accounting support and to assist with the development and documentation of formal finance policies and standard operating procedures (SOPs). These SOPs and policies will establish consistent accounting practices, clarify review and approval responsibilities, and provide appropriate documentation to support accounting judgments and GAAP‑compliant financial reporting. In addition, management will implement targeted training and cross‑training within the finance function to strengthen internal technical accounting knowledge and reduce reliance on single individuals for critical accounting functions. Periodic technical review by qualified internal and external personnel will be incorporated into the close and review process to support accurate application of accounting standards. Responsible Party Outsourced CFO; Director of Finance Target Completion Ongoing Action 12: Improve segregation of duties and compensating controls where full segregation is not feasible Planned Implementation To strengthen segregation of duties within the finance function, management has hired a full‑time Finance Associate, which will allow for clearer separation of transaction processing, review, and reconciliation responsibilities. In addition, management has engaged a part‑time, outsourced accounting firm to provide supplemental support, oversight, and review of selected accounting activities. Responsible Party Vice President, Outsourced CFO; Director of Finance, Finance Assistant Target Completion Within six months Action 13: Continued segregation of duties Planned Implementation Where limited staffing continues to constrain full segregation, management will implement and document compensating controls, including review of reconciliations, journal entries, and financial reports by qualified personnel. Management believes these actions will enhance the design and operating effectiveness of internal controls, reduce reliance on single‑person processes, and support more accurate and reliable financial reporting in accordance with GAAP. Responsible Party Vice President, Outsourced CFO; Director of Finance, Finance Assistant Target Completion Within six months

Controls Over Federal Programs Management acknowledges that documented control procedures were absent across all selections tested for federal expenditures, and that payroll allocations were not consistently reviewed or supported throughout the year. The Organization will require that all invoices coded to federal award programs include documentation of review, proper allocation rationale, and management approval before payment is processed. Payroll allocations will be updated in both the payroll and accounting systems on a regular basis, supported by actual time records or documented time studies rather than year-end estimates. This process has already taken place in late 2025 and the CFO and Controller will oversee the process.

Period of Performance Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: We recommend that the Organization design, implement, monitor and maintain evidence over internal controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will assign responsibility for maintaining source documentation to a specific individual or team and develop a system for organizing and storing source documentation, such as a centralized electronic database. Monitoring and testing procedures will be implemented to ensure that source documentation is being maintained and is readily accessible. Lastly, there will be regular reviews and updates to the system for organizing and storing source documentation as needed to ensure ongoing effectiveness. Name of the contact person responsible for corrective action: Lyn Elliot, CEO Planned completion date for corrective action plan: 7/1/2026

CONTACT PERSON: A. Nicole Verner, Finance Director, averner@cityoflakecity.org CORRECTIVE ACTION: The City acknowledges the finding related to expenditures not being approved prior to disbursement for federally funded programs. Management recognizes that staffing changes contributed to insufficient oversight and monitoring of grant-related expenditures. To address this finding, the City is implementing strengthened internal controls over grant expenditures to ensure that all costs are properly reviewed and approved prior to payment. The City will require that all expenditures charged to grant funds, including Coronavirus State and Local Fiscal Recovery Funds, receive documented pre-approval from appropriate management personnel prior to disbursement. This approval will confirm that the expenditure is allowable, properly classified, and consistent with the purpose of the grant. A standardized grant expenditure approval form or checklist will be implemented to document the review process. This documentation will be maintained with the supporting records for each transaction. The City will establish a segregation of duties within the grant management process so that no single individual is responsible for initiating, approving, and processing grant-related disbursements. In addition, a secondary review process will be implemented for all grant expenditures to ensure compliance with federal requirements and City policies. The City will also maintain detailed records of all grant expenditures and perform periodic internal reviews to ensure compliance with applicable guidelines, even when funds are used under the revenue loss provision. Training will be provided to staff responsible for grant administration and financial processing to ensure a clear understanding of allowable costs, approval requirements, and documentation standards. Management will monitor compliance with these procedures on an ongoing basis and take corrective action if any deficiencies are identified. PROPOSED COMPLETION DATE: June 30, 2027

Planned Corrective Action: The Division will implement their control of ensuring that they only charge allowable costs incurred during the approved budget period of a federal award’s period of performance or will obtain authorization from the grantor for any costs incurred before the grant's approved budget period. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller

Finding No.: 2024-051 Period of Performance Responding Agency: Guam Homeland Security (GHS) Responsible Personnel: Esther Aguigui, Director GHS will create a Standard Operating Procedure (SOP) to establish internal policies and procedures over compliance with applicable period of Performance requirements, as well as retention of all grant agreements. GHS will also identify department personnel responsible.

Finding No.: 2024-046 Period of Performance Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director DPHSS disagrees with this finding and provided documentation of grantor approval to use the FY 2024 award to pay prior year obligations. The enclosed communication from Linda Gee, CMS, dated July 1, 2021, provides more information. 45 CFR 95.7 (https://www.ecfr.gov/cgi-bin/text-idx?node=pt45.1.95&rgn=div5#se45.1.95_17) provides that a state Medicaid agency (i.e. Guam Medicaid Agency) has up to two years to file for a claim that it made. DPHSS welcomes the opportunity to discuss and collaboratively identify the relevant information and guidance during an entrance conference for each year’s audit.

Finding No.: 2024-038 Period of Performance Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director DPHSS ELC Program disagrees with the findings. Condition 1: The questioned labor costs of $16,668 align with payment of Core funded staff during that approved budget period for BP01. The PPE coincides with two draws for the ending and beginning of those fiscal years. Supporting documents were submitted twice, once on February 9, 2026, and February 20, 2026, including the Notice of Award (NOA) for this grant with issue date of July 9, 2024. Condition 2: The question of compliance with period of performance was justified through supporting documentations as reflected in the NOAs and extensions of NOAs which were provided twice February 9, 20206 and February 23, 2026. Program also noted that core funds have expanded authority to be utilized in subsequent budget periods throughout the 5-year cycle of the Cooperative Agreement. Upon auditor’s review, a correspondence email noted that the documents were received and findings were removed for all but on expense. Although all supporting NOAs were submitted for every expenditure amount, a follow up email with the last NOA for 6NU50CK000561-05-00 was provided again as an attachment.

Finding No.: 2024-035 Program Income Responding Agency: Guam Environmental Protection Agency (GEPA) Responsible Personnel: Michelle Lastimoza, Director Guam EPA has implemented processes relevant to the monitoring and reconciliation of program income. As part of our Correction Action for the FY2023 audit, which is a repeat finding in FY2024, Guam EPA is attaching a sample report of all program income collected through the Transaction Processing System (TPS) to include external payments received by DOA. Also, variances not captured by this report, consisting of payments/transactions submitted directly to DOA via electronic method of payments, are being reconciled by our staff and DOA.

Finding No.: 2024-034 Period of Performance Responding Agency: Guam Environmental Protection Agency (GEPA) Responsible Personnel: Michelle Lastimoza, Director Request to DOA will require immediate collaboration between Guam EPA and DOA to gather, reconcile, and provide all supporting documentation to support compliance with the period of performance in question.

Finding No.: 2024-024 Reporting Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency is reviewing its federal grants management to ensure robust handover and succession plans are in place of future programs.

Finding No.: 2024-020 Reporting Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency disagrees with this finding. Please refer to a letter dated March 31, 2026, regarding Reports on Compliance September 30, 2024

Finding No.: 2024-011 Period of Performance Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director (DPHSS) The DPHSS WIC Program disagrees with the findings. All supporting documents related to the findings were provided promptly on March 3,2026 when request was received on February 26,2026. In accordance with WIC FY 2024 Closeout Guidance and the requirements under 2 CFR 200.344, the WIC Program is allowed 90 days after the end of the period of performance to submit all final financial reports, as well as 90 days to liquidate all obligations incurred during the period of performance. For FY 2024, the closeout timeline required that all obligations be liquidated no later than January 31, 2025. The program adhered to these federal requirements. All obligations were liquidated prior to the close of the fiscal year grant, and obligations were reported in the fiscal year in which they occurred, consistent with 7 CFR 246.17. Furthermore, the final closeout report was submitted within 120 days after the end of the fiscal year, fully complying with WIC closeout procedures. Based on the timely submission of all supporting documentation and adherence to federal closeout regulations, the DPHSS WIC Program maintains that the questioned costs were appropriately obligated, liquidated, and reported.

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. Response: The Department concurs with the finding and the need to enhance procedures and strengthen controls over processing expenditures to ensure compliance with the awards’ period of performance. Corrective Action: The program will enhance procedures and strengthen controls to ensure expenditures presented for payment are allowable and within the awards’ period of performance. Program leadership will develop and document an internal expenditure review process to ensure a complete review of presented expenditures for payment is completed prior to submission to the agency’s Accounts Payable Department for processing. Name of contact person responsible for the corrective action: Jameshyia Ballard Anticipated date for completion of corrective action: September 30, 2026

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-012 1. Finding Summary The auditor determined that the institution disbursed Pell Grant funds more than 10 days prior to the first day of classes, in vio]ation of federal Title IV disbursement timing requirements. As a result, the institution could not demonstrate compliance with applicable federal regulations governing the timing of Pell Grant disbursements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that Pell Grant funds were disbursed earlier than permitted under federal Title IV disbursement timing requirements due to a miscalculation of the days. 3. Root Cause Analysis The root cause of this finding resulted from by inaccurate or prematurely scheduled disbursement dates, limited coordination between the Financial Aid and Business Offices on the approved disbursement calendar, and insufficient controls to ensure Pell Grant funds were released in accordance with federal timing requirements. 4. Corrective Action(s) Management will implement a standardized calendar of disbursement dates annually based on the academic calendar. Description of Corrective Actions Management will prepare an annual disbursement calendar based on the academic calendar, which will be reviewed by both the Business Office and Office of Financial Aid to ensure compliance to federal Title IV disbursement timing requirements. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of early federal disbursements by strengthening oversight, implementing a disbursement calendar, and reinforcing staff understanding of federal timing requirements. 6. Responsible Party • Office/Department: Business Office • Title of Responsible Official: Senior Accountant • Name (optional): ___ _________ _ 7. Implementation Timeline • Corrective action implemented: (Yes) No • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) (Fully implemented) Partially implemented Not yet implemented Evidence of Implementation Academic Year 2026-2027 Disbursement Calendar. 9. Monitoring and Sustainability The University will continue to prepare a disbursement calendar annually before any new year disbursements are made.

Finding 2024-017 Significant Deficiency in Internal Control – Earmarking Condition: Under the Coronavirus State & Local Fiscal Recovery Funds (21.027), the 2022 Final Rule, recipients can elect a one-time “standard allowance” of $10 million (not to exceed the recipient’s award amount) to spend on the “provision of government services” during the period of performance. Alternatively, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the 2022 Final Rule to determine the amount of SLFRF funds that can be used for the “provision of government services.” The City of Danbury elected to claim the standard allowance even though their initial award from Treasury exceeded that. Contact Person: Kara Prunty, Assistant Director of Finance – Grants, City of Danbury Corrective Actions Completed: We agree with the finding. The City implemented a controlled SLFRF project classification and support process by documenting approval of each project’s expenditure category/allowability with performing periodic reconciliations tying the tracker to the general ledger and reported totals, with approvals and reconciliations retained in the SLFRF grant file.

Management will implement procedures to identify and properly allocate prepaid and multi-period expenses across the applicable benefit periods. Prepaid expenses will be recorded and amortized over the service period in accordance with GAAP and federal cost principles.

The Academy learned of deficiencies pertaining to allowable indirect costs during the 2024 calendar year, at which time, after consultation with the funder, changes were made to the policies for calculation of indirect costs for the grant.

H. Period of Performance Timely Payment of Financial Obligations Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: As the grant period has ended, we recommend that the Corporation works with the funding agency to remedy the period of performance noncompliance. In addition, we recommend that the Corporation reassess the design of its period of performance controls to identify where enhancement or additional controls are needed over liquidation of financial obligations subsequent to the end of a grant award. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue to educate all grant managers on (1) the reporting capabilities within the system that can be utilized in the execution of monitoring payment status on individual invoices that have been submitted to granting agencies for reimbursement, and (2) the requirement to use their grant specific general ledger coding when orders are placed with vendors that are set up under the Corporation’s group purchasing process. For the specific vendor noted in Finding 2024-003, a grant number input field has been added to the group purchasing orders to allow for enhanced tracking and review of expenditures associated with grants and the monitoring of payment of those expenditures. The use of the accurate grant general ledger coding by grant managers when orders are placed will reduce the time between placement of order and payment of the invoice. The grant manager responsible for oversight of BHSB grants will work with BHSB to remedy the period of performance noncompliance noted in Finding 2024-003. Anticipated Completion Date – June 30, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

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