Corrective Action Plans

Finding 2025-001 Significant Deficiency in Internal Control over Compliance - Reporting AL# 10.553 & 10.555 – Child Nutrition Cluster Corrective Action Plan Employee re-alignment and training was initiated beginning in August 2025, as well as revision to the review process for meal counts to include a second review prior to submission. In addition, the new system was evaluated for proper configuration to mitigate further issues. Person(s) Responsible M. Thorne, Operations Coordinator Anticipated Completion Date Corrective actions were substantially completed by October 2025.

Condition: The Commission did not complete fiscal year 2025 recertifications. Planned Corrective Action: Staff have been retrained on the compliance requirements under the standards of the HCV Program through the oversight of the Rental Assistance Department Manager and Continued Occupancy Supervisor. The Department Manager and Supervisor continue to utilize all Yardi monitoring reports to ensure the Department is operating in accordance with industry standards. Reporting is be done and monitored monthly to meet set goals. Weekly, Department Manager has review the certification pipeline to ensure compliance and follow up with the Housing Specialist to ensure compliance and meeting set weekly and monthly goals and metrics. We continue to work in accordance with HUD rules and regulations where Annual Recertification processes are concerned. Per HUD communication provided to us, as of June 30, 2025, HCV is 100% compliant with HUD recertification requirements. Contact person responsible for corrective action: Felicia Burris, HCV Program Manager Anticipated Completion Date: 7/1/2025

November 21, 2025 FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Otis College of Art and Design agrees with the finding. Upon review of the finding, Financial Aid administration met with Registrar’s staff to create a new procedure whereby immediate reporting of withdrawals are made directly to NSLDS in addition to the regularly scheduled monthly reports to NSLDS through the National Student Clearinghouse (NSC). This immediate reporting should eliminate any timing issues with the monthly reports through NSC. In addition, a joint effort to streamline the routing of withdrawal forms to the appropriate departments for faster processing is underway. This reprocessing of the withdrawal forms will be implemented in the next 120 days. Responsible Office and Individuals The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto and Registrar, Nicole Raef are the responsible individuals for implementation of the corrective action plan. Corrective Action Plan The Registrar implemented a centralized tracking system that is now used for every withdrawal and graduation status change at all points in the semester. Registration reviews the withdrawal list weekly to ensure each change is accurately reflected in both NSC and NSLDS. To address graduation status updates, we are adjusting the timeline of our final spring enrollment report to NSC so it is submitted at the end of May. This allows NSC to transmit the data to NSLDS at the beginning of June resulting in fewer manual updates in NSLDS. Registration will then review all graduated students to confirm accurate NSLDS reporting rather than relying solely on Clearinghouse submissions. In addition, the Registration office will review and correct the NSC error report on a monthly basis. The Financial Aid and Registration offices will also initiate quarterly meetings to ensure timely submissions and address any emerging issues.

U.S. Department of Agriculture Passed Through the North Dakota Department of Public Instruction and the Minnesota Department of Human Services Federal Financial Assistance Listing # 10.568 All Awards Federal Financial Assistance Listing # 10.569 All Awards Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations and reviews for The Emergency Food Assistance Programs. Responsible Individuals: Kate Molbert, COO David Stachon, CFO Corrective Action Plan: The GPFB will ensure all documents for TEFAP programs have proper signatures by necessary parties going forward. An electronic signature process has been implemented to make the dissemination, review and storage of this process easier. Also, additional staffing has been hired to manage this process in the form of a Programs and Operations Compliance Manager with substantial compliance experience. Anticipated Completion Date: Immediate

Condition & Criteria: For three aviation program students, cost of attendance calculations were based on expected high-cost courses, but actual enrollment differed, resulting in overstated costs and excess aid disbursement. Auditor’s Recommendation: Adjust cost of attendance based on actual courses attended and fees incurred. Corrective Action: The Financial Aid Department now verifies actual course enrollment prior to disbursement for specialized programs, ensuring accuracy and compliance. Beginning Winter term 2026, mid-term audits for the aviation program have been implemented to strengthen oversight. Additionally, policy updates now require real-time cost of attendance adjustments for all individualized programs to maintain consistency and alignment with federal regulations. Responsible Person: Director of Financial Aid, with support from Aviation Program Director. Anticipated Completion Date: Begin implementation immediately and accomplish full implementation by Spring 2026; ongoing monitoring.

The District will review the work performed by the individual preparing the reports before submission

Federal Agency Name: United States Department of Agriculture Assistance Listing Number: #10.766 Program Name: Community Facilities Loans and Grants Finding Summary: During our testing, there was no formal review separate from the preparer over the reserve fund reconciliation for the federal program and there was no formal review of the balance in comparison to the required minimum reserve balance. Due to there being no formal review of the balance in comparison to the required minimum reserve balance, the reserve balance was underfunded as of June 30, 2025 in the amount of $17,486. Corrective Action Plan: We will implement additional control processes to ensure a formal review over the reserve fund reconciliation and a formal review of the balance in comparison to the required minimum reserve balance is completed by staff separate from the preparer. On November 28, 2025, the minimum reserve balance was fully funded at $358,800. Responsible Individual: Mandy Robinson, Administrator Anticipated Completion Date: 11/28/2025

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – ALN NOS. 84.027 AND 84.173 2025-001 Internal Control Over Compliance With Federal Allowable Costs Requirements Finding Summary 2 CFR § 200.302(b)(3) requires Independent School District No. 911 (the District) to maintain records that adequately identify the source and application of funds for federally funded activities in accordance with 2 CFR 200 Subpart E – Cost Principles. The District did not have sufficient controls to assure adequate and timely documentation of time and effort was created and retained to support salary costs charged to federal programs and ensure compliance with this requirement. Corrective Action Plan Actions Planned – The District will review policies and procedures for maintaining time and effort documentation for its employees in its federal programs to ensure compliance with the Uniform Guidance in the future. Official Responsible – Director of Finance and Operations, Christopher Kampa. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Director of Finance and Operations, Christopher Kampa, will assure appropriate internal controls and procedures are updated and in place to ensure adequate time and effort documentation is maintained to support all employee salaries charged to federal programs in the future.

Views of Responsible Officials and Corrective Action: The District has added reconciling the accounts receivable balance from the billing software to the general ledger accounts receivable balance, to their monthly closing process.

Views of Responsible Officials and Corrective Action: The District will strive to gain necessary knowledge needed to prepare a full set of financial statements. The District will appoint a competent individual who possesses the skill knowledge and experience to review and approve the draft reports and assume all relevant management responsibilities.

Views of Responsible Officials and Corrective Action: The District will strive to segregate as many accounting functions as practical with the limited staff available.

Planned Corrective Action: The district will implement controls for monitoring reporting grant requirements and grant expenditures to ensure compliance with reporting and period of performance requirements for federal grants. Anticipated Completion Date: 6/30/26 Responsible Contact Person: Hiwot Abraha

Federal Award Finding Number: 2025-001. Planned Corrective Action: Enhance procedures over the NSLDS system to ensure accurate and timely reporting moving forward. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: George Mastoridis, Director of First Coast Technical College and Elizabeth Moore, Director of Accounting

The Accounting Manager and Executive Director for the year ended June 30, 2025 were terminated in October 2025, and the former Executive Director has returned to assist in implementing necessary controls and processes and train property level staff.

The Accounting Manager and Executive Director for the year ended June 30, 2025 were terminated in October 2025, and the former Executive Director has returned to assist in implementing necessary controls and processes and train property level staff.

The City will ensure that all activity is recorded timely related to Federal Drug Forfeitures so that the Equitable Sharing Agreement and Certification can be completed within 60 days of the City’s fiscal year end.

The City will work with its vendors and engineering/accounting personnel to ensure that invoices are submitted and paid as soon as possible following the end of each reporting period so that reporting deadlines to grantors are complied with in future periods.

2025-003: a) I have visited with our lawyer about the procurement policy. b) I am in the process of viewing other towns and writing ours. I plan to have this completed by the end of the month. c) When completed the mayor and council will review and approve or make corrections. The final policy will be approved at the next council meeting. After approval I will submit it to the CPA.

U.S. Department of Education 2025-001: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During our testing of enrollment status reporting, we noted the change in enrollment status was not reported within 60 days. Recommendation: We recommend Hagerstown Community College reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid has contacted the National Student Clearinghouse (NSC) to assess whether any errors occurred during the file transmission process. As of the date of this submission, HCC has not received a response from NSC. Upon receipt of NSC’s findings, HCC will work collaboratively with NSC to identify the root cause of the error and implement corrective actions to prevent recurrence. HCC will continue to perform periodic spot checks of student records transmitted to NSC and subsequently reported to the National Student Loan Data System (NSLDS). Any discrepancies identified through these reviews will be addressed through coordinated corrective action by the Financial Aid, Registrar, and Institutional Effectiveness offices to ensure data accuracy and regulatory compliance. Name(s) of the contact person(s) responsible for corrective action: Dr. Charles M. Scheetz, Director of Financial Aid and W. Christopher Baer, Registrar Planned completion date for corrective action plan: June 30, 2026

Corrective Action Plan December 18, 2025 Massachusetts Department of Elementary and Secondary Education Office of Charter Schools and School Redesign 135 Santilli Highway Everett, MA 02149 Lawrence Family Development Charter School respectfully submits the following corrective action plan for the year ended June 30, 2025: AAF CPAS 50 Washington Street Westborough, MA 01581 Audit period: July 1, 2024 to June 30, 2025 (Fiscal Year 2025) The findings from the December 22nd schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - FINANCIAL STATEMENT AUDIT FINDINGS SIGNIFICANT DEFICIENCY 2025-01 Massachusetts Teachers' Retirement Board (MTRB) Remittances Regulations outlined in DESE's Charter School Audit Guide require Massachusetts Teachers' Retirement System (MTRS) payroll withholdings to be remitted to the MTRB within ten days of the following month. During our compliance testing, we noted nine instances, out of twelve months tested, for which the MTRS payroll withholdings were not remitted to the MTRB within ten days of the following month. Recommendation: In order to comply with Commonwealth of Massachusetts' MTRB regulations and charter school compliance requirements established by DESE, management should ensure that controls are in place to ensure all MTRS payroll withholdings are remitted timely. Action Taken: We concur with the recommendation, and LFDCS has implemented a policy requiring all MTRS payments to be completed within the first ten calendar days of each month. Effective Date: December 1, 2025 SIGNIFICANT DEFICIENCY 2025-02 Payroll Records The Federal government requires Form I-9's be maintained for all eligible employees. Out of the twenty-five selections tested, we noted one 1-9 form which was not properly completed by the School. We also noted four additional selections where the 1-9 form was unable to be located. We also noted there was no supporting documentation maintained for two W-4 forms. The School experienced turnover in the accounting and finance department during fiscal year 2025. Review of required document was not performed on a timely basis. Because of the failure to maintain required forms, ineligible employees may be added to payroll. Recommendation: Procedures should be implemented requiring the completion of required forms and the formal review and approval should be performed prior to adding employees to payroll. Action Taken: We concur with the recommendation, and LFDCS has implemented procedures to review personnel files for completeness and accuracy before new employees begin working at the school. Effective Date: December 1, 2025 2025-03 General Ledger Maintenance During fiscal year 2025, several general ledger accounts were not properly reconciled to their respective subsidiary ledgers, journals, or supporting schedules. In certain instances, reconciliations were prepared; however, variances were not clearly identified, investigated, or resolved. In other cases, reconciliations were performed in an untimely manner. The accounts affected included revenue and the related Federal expenditures, cash, accounts receivable, accounts payable, and due from Lawrence Prospera (the Fund). Unreconciled variances were also noted in various expense and accrued expense balances. Recommendation: Management should implement policies and procedures to ensure that all general ledger accounts are reconciled to the respective subsidiary ledgers, journals, or supporting schedules on a timely basis. Any variances identified during the reconciliation process should be promptly investigated and resolved to maintain the accuracy and reliability of the financial statements and ensure compliance with Federal grant reporting requirements. Implementing these procedures will strengthen internal controls, help prevent potential misstatements in the financial statements, and facilitate a smoother and more efficient audit process. Action In-Process: We concur with the auditor's recommendation. The LFDCS is in the process of implementing an accounting system while also developing accounting policies that set comprehensive standards and procedures to ensure the integrity and accuracy of the General Ledger (GL). The completed policy will include internal controls to safeguard financial data, prevent errors, and reduce the risk of fraud. It will also require segregation of duties by defining distinct roles for authorization, data entry, and review so that no individual is responsible for both recording transactions and reconciling accounts. These measures will provide accurate verification of assets and liabilities through monthly balance sheet account reconciliations and will enable timely and reliable financial reporting and budget-to-actual variation analysis. Anticipated Effective Date: March 1, 2026 2025-04 Bank Reconciliations During the fiscal year 2025 audit, we noted that the School's operating bank account reconciliations had not been prepared for several months after month end and did not agree to the reconciled bank balance. As a result, a large year-end adjustment was required before the audit to record previously unrecorded transactions in the general ledger. When bank reconciliations are not performed consistently and in a timely manner, there is an increased risk of unauthorized transactions or bank errors going undetected. Management should prepare bank reconciliations immediately upon receipt of the monthly bank statement, further, any outstanding checks which have not cleared within a reasonable time should be investigated upon completion of the monthly reconciliation. Recommendation: There is a lack of segregation of duties as it relates to the bank reconciliation process. The same employee who prepares the bank reconciliations also records the related journal entries in the general ledger. In addition, we did not observe evidence of management review or approval of the bank reconciliations prior to recording activity in the accounting records. This lack of segregation of duties increases the risk of errors or potentially resulting in misstatements of cash balances or unauthorized transactions. Action In-Process: We concur with the auditor's recommendation. Once the accounting system implementation is complete, LFDCS will adopt a reconciliation policy that ensures all cash transactions are properly recorded, complete, and any differences are resolved within ten days of the bank statement closing date. High-volume accounts will be reconciled weekly or more frequently as needed. To maintain sufficient segregation of duties, the Finance Team will prepare the reconciliations while the Director of Finance or another designated approver review and approve them. Under no circumstances will the same person prepare and approve the reconciliation. Additionally, the School will set up an integration between its bank and QuickBooks Online so that bank-cleared transactions are automatically downloaded, reducing manual data entry and increasing the efficiency and accuracy of the reconciliation process. Any discrepancies identified during the process will be investigated and corrected within ten days of month-end, and all reconciliations will be securely saved and readily available. Anticipated Effective Date: March 1, 2026 MATERIAL INSTANCE OF NONCOMPLIANCE 2025-05 Certified Procurement Officer Regulations outlined in the Massachusetts Department of Elementary and Secondary Education's (DESE) Charter School Audit Guide require a charter school administrator who serves as procurement officer to have a valid Massachusetts Certified Public Purchasing Official (MCPPO) designation. During fiscal year 2025, we noted that the School does not have any administrator who has MCPPO designation. Recommendation: In order to comply with DESE's procurement requirements, management should ensure that proper controls are in place and operating effectively to ensure that a designated individual has enrolled and receives a valid MCPPO designation. Management should also develop a checklist that tracks expiration date for MCPPO eligible employees to ensure timely renewal. Action In-Process: We concur with the auditor's recommendation. LFDCS acknowledges the requirement outlined in the Massachusetts Department of Elementary and Secondary Education's (DESE) Charter School Audit Guide that a charter school administrator serving as the procurement officer must hold a valid Massachusetts Certified Public Purchasing Official (MCPPO) designation. To comply with this requirement, the directors of facilities and finance in addition to the grant accountant will enroll in the MCPPO certification program offered by the Massachusetts Office of the Inspector General and ensure they complete the training if not certification process. LFDCS will also implement internal controls to track MCPPO certification status and expiration dates to ensure compliance and timely renewal. The Finance Director completed the initial course, Public Contracting Overview, on December 17th, 2025. Anticipated Effective Date: May 1, 2026 If the Department of Education and Secondary Education has questions regarding LFDCS's plans, please call Mark Ventre, Director of Finance, at 978.216.0461, extension 185. Sincerely yours, Signature : Mark Ventre Email: mventre@lfdcs.org Mark Ventre Director of Finance Lawrence Family Development Charter School

2025-001 Student Financial Aid Cluster- Reporting Anticipated completion date: Done Contact person: Nola Rocha Corrective actions: The incorrect inclusion of non-credit course data for new programs in the annual FISAP report resulted from a misinterpretation of reporting criteria. This isolated error affected one reporting element within an otherwise accurate submission. The issue was promptly addressed through clarification of FISAP guidance, staff retraining, and updates to procedural documentation and review checklists to ensure non-credit course activity is properly excluded in future reports. While the dollar amount could be viewed as measurable the financial reporting would not result in any financial impact, as the Department of Education allocates Campus-Based Program funds based on institutional requests and does not provide allocations in excess of those requests.

Recommendation #1: We recommend the District develop a system to review the maintenance of effort )MOE) calculations with all supporting documentation before submitting it to NYSED. Response: The District accepts this finding and has trained the new staff members on implementing this recommendation to gather the Maintenance of Effort (MOE) calculations. Anticipated Completion Date: March 2026 Person Responsible for Corrective Action Plan: Jerel Cokley - Asst. Supt. For Business

County staff will receive annual daysheet training. The County will conduct training on the time sheet process. The County will continue random monthly reviews of Daysheets and timesheets initiated for May 2025. For those staff identified by the random monthly review with discrepancies, supervisors will provide refresher training on Daysheet and timesheet procedures. Additional targeted reviews will be completed monthly until the deficiencies are corrected.

The County will complete a quarterly review of errors in income and documentation. For those staff identified by the targeted review with errors in these areas, supervisors will provide refresher training on Medicaid policy requirements. Additional targeted reviews will be completed monthly until the deficiencies are corrected.

Management has set up training to address all issues regarding the wait list and how to go about selecting those off the waitlist. This training will take place in January of 2026 And it will help those on site to have a full understanding of what is needed when it comes to our wait list.