Corrective Action Plans

2024-002 Internal Controls Over Compliance - Special Tests and Provisions (Tri-Partite Board) - Community Service Block Grant (CSBG) - CFDA 93.569 - Grant Period Year Ended September 30, 2024 Criteria: In accordance with the requirements of the Program outlined in ALN 93.569 CSBG, and the CSBG Act at 42 USC 9910, nonprofit organizations administer CSBG through a board. One-third (1/3) of the board members must be chosen in a democratic selection process adequate to assure that these members are representative of the low-income individuals and families served. An additional 1/3 of the board must be public elected and/or appointed officials. Condition: The Agency was unable to meet the 1/3 requirements for the public elected/appointed officials and the 1/3 requirement for low-income individuals and families served during the year ended September 30, 2024. Cause: While the Agency's controls did identify a lack of participation in these areas, they did not include control activities to resolve the non-compliance in a timely manner. Effect: The Agency is out of compliance with the provisions requiring Tri-Partite Board as defined by the CSBG Act at 42 USC 9910. Recommendation: We recommend the Agency recruit board members from the areas identified for compliance with this requirement. Corrective Action Plan: The Capital Area Community Action Agency Board membership fluctuates over time. Sometimes there are several public representatives or their designees on the board. Other times there are several private sector representatives. As a tripartite board, low-income representatives are always on the board. While the numbers are not always equal, the Agency strives to meet the spirit of the law in its recruitment efforts. The Board will work to develop a more robust recruitment method to ensure a balance of representation from the three sectors, as well as the eight counties we serve. We anticipate correcting this finding by the next review period.

The policies and procedures around the Single audit will be reviewed, assigning responsibility, and implementing tracking systems. The CEO, COO, CFO, and Grants Manager will be responsible for overseeing the data collection and submission process internally, keeping track of the audit deadlines to ensure that all processes are moving forward in a timely fashion. All relevant parties will be trained on the reporting requirements and due dates.

Finding 2024-005 Significant Deficiency in Internal Control over Compliance and Noncompliance – Reporting Deadline for Federal Single Audit Questioned Programs ALN 15.022 Tribal Self Governance Agencies: Department of Interior ALN 84.250 American Indian Vocational Rehabilitation Services Agencies: Department of Education Award Numbers GT-OSGT812- Year 2013 GT-OSGT812- Year 2017 GT-OSGT812- Year 2018 GT-OSGT812- Year 2019 GT-OSGT812- Year 2020 GT-OSGT812- Year 2021 GT-OSGT812- Year 2022 GT-OSGT812- Year 2023 GT-OSGT812- Year 2024 GT-OSGT812- Year 2025 H250N210051- Year 2023 H250N210051- Year 2024 Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2024. Status In Progress. Management’s Corrective Action Plan Management acknowledges that the data collection form and reporting package was filed late for Fiscal Year 2024 due to employee turnover. As these positions have been filled subsequent to year end, we do not anticipate any such issues for Fiscal Year 2025.

Finding 2024-003 Significant Deficiency in Internal Control Over Compliance – Eligibility Application Review Questioned Programs ALN 84.250 American Indian Vocational Rehabilitation Services Agencies: Department of Education Award Numbers H250N210051- Year 2023 H250N210051- Year 2024 Condition The Association is not consistently following their own internal control procedures for keeping evidence of reviewing the eligibility certification form. Status In Progress Management’s Corrective Action Plan Vocational Rehabilitation (VR) will update its required document checklist to include a check for required signatures. The intake staff will utilize the checklist for its first level of application intake to ensure all supporting documents are included and the application is complete, including required signatures. Another step VR will add in the process is a second level of review. Each application that has been approved for support will be reviewed by a second reviewer before final approval. Further, each application that exceeds an award of $10,000, will be reviewed by a third approver. Since applications for services are sometimes foreword to AVCP VR by the Yukon Kuskokwim Health Corporation Audiology Department, AVCP VR will conduct regular training to Audiology staff on the correct process for completing its application. Internally, AVCP VR will continue to conduct yearly training to Village based AVCP staff, who sometimes accept and forward applications to the VR staff, on the correct process for completing its application. Lastly, AVCP VR will update its internal policies and procedures to include these four key steps to ensure applications are complete and signed

Director of Operations & Impact will draft an 18-month reporting deliverables schedule to be reviewed quarterly. The schedule of reporting deliverables will be added to a dedicated calendar in SharePoint, shared with the President and programs team staff, and a series of reminders and notifications will be integrated into the system. The system itself will be reviewed every six months going forward to address any technological issues and make recommendations for improved functionality. Planned Implementation Date of Corrective Action: 9/22/25 Person Responsible for Corrective Action: Director of Operations & Impact

Walla Walla County is taking significant steps to address the recent audit finding regarding inadequate internal controls for compliance with federal requirements. Development of a New Policy To rectify this issue, the county is committed to formulating a new policy specifically tailored to meet federal standards. This development process is already in motion, with the expected completion date set for December 2025. Enhancing Internal Controls We believe that the new policy will significantly improve our internal controls and ensure full compliance with federal mandates. Training Initiatives Additionally, we will seek training opportunities to increase the knowledge of all staff regarding federal programs and compliance requirements, ensuring adherence to these programs and grants.

Views of Responsible Officials and Planned Corrective Action — Grace House has created and will implement the following new controls: a) Every reimbursement request made by any employee will require approval from the Executive Director, Assistant Director, or board of directors vote where appropriate. b) For rental invoices, the immediate supervisor must approve all rental invoices for payment processing before being submitted to the administrative office. If the immediate supervisor is absent, the invoice must be approved by the Executive Director or Assistant Director. c) When a new client invoice is submitted for approval for an existing approved landlord, the invoice along with the traditional client identifying information will be reviewed by both the immediate supervisor and the Executive Director. d) When a new client invoice is submitted for approval for a new landlord, the invoice will be reviewed by both the immediate supervisor and the Executive Director. Each invoice requires a W9 form to validate the legal name, property records verifying ownership matching the legal name on the W9, a picture ID of the individual listed on the W9, and a copy of the agreement if a property management company is listed on the W9 instead of an individual. e) All new clients and landlords will be researched through an investigative software to prove there is no evidence of false identity. f) Grace House has contracted an independent certified fraud investigator to conduct periodic reviews for compliance with fraud prevention policies at least semiannually but beginning quarterly through 2025.

Management concurs. Procedures have been established to ensure timely submission of the Single Audit Reports and SF-SAC forms. Internal deadlines will be implemented to allow adequate time for audit completion and compliance with the Uniform Guidance.

Condition: The County did not report project obligations or expenditures or provide a project description for funds spent under the revenue loss eligable use catagory. Cause: This condition appears to be the result of a misunderstanding of what was required by the Compliance and Reporting Guidance. Auditor Recommendation: We recommend that the County implement policies, procedures and internal controls to ensure that all required reporsts are submitted correctly and accurately and evidence of the submission is retained. Plan of Action: The Finance department will provide education to the other departments on which categories and what sort of expected documentation is needed for expenditures under this program and verify that they are appropriated to the correctly related funds. Finance staff will follow up with the departments prior to year end to ensure we have what documentation is needed, properly recorded. Date of implementation: Immediately and ongoing.

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.

Completion of audits by the required submission date of March 31st will be prioritized so Federal Audit Clearinghouse submission will occur by the due date.

Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027 Recommendation: We recommend the City implement procedures to ensure the accuracy of quarterly reporting and maintain supporting documentation for each of the amounts reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All quarterly reports were reviewed and combined into a single report. All obligations and expenses as of 6/30/2024 were examined and a determination of correct obligation and expenses was determined. These new numbers will be used for the next reporting period. The new report will continue to be used moving forward. Name(s) of the contact person(s) responsible for corrective action: Angie Murray Planned completion date for corrective action plan: 10/15/2025

Congressionally Mandated Projects - Assistance Listing #66.202 Recommendation: We recommend that the City strengthen its internal controls over federal reporting requirements to ensure timely compliance with all federal reporting deadlines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Department personnel inquired, through their contact for the grant, about the reporting requirements. Multiple reimbursement requests were submitted and the all payments were received. No notification was received regarding any missing reports. As of 7/24/2025, all reporting was up to date. Name(s) of the contact person(s) responsible for corrective action: Angie Murray Planned completion date for corrective action plan: 7/24/2025

Management agrees with the finding and will evaluate expenditures of federal awards each year to ensure the filings are done timely.

The Organization will revisit the internal control process around invoice submissions and reimbursement request review. The Organization has since hired an outsourced accountant to assist with record keeping and assisting with ensuring compliance with Uniform Guidance. The Organization strives to remain compliant with Uniform Guidance in all respects to present both accurate and transparent records. If the Missouri Department of Social Services or the U.S. Department of the Treasury have questions regarding this plan, please call Jennifer Gadsky, MSW, LCSW, Executive Director, at (314)-938-4414.

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.063 Condition: During our audit procedures, we noted that the 1 student withdrawal did not have a return to Title IV calculation completed timely as the student officially withdrew 8/29/23 and the calculation was not completed until 3/24/25. We also noted that the calculation that was performed did not include documentation of the control process to review and approve the calculations prior to changes being made to the student’s award. Auditors’ Recommendation: We recommend the institution maintain proper documentation in accordance with federal grantor requirements and ensure that the documents are readily available for review upon request, including monitoring of students with triggering events that require a return to Title IV calculation to be completed, reviewed, and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Auditors’ Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act that have not been completed and documented and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. The new systems are Jenzebar products and are fully compliant. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Student checks related to student refunds of Title IV federal financial aid was outstanding more than 240 days as of June 30, 2024. Auditors’ Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University is implementing financial internal controls policies and processes to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards and ensure compliance with the DOE. This includes procedures related to outstanding student refund checks over 240 days. Name(s) of the contact person(s) responsible for corrective action: Denise Johnson, Interim Controller, Bursar Dept. Supervisor Planned completion date for corrective action plan: June 30, 2025

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: 2 students of the 22 students selected for eligibility did not maintain academic satisfactory progress and were on probation but did not receive notifications. Auditors’ Recommendation: We recommend that the University review its satisfactory academic progress policy to ensure that all notifications are completed as required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

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.

Finding 2024-001 Condition During the year under audit, the Organization did not make two scheduled debt service payments when due as a result of insufficient available funds. The payments were subsequently remitted after the due dates; however, the Organization was in noncompliance with the terms of its debt agreements at the time of the missed payments. Corrective Action Plan Corrective Action Planned: As noted in Finding 2024-001, recommendations for management to strengthen its cash flow forecasting and monitoring processes to ensure that adequate funds are reserved and available to make debt service payments when due. Name(s) of Contact Person(s) Responsible for Corrective Action: Joann Bazanos, CEO/CFO Anticipated Completion Date: Management is aware of the requirement to make timely debt service payments and has implemented procedures to ensure funds are available when payments are due. As of the report dated October 3, 2025, the Organization is current on all required debt service payments.

Internal Controls over Grant Management (Significant Deficiency and Noncompliance) Recommendation: We recommend the City develop a grants manual or additional written policies that comply with the requirements of 2 CFR 200 and ensure compliance. Response to 2024-001: Internal Controls over Grant Management Significant Deficiency and Non-Compliance In response to the Deficiency in the City of Tallassee’s corrective action plan, the City was in the process of establishing a written financial management system in accordance with 2 CFR 200.302 to include written procedures to implement requirements for payment methods and determine allowability of costs in accordance with subpart E. The City of Tallassee has financial management internal controls in place. All of the City’s grant activities (Federal and State) are tracked in funds under unique assigned general ledger numbers for each grant awarded to the City. The City contracts out grant management to certified and approved grant management commissions and engineering firms for required tracking and reporting to the appropriate state and federal agencies.

The Finance Department Managemetn will implement policies to ensure timely financial reporting and esnure the timely completion of an audit. The city expects to have these issues addressed by June 30, 2026. The responsible party is Patrick Williams, Chief Accountant

CORRECTIVE ACTION PLANS Oversight Agency for Audit: U.S. Department of the Treasury The City of Haverhill, Massachusetts respectfully submits the following corrective action plans for the year ended June 30, 2024. Name and address of the independent public accounting firm: CBIZ CPAs P.C. 9 Executive Park Drive, Suite 100 Merrimack, NH 03054 Audit Period: July 1, 2023, through June 30, 2024 The findings from the June 30, 2024, schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding 2024-005: Improve Controls and Documentation Over Allowability of Costs Federal Agency: U.S. Department of Education Award Name(s): Twenty-First Century Community Learning Centers Assistance Listing Number(s): 84.287, 84.287C Award Year: 2023, 2024 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the City is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. The Code of Federal Regulations Section 200.403(g) states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation. Condition and Context: A sample of payroll expenditures were tested in order to determine if costs were allowable and adequately approved. As a result of our testing, it was determined that one payroll transaction had no timesheet approval, and one payroll transaction was self-approved. Payroll expenditures charged to the programs are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. This supporting documentation should be standardized and should include all required elements in accordance with applicable cost principles. Cause: The City did not have adequate controls in place to provide sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements. Effect or Potential Effect: Due to the weakness in internal controls and compliance noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Questioned Costs: Due to the condition noted above, we were unable to determine if the costs charged to the applicable grants are allowable. AL Number(s) Name of Federal Program or Cluster Questioned Costs 84.287, 84.287C Twenty-First Century Community Learning Centers $5,450 Recommendation: Management should enhance procedures and controls in place over the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Views of Responsible Official: The School Department recognizes the weaknesses identified in grants management, as well as in the approval and allocation of allowable costs. To address these issues, the School Department has recently hired a new Business Manager/Chief Financial Officer (CFO). This individual is responsible for implementing appropriate internal controls that align with Best Practices, particularly in key areas such as invoice approval, payroll approval, grants management, and procurement compliance. To ensure ongoing improvement, training will be provided continuously for all staff members responsible for managing federal grants. This training will include; • Procedures to reconcile internal records with federal and state reports. • Maintain a process to ensure that costs charged to grants are allowable, necessary and reasonable, and properly allocated, and that these determinations are made in a consistent manner. • Determine whether indirect costs will be allocated to grant programs, and if so, maintain an appropriate process to make the allocation. • Maintain a process to track information about local matching funds, including identification of the source of such funds. • Identify and segregate costs as necessary for the grant (e.g., separate allowable and unallowable costs, separate direct costs from indirect costs, and separate administrative costs. • Account for and track grant-funded capital items. • Document grant procedures. • Maintain a comprehensive list of reporting requirements and a reminder system for meeting the reporting deadlines. • Identify who is responsible for the various reporting requirements. • Establish methodologies for the preparation of specialized reports. • Establish processes for obtaining all of the information needed for the Schedule of Expenditures of Federal Awards (SEFA). • Develop and document an understanding of audit requirements specific to grants, including those in Generally Accepted Government Auditing Standards (GAGAS), Generally Accepted Auditing Standards (GAAS), and Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). • Develop and document an understanding of audit requirements for grant close-outs. • Report if any process or internal control issues identified were resolved.

CORRECTIVE ACTION PLANS Oversight Agency for Audit: U.S. Department of the Treasury The City of Haverhill, Massachusetts respectfully submits the following corrective action plans for the year ended June 30, 2024. Name and address of the independent public accounting firm: CBIZ CPAs P.C. 9 Executive Park Drive, Suite 100 Merrimack, NH 03054 Audit Period: July 1, 2023, through June 30, 2024 The findings from the June 30, 2024, schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding 2024-004: Improve Controls and Documentation Over Allowability of Costs Federal Program Information Federal Agency: U.S. Department of Education Award Name(s): Title I Grants to Local Educational Agencies Assistance Listing Number(s): 84.010 Award Year: 2023, 2024 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Award Name(s): COVID-19 – Education Stabilization Fund Assistance Listing Number(s): 84.425 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Award Name(s): Twenty-First Century Community Learning Centers Assistance Listing Number(s): 84.287, 84.287C Award Year: 2023, 2024 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Award Name(s): Special Education Cluster Assistance Listing Number(s): 84.027, 84.173 Award Year: 2023 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the City is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. The Code of Federal Regulations Section 200.403(g) states that for costs to be allowable under Federal awards, they must be adequately documented and there must be sufficient documentation. Condition and Context: A sample of invoices were tested in order to determine if costs were allowable and adequately approved. As a result of our testing, it was determined that invoices were not approved for two transactions in the Title I Grants to Local Educational Agencies program and three invoices in the COVID-19 Education Stabilization Fund program. In addition, invoices were not able to be provided for three invoices in the COVID-19 Education Stabilization Fund program, one invoice in the Twenty-First Century Community Learning Centers program, and one invoice in the Special Education Cluster. Cause: The City did not have adequate controls in place to ensure invoices were properly approved and retained. Effect or Potential Effect: Due to the weakness in internal controls and compliance noted above, there is a risk that amounts charged to federal awards may not be allowable or in accordance with applicable cost principles. Questioned Costs: Due to the condition noted above, we were unable to determine if the costs charged to the applicable grants are allowable. AL Number(s) Name of Federal Program or Cluster Questioned Costs 84.010 Title I Grants to Local Educational Agencies $82,488 84.425 COVID-19 Education Stabilization Fund $136,876 84.287, 84.287C Twenty-First Century Community Learning Centers $1,305 84.027/84.173 Special Education Cluster $1,945 Recommendation: The City should enhance internal controls over the invoice approval and retention process in order to provide reasonable assurance that federal award transactions are allowable and in accordance with the applicable cost principles. Views of Responsible Official: The School Department recognizes the weaknesses identified in grants management, as well as in the approval and allocation of allowable costs. To address these issues, the School Department has recently hired a new Business Manager/Chief Financial Officer (CFO). This individual is responsible for implementing appropriate internal controls that align with Best Practices, particularly in key areas such as invoice approval, payroll approval, grants management, and procurement compliance. To ensure ongoing improvement, training will be provided continuously for all staff members responsible for managing federal grants. This training will include; • Procedures to reconcile internal records with federal and state reports. • Maintain a process to ensure that costs charged to grants are allowable, necessary and reasonable, and properly allocated, and that these determinations are made in a consistent manner. • Determine whether indirect costs will be allocated to grant programs, and if so, maintain an appropriate process to make the allocation. • Maintain a process to track information about local matching funds, including identification of the source of such funds. • Identify and segregate costs as necessary for the grant (e.g., separate allowable and unallowable costs, separate direct costs from indirect costs, and separate administrative costs. • Account for and track grant-funded capital items. • Document grant procedures. • Maintain a comprehensive list of reporting requirements and a reminder system for meeting the reporting deadlines. • Identify who is responsible for the various reporting requirements. • Establish methodologies for the preparation of specialized reports. • Establish processes for obtaining all of the information needed for the Schedule of Expenditures of Federal Awards (SEFA). • Develop and document an understanding of audit requirements specific to grants, including those in Generally Accepted Government Auditing Standards (GAGAS), Generally Accepted Auditing Standards (GAAS), and Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). • Develop and document an understanding of audit requirements for grant close-outs. • Report if any process or internal control issues identified were resolved.