Corrective Action Plans

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.

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

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.

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

Finding Number: 2024-040 Finding Name: Inaccurate Information Included in the Financial Reports Finding Condition(s): The Illinois Department of Transportation (IDOT) did not prepare accurate federal financial status reports for the Airport Improvement Program. Additionally, the auditors noted the supervisory review procedures performed for this report were not at an appropriate level of precision to identify the errors identified in our testing. Finally, the auditors concluded that IDOT does not perform analytical procedures to identify potential errors or unusual fluctuations in reported amounts. Name of Contact Person(s): Joe Segobiano, Bureau Chief of Administrative Services – Illinois Department of Transportation, Division of Aeronautics Corrective Action(s): IDOT Aeronautics has developed requirements for and has published a request for proposal for a new Airport Project Management Systems (APMS). The replacement APMS will have an automated Federal Reporting Tool. One of the main requirements for the APMS replacement system is a real-time automated Federal Reporting Tool. Proposed Completion Date: July 1, 2026

Finding 2024-04 Schedule of Expenditures of Federal Awards. Management concurs with the finding. IHS will be working with the new outside CPA firm to develop a grant bridging report beginning FY2025/26.

Significant Deficiency in Internal Controls over Compliance Condition: As of the March 31, 2024 reporting date, the Town’s Project and Expenditure report had reported cumulative expenditures that were approximately $29,900 less than what was recorded in the grant fund on the general ledger Corrective Action Planned: FY2026 Grant activity is being reconciled to the General Leger with the help of the outside consultant. This process will be completed by the end of January, 2026. In FY26 reconciliation will be performed quarterly, and will be up to date no later than end of March 2026. Anticipated Completion Date: March 2026 Contact: Anna Noyes, Town Accountant

The Village will add additional procedures or controls to ensure all components of reporting federal expenditures are accurately reported.

The County will create a monthly reconciliation of program income for the grant. This reconciliation will ensure that amounts reported in the IDIS system agree to those amounts reported in Workday. The reconciliation will be reviewed by the department and a copy provided to the Fiscal Services Supervisor Senior – Grant Accounting each month for review by Fiscal Services.

U.S. Department of Housing and Urban Development 2024-003 Community Development Block Grants – Assistance Listing No. 14.218 Recommendation: We recommend that management identify its collections related to program income in a timely manner, modify its draw request appropriately, and report the accurate amounts to HUD. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The county will continue to report the correct amount of program income to HUD. Receipts will be entered more timely to include as much December program income in the IDIS system prior to that system’s 12/31 close, as any entries made after 12/31 are considered for the future year. Name of the contact person(s) responsible for corrective action: Director of Community Development Planned completion date for corrective action plan: 12/31/25

U.S. Department of Housing and Urban Development 2024-003 Community Development Block Grants – Assistance Listing No. 14.218 Recommendation: We recommend that management identify its collections related to program income in a timely manner, modify its draw request appropriately, and report the accurate amounts to HUD. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The county will continue to report the correct amount of program income to HUD. Receipts will be entered more timely to include as much December program income in the IDIS system prior to that system’s 12/31 close, as any entries made after 12/31 are considered for the future year. Name of the contact person(s) responsible for corrective action: Director of Community Development Planned completion date for corrective action plan: 12/31/25

Finding 2024-003 – As of the March 31, 2024 reporting date, the Town reported projects approved by the Select Board as obligated rather than purchases, contracts and agreements that met the Federal criteria of an obligation. The Projects and Expenditure report for the period ending March 31, 2024 was not filed until March 25, 2025. Corrective Action Planned: The Projects and Expenditure report for period ending March 31, 2024 was filed after the deadline due to a technological issue preventing access to the portal that was documented with both the U.S. Treasury and Login.gov Helpdesk. A new managed service provider working for the Town of Clinton was successful in correcting the issue for a timely filing of the 2025 report and all State and Local Fiscal Recovery Fund (SLFRF) projects were obligated by the 12/31/24 deadline. Completion Date: April 30, 2025 Contact: Michael J. Ward, Town Administrator

View of Responsible Official The Housing Trust acknowledges the finding. Prior staffing and system limitations created gaps in tracking recycled funds and aligning general ledger data to SEFA. Since then: - A dedicated Finance Manager now oversees all financial activities. - A grant-specific chart of accounts structure has been created in QBO. - Each grant now has a dedicated class and project for transaction tracking. - Recycled funds are being tracked separately from new funds in both QBO and the reimbursement log. - SEFA schedules will be reconciled monthly and reviewed with each billing cycle. Corrective Action Plan Timeline - Finalize and adopt new Grant Management Policies: by September 2025 - Implement monthly SEFA reconciliations: by September 2025 - Complete staff training on program income and federal grant tracking: by September 2025 Designated Employee Responsible for Corrective Action - Finance Manager - Assets Specialist Assistant - Accounting Technician