Corrective Action Plans

Contact Person Michelle Erickson Corrective Action Plan The Abused Adult Resource Center will form a process to ensure filing of personnel action forms is consistent and that hardcopies of personnel action forms are available. Completion Date Fiscal Year 2025

Contact Person Michelle Erickson Corrective Action Plan The Abused Adult Resource Center’s payroll allocations for grants will be documented on timesheets and the hard copies will be filed or scanned onto a local drive kept by the Center. Completion Date Fiscal Year 2025

Contact Person Michelle Erickson Corrective Action Plan The Abused Adult Resource Center’s payroll allocations for grants will be documented on timesheets and approved and the hard copies will be filed or scanned onto a local drive kept by the Center. Completion Date Fiscal Year 2025

The organization acknowledges that time and effort procedures were not consistently followed throughout FY24. The organization has implemented a new system of reporting designed to capture time and effort of all employees charged to government grant and contracts, as well as other grants and contracts awarded to the agency from the philanthropic community. Additionally, along with the timesheet, the agency now requires that an attestation statement is prepared quarterly by Program Managers and Directors for all employees charged to grants to attest to the actual amount of time spent and allocated to the grants. The organization has expanded administrative oversite of the finance department and financial data and has hired a Finance Director who has spent a considerable amount of time training staff and managers regarding their allocations and their obligations to track their time. The Finance Director has trained our expanded finance team on ensuring that accounting policies and procedures are strictly adhered to and that GAAP is uniformly applied to all financial data of the agency.

The organization acknowledges that unallowable rent costs were claimed and payment received under government grants and contracts resulting in overstating revenues for FY24, and that adjustments were necessary to the financial statements to correct the resulting deficiencies. As indicated, however, this overstating was due to the unique situation that existed as a result of the landlord’s breaking the organization’s lease, suddenly and without notice. Rent costs were claimed for as long as the organization was liable for the rent. After the liability was forgiven by the landlord, rent costs were returned to the funders.

A procedure has been created for this and will be implemented and looked at 1/4ly so funds can be spent down during the school year. Immediate steps were taken to do a spenddown plan and the food serviced fund was used for the program to bring down the fund balance to less than the three-month average expenditures.

Training has been completed for staff responsible for the MOE. In the past ten years the MOE’s were completed both ways and always accepted by the STATE. A procedure has been completed, that includes an internal review process to verify the accuracy of data used for MOE reporting. We are working with the New Hampshire Department of Education to correct and resubmit the five sets of worksheets using the appropriate financial figures.

Management will reimburse the County for unallowable costs. Management will also strengthen internal controls over cost allowability, including staff training, implementation of formal pre-approval process, and a documented review checklist prior to reimbursement submission related to federal programs to ensure compliance.

Management will update the written conflict of interest policy to clearly define disclosure requirements. All employees and board members involved in procurement will complete an annual conflict of interest disclosure form. The Chief Executive Officer and Director of Finance will review and maintain all conflict of interest disclosures prior to awarding any contract. Staff training on conflict of interest compliance with be conducted by December 31, 2025.

Federal award findings and questioned costs 2024-001. Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names:84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Luisa Ott Anticipated completion date: June 30, 2025 The District agrees with the finding. After reviewing the students in the finding, the District re­processed the Return of Title IV calculation. The students records were updated and resulted in an amount of $109.45 to be returned to the students by offsetting their current balance with the District. The District will fund the reimbursement with institutional funds. During the fiscal year ending June 30, 2024, the District created a supporting automated processes to identify potential Return to Title IV accounts. This new process utilizes the student information system to automatically compute student Return to Title IV calculations. The District will also be implementing new procedures to ensure that the proper amount of scheduled breaks are included and reviewed as a final step before returning the funds.

The Financial Aid and Registrar’s Offices are refining the withdrawal notification and reconciliation process to ensure that both official and unofficial withdrawals are accurately identified and routed for R2T4 calculation within the required timeframe. All identified cases were reviewed, corrected, and documented. The funds totaling $31,830 (Direct Loans) and $3,499 (Pell Grants) have been returned, and student accounts were reconciled accordingly. The Financial Aid Office, in coordination with the Information Technology team, is reviewing the SIS configuration to determine why certain Fall 2024 calculations were one day off, despite correct data entry. Adjustments will be made to eliminate any system-level rounding or timestamp discrepancies that could affect future calculations. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

This finding was related to staff turnover within the financial aid, student accounts and business offices. The hiring of qualified staff properly trained should avoid this error going forward. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

Finding 2024-003: Incorrect Refund Calculation Comments on Finding and Recommendations: The College agrees with this finding as determined in the audit and states that the College had deficiencies related to the the return of funds to the Department of Education based on a miscalculation of the last day of attendance. Actions Taken or Planned: The College has returned the funds to the Department of Education and has instituted greater coordination between our departments including but not limited to the Academic Dean, Registrar, Accounting/Bookkeeping, Student Services and Financial Aid to ensure that last dates of attendance are accurately calculated to prevent future occurrences.

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Quincy, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: CBIZ CPAs P.C. 53 State Street, 17ᵗʰ Floor Boston, MA 02109 Audit period: July 1, 2023 through June 30, 2024 The finding from the June 30, 2024, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Financial Statement Finding Finding 2024-001: Certain Department Expenditures Exceeding Appropriated Amounts – General Fund – Significant Deficiency Condition: During 2024, it was noted that expenditures in the public safety and education functions exceeded the amounts appropriated by the City Council for the fiscal year. Criteria: Massachusetts general law prohibits the City from incurring liabilities in excess of appropriations in each department with certain specific exceptions, such as snow and ice removal costs, state and county charges, and debt service. Prudent budgetary control and monitoring are essential to ensure compliance with such requirements. Cause: The overspending of these appropriations occurred due to an inadequate internal control system to ensure timely budget amendments. Effect: Overspending appropriations in the General Fund constitutes noncompliance with state law and exposes the City to potential fiscal consequences, as the state may require the City to raise such deficits in the subsequent fiscal year. It may also indicate a weakness in the City's internal controls over budgetary compliance. Recommendation: We recommend that City management strengthen internal controls over budgetary compliance. Management should strengthen its’ procedures throughout the year to monitor budget-to-actual expenditures and ensure timely action, such as requesting formal budget amendments when actual expenditures approach or exceed authorized appropriations. Views of Responsible Officials: The Municipal Finance Office will be implementing procedures to ensure that the Municipal Finance Office and relevant department heads document reviews of budget to actual reports monthly throughout the year, with increased review intervals during June. The purpose of this increased monitoring is to ensure that potential budgetary appropriation deficits are identified in a timelier manner that will allow for any necessary budgetary amendments to be approved by the City Council. Finding 2024-002: Information Technology Controls in Financial Statements – Significant Deficiency Condition: During 2024, we noted the following deficiencies relating to information technology controls in the financial statement reporting process: • User Access Mirroring: When new users are provisioned in the accounting system, access rights are often “mirrored” from existing users without sufficient review of job responsibilities. This practice results in users receiving access to system functions beyond what is necessary for their roles and may compromise segregation of duties. • Privileged Access: A review of privileged user listings indicated access accounts with no exclusionary parameters. • Inadequate Controls Over System Upgrades: When implementing accounting system upgrades, controls over change management including testing, documentation, and approval, were not adequately designed or consistently applied. Instances were noted where upgrades were implemented without thorough pre-deployment testing and formal approval from finance or IT management. Criteria: Best practices and standards for internal control require: • Role-based access provisioning aligned with users’ responsibilities and effective segregation of duties. • The use of exclusionary parameters enhances the ability to monitor system access for unauthorized access. • Robust change management controls over system upgrades, including testing, documentation, and management approval, to ensure system integrity and minimize the risk of errors or unauthorized changes impacting financial reporting. Cause: These deficiencies appear to result from a lack of formalized policies and procedures for user access provisioning and for managing and documenting accounting system upgrades. Effect: The deficiencies increase the risk of: • Unauthorized access or inappropriate transactions due to excessive or incompatible user rights, undermining segregation of duties and accountability. • Errors, omissions, or unauthorized changes introduced during system upgrades, potentially affecting the integrity and accuracy of financial data and financial statement preparation. Recommendation: We recommend that City management: • Implement procedures to provision user access based on individual roles and responsibilities, with documented review and approval to ensure segregation of duties is maintained. This should be evidenced by written approval that is approved by Municipal Finance and Information Technology office. • Enhance the current process of implementing accounting system upgrades, including requirements for comprehensive pre-deployment testing, clear documentation, and explicit written approval from the Municipal Finance Office and the Information Technology office, prior to going “live” with the upgrade. • Periodically review system access and upgrade processes to ensure ongoing compliance with internal control standards. Views of Responsible Officials: The City will keep these recommendations in mind as it works to upgrade its already existing best practice IT control environment. Finding and Questioned Costs – Major Federal Program Audit Criteria or Specific Requirement: Uniform Guidance section 2 CFR § 200.430(g) requires non- Federal entities to maintain records that accurately reflect the work performed by employees whose salaries are charged, in whole or in part, to Federal awards. For employees working on a single Federal program, semi-annual certifications are required to document time and effort. Condition and Context: During testing of 40 payroll transactions for employees charged to the Special Education program, the City was unable to provide semi-annual certifications supporting that salaries and wages were properly allocated to the grant. Cause: The City did not have adequate procedures in place to ensure that required time and effort certifications were retained and readily available for payroll charged to Federal awards. Effect or Potential Effect: Failure to maintain required time and effort documentation resulted in the questioned costs documented below. Questioned costs are reported as follows: AL Number: 84.027 Name of Federal Program or Cluster: Special Education Cluster Questioned Costs: $2,572,675 Recommendation: We recommend the City establish and implement procedures to ensure that semiannual certifications are completed, maintained, and reviewed for all personnel whose salaries are charged to Federal awards. Views of Responsible Officials: This is a questioned cost due to the School Department not having completed certain administrative paperwork, required by grant regulations. We have implemented procedures during FY2025 to address this matter. The required paperwork will be retained on file going forward.

To prevent recurrence, management will implement the following actions: 1. Upgrade Accounting Services: The Foundation will upgrade its accounting services to ensure stronger internal controls and compliance with federal requirements. This will be accomplished either by enhancing the level of services provided by the current accounting firm or, if it is determined that the curret provider cannot meet the Foundation’s needs, byinitiating a formal RFP process to identify and engage a qualified service provider with expertise in nonprofit and federal grant compliance. This action is targeted for completion by March 31, 2026, and will be led by the Chief Executive Officer. 2. Consolidate Service Arrangements: Evaluate and move certain contracts and services currently managed through the affiliated LLC under the Foundation’s umbrella to reduce complexity and improve oversight. This action is targeted for completion by June 30, 2026 and will be led by the Chief Executive Officer.

Condition: The District did not claim expenditures in conformity with the approved detail budget. Plan: The Business Office will install stricter controls over grants and grant reporting to ensure these findings are fixed. Due to the late completion date of this audit, the results will not be seen until the FY26 audit. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Dr. Albert Holmes

Condition: The District did not claim expenditures in conformity with the approved detail budget. Plan: The Business Office will install stricter controls over grants and grant reporting to ensure these findings are fixed. Due to the late completion date of this audit, the results will not be seen until the FY26 audit. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Dr. Albert Holmes

Contact Person Responsible for the Corrective Action Plan: County Finance Department – Dominic Ochei, Chief Financial Officer (CFO) Corrective Action Plan: The Finance Department will work with the County’s Procurement department to ensure that the procurement policies are adhered to, for all grant-related expenditures. Anticipated Completion Date: December 2025

Will speak to Department Heads and make sure that the language is added to contracts in regard to suspension and debarment. Will also have a form for vendors to sign if purchasing products. If we are not able to have the first two options done will be sure to use SAM.gov to look up information prior to ordering and take screen shots showing the date. An SOP will be written up and provided to auditors to make sure we are complying with requirements.

Grantee Response and Corrective Action Plan: AVLF concurs with the recommendation. The Organization will take the following corrective actions: 1. Remit corrected timesheets to the Agency for information purposes. 2. Revise the organization’s policy to include review and reconciliation of SER’s and timesheets prior to submission to the Agency. Responsible Parties: Jason Levister, Controller Date to be Completed: October 2025

1. Current Findings on the Schedule of Findings and Questioned Costs A. Finding 2024-001 Supportive Housing for the Elderly (CFDA# 14.157) Reserve for Replacement Deposits The Project did not repay the $31,958 Reserve for Replacement loan advance by the due date of May 1, 2024. (1) Comments on the Finding and Each Recommendation Management concurs with this finding, agrees with the auditor recommendation, and the Project has repaid the loan advance. (2) Actions Taken on the Finding The Project has repaid the Reserve for Replacement loan advance. B. Status of Corrective Actions on Findings Reported in the Summary Schedule of Prior Audit Findings The prior year finding was resolved.

Official: Janelle Lawrence, Executive Director. Date of Discussion: October 3, 2025. Planned Corrective Actions: To reduce misidentification of expenses for allowed activities, the Organization has implemented a dual-review process for all grant expenses to ensure that eligible costs are identified and submitted. Staff will also receive updated training on allowable expense categories to reduce misinterpretation. In monitoring payroll activities, the Organization has revised its grant payroll allocation process to ensure that duties performed under specific roles are billed at the appropriate rate. Future budgets will more clearly distinguish between roles and corresponding pay rates to prevent overages. All projects will undergo budget-to-expense reconciliation on a monthly basis to safeguard against missed claims and ensure that grant resources are maximized without exceeding allowable limits.

Corrective Action Plan Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Management acknowledges that the late engagement of the external auditors contributed to the delayed completion and submission of the Single Audit. To prevent recurrence, management will establish a proactive annual audit planning schedule that ensures auditor engagement well in advance of the reporting deadline Official Responsible for Ensuring CAP: Paul Walker, Chief Executive Officer Planned Completion Date for CAP: Immediately Plan to Monitor Completion of CAP: Management will maintain an annual audit calendar with milestone dates for financial statement preparation, auditor fieldwork, and report submission. The CEO will review progress monthly to ensure timely completion.

The shortage to the security deposit account was funded in August and September 2024 to correct the deficiency

In 2020, Intelligent Transportation Systems (ITS) was the sole bidder for the District’s camera project. The selected camera vendor was Hanwha Vision. In 2023, ITS was sold. At the time of the sale, ITS had only completed a portion of the project. On February 22, 2023, the District extended the GIS contract of Environmental Science Services (ES2) through February 17, 2024, and transferred the remaining scope of the camera project from ITS to ES2. The camera technology was integrated into the GIS environment for the District. The remaining cameras to be installed were purchased under the ES2 2023 contract at a lower price than in the ITS 2020 awarded low bid. In retrospect, the District should have rebid the project because the cameras were funded under the Port Security Grant Program (PSGP). The oversight was mainly caused by the transition of District executive personnel starting in 2023. Though this was an oversight, the camera technology integrated in the GIS environment increases the Port’s safety and security posture. The District now adheres to its newly adopted Procurement Policy to prevent recurrence. Management will ensure the following processes are added to the financial management policies and procedures over federal and state funds to ensure full compliance with federal procurement standards, Louisiana Bid Law, Procurement Code, contract management protocols, and grant administration requirements: • The District is reviewing and updating its procurement policies to ensure alignment with federal procurement regulations, including those outlined in 2 CFR Part 200 (Uniform Guidance). All PSGP-funded procurements will be subject to competitive bidding procedures, proper documentation, and approval protocols to ensure transparency and compliance. • The District has reinforced its procurement procedures to ensure that all purchases exceeding $60,000 are formally advertised and awarded in accordance with Louisiana Revised Statute 38:2212. For purchases between $30,000 and $60,000, staff are required to obtain, document, and retain at least three competitive quotes in the procurement file. No significant purchases will be made without prior approval from the governing authority. • Formal procedures have been implemented to ensure that all PSGP-related contracts are properly executed, monitored, and supported by complete documentation. These procedures will includes verification of scope, deliverables, and performance timelines prior to payment authorization along with any solicitations, bids or quotes, evaluations, approvals, and any supporting documentation required by law and internal policy.• The District has designated a marine inspector to oversee PSGP grant activities, including expenditure review, documentation standards, and reporting requirements. All disbursements will be cross-checked against the approved Investment Justification (IJ) and verified for compliance with the grant’s period of performance. • Management is actively consulting with FEMA to assess the allowability of identified questioned costs. The District will follow FEMA’s guidance to resolve any discrepancies and ensure that all expenditures meet federal standards. • Mandatory training sessions are being scheduled for staff involved in procurement, contract management, and grant administration. These sessions will cover federal compliance requirements, internal control