Corrective Action Plans

CORRECTIVE ACTION PLAN2025-001 [2023-001]—TRACKING AND VALUATION OF MORTGAGE RECEIVABLES AND AMOUNTS DUE TO GRANTORType of Finding: (A) Material Weakness in Internal Control Over Financial ReportingStatement of ConditionWhile the Housing Trust has begun a complete review of its loan portfolio, the project has not yet been completed. Therefore, we were unable to obtain sufficient audit evidence to support the Housing Trust’s tracking and valuation of its mortgage receivables and amounts that are due to grantor.Per our audit procedures, we noted that management was unable to provide the following:A reasonable methodology for estimating its allowance for loan losses.Funding provided by grantors for the loan programs that should also be classified as amounts that are due to grantor.Not all current year loans were recorded in the general ledger (approximative $512,066) and approx. $481,201 were recorded twice.A net prior year adjustment of $36,460 for mortgages receivable and $35,000 for land leases held was necessary.Reclassification between loans accounts and grant revenue were necessaryContextThe Housing Trust has a portfolio of over six-hundred individual mortgage receivables that include both non-amortizing and amortizing loans, which management has valued at approximately $25,291,075. These loans have been funded by several sources, including federal, state, and local funding. Some of the grantors have established in their agreements that these funds do not belong to the Housing Trust, but actually belong to the grantor. CriteriaThe Housing Trust should ensure it has a board-approved policy for its loan portfolio to ensure that these assets are properly tracked, classified, and maintained with specialized loan management software that can perform the following:Loan Classification and TrackingEach loan is properly identified with its funding source (federal, state, local, etc.) and type of restriction Each loan agreement has the funding source specifiedThe current status of each loan is tracked (current, delinquent, defaulted)Loan funding that has been established as due to the grantor is properly tracked.Compliance and ReportingEnsure the loans comply with the specific guidelines of their respective funding source. Audit trails are available for all transactions and valuations.The receivables and related interest accruals supported by the loan management software should be reconciled to the Housing Trust’s accounting software.Financial TrackingThe valuation of the portfolio should be updated periodically (at least quarterly) for any changes in loan status or market conditions.All new loans should be recorded in the general ledger A loan loss policy was established that includes a loan loss methodology incorporating risk classes based on the borrower’s ability to repay. However, the calculations seem to follow a different methodology established afterwards. The policy should be updated with calculation methodology and with the backup research of historical data. A loan review committee should be responsible for reviewing and approving the classifications of loans and the associated allowance for loan losses which should be supported by high-quality data collection on each borrower’s payment history and any relevant economic indicators. The calculations and methodology should follow the approved policy, or the policy should be improved to include all factors mentioned above.EffectThe auditors were not able to verify the accuracy of the loan records and financial statements related to mortgage loans, the related accrued loan interest, the allowance for loan losses and loan funding that should also be recorded as due to grantor. CauseWhile the Housing Trust has begun a complete review of its loan portfolio, the project has not yet been completed. Therefore, the loan portfolio tracking and valuation have not yet been designed or implemented to support its policies and procedures or provide the loan review committee with a workable system for reviewing, approving and monitoring the organization’s mortgage receivable portfolio. The methodology seems to be changing, and the calculations do not seem to be accurate,RecommendationWe recommend the Housing Trust update policies and procedures for its loan portfolio as identified in the “Context” section of this finding to include methodology, risk assessment, historical loan data research, calculations method with reasoning.View of Responsible OfficialThe Housing Trust acknowledges the finding. Due to turnover in prior years, historical loan records and tracking systems were incomplete or inaccurate. Since then, SFCHT has taken the following steps:A second title company has been contracted to obtain final loan data for the 2026 loan portfolio. A title company will also be engaged annually at year-end to identify and resolve any differences arising during the year.Establish one master loan inventory using Portfol data. This inventory will serve as the master loan control schedule for monthly financial reconciliations. All differences will have a documented resolution, including reconciliation of receivables and related interest between the two systems. Reconciliations will be completed by the 15th business day of the following month.Create a new loan-recording process for every loan closing.Create a Due to Grantor Matrix based on findings from the annual loan review performed by the title company. Supporting documentation, such as grant agreements, correspondence, or other applicable documentation, will be maintained.Review the ASC 326 loan loss methodology to ensure it reflects the actual calculation methodology and is supported by appropriate research. This review will be performed quarterly.Establish a formal loan review committee and process to review loan calculations and the allowance for loan losses. The committee will meet quarterly and review reports from Portfol. Meeting minutes will document updates, decisions, and changes.Corrective Action Plan TimelineFinalize and implement the loan loss methodology: by December 2026Begin monthly Portfol-to-QBO reconciliations: by September 2026Fully hand over all loans to Amerinat by end of 2026; Land Leases will remain “in-house”Continue staff training and Executive-level reviewDesignated Employee Responsible for Corrective Action-Director of Operations-Accounting Specialist2025-002 [2023-002]—FINANCIAL CLOSE AND RESTATEMENTS TO BEGINNING NET ASSETSType of Finding: (A) Material Weakness in Internal Control Over Financial ReportingStatement of ConditionDuring the audit of the financial statements, we noted that material adjustments and restatements were necessary to correct errors in the current and previously reported financial statements. A summary of the areas and the net effect of the changes are as follows: Type Amount, net Accounts Receivable $ (13,490) Grants and Contracts Receivable 830,747 Accrued Interest 5,798 Amortizing Loan Receivable 419,551 Non-Amortizing Loans Receivable (433,722) Land Held in Trust (61,323) Other Assets (145,000) Prepaid Expenses (61,940) Notes Receivable (195,000) Developments Projects (184,559) Real Estate Inventory to Sell (333,079) Fixed Assets (785,081) ROU Accumulated Amortization (7,511) Accounts Payable (807) Due to Grantor 10,000 Grant Advances (97,963) Accrued Expenses (6,249) Other Current Liabilities 52,841 Lease Liabilities 7,845 Notes Payable (9,710) Net Assets 1,154,733 Total $ 146,081 CriteriaAccounting Standards Codification (ASC) 265 “Presentation of Financial Statements—Communicating Internal Control Related Matters Identified in an Audit” requires that deficiencies in internal control over financial reporting be communicated to those charged with governance when the design or operation of a control does not allow management or employees to prevent or detect misstatements on a timely basis.The correction of material misstatements indicates the existence of a material weakness in internal control over the maintenance of the organization’s financial statements.EffectThe material adjustments and restatements resulted in significant changes to the current year balances and beginning balances of the organization’s unrestricted and restricted net assets. These adjustments could potentially undermine the stakeholders' confidence in the financial information presented by the organization and may lead to difficulties in securing future funding or maintaining current donor relationships.CauseThe material misstatements were caused by a weakness in the development and implementation of internal controls and financial reporting processes, as well as significant turnover in the organization’s management.RecommendationWe recommend the Housing Trust strengthens its internal controls and financial reporting processes to prevent future occurrences of such errors. This could involve adding additional staff, training current accounting staff and implementing more robust review procedures to ensure that all financial reporting is in strict accordance with GAAP. View of Responsible OfficialThe Housing Trust acknowledges the finding. In prior years, however, internal controls were insufficient. There was no formal month-end close or review process, and prior audits relied on outdated balances without verification. Under new leadershipA formal monthly close calendar has been established, with the monthly close to be completed within 10-15 business days.Create a supporting schedule for every balance sheet account. These schedules will be used as part of the monthly reconciliation process and will be certified.A grant receivable roll-forward will be prepared for each grant, compared to QuickBooks, and reconciled monthly.Each development project will have its own subledger, which will be reconciled monthly.A detailed fixed asset register will be maintained and reconciled quarterly.6. To help prevent future restatements, establish a formal journal-entry control process that requires appropriate supporting documentation and approvals.7. Establish a policy requiring documentation and approval for any changes made to beginning balances.8. The CEO and Finance Committee will perform monthly analytical reviews using the balance sheet, profit and loss statement, and actual-to-budget comparisons.9. Establish a reconciliation exception and audit adjustment log to track outstanding issues requiring resolution, including a timeline for resolving each item.Corrective Action Plan Timeline The timeline to complete this is prior to December 31, 2026.Designated Employee Responsible for Corrective Action-Director of Operations-Accounting Specialist2025-003 [2024-003] - GRANT TRACKING AND SEFA RECONCILIATIONFederal Agency: U.S. Department of Housing and Urban Development (HUD)Federal Program: Housing Opportunities for Persons With AIDS (HOPWA)Assistance Listing Number: 14.241Award Number and Period: [NMH240051], [November 1, 2024 – October 31, 2027]Type of Compliance Requirements: Internal Controls Type of Finding: (B) Significant Deficiency in Internal Control Over Financial ReportingKnown Questions Cost: NoneStatement of ConditionDuring our audit, we identified initial differences between expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) and the general ledger. Management subsequently provided additional supporting schedules and completed a reconciliation of the SEFA to the general ledger. However, the reconciliation required manual effort because one federal award included program income amounts that had not been properly reconciled or corrected, another federal award had expenses that did not belong to the award, and recycled funds were tracked separately partially only from new grant funds in the accounting records. Some of expenses did not have appropriate backup documentation, however, the billing to the grant was correct. Expenses from program income for salaries did not match the timesheets. CriteriaPer 2 CFR 200.302 and 200.510(b), recipients of federal awards must maintain accurate, current, and complete records that adequately identify the source and application of funds. Grant expenditures must be traceable to the financial records and properly classified. Program income, including recycled funds, must be used and tracked in accordance with federal requirements and grantee policies. Specifically, all grants should be tracked separately in the general ledger, and the revenue and expenses should match the reimbursement grants. The SEFA reconciliation should be done thoroughly and discrepancies reconciled or resolved, if that is the case. The policies for recycling the funds should be updated with the financial tracking in the general ledger and update with all grantor recommendations. The HOPWA program policy was updated in July 2025.The recycled funds received/spent should be separately tracked and used per policies and grantor recommendations.EffectThe lack of properly tracking expenditures and recycled funds increases the risk of misstating the SEFA, billing non-allowable or duplicate costs to the grantor, and not meeting timeliness or use restrictions related to program income. This may lead to questioned costs or future audit findings.Recycled funds not properly tracked separately may result in noncompliance with the application of loan funding. CauseThe issues stemmed from frequent staff turnover and the complexity of accounting for loans and recycled funds across departments. RecommendationWe recommend the Housing Trust:Revise and implement grant management policy and procedures that ensure each grant has a dedicated general ledger account.Require all reimbursement requests to be supported by general ledger detail.Ensure program income and recycled funds are separately tracked in accordance with federal guidelines (separate classes).Establish regular reconciliations between Finance and Program records to maintain consistency.View of Responsible OfficialThe Housing Trust acknowledges the finding. Corrective Action Plan: 1. A master grant register has been created that includes all active grants and federal awards.2. Each grant will have a unique class/project established in QuickBooks to capture payroll and other grant-related expenses. Reports will be generated monthly.3. Each grant will be reconciled monthly.4. Grant reimbursement requests will be supported by appropriate documentation.5. Payroll review procedures have been established to confirm that payroll costs are properly allocated to grants.6. Program income will be tracked separately for all applicable income and expenditures.7. Monthly SEFA reconciliations will be completed for all grants, including grants that do not meet the definition for inclusion in the SEFA.8. A grant reconciliation exception log will be established to track outstanding issues, responsible parties, and timelines for resolution. Corrective Action Plan Timeline- Finalize and adopt new Grant Management Policies: by September 2026- Implement monthly SEFA reconciliations: by September 2026- Complete staff training on program income and federal grant tracking: by September 2026Designated Employee Responsible for Corrective Action-Director of Operations-Accounting SpecialistCurrent Year Findings 2025-004 - Program Income Federal Agency: U.S. Department of Housing and Urban Development (HUD)Federal Program: Housing Opportunities for Persons With AIDS (HOPWA)Assistance Listing Number: 14.241Federal Award: [NMH240051], [November 1, 2024 – October 31, 2027]Compliance Requirement: Program Income Known Questions Cost: None Type of Finding: (F, G) Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Noncompliance related to Federal Awards Statement of Condition During 2025, the Housing Trust received certain repayments of loans originally funded by HOPWA awards. Of this amount, certain amount may have remained unspent or had not been recorded/reconciled in accordance with HUD requirements as of December 31, 2025. Management did not maintain a documented control to identify HOPWA repayment receipts, determine the applicable award requirements, reconcile receipts and expenditures among IDIS, QuickBooks, and the program-income subsidiary record, and document approval of their disposition. Criteria Under 2 CFR 200.307(c), program income earned after a Federal award’s period of performance is subject to Federal requirements only when required by Federal agency regulations or the terms and conditions of the award, and the Federal agency may establish appropriate disposition requirements through closeout. HUD may require HOPWA-funded loan repayments received after the original award period to be recorded as program income.CauseThe Housing Trust had not designed and assigned ownership of a formal program-income and grant-closeout control addressing repayments generated from HOPWA-funded loans after the originating award’s period of performance. Effect Program income may have been subject to incorrect or untimely reporting/use, increasing the risk of noncompliance and misstatement of federal expenditures. Known questioned costs were unknown. RecommendationHousing Trust should implement a documented monthly program-income reconciliation and grant-closeout control that identifies the originating award, applicable HUD disposition requirement, IDIS receipt, QBO classification, eligible use, remaining balance, reviewer approval, and resolution of differences. Evidence of HUD determinations for post-period receipts should be retained with the reconciliation.Views of Responsible Officials: SFCHT acknowledges the finding and notes that the New Mexico HOPWA program is the only documented HUD grant that funds mortgages.Management has established a formal process to identify and track repayments associated with HOPWA-funded loans. Management will maintain a subsidiary program income register that identifies the originating federal award, receipts, applicable HUD disposition requirements, accounting classification, eligible expenditures, and remaining balance. Program income activity will be reconciled monthly among loan-servicing records, QBO, IDIS, and supporting program records. Written HUD determinations regarding post-period repayments will be retained when applicable.Corrective Action Plan TimelineAn onsite meeting with HUD HOPWA representatives is scheduled for September 10, 2026, at the Santa Fe offices. During this meeting, policies and procedures, including the program income policy, will be reviewed and formalized, and a HUD determination log will be established.The HOPWA Program Income Register will be implemented, and repayment schedules for HOPWA loans will be documented in the master loan inventory. Implementation date: July 2026.HOPWA program income will be expended before additional HOPWA IDIS reimbursement requests are approved.A historical review of HOPWA loans and funding sources will be completed. Target date: August 2026.QBO, Portfol, Amerinat, and IDIS will be reconciled monthly. Beginning: July 2026 and ongoing.Post-period repayments and related HUD determinations will be reviewed. Target date: September 2026.Designated Employee Responsible for Corrective Action Director of Operations, with assistance from the Accounting Specialist and HOPWA HUD program staff, as applicable.Signature Title

Temple Landing II was funded with PRI with a completion deadline of March 2024. The project applied several times for LIHTC from the Massachusetts EOHLC. With the project unfunded, Management notified CDFI of the delays in the project and the missed completion deadline in April 2025 and again in March 2026. The project has since been awarded 9% LIHTC and is scheduled to close in August 2026. Columbia Crossing was funded with PRI with a completion deadline of April 2025. The project applied several times for LIHTC from the Massachusetts EOHLC. Management notified CDFI of the delays in the project and the missed completion deadline in March 2026. The project was awarded 9% LIHTC and gap financing from MA EOHLC and closed in April 2026. Terri Manor was funded with PRI with a completion deadline of April 2025. The project applied several times for gap financing from the Ohio state HFA. Management notified CDFI of the delays in the project and the missed completion deadline in March 2026. The project won a funding award from HUD’s GRRP program and after delays in program funding is scheduled to close in December 2026. On April 20, 2026, CDFI Fund provided a one-year cure period to March 31, 2027 for all three projects. While it is expected that all three projects will have closings in 2026, construction will not be completed on Temple Landing II and Columbia Crossing until 2027 and Terri Manor until 2028.

Management concurs that stronger documentation surrounding the collection and monitoring of Continuum of Care program income would have strengthened internal controls and the audit trail. The finding relates to a program that has since been discontinued. Throughout the audit period, all program income that was collected was used for allowable program purposes; however, management acknowledges that documentation supporting assessment, collection, monitoring, and reconciliation procedures should have been more comprehensive. Although this activity is no longer part of the Organization's operations, Ability1st has strengthened its overall documentation standards. Should the Organization administer future programs involving program income, written policies and procedures will be implemented prior to program implementation and will include: • documented fee assessment methodology; • collection and deposit procedures; • reconciliation requirements; • supervisory review; • record retention standards; and • periodic internal monitoring. Management believes these procedures will provide an appropriate level of accountability and compliance with federal requirements should program income be collected in the future. Responsible Official: Executive Director Implementation Date: Completed for discontinued program; procedures will be implemented before any future program income activity.

Finding No. 2025-002 – Failure to Properly Apply Current Federal Poverty Guidelines in the Sliding Fee Discount Program (SFDP) Federal Program: Health Center Program Cluster, ALN 93.224 – U.S. Department of Health and Human Services (HHS) Contact Person Responsible for Corrective Action Guillermo J. Jiménez Ramos, Chief Financial Officer Views of Responsible Officials Management concurs with the finding. Corrective Action Taken and Planned 1. Resolution of the two identified cases. The Hospital reviewed and resolved the two patient accounts identified in the audit sample in which an incorrect sliding fee discount percentage was applied: • In the first case, the discount applied resulted in a charge to the patient below the amount that corresponded under the correct Federal Poverty Guidelines discount tier, and a lower amount was collected from the patient. Management evaluated the account and determined not to retroactively bill the patient for the remaining difference, consistent with the Hospital’s mission and its policy of not creating barriers to care for patients eligible under the Sliding Fee Discount Program. • In the second case, the Hospital billed and collected from the patient an amount higher than the amount that corresponded under the correct discount tier. This case was resolved and the amount collected in excess of the correctly discounted amount was returned to the patient by check no. 95274, issued on May 29, 2026. Documentation of the refund is retained in the patient’s account file. 2. Questioned cost. The known questioned cost of $245.97 has been repaid and offset by the Hospital. Supporting documentation of the resolution is available for review by the awarding agency. 3. Current Federal Poverty Guidelines implementation. The Sliding Fee Discount Schedule will be updated to the current Federal Poverty Guidelines (FPG) issued annually by HHS, and a standing procedure will be established requiring that the updated schedule be approved and incorporated into the Hospital’s billing system (eClinicalWorks) within thirty (30) days of the annual publication of the FPG. 4. Review of sliding fee determinations. The review process over sliding fee discount determinations, which had previously been performed by the Billing Department and was later delegated to the information management staff, has been returned to the Billing Department to ensure that discounts are properly applied to patients in accordance with the Sliding Fee Discount Program policies and the updated fee schedule. 5. Strengthened internal controls. A secondary review control will be implemented under which a quarterly sample of new and renewed SFDP eligibility determinations will be re-verified by the Billing Department against the current FPG schedule, income documentation, and household size, with the results documented in a monitoring log subject to review by the Chief Financial Officer. 6. Training. Formal training on the SFDP policy, the current FPG schedule, and the related documentation requirements will be provided to all registration, billing, and eligibility staff, with attendance documented. Refresher training will be provided annually upon each FPG update. Anticipated Completion Date Items 1 and 2 – Completed. Items 3 through 6 – October 31, 2026.

Finding Number: 2025-003 Finding Title: Reporting – PR29 CDBG Cash on Hand Quarterly Report Program: 14.218 Community Development Block Grants/Entitlement Grants Name of Contact Person Responsible for Corrective Action: Matthew Bower, George Hardgrove Corrective Action Planned: The City acknowledges this finding. City has communicated directly with Housing and Urban Development for clarification on reporting requirements and intends on following the updated guidance they provided. Anticipated Completion Date: July 31, 2026

Memo: Cause and Corrective Action Plan for Finding 2025-003 This correspondence serves as Cook County Health (CCH) and Cook County Department of Public Health (CCDPH) response to Finding 2025-003. During the FY2025 Single Audit, one audit finding was identified by Washington, Pittman & McKeever, LLC. The root cause and corrective action plan is identified below. Condition During the current audit period, the Cook County Department of Public Health (DPH) did not comply with federal regulations regarding the use and reporting of program income as it relates to funds awarded through the RWHAP Root Cause Analysis The HIV grants transitioned to CCH from an external organization in July 2025. Award amounts were granted in multiple phases, requiring four budget revisions, with the final revision approved in December 2025. The contractual period covered March 2025 through December 2025. During the transition period, CCH lacked formal operational procedures to identify, record, and track program income. Several operational and administrative challenges contributed to this issue, including: • No written internal procedures were in place to define or track program income requirements. • No formal transition teams were established to identify core grant obligations, resulting in unclear interpretation of sponsor requirements. • CCH had not yet identified the appropriate internal systems or interdepartmental collaborations necessary to retrieve and reconcile program income data. • Organizational priorities during the transition focused on maintaining existing deliverables, including vouchering, budget compliance, hiring, and onboarding of direct and administrative staff. • Staffing Shortages, CCH onboarded personnel quickly as contractual employees, direct staff transitioned onboard as CCH employees in phases upon execution of grant contracts. Corrective Action Plan CCH Director of Grants Accounting is implementing formal written processes and procedures to ensure compliance with Federal Uniform Guidance requirements related to program income. The corrective action plan includes: • Developing standardized written procedures that clearly define program income requirements and tracking responsibilities. • Establishing shared roles and responsibilities across departments to support consistent data collection, reconciliation, and reporting. • Identifying the specific data elements required to accurately record and monitor program income. • Formalizing interdepartmental collaboration processes necessary to retrieve and validate program income information. • Defining the systems and reporting tools that will be used to track and maintain program income records. • Providing staff training on program income requirements, documentation standards, and compliance expectations. These actions will strengthen internal controls and ensure timely, accurate identification and tracking of program income moving forward, official approval/implementation is expected December 2026

Management agrees controls over dual counts of program income should be complied with and will follow up with centers that do not comply with controls.

Reporting of Prior Year Program Income Auditor Description of Criteria, Condition, and Effect: In accordance with 2 CFR § 200.307, program income must be used in accordance with the terms and conditions of the federal award and must be accounted for and reported accurately. Recipients are required to reconcile program income received and expended during the grant period to ensure it is used for allowable purposes and properly reflected in financial reports. Failure to reconcile and report program income may result in noncompliance with federal grant regulations and could impact the allowability of costs charged to the award. The County recognized a substantial amount of program income during the fiscal year ended September 30, 2025, for program income that was received in prior periods but incorrectly reported as unearned over many years. It is unclear what portion of this prior year unearned revenue was reported to the Department of Housing and Urban Development ("HUD") through the Integrated Disbursement and Information System ("IDIS") now that the revenue has been properly recognized in the general ledger. The County has a risk of inaccurately reporting program income to HUD. The County is also exposed to an increased risk noncompliance could occur and not be prevented or detected by the County's internal controls. Auditor Recommendation: We recommend the County review its prior year records to determine which portion of the currently recognized revenue has already been reported to HUD. Additionally, the County's Neighborhood and Housing Development ("NHD") department should coordinate with HUD to establish the appropriate approach for reporting and expending this program income going forward. Corrective Action: An in-depth review of all program income activity dating back to 1995 is currently underway within both the general ledger and the IDIS system. The purpose of this review is to determine the total amount of program income received and reported to HUD. Upon completion of the review, the County will collaborate with HUD to determine the appropriate use and expenditure of the identified funds in accordance with applicable program requirements. Responsible Persons: Khadija Walker-Fobbs Neighborhood and Housing Development Officer, Curtis Smith, Chief, Neighborhood and Housing Development and Brian J. Lefler, Chief Financial Officer Anticipated Completion Date: September 2026

2025-016 WIOA Cluster 17.258, 17.259, 17.278 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. The Department should review its procedures to ensure that ETA 9130 reports are accurate and agree with supporting documentation. We further recommend that internal controls are enhanced to ensure that reports are reviewed for accuracy prior to submission. Action taken in response to finding: ETA 9130 reports are jointly reviewed by Finance and program staff before submission and certification. Supporting documentations are cross-checked for accuracy and completeness, and all relevant files are maintained in a centralized, shared folder to ensure transparency and accountability. This multi-layered review and documentation process has been incorporated into a standard quarterly reporting procedures to prevent future discrepancies and ensure federal reporting integrity. New internal controls and procedures were established 8/30/2025, in which this audit has not reviewed yet. Name(s) of the contact person(s) responsible for corrective action: Finance: Sarah Shannon, Ken Luke, Vina Yung, DCS: David Manning Planned completion date for corrective action plan: Already completed – staff trained and provided with new SOP on 8/30/2025.

Finding: 2025-076 - The Alaska Industrial Development and Export Authority’s (AIDEA) controls were not designed to detect noncompliance in program income reported in AIDEA’s annual report. During our testing of reports, we noted that the annual report tested did not report interest earned on deposit accounts. The amount of interest income not included on the annual report totaled 167,023, which represents the cumulative interest income earned for the program from deposits since inception Questioned Costs: None Assistance Listing Number: 11.307 Assistance Listing Title: Economic Development Cluster COVID- 19 Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): Agree Corrective Action (corrective action planned): DCCED manages this program on behalf of AIDEA. DCCED will incorporate a new internal control procedure requiring that each year’s final EDA-209 report be reviewed and approved by AIDEA’s Controller or Chief Financial Officer prior to submission and includes backup that supports each number. This review step will ensure the completeness and accuracy of all future filings. Completion Date (list anticipated completion date): 06/30/2026 (or the date of when the next EAD-209 report is due) Agency Contact (name of person responsible for corrective action): jkornmuller@aidea.orq, aleavitt@aidea.orq, andy.macaulay@alaska.qov

Finding 2025-001: Rural Rental Housing Loans Assistance Listing Number: 10.415 U.S. Department of Agriculture (Repeat of Finding 2024-001) Compliance Requirement: Eligibility, Program Income Type of finding: Internal Control Over Compliance (significant deficiency) Recommendation: The Organization should strengthen its internal controls with adopted policies and procedures to ensure a review process is established through adequate segregation of duties. The Organization should consider assessing and realigning the duties and responsibilities of the Executive Director, Administrative Assistant, and Alamosa Property Manager to provide for a review process of tenant eligibility determinations and the monthly housing assistance payment requests for the Sierra Vista Alamosa Housing Complex. Action Taken: This finding was from the actions of the pervious on-site manager, concerning the Alamosa Complex only. Sierra Vista/Alamosa Complex has already implemented the internal control concerning compliance in house. Priscilla and Alonzo will make sure that all internal compliance issues are segregated and check by at least 2 persons in the office, and if needed, the Executive Director can request viewing of internal control procedures as well. Alonzo and Priscilla prepare and review along with signatures of the review and approval dates of internal affairs. "This institution is an equal opportunity provider." If there are questions regarding this plan, please call the responsible party at (719)852-5505. Sincerely yours, Corinna Garcia Executive Director Monte Vista Community Center Housing Authority, Inc.

Finding 2025-02 Schedule of Expenditures of Federal Awards. Management concurs with the finding. We will continue to refine our process under GAAP reporting to reduce reconciling items.

Inclusive Ventures Small Business Program – Assistance Listing No. 59-059 Recommendation: We recommend that management develop and implement written procedures to track, record, and report program income, including interest earned on Federal advances. 2660 Riva Road, Suite 200, Annapolis, MD 21401 􀆔 t (410) 222-7410 􀆔 f (410) 222-7415 􀆔 www.aaedc.org Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We recognize the importance of maintaining clear, consistent procedures to ensure that all program income, including interest earned on Federal advances, is properly tracked, recorded, and reported in compliance with applicable requirements. To address this recommendation, management will develop and implement formal written procedures that outline the processes and responsibilities for identifying, documenting, and reporting program income. These procedures will include guidance on calculating and recording interest earned on Federal funds, as well as periodic reconciliation and review controls to ensure accuracy and completeness. In addition, relevant staff will be trained in the new requirements to promote consistent application and ongoing compliance. Name(s) of the contact person(s) responsible for corrective action: Lisa Grunder, Vice President of Administration Planned completion date for corrective action plan: March 23, 2026.

Audit Period: Year End June 30, 2024 The Road Home Corporation d/b/a Louisiana Land Trust (LLT) respectively submits the following corrective action plan for the year ended June 30, 2024. Condition: Louisiana Land Trust (LLT) does not have adequate controls in place to ensure that LLT credit card transactions and bank accounts are properly monitored and comply with its own policies and federal program regulations, increasing the risk of theft and fraud. Actions to be taken – 1. Management concurs and has taken action to make certain that all credit card transactions/ statements as well as all bank accounts are monitored on a regular basis to ensure that each account reconciles properly. 2. Management has changed its internal procedures and reassigned responsibilities to staff to help ensure proper checks and balance take place on a regular basis. 3. Management has worked with our new outside CPA firm to integrate all accounts into our bookkeeping system to allow for automatic transaction reconciliations. If there are any questions regarding the actions taken, please feel free to reach out and let me know.

During the period that was reported on the finding, the manager in charge of the CDGB-MIT program was taking on additional workload while carrying out onboarding and training procedures for the program coordinator that would be assigned to assist with carrying out both programatic and administrative duties under the grant. Although the coordinator's training period concurred with the report's deadline, causing the one-day delay in submitting the required information, subsequent reports are being completed in a timely manner due to the addition of program personnel.

Federal program title: Community Development Block Grant – CFDA 14.228 Condition: During our test of the reporting requirements, we determined that the County did not submit the required reports under Reporting of the Compliance Supplement. Recommendation: CLA recommends the County develop procedures, such as reporting checklist to ensure that reporting requirements are tracked and met. Additionally, CLA recommends that the County perform cross training with employees to ensure that knowledge is shared among the team members. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Staff will work to prioritize the completion of the past due reporting requirements. All active CDBG grant projects have been completed with all outstanding reports for the closeout being submitted. The only outstanding reports as of the writing of this are the required PI reports. Staff will do their best to get these updated and submitted. Once caught up, cross-training will be explored. Name(s) of the contact person(s) responsible for corrective action: Suzie Hawkins Senior Financial Analyst – County Administrative Office Planned completion date for corrective action plan: As time Allows

PDOA: 1. Strengthen internal controls over program income. 2. Recalculate FFY 2024 program income balances and submit amended report. 3. Implement a tracking log to actively monitor program income reporting levels. 4. Improve reporting of cost sharing and program income to ensure it is in compliance with federal regulations. 5. Provide training to PDA and AAA fiscal staff on program income. Anticipated Completion Date: 06/30/2026 Contact Names: Jason Kavulich, Secretary of Aging ; Jennifer Beck, Fiscal Management Specialist & PDOA Audit Liaison OB-OCO: As of 02/25/2026, the procedures for preparing the Federal Financial Report (SF‑425) were updated to include additional controls for reviewing and certifying the report prior to submission. These updates require the Pennsylvania Department of Aging to verify all program income forms to ensure they are relevant and applicable to the reporting period covered by the SF‑425. The updated procedures also require PDOA to conduct a full review of the SF‑425 and certify its accuracy via email before the Bureau of Accounting and Financial Management completes the submission in PMS. By June 30, 2026, OCO will further enhance the accuracy of financial reporting on the SF‑425 by updating the Title III working papers to incorporate linked data sources and formulas, reducing reliance on manually entered figures. Anticipated Completion Date: 06/30/2026 Contact Names: Jamie Jerosky, BAFM Assist. Director; Matt Stubb, BAFM Integrated Financial Service Mgr.; Carol Waite, BAFM Mgr.

2025-005: Funds available from program income were not disbursed before the Organization requested additional drawdowns. The Organization was not appropriately with tracking and utilizing program income. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: August 2025 Views of responsible officials and planned corrective actions: Issues identified during the audit were indicative of an overall lack of controls and processes due to the change in Finance department staff and loss of knowledge. As of August 2025, program income is no longer being generated by the grant. The new CFO and Finance staff have also implemented processes and controls to ensure proper tracking and utilization of program income related to grants. The CEO will provide ongoing oversight to ensure processes and controls are being adhered to by the Finance Department.

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Community Development Block Grants/Entitlement Grants Assistance Listing Number: 14.218 Finding Summary: One of three quarterly PR29 Cash on Hand reports submitted to HUD contained an inaccurate figure for revolving funds received on Line 13, due to insufficient internal review and reconciliation. Additionally, the amount on Line 5 on the PR26 Financial Summary Report was unable to be supported. Corrective Action Plan: The City will strengthen internal controls over CDBG reporting by: • Implementing a documented secondary review process for all PR29 and PR26 reports. • Requiring reconciliation of source data to report figures prior to submission. Responsible Individual(s): Melissa Kinzler, Finance Director Tom Hazen, Grant Administrator Anticipated Completion Date: January 2026

HIV Formula Care Grant (AL93.917) - Significant Deficiency 2025-001 Management agrees with the finding and will enhance the current processes. Subsequent to year end, management created a tool to ensure all elements of program income, as well as related expenses incurred, are properly tracked, reported, and utilized in accordance with federal requirements. Additionally, written policies are being drafted to reflect these procedures. Implementation is expected by January 31, 2026.

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

This problem only applied to the HHS program that was eliminated in December 2023. All other programs that we contract with are paid in arrears and there are no advances. We have proposed a settlement agreement with HHS to eliminate the overpayment and interest. Benjie Read will be responsible for the settlement agreement, by October 31, 2026.

"Management concurs that stronger documentation surrounding the collection and monitoring of Continuum of Care program income would have strengthened internal controls and the audit trail. The finding relates to a program that has since been discontinued. Throughout the audit period, all program income that was collected was used for allowable program purposes; however, management acknowledges that documentation supporting assessment, collection, monitoring, and reconciliation procedures should have been more comprehensive. Although this activity is no longer part of the Organization's operations, Ability1st has strengthened its overall documentation standards. Should the Organization administer future programs involving program income, written policies and procedures will be implemented prior to program implementation and will include: • documented fee assessment methodology; • collection and deposit procedures; • reconciliation requirements; • supervisory review; • record retention standards; and • periodic internal monitoring. Management believes these procedures will provide an appropriate level of accountability and compliance with federal requirements should program income be collected in the future. Responsible Official: Executive Director Implementation Date: Completed for discontinued program; procedures will be implemented before any future program income activity."

The Village will submit required reports on time.

The Authority implemented a new policy to track and document program income: a. Upon receipt of program income, it shall be entered individually into IDIS and assigned to an activity or activities within fifteen (15) calendar days of receipt. b. At the next request for funds for an activity which includes funding from program income, program income shall be used prior to requesting federal funds for the activity. c. The request for federal funds shall be prepared by the Fiscal Officer and reviewed by one of the Assistant Fiscal Officers to determine if program income is being used prior to the request of federal funds. d. If it has been determined and documented that program income is being used prior to the request for federal funds, the request shall be forwarded to the Executive Director for approval. This finding has since been resolved in 2025, with a new policy developed and implemented on April 1, 2025.