Corrective Action Plans

Findings Reported by Uniform Guidance – The following steps have been taken or will be taken to address Finding 2024-005: • Heart City Health Center, Inc. will refine and change controls that deal with tracking of when expenses are incurred to confirm that no drawdown receipt is received before then or in the incorrect grant period

Management has updated its compliance responsibility procedures to clarify roles and responsibilities and to ensure accountabilities for all federal reporting requirements. Specifically: • A compliance calendar will be established to track all non-standard reporting deadlines (other than monthly or quarterly cost reimbursement grant request). • Responsibility for preparing and submitting DRGR reports has been formally assigned to Finance Department. • Verification procedures have been implemented to confirm that all reports are filed timely. • Periodic internal reviews will be conducted to ensure compliance with reporting requirements.

The Organization will continue efforts to obtain written confirmation from the Department of Commerce, compile all available email correspondence and notes from verbal conversations, and prepare a detailed timeline of authorization requests and responses. Further, the Organization will submit a formal response to the Department of Commerce regarding questioned costs, provide documentation supporting the allowability of expenses, and request a formal resolution of questioned costs. Person Responsible: Steve Sanders, Grant Manager, Tel: 207-249-8578 Estimated completion: December 2025

2023-002: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout procedures, consequently, the district will monitor closely all grants spending throughout each grant cycle. For both state-administered and direct grants, regardless of the period of availability, the District must liquidate all obligations incurred under the award Reports not later than 90 days after the end of the funding period unless an extension is authorized. These procedures are included in the Financial Procedures Manual (pages 226-230 under Section G— Timely Obligation of Funds) Key Control Key Actions Resources Needed Timeline Outcome Grants Management Use appropriate resources to mitigate any errors, omissions and ensure timely maintenance of records and reporting Grant Management Form Grant Award Letter Internal Controls Guide GEM$ Trainings FY24, FY25 ongoing Implementation of preventive controls for ALL grant funding Contacts: School Business Manager & Town Accountant Submitted by, Annette Colón, Business Manager MBA, MCPPO, Notary Public Clinton Public Schools 150 School St. Clinton, MA 01510 (978) 365-4200 x 12241 colona@clinton.k12.ma.us

Audit Finding Reference: 2024-001 (Reporting) Planned Corrective Action: NUL acknowledges the reporting requirements outlined in Article VI of the FY22 and FY24 CPF Grant Agreements with HUD. We respectfully note, however, that while we are fully aware of these reporting requirements, we were unable to submit the required reports because the Disaster Recovery Grant Reporting (DRGR) system was not available for submissions during the relevant periods. As such, even if we had attempted to file, submission could not have occurred due to the system’s unavailability. We were in contact with the administrators of HUD on a regular basis during the reporting period. Both HUD and NUL were fully aware of the DRGR system short falls. We emphasize that NUL maintains a strong record of timely and accurate federal reporting and does not typically experience issues with missed or late submissions. This instance is an isolated occurrence and is not reflective of our overall compliance practices. Once the DRGR system becomes available, NUL will promptly submit all required FY22 and FY24 reports to ensure compliance. To further strengthen our processes, NUL is committed to implementing a financial reporting calendar to supplement our existing internal controls and ensure continued timely compliance with all reporting obligations. This reporting calendar will be disseminated to all NUL departments that work with and are responsible for federal grant reporting.

The Agency agrees with the finding. We will provide training to program managers who are approving program expenditures to ensure proper allocation of costs to the appropriate grant cycles. We will also update our purchasing procedures to ensure that the proper allocation of costs is reviewed prior to supervisor's approval of the cost.

FINDING 2024-004 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Ann Stark Contact Phone Number and Email Address: 317-745-9315 / astark@co.hendricks.in.us Views of Responsible O􀆯icials: We concur with the findings. Description of Corrective Action Plan: The Grant Administrator will monitor all claims that will be used for the quarter and send them to the reporting agent to report after the quarter ends. She will be diligent to track any claims coming in outside of that quarter so that reporting is accurate. She will provide the reporting agent with all claims relevant to that quarter’s report. Anticipated Completion Date: This will be done quarterly starting with the quarter ending on September 30th, 2025. The Grant Administrator will submit these claims to the reporting agent one week after the quarter ends. The Financial Administrator will sign o􀆯 on the LOW report to verify the claims match.

Contact Person(s): Bridgette Zappacosta, CFO Corrective Action Planned: Management concurs with the finding. We acknowledge that expenditures were charged outside of the applicable award period due to timing of invoice receipt and data entry errors. The Organization has reviewed its internal controls and will strengthen procedures to ensure compliance with federal requirements. Specifically, we are revising our grant expenditure procedures, implementing new software which includes additional review controls and is specific to grant reporting, and providing targeted staff training on period of performance compliance. We will also perform quarterly monitoring of federal award expenditures to verify compliance. Anticipated Completion Date: December 31, 2025

Finding 2024-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Reporting Contact Person Responsible for Corrective Action: Cindy Poore Contact Phone Number and Email Address: 317-733-2809, cpoore@zionsville-in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Below is the process for submitting required grant reporting. 3. The Director will input the required information 4. Prior to submission of the report, the Director will have the Deputy Director verify the information that has been entered against the supporting documentation. 5. The Deputy Director will let the Director know if it is ok to submit the report. 6. The Director will submit and print a completed submission document that the Deputy Director will verify again. 7. The Deputy Director and Director will both sign and date the completed report. 8. This will be filed for audit purposes. Anticipated Completion Date: This is already taking place. The 2025 filing in April followed this process.

Finding 2024-004: Cutoff Procedures Issue: Previously, there were no formal cutoff procedures to ensure expenses were recorded in the correct period, which caused inconsistencies and required post-year-end journal entries to correct expense timing. • What's been done: Contracts are now recorded as prepaid or accrued expenses and are being expensed monthly. • Next steps: Salaries and benefits incurred before month-end will be accrued to grants at grant cutoff dates (e.g., September 30) and at year-end. Estimated monthly accruals for salaries will be implemented. • Timeline: Full implementation by the end of September 2025. • Responsible party: Finance manager with oversight by President

The Foundation immediately paid the vendor the full amount upon learning of this finding from the auditor and verified that the vendor received the payment. The recording of Grant Revenue/Accounts Receivable and Grant Expenses/Accounts Payable is now done for each grant expense immediately upon approval from the Foundation and submission to New York State for reimbursement. This was previously not done. The changes to the recognition of revenue and expenses are already in effect and should eliminate any future finding related to the non-payment of expenses that have been reimbursed through grants.

Finding 2024-001 Internal Control Deficiency over Allowable Costs Federal Grantor: United States Department of Homeland Security Assistance Listing No.: 97.036 Award Period of Performance: January 1, 2020 – July 1, 2022 Summary of Finding: Management did not consistently retain documentation evidencing the performance of internal controls in place to review and approve FEMA expenditures submitted to the FEMA Portal. Corrective Action Plan: Management implemented corrective action on December 31, 2024 to ensure evidence of controls is retained. Responsible Party: Wah-chung Hsu, Chief Financial Officer Completed Date: December 31, 2024

2024-004 FINDING: Period of Performance Responsible Officials: Daniel Ainslie, Finance Director, Jamie Toennies, Grants Division Manager Corrective Action Plan: Written communication will be sent to department directors and staff involved in grant administration addressing the compliance requirements associated with Period of Performance. This communication will specifically state that no federal funds will be spent outside of this time period without written approval by grantor and/or approved budget modification. In addition, the City’s Uniform Grant Guidance Polices/Procedures will be updated to include a section on Period of Performance compliance requirements. Anticipated Completion Date: December 31, 2025

Finding 2024-001 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over compliance it was noted that one expense charged to the 2023 Hi Quality Instructional Materials grant major program was not an allowable expenses. Criteria: Costs charged to the 2023 Hi Quality Instructional Materials grant major program should meet the requirements as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Context: During our review of expenses charged to the 2023 Hi Quality Instructional Materials grant it was noted that one expense that was charged to the grant whose service period was outside the period of performance and thus an unallowable cost. Effect: Town of Bellingham was not in compliance with the allowable costs/ cost principals requirement as set forth by the Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Questioned Costs: $2,170.00 Cause: The District utilized the FY2023 Hi Quality Instructional Materials grant to fund subscription(s) that support organizational assessment data results for Social & Emotional learning, with the understanding that the subscription started during the grant's timeframe but did not consider that the subscription would extend beyond the grant period. Identification as a Repeat Finding: N/A Recommendation: We recommend the Town of Bellingham follow procedures to ensure that expenditures charged to the grants are allowable costs as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles) Responsible for Corrective Plan: Director of Finance Estimated Completion Date: September 1, 2025 Action Taken: The District will not utilize grant funds to support subscriptions that span outside of the grant-funding timeframe.

FINDING 2024-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Wendy Marples Contact Phone Number and Email Address: 812-338-2142/ auditor@crawfordcounty.in.gov Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The County Auditor will ensure that any future ARPA funding will be reported correctly and broken out by project. This will also be verified with the ledger for the same period. Internal controls within the office will ensure the County Auditor reviews everything is correct prior to submission. Anticipated Completion Date: December 31, 2025

FINDING 2024-003: Finding Subject: COVID 19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Toni Loper, Town Clerk-Treasurer Contact Phone Number and Email Address: 765-857-2377 / ridgevilleclerk@gmail.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In regards to the current finding over the reporting period under audit all pertinent issues will be corrected in the following annual project and expenditure report, due in April, 2026. The town will contract with Local Government Services to prepare the annual project and expenditure report, develop a procedure where the Clerk-Treasurer or any Town employee with proper training and knowledge will review the report prior to submission for accuracy and completeness before final filing. The Clerk-Treasurer or respective town employee who will review the report, will receive the proper training over the respective program. Any correspondence between Local Government Services and the Town of Ridgeville will be documented accordingly. Anticipated Completion Date: Policies and procedures to be documented and adopted by March 18, 2026. Full implementation and testing to be in place for the 2025 fiscal year reporting cycle.

Noncompliance with Period of Performance (Public Housing Capital Fund ALN 14.872) We will implement controls to ensure that the amounts reported in ELOCCS for obligations and expenditures are properly supported by an underlying contract or invoice. Date of completion: Ongoing

FINDING 2024-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-882-6426 clane@vincennes.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All reports will be prepared by the clerk’s treasurer’s office and will be reviewed by someone who is knowledgeable about the reporting requirements prior to submission. They will review reports for errors and omissions. After this additional review, the report will be submitted. Anticipated Completion Date: This corrective action plan will go into effect immediately.

Finding Number 2024-007: Period of Performance – Material Weakness in Internal Control over Compliance and Noncompliance Corrective Action: To ensure compliance with 2 CFR §200.344(b), Management will implement formal policies and procedures requiring that all financial obligations under federal awards be liquidated within 120 calendar days after the end of the period of performance. Grants Accounting will establish a documented review and tracking process to monitor grant deadlines, identify outstanding obligations, and ensure timely payments. These actions are intended to strengthen controls, ensure timely liquidation of expenditures, and prevent recurrence of prior year findings. Name of Responsible Individual(s): Jason Brenier, Shelly Courtois, Judy Bokhari, and Sandra Shannon Anticipated Completion Date: September 2025

Finding Number 2024-004: Period of Performance and Allowable Costs/Cost Principles – Significant Deficiency in Internal over Compliance Corrective Action: Management will enhance oversight of payroll allocations and rental assistance charges, update written procedures, and train Grants Accounting staff on period of performance requirements, cost allowability, documentation, and grant closeout. Monthly meetings with grantors have been initiated to monitor spenddown, address processing issues, and ensure proper cut-off. Management will also collaborate with the Payroll Service Provider to improve allocation accuracy and reduce manual errors. A documented review and approval process at period-end will further ensure costs are charged to the correct funding period and comply with federal requirements. Name of Responsible Individual(s): Jason Brenier, Judy Bokhari, Luz Gonzales-Toscano Anticipated Completion Date: January 2025 – immediate term and December 2026 software implementation.

FINDING 2004-006 Finding Subject: COVID-19-Coronavirus State and Local Fiscal Recovery Funds Reporting Contact Person Responsible for Corrective Action: Celita Green, City Controller Contact Phone Number and Email Address: 219-881-5085 Views of Responsible Officials: We concur with the finding that Total Cumulative Expenditures reported for Quarter 2 report (April 1, 2024 to June 30, 2024) and Quarter 3 report (July 1, 2024 to September 30, 2024) were understated. However, there is no mechanism to file corrective to the State and Local Fiscal Recovery Funds (“SLFRF”) Compliance Quarterly Reports with the Treasury reporting system once they are submitted. The City did make cumulative adjustments in the Quarter 4 report (October 1, 2024 to December 31, 2024) to agree with Cumulative Expenditures in the Report with the City’s accounting records, once the City determined the cumulative totals were inaccurate prior to being audited. Description of Corrective Action Plan: As stated above, the City did make cumulative adjustments in the Quarter 4 report (October 1, 2024 to December 31, 2024) to agree with Cumulative Expenditures with the City’s accounting records, in accordance with the periodic updates to the “Compliance and Reporting Guidance for State and Local Fiscal Recovery Funds” issued by the U.S. Department of the Treasury, which indicates how to make cumulative adjustments in the current quarter’s report. Since the 4th Quarter 2024 Compliance Report, the City’s totals agree with Treasury Quarterly Reports to date. . Anticipated Completion Date: Actions were completed on January 30, 2025

Condition: The Organization’s expenditure reports filed with the grantor for the cost reimbursement-based grant were overstated, and the Organization was overpaid by $182,167, of which $26,730 was received after yearend. The overpayment has not yet been refunded back to the grantor, over a year after the performance period of the grant had ended. Recommendation: The Organization should coordinate with the grantor the return of the unspent funds. The Organization should reevaluate its grant expenditure reporting procedures to better mitigate the risk of inaccurate filing and improper reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and recommendation. The anticipated completion date for the corrective action is October 30, 2025.

Finding 2024-005: PERIOD OF PERFORMANCE Description of Finding: Capital Funds identified in the PHA's CFP 5-Year Action Plan to be transferred to operations are obligated by the PHA once the funds have been budgeted and drawn down by the PHA. Capital Funds transferred to operations (BLI 1406) are not considered obligated until the PHA has budgeted and drawn down the funds. To meet this requirement, the funds must be budgeted in line BLI 1406 (Operations) and the PHA must submit the voucher request in LOCCS. (24 CFR Section 905.314(I)). Statement of Concurrence or NonConcurrence: The Authority had obligated capital funds related to operations (BLI 1406) for Capital Fund years 2020 and 2022 prior to the voucher request date for these draws. The Authority had six open capital fund grants during fiscal year 2024 (Capital Fund years 2019-2024). The Authority obligated the BLI 1406 funding for Capital Fund 2020 in March 2024 and Capital Fund 2022 in May 2024. The Authority submitted the voucher requests in February 2025. Corrective Action: Funds in 1406 will be drawn down directly after obligation. Name of Contact Person: Cheryl Thibeault Projected Completion Date: 09/30/2025

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2024 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2024-004 – Period of Performance Description of Finding: There was no evidence, such as a signature, evidencing review and approval by a direct supervisor of the timesheets. Time and effort reports were not done. Statement of Concurrence: We concur with the finding above. Corrective Action: BCHN has put together a training program for employees to ensure that timecards are reviewed and approved by both the employee and the supervisor on a bi-weekly basis. Before payroll is processed, approvals by employees and supervisors will be checked. HR will provide a monthly time and effort report to the finance team. This report will provide total number of hours worked by each employee for each assigned cost center. Completion Date: October 2024. Name of Contact Person: Alicia Tenny Chief Financial Officer Tel. No.: (917) 364-1156 E-mail: atenny@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call Alicia Tenny at (917) 364-1156. Sincerely yours, _________________________ Alicia Tenny Chief Financial Officer

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Cheney January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The City did not have adequate internal controls for ensuring compliance with federal allowable costs, matching and reporting requirements, and it did not comply with federal allowable costs and matching requirements. Name, address, and telephone of City contact person: Cindy Niemeier, Finance Director 609 2nd Street Cheney, WA 99004 509-498-9215 Corrective action the auditee plans to take in response to the finding: The City of Cheney recognizes the error in classifying a grant received from the Washington State Department of Commerce as a state grant rather than a federal pass­ through grant, which makes this funding source ineligible as matching funds in the funding awarded from the Department of Reclamation. The City has contacted the Department of Reclamation federal program to disclose the error and determine the required corrective action. The City of Cheney has proposed replacing the submitted reimbursement requests with City expenses as allowable matching expenses. The City is currently waiting on the Department of Reclamation for direction. The 2024 reporting error was corrected in 2025. Future projects with multiple funding sources will continue to be managed by the individual departments. The additional internal control will require the departments to meet quarterly with Finance to conduct internal audits of the reimbursement requests and completed reporting. Anticipated date to complete the corrective action: December 31, 2025