Corrective Action Plans

Reporting – Data Collection Form and Reporting Package (Significant Deficiency) U.S. Department of Education Adult Education – Basic Grants to States (Federal Assistance Listing #84.002) Federal Award Year: 2023-20 Responsible Officials Contact Information: 1) Archana Jayaram, CEO Telephone 718-310-5626 ajayaram@wearebcs.org 2) Jodi Querbach, COO Telephone 718-310-1015 jquerbach@wearebcs.org View of Responsible Officials and Corrective Action Plan: Management agrees that the single audit reporting package was not submitted within the required timeframe due to key employee turnover coupled with staffing challenges subsequent to year end. This was also after a period of time when the organization’s finance functions were externally managed by an accounting firm. The former firm held the general ledger data for BCS and has been slow to turn it over in a manageable manner causing the delay in filing of the single audit report package. Frank Lei (current Chief Financial Officer) was hired in February of 2025 and has actively hired a new internal finance team, including a controller Daniel Pensante, hired in March of 2025. In our new configuration, BCS will: 1) own its financial software and data, 2) be sufficiently staffed to run its day-to-day financial operations, 3) be able to support program operations in an efficient manner, and 4) be able to respond and complete audits on time. Management will ensure that the single audit report package is submitted before the March 31, 2027 deadline.

The Department is working with Human Resources to strengthen procedures for initiating, completing, and maintaining documentation for required background investigations in accordance with tribal policy. Person Responsible: Kayla Tallbear, Acting Treasurer Estimated Completion Date: December 31, 2026

Approval responsibility for both Project and Expenditure Reports and Obligation and Expenditure Reports were reassigned from the Lt. Governor to the Acting Treasurer to improve the timeliness of report review and submission. For financial reports, the Department has strengthened its reporting process by requiring secondary review and approval prior to submission and will continue monitoring report preparation and filing to support timely compliance. Person Responsible: Kayla Tallbear, Acting Treasurer Estimated Completion Date: December 31, 2026

Management will review reports on a more frequent basis and will to the best of our abilities, schedule recertifications well in advance to advance to ensure recertifications are completed timely. Verterans will now be notified at the 60 day mark in order to retain eligibility.

CRT will initiate an outreach plan for low-income representation to fill the open positions on the Board. The President and Chief Executive Officer or designee will solicit Low-Income Director nominations from organizations and groups within the agency or the community that are recognized as serving or representing low-income residents following federal regulations, State statutes, CRT By-Laws and agency approved Democratic Selection Procedures. Upon review of the qualifications of the nominated candidates by the CRT Nominating Subcomittee, they will vote to select the best qualified candidate(s) for appointment to the Board. After the candidate(s) have been determined by the Nominating Subcommitee to meet the qualifications, the Board will vote whether to elect the proposed individual to the Board.

Management has implemented a formal procedure to ensure that future Single Audits are completed and submitted within the required timeframe. This procedure includes the following actions: First Quarter (January – March): The Purchasing Unit will initiate the procurement process for the independent auditors, in coordination with the Fiscal Manager, while year-end closing activities are being completed, to ensure timely engagement of audit services. Second Quarter (April – June): Once the auditor is engaged, the program will initiate the audit engagement and provide the required documentation in accordance with the established audit schedule.

Views of Responsible Officials and Planned Corrective Action The Organization concurred with the prior year (2023-004) and current year renumbered recommendation (2024-004), acknowledging that the unexpected resignation of the former independent auditor (January 2023), and the domino effect of a delay in securing a new independent auditor (April 2023) continue to challenge the Organization, however, the Organization notes the status and progress of the following single audits: • June 30, 2022, filed in the Federal Audit Clearinghouse (FAC) in February 2025. • June 30, 2023, filed in the FAC in March 2026. • June 30, 2024, final review by Board in progress, projected filing in the FAC in June 2026. • June 30, 2025, engagement field work in progress with projected filing date no later than September 2026. • June 30, 2026, engagement letter signed with scheduled field work to commence after the June 30, 2025, audit FAC filing; projected to be completed with related FAC filing, no later than March 2027. The Organization notes the corrective actions that have been implemented, regarding internal controls to ensure compliance with the Uniform Guidance with respect to the submission deadline of single audit reports and the Data Collection Form: A. Internal Controls in Practice Since Inception of New Auditor Engagement – April 2023. As noted in the prior year corrective action response, the Organization established internal compliance controls related to the timely submission of single audit reports. Such process and review controls are implemented by the director of administrative operations, chief of staff (since December 2024), and chief executive officer; and subsequently communicated to the Board finance sub-committee and full Board, including the documented Board action(s) taken (e.g., Board agenda, minutes). B. Financial Policies and Procedures – May 2025. By May 2025, the Organization completed financial policies related to: implementation of significant accounting policies, internal control environment, cash and banking, cash disbursements and check issuance, payroll processes, procure to pay and revenue recognition policies, processes and procedures. Note the internal control policy of the Organization documents process and review controls, which were already in practice, applying to the timely filing of single audit reports. The current practices of the Organization, to the present period of the report dated June 17, 2026 is consistent with established process and review controls for timely submission of single audit reports.

Mansfield Foundation Corrective Action Plan Summary Reviewed and Approved: Frank Jannuzi, Sara Harriger, Lisa Hosegood May 28, 2026 Action 1: Relevant to single audit finding 2024-001: Use external controller services support to ensure timely submission of Required Federal Financial Reports. Planned Implementation An external accounting/controller firm has been engaged to provide oversight and ensure that all bookkeeping and reporting tasks are completed on time. They report to the Vice President and President and work directly with the Director of Finance. They will provide weekly and monthly monitoring of financial procedures, regular financial reporting to management, and track grant reporting deadlines. This arrangement will continue for the foreseeable future. Responsible Party Outsourced CFO; Director of Finance Target Completion Ongoing Action 2: Relevant to single audit finding 2024-001: Apply an internal tracking system to ensure timely submission of Required Federal Financial Reports. Planned Implementation A reporting calendar will be established and maintained by the Director of Programs, with deadlines flagged 30 days in advance. Automated reminders will be circulated to responsible staff one month, two weeks, and one week prior to each filing deadline Responsible Party Outsourced CFO; Director of Finance, Director of Programs Target Completion Implement within three months Action 3: Relevant to single audit finding 2024-001: Implement a management review system to ensure timely submission of Required Federal Financial Reports. Planned Implementation The Vice President will verify completion of each report prior to submission. The President will receive confirmation that the report was submitted on or before the required deadline. Responsible Party President, Vice President, Director of Finance Target Completion Implement within three months Action 4: Relevant to single audit finding 2024-001: Implement a regular briefing to leadership to ensure compliance and monitor timely submission of Required Federal Financial Reports. Planned Implementation Twice annually, the Director of Finance will brief leadership on the status of required reports and confirm compliance. Responsible Party Outsourced CFO, Director of Finance Target Completion Implement within three months Action 5: Relevant to single audit finding 2024-001: Assign clear lines of responsibility to ensure timely submission of Required Federal Financial Reports. Planned Implementation The President and Vice President are ultimately accountable for submission of timely reports and will provide adequate resources and support, monitor regular bookkeeping and grant deadlines, and hold staff accountable for preparation of the reports. The Directors of Programs and of Finance will be the primary lead for monitoring deadlines, gathering information, and effectuating the timely preparation and submission of all financial reports. Responsible Party President, Vice President, Director of Programs, Director of Finance Target Completion Ongoing Action 6: Develop and formally document a standardized month‑end and year‑end close checklist, including required reconciliations, review sign‑offs, and reporting deadlines. Planned Implementation Management will implement a formal month‑end and year‑end close checklist that outlines key close activities, required account reconciliations, documentation standards, review and approval sign‑offs, and established reporting timelines. The checklist will clearly assign responsibility for each task to designated finance personnel to ensure accountability and consistency in execution. Responsible Party Outsourced CFO; Director of Finance Target Completion Implement for the next fiscal quarter close Action 7: Establish documented review procedures for key balance sheet accounts, including independent review of reconciliations and journal entries. Planned Implementation Management will implement formal, documented review procedures requiring monthly balance sheet reconciliations for all accounts, prepared on a timely basis and reviewed by appropriate Finance lead. In addition, management will require review and approval of journal entries associated with period‑end close activities to strengthen oversight and reduce the risk of error or misclassification. These review procedures will be integrated into the month‑end and year‑end close process and retained as part of the Foundation’s accounting records. Responsible Party Outsourced CFO; Director of Finance Target Completion Ongoing Action 8: Implement a formal budget‑to‑actual review process with documented explanations and periodic reporting to the Board of Directors Planned Implementation Management will establish a standardized budget‑to‑actual review process to be performed on a recurring Quarterly basis. This process will include preparation of variance analyses with documented explanations for significant differences between actual results and the approved budget. These reviews will be completed timely and used as a monitoring control to identify unexpected trends or potential misstatements requiring further review. Responsible Party Outsourced CFO; Director of Finance, Director of Programs Target Completion Implement within three months Action 9: Implement a structured system for tracking grants and contributions, including documentation of donor intent, restriction classification, and release schedules Planned Implementation Management will implement formal grant and contribution tracking procedures designed to document donor and grantor restrictions at the time of receipt and to monitor those restrictions throughout the life of the award. These procedures will support appropriate classification of net assets with and without donor restrictions and timely recognition of releases from restriction in accordance with donor intent and applicable GAAP rules. Responsible Party Outsourced CFO; Director of Finance Target Completion Implement within three months Action 10: Establish procedures for timely identification and release of donor‑restricted funds in accordance with donor and grantor requirements Planned Implementation Management will implement documented procedures to ensure that donor‑imposed restrictions and grantor requirements are identified at the time of receipt and tracked throughout the life of the contribution or grant. These procedures will include quarterly review of restricted net asset balances to ensure that restrictions are released in a timely manner when the applicable purpose or time requirements are satisfied. Responsible Party Outsourced CFO; Director of Finance Target Completion Ongoing Action 11: Strengthen technical accounting review through training, cross‑training, and use of qualified external resources as needed. Planned Implementation To address this recommendation, management has engaged an outsourced accounting team to provide technical accounting support and to assist with the development and documentation of formal finance policies and standard operating procedures (SOPs). These SOPs and policies will establish consistent accounting practices, clarify review and approval responsibilities, and provide appropriate documentation to support accounting judgments and GAAP‑compliant financial reporting. In addition, management will implement targeted training and cross‑training within the finance function to strengthen internal technical accounting knowledge and reduce reliance on single individuals for critical accounting functions. Periodic technical review by qualified internal and external personnel will be incorporated into the close and review process to support accurate application of accounting standards. Responsible Party Outsourced CFO; Director of Finance Target Completion Ongoing Action 12: Improve segregation of duties and compensating controls where full segregation is not feasible Planned Implementation To strengthen segregation of duties within the finance function, management has hired a full‑time Finance Associate, which will allow for clearer separation of transaction processing, review, and reconciliation responsibilities. In addition, management has engaged a part‑time, outsourced accounting firm to provide supplemental support, oversight, and review of selected accounting activities. Responsible Party Vice President, Outsourced CFO; Director of Finance, Finance Assistant Target Completion Within six months Action 13: Continued segregation of duties Planned Implementation Where limited staffing continues to constrain full segregation, management will implement and document compensating controls, including review of reconciliations, journal entries, and financial reports by qualified personnel. Management believes these actions will enhance the design and operating effectiveness of internal controls, reduce reliance on single‑person processes, and support more accurate and reliable financial reporting in accordance with GAAP. Responsible Party Vice President, Outsourced CFO; Director of Finance, Finance Assistant Target Completion Within six months

Finding 2024-009 – Completion and Submission of Annual Single Audit - Significant Deficiency/Noncompliance Condition/Context: The County's Single Audit and reporting package was delayed for the year-ended December 31, 2023, as a result of turnover within its Budget and Finance Office, beyond the nine month due date. Corrective Action: The Controller’s office has new procedures in place to help facilitate the year end closing process so the audit can be completed in a timely manner. Responsible for Implementing Corrective Action: Controller’s Office Anticipated Completion Date: We anticipate this to be completed in coordination with the 2026 audit.

Schedule of Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-004: Significant Deficiency in internal Controls and Noncompliance Over Reporting Responsible Official’s Response and Corrective Action Plan We concur with the findings. We acknowledge the importance of adhering to the federal guidelines for the submission of the reporting package within the mandated nine-month period. To address this, BCI will implement the following actions: 1. Policies and Procedures Development: We will create and enforce comprehensive policies and procedures to ensure that audits are initiated and completed promptly. This will include detailed timelines and checkpoints to monitor progress throughout the audit process. In addition, we will adhere to a year-end closing process that reconciles all significant accounts. 2. Training for Grant Administration: We will provide training for individuals responsible for administering federal assistance programs within BCI. This training will cover essential aspects of grant administration, ensuring that our team is well-equipped to manage these programs efficiently and in compliance with federal requirements. Planned Implementation Date of Corrective Action Plan September 1, 2024 Person Responsible for Corrective Action Plan Caryn York, President & CEO

Schedule of Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-003: Significant Deficiency and Noncompliance over Eligibility Responsible Official’s Response and Corrective Action Plan: We concur with the findings related to deficiencies in Internal Controls and Noncompliance over Eligibility related to our federal grant. In response, BCI has streamlined document collection and tracking and has strengthened its onboarding and document retention procedures to ensure all member files include the required documentation, including the signed member agreements. Planned Implementation Date of Corrective Action Plan September 1, 2024 Person Responsible for Corrective Action Plan Caryn York, President & CEO

This has been corrected with current staff. We are making sure that all reports are filed on time and correctly. Responsible Official: Director of Finance Expected Completion Date: The report was corrected 4/14/2026 with the completion of the 2025 SLFRF Compliance Report.

Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: A separate individual with supervisory authority over the preparer should be assigned to review and approve the cash drawdowns and reports prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization has designated an individual to review and approve the cash reimbursement requests and reports prior to submission. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2025

Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will apply its current procurement policy to new and existing vendors in order to comply with applicable procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2025

FINDINGS - U.S ECONOMIC DEVELOPMENT ADMINISTRATION, ALN# 11.307 SIGNFICANT DEFICIENCY Finding 2024-001 - Reporting: The U.S. Economic Development Administration ALN # 11 .307 require reports to the appropriate federal agency for revolving loan funds and grants. Response to Aydjt finding 2024-001: Background: The FY2024 Semi-Annual Revolving Loan Fund Financial Reports were not submitted within the required timeframe. Current accounting and RLF management were not responsible for report preparation during the reporting period and unable to verify the specific circumstances that resulted in the late submissions. The finding indicates that report controls and monitoring procedures in place at the time were not sufficient to ensure required deadlines were met primarily due to accounting and RLF staff turnover. Conclusion: Staffing turnover was mitigated in Fall 2025 allowing significant progress towards existing corrective action plan. Progress was as follows: • Developing updated and written procedures for RLF reporting. • Ensuring current key staff members and management have access to reporting instructions and supporting documentation. • Ensuring periodic management review of reporting deadlines and requirements.

Management acknowledges the importance of maintaining appropriate segregation of duties and documented independent review for match calculations and supporting documentation. Corrective actions implemented include the development and implementation of written procedures for preparing, reviewing, and approving match calculations and supporting documentation as well as requiring independent review and documented approval of match calculations by a staff member not involved in the preparation.

Management acknowledges the need to ensure that required documentation is complete and retained in each tenant file, including executed leases, required forms, inspection documentation, and other required program documents. Corrective actions implemented include the creation and use of a standardized eligibility determination checklist that requires documented supervisory sign-off in each tenant file to ensure all required documentation is complete prior to assistance approval. Staff have completed refresher training on timing requirements, documentation standards, and calculation procedures.

Management acknowledges the importance of completing rent reasonableness determinations timely (i.e., prior to lease execution) and ensuring the accuracy of amounts used in the calculation. Corrective actions implemented include the creation and use of a standardized eligibility determination checklist that requires documented supervisory sign-off in each tenant file which includes verification of the lease amount and calculation prior to lease execution. Staff have completed refresher training on timing requirements and calculation procedures.

Management acknowledges the need for consistent documentation and secondary review to support income determinations and rent calculations, including ensuring calculations are based on appropriate income measures. Corrective actions implemented include the creation and use of a standardized eligibility determination checklist that requires documented supervisory sign-off in each tenant file confirming the income calculations and rent determinations. Staff have completed refresher training on documentation standards and calculation procedures.

Management recognizes the importance of maintaining clear, documented evidence of supervisory review of eligibility determinations, income calculations, and supporting documentation. Corrective actions implemented include the creation and use of a standardized eligibility determination checklist that includes supervisory review steps requiring documented supervisory sign-off in each tenant file prior to finalizing eligibility. A standardized tracker is also being used to ensure completeness of the process.

CORRECTIVE ACTION PLAN: Assign Responsibility Designate the GIS Analyst and Lead Coordinator (or Controller, if applicable) as the individuals responsible for coordinating the preparation and submission of all required progress reports. Require the Chief Financial Officer or Executive Director to review and approve each report prior to submission. Implement a Compliance Calendar Develop a centralized compliance calendar listing all reporting requirements, due dates, responsible personnel, and review deadlines. Establish automated reminders at least 30, 15, and 5 days before each due date. Create a Reporting Checklist Develop a standardized checklist to ensure that all financial and programmatic information is complete, accurate, and supported by appropriate documentation before submission. Improve Interdepartmental Coordination Conduct regular meetings among program, accounting, and compliance personnel to gather required information and monitor progress toward upcoming deadlines Management Review and Approval Require documented evidence of management review and approval before each progress report is submitted. Maintain Submission Documentation Retain copies of submitted reports, supporting schedules, and confirmation of receipt from PRDOH. Staff Training Provide training to relevant personnel on grant reporting requirements and internal procedures to ensure continued compliance

CORRECTIVE ACTION PLAN: Management will establish and implement formal controls to ensure that the Data Collection Form and the Single Audit reporting package are prepared, reviewed, and submitted to the Federal Audit Clearinghouse within the required nine-month deadline. Planned Actions Implement a Compliance Calendar Develop a regulatory compliance calendar that includes all key milestones and deadlines related to the Single Audit process, including draft financial statements, auditor fieldwork, management review, and submission to the Federal Audit Clearinghouse.Set automated reminders beginning six months after fiscal year-end. Improve Coordination with External Auditors Schedule planning meetings with the external auditors shortly after fiscal year-end to confirm timing, required documentation, and target completion dates. Monitor progress throughout the audit to identify and resolve delays promptly. Management Review and Approval Require documented review by the Finance Director to confirm that all components of the reporting package are complete and that submission has been made and acknowledged by the Federal Audit Clearinghouse. Retain Submission Evidence Maintain copies of the submitted Data Collection Form, reporting package, and confirmation of acceptance by the Federal Audit Clearinghouse.

Views of Responsible Officials and Planned Corrective Actions: ATS has drafted an organization-wide procurement policy to ensure it includes all the Uniform guidance procurement elements. The draft will be reviewed by senior management for comment prior to formal issuance.

Management has implemented the following corrective actions: 1. Established a formal year-end closing timeline that includes deadlines for completion of the trial balance, account reconciliations, and supporting schedules. 2. Assigned responsibility to the Executive Director to monitor progress toward year-end closing milestones and ensure information is provided to the auditors on a timely basis. 3. Developed a comprehensive audit preparation checklist identifying all schedules, reconciliations, and documentation required by the auditors. 4. Scheduled pre-audit planning meetings with the auditors to establish mutually agreed-upon deadlines and identify potential issues that could delay audit completion 5. Implemented periodic status reviews during the audit process to monitor progress and address outstanding auditor requests promptly.

The Organization should develop a compliance calendar that includes financial reporting deadlines and set automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end, and the auditors should put this engagement on their calendar well in advance of the due date. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. The Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight.