Corrective Action Plans

Research and Development Cluster— Assistance Listing Nos. Various Recommendation: We recommend that the University review its procedures around review and approval of R&D expenditures to ensure that only valid expenditures are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University does have existing internal control processes over its federal grants. The principal investigators code, approve, and submit expenditures for payment. In addition, principal investigators receive periodic grant reports which include the detail of all transactions charged to their grants for review. The University will add an additional control step to review coding of research and development payment requests in the ERP system prior to payment. Names of the contact persons responsible for corrective action: Gerri Stepanek and Carole Kampf Planned completion date for corrective action plan: September 1, 2025

Finding 2025-001 Federal assistance listing number and name: 10.415 Rural Rent Housing Loans Awards numbers and years: 2025 Federal agency: United States Department of Agriculture Compliance Requirement: Activities allowed or unallowed, allowable costs/ cash management, eligibility, equipment, period of performance, procurement, program income, reporting, special tests Questioned Costs: None Name of contact person and title: Pat Bishop, President Condition and Context: The auditee did not submit the required audit reports to the Federal Audit Clearinghouse (FAC) and Rural Development (RD) in a timely manner. Specifically:  The 2023 Audit Report was not submitted to the FAC as required under 2 CFR Part 200, Subpart F.  The 2024 Audit Report was submitted past the regulatory deadline to both the FAC and RD. Management Response: Management plans to develop and implement an internal audit compliance calendar with clearly defined submission deadlines for all audit-related deliverables, including due dates for the FAC and RD and Create an internal checklist and sign-off process to confirm that each audit deliverable has been submitted to all required agencies and portals. Status: In progress Anticipated Completion Date: Estimated 2025

Management agrees with the finding and will establish the internal control recommendations outlined in the Schedule of Findings and Questioned Costs. Internal control procedures will be developed and implemented by September 2025.

The Ministry disagrees with the findings. The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date (last day for obligations) and Closing Date (last day to liquidate encumbrances) in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with funding requirements.

The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date and Closing Date in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with funding requirements. The Ministry acknowledges, however, that the process still requires human input and oversight. As a result, there remains a risk that expenditures may be processed or incurred outside the approved funding period due to human error. The Ministry will reinforce and continue to strengthen its review and monitoring procedures to minimize this risk and ensure expenditures are charged to the appropriate funding period.

The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date and Closing Date in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with funding requirements. The Ministry acknowledges, however, that the process still requires human input and oversight. As a result, there remains a risk that expenditures may be processed or incurred outside the approved funding period due to human error. The Ministry will reinforce and continue to strengthen its review and monitoring procedures to minimize this risk and ensure expenditures are charged to the appropriate funding period.

Remediation Steps Completed: MFF will implement the following corrective actions between June 2026 and September 2026 to remediate the finding and address the cause of the finding. • A new contract financial firm and contracted Financial Officer was selected and engaged in February 2025 for regular and ongoing financial management and oversight. • Michigan Founders Fund has implemented balance sheet reconciliations to be prepared and completed by identified staff/consultants monthly to ensure expenditures are correctly captured in a timely fashion. • Michigan Founders Fund has documented accounting policies and procedures to reflect month-end processes and provide training to staff on current and future policies in coordination with contracted support. Implementation, Monitoring, and Sustainability of the Corrective Action: Michigan Founders Fund has implemented the above corrective actions to remediate the finding and address the cause of the finding. To ensure these controls remain effective beyond initial adoption and specifically prevent recurrence of costs charged outside the approved period of performance, MFF has built the following monitoring controls into its normal operating cycle: • As part of the monthly balance sheet reconciliation, designated staff/contractors will verify that all expenditures charged to the award were both incurred and obligated within the award's approved period of performance before the entry is posted. Any transaction falling outside the eligible period will be flagged, held from posting to the federal award, and routed for review. • The Executive Director will continue to review and approve all monthly journal entries prior to posting to the general ledger, with specific attention to period-of-performance alignment for federally funded transactions. Approval will be evidenced in writing and retained in accordance with the record retention requirements. • In addition to monthly reconciliations, the Financial Officer will perform a quarterly reconciliation of cumulative expenditures against the award's approved budget period and reporting deadlines, confirming that reported costs align with the eligible period of performance. • MFF's documented accounting policies and procedures will include specific cutoff procedures for the close of the period of performance, ensuring costs are not recorded in the wrong period and that any year-end or award-end accruals are properly evaluated. • All staff and contractors involved in processing or approving federally funded transactions will receive training on period-of-performance requirements as part of onboarding and as part of the annual policy review, ensuring the control does not depend on any single individual's institutional knowledge. • The Executive Director, with support from the Financial Officer, is responsible for overall monitoring and execution of these corrective actions. Any identified instance of an out-of period expenditure will be documented, corrected, and reported to the Board (or Finance/Audit Committee) at its next regularly scheduled meeting. Anticipated Completion Date: September 2026 Contact Person: Rishi Moudgil, Executive Director Contact Phone Number: (313) 338-8292

Finding 2024-003: Activities Allowed and Unallowed, Allowable Costs, Period of Performance (Title V, C FDA 93. U0 1) Material Weakness (Repeat Finding: 2021-003, 2022-003, 2023-003) Condition: Title V expenditures were recorded through summary journal entries without transactionlevel detail, preventing the auditor from selecting a valid sample or testing compliance. A disclaimed opinion on compliance was issued for this major program. Questioned costs are undetermined due to scope limitation. Corrective Action: • Restructure the chart of accounts/ GL coding so every Title V transaction is individually recorded and traceable to source documentation, rather than aggregated into journal entries. • Require program/grant coding at the point of transaction entry (accounts payable, payroll allocation, purchasing) rather than after the fact. • Implement a quarterly internal review reconciling Title V ledger detail to the approved Title V budget and contract terms. • Provide finance staff training on Uniform Guidance recordkeeping requirements (2 CFR §200.302, §200.333) specific to federal award transactions. Responsible Party: Chief Financial Officer Anticipated Completion Date: GL restructuring to be implemented concurrent with the Organization's new fund accounting system (Blackbaud Financial Edge NXT), implementation kickoff August 13, 2026; complete by March 31, 2027, with the first fully traceable Title V transaction month in April 2027

Management will improve internal processes and controls to include the following: Monthly staff training for documentation retention requirements and policies, Quarterly audits of program expenditure documentation, and Annual Uniform Guidance compliance training.

Juel Fairbanks Chemical Dependency Services has implemented a change in how we do our day-to-day process of approvals of payments, authorized signature for payments prior to being issued.

Once payroll is processed by the Department of Finance (DOF), a Flex Earnings Report is generated by the Analyst on each payday. A reconciliation is then performed to ensure that all employees, along with their respective fringe benefits, are accurately captured and drawn. Following this process, DOF posts the payroll to the accounting system. However, staffing has identified that deficiencies can occur in DOF’s postings, sometimes arising in periods subsequent to the actual payday. To address this, the Department of Human Services (DHS) has incorporated an internal control requiring retrospective reconciliation of accounts against the Flex Earnings Report to verify accuracy. Additionally, DHS plans to engage with DOF to better understand the underlying factors and nuances that result in discrepancies between DOF postings and the account coding reflected in the Flex Earnings Report. The Federal Grants Financial Analyst also plays a key role in ensuring that transactions are recorded in the appropriate accounting period and that costs are properly allocated. In this particular instance, no federal funds were drawn.

VIDE is strengthening its internal controls and record retention procedures to ensure strict adherence to federal period of performance and liquidation provisions. To address the missing payment support, the department is enforcing a strict back-end system control. All required supporting documentation evidencing payment must be attached directly to the transaction entry within the ERP system prior to final disbursement. To address the specific instance regarding the missing indirect cost reimbursement report, VIDE will leverage its newly finalized Indirect Cost Standard Operating Procedure (SOP). VIDE will coordinate with the Third-Party Fiduciary Agent (TPFA) to ensure that all detailed reimbursement reports are actively verified and securely stored in a centralized repository before indirect costs are drawn down and liquidated. Furthermore, the Office of Fiscal and Administrative Services will implement a mandatory final review step during the grant closeout and liquidation phase. This review will systematically verify the presence and accuracy of all payment and indirect cost documentation within the ERP and SharePoint repositories, ensuring that all expenditures are properly supported, allowable, and completely liquidated within the mandated period of performance timeframe.

The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including period of performance. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.

The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including fiscal and administrative requirements for expending and accounting for payroll expenditures. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.

OTAG recognizes the need to strengthen internal controls related to cash management reporting, matching requirement monitoring, and grant period-of-performance compliance. A comprehensive review of existing Master Cooperative Agreement Appendices management processes has been initiated to identify control weaknesses and implement corrective measures. OTAG will implement tracking tools to monitor award periods, liquidation deadlines, and expenditure charging. Personnel will verify Master Cooperative Agreement Appendices periods prior to processing transactions. Expenditures charged to awards will undergo review to confirm alignment with the applicable award and performance period with cross reconciliation of the Government of the Virgin Islands procurement methods, and the Government of the Virgin Islands fiscal enterprise system. Policy and Procedure Enhancements: OTAG will update SOPPs to address cash management, reporting requirements, matching calculations, expenditure monitoring, and period-of-performance reviews. Training will be provided to personnel upon implementation of the revised procedures. Preventive Measures: •Monthly grant reconciliation reviews. •Quarterly compliance monitoring. •Management review of reimbursement requests and matching calculations. •Annual internal compliance assessment. •Centralized documentation repository for grant records. Monitoring & Accountability: The Adjutant General and Executive Director will monitor implementation and effectiveness. Quarterly compliance reports will be provided to agency leadership, and corrective actions will be tracked through completion.

OTAG has reviewed the payroll transactions identified during the audit and has initiated corrective measures to strengthen controls over payroll documentation, appendix charging, and period-of-performance compliance. Payroll expenditures charged to Master Cooperative Agreement Appendices will be subject to quarterly review to verify that timesheets, payroll registers, and supporting documentation are complete, accurate, and retained in accordance with the SF-270 submission requirements. Payroll charges will also be reviewed against periods of performance before posting to ensure costs are assigned to the correct award. OTAG will revise its SOPPs to establish formal procedures for payroll certification, documentation retention, reconciliation of payroll records to timesheets, and review of Master Cooperative Agreement funded personnel costs. Training will be conducted for personnel on documentation standards and allowable cost requirements. To prevent recurrence, monthly reconciliations between payroll records and supporting timesheets will be performed and documented. Quarterly compliance reviews will evaluate payroll charges and supporting documentation for accuracy and completeness. Monitoring & Accountability: The Adjutant General and Executive Director will jointly oversee implementation. Results of monthly reconciliations and quarterly reviews will be reported to executive management.

As part of the close-out process, all open purchase orders are now submitted to the Department of Finance for closure. The grant close-out process has been shifted to the OMB to ensure the grant is no longer available for transaction entries or liquidations. Additionally, a dedicated Federal Grants Financial Analyst is being integrated into the workflow to ensure compliance. Additionally, a Director of Federal Grants has been onboarded to add an additional level of oversight.

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.