Corrective Action Plans

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.

Management have put together a recertification team that will oversee our recertifications and we will bring staff on site in to train going forward in the future This will help to ensure that all documents are signed all consent forms there will also be training that deals with tenant selection on the wait list as well as training with maintaining tenant files.

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Contact Person: Monique Mata, Chief Financial Officer Anticipated Completion Date: August 31, 2026 Planned Corrective Action: The District was not aware of the change in calculating indirect cost for Child Nutrition Cluster. The District will review the indirect cost calculation for the affected fiscal year and confirm the amount of overcharged indirect costs. The District will determine the appropriate method for reimbursing or adjusting the $189,745 overcharge to the Child Nutrition Program. Any required repayment or journal entry correction will be completed. The District will update its indirect cost rate guidance to exclude food service management company payments exceeding $50,000 from the indirect cost base. The District will conduct an annual internal review of indirect cost calculations to ensure continued compliance with USDA and ADE guidance. The District will maintain communication with ADE School Finance and Health & Nutrition Services to stay current on guidance updates.

Reporting views of responsible officials and planned corrective actions The Organization will enhance its controls to actively monitor the work order system to ensure appropriate repairs are being completed in a timely manner.

Finding 2025 – 003 - Reporting (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. To enhance the effectiveness of internal controls and ensure that all Title III reports are accurate, properly reviewed, and approved prior to submission, the Fiscal Service office will require management to review and sign off as confirmation of approval prior to submission.

Finding 2025 – 002- Allowable Costs & Period of Performance (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. To strengthen policies and procedures surrounding grant disbursements and ensure expenses are properly approved and allowable under the specific grant budget, the Fiscal Service Office along with the Human Resources Department will implement a process to properly document, review, and approve all allowable grant pay rates and salaries.

Finding 2025 – 004 - Special Tests and Provisions- Enrollment Reporting (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. The Director of Admissions and Records has stated that students who have a student attribute in Banner of INTL will no longer be excluded from the National Student Clearinghouse enrollment reporting upload so as to prevent any reporting issues due to human error when processing admissions applications.

Sliding Scale Assessment Billing Planned Corrective Action: Clinic management will implement additional checks and balances to ensure that Sliding Fee Application Forms and written income verification documentation are included in patients’ records and agree to the sliding fee level maintained in the electronic health records system. The Revenue Cycle Manager will increase the level of monitoring of required documentation of sliding fee levels used in billing patient charges. Person Responsible for Corrective Action Plan: Steonée Laskey, Chief Operations Officer Anticipated Date of Completion: January 31, 2026

2025-002 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education - Federal Work Study Program, ALN #84.033) The University noted that multiple students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class without verification of a reasonable exemption. Management Response Management concurs with the auditor’s finding. Due to incomplete documentation of reasonable exemptions, students were paid Federal Work Study funds for time worked during regularly scheduled class meeting times. Responsible Person(s) Alex Campbell, Director of Financial Aid, and Bobbi Farris, Manager for Student Employment, are the responsible parties for the corrective action. Corrective Action Plan Upon identifying deficiencies related to the lack of documentation for allowable exemptions, the University immediately communicated with all Student Employment Supervisors regarding permitted exemptions and required documentation for students to work during scheduled class times. These requirements and exemptions are reviewed and agreed upon during the annual Student Employment Supervisor Trainings, which occur prior to job postings. Students are notified of the documentation required to be exempt and eligible to work during a scheduled class time during the onboarding process. In collaboration with Information Technology and third-party consultants, the Student Employment Office is enhancing reporting functions to ensure accurate identification of students with conflicting work and class times and to flag any conflicting entries for review and resolution prior to approval. These reports will be reviewed each pay period to ensure accurate documentation is obtained for any conflicting times flagged. While these fields are being implemented, regulations related to working during scheduled class times have been reinforced with both students and supervisors. Beginning with the Spring 2026 term, the University will implement a new policy prohibiting students participating in the Federal Work Study Program from working during scheduled class times, regardless of any met exemptions. All Student Employment Supervisors will be notified of this updated policy by the end of the Fall 2025 term. Training will continue on an annual basis to ensure proper procedures are followed by Student Employment Supervisors and students participating in the Federal Work Study Program. The Director of Financial Aid and Manager for Student Employment will review student time records each pay period to ensure full compliance with these policies. Expected Completion Date This corrective action plan was implemented in September 2025, during the Fall 2025 term. Final implementation will occur at the start of the Spring 2026 term.

2025-001 Significant Deficiency: Awards in Excess of Aggregate Limits (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University awarded and disbursed Federal Direct Loans beyond aggregate limits. Management Response Management concurs with the auditors’ finding. Due to delays and changes in the National Student Loan Data System (NSLDS) post-screening process for the 2024–25 award year, Federal Direct Loans were inadvertently awarded and disbursed to students who had previously exceeded Federal Direct Loan aggregate limits. Responsible Person(s) Alex Campbell, Director of Financial Aid, and Kaitrin Parrett, Assistant Director of Financial Aid, are designated as the individuals responsible for implementing the corrective action. Corrective Action Plan Upon identifying deficiencies in loan aggregate reporting and over-award status, the Financial Aid Office initiated communication with the identified students to inform them of their overaward status and the process for resolving inadvertent overborrowing. In collaboration with software engineers, the Financial Aid Office is developing updated reporting to ensure proper identification of students who are ineligible due to meeting or exceeding aggregate limits set by the U.S. Department of Education. The Financial Aid Office tested and reviewed NSLDS post-screen data and student loan aggregates prior to the disbursement of Fall 2025 Federal Direct Loans to ensure students were not awarded or disbursed aid for which they were ineligible. Reviews of NSLDS post-screen data confirm that the Student Information System (SIS) accurately identifies student aggregate borrowing flags. The Financial Aid Office is also monitoring designated mailboxes to ensure any additional NSLDS post-screen data is reviewed and aggregate limits on student accounts are updated accordingly. All financial aid staff involved in awarding federal loans completed additional training on NSLDS review requirements, aggregate limit monitoring, and reaffirmation procedures prior to Fall 2025 disbursements. Training will continue on a quarterly basis to ensure proper procedures are followed by Financial Aid staff. Compliance reviews will be conducted on a semester basis to ensure that Title IV aid is not awarded to students in excess of their annual or aggregate limits. The Director and Assistant Director of Financial Aid will review aggregate limit reports monthly as part of the University’s internal operational calendar. Expected Completion Date This corrective action plan was implemented in September 2025, prior to Fall 2025 aid disbursements, which began on September 12, 2025.

Underfunding of Replacement Reserve Significant Deficiency in Internal Control over Compliance and an Immaterial Instance of Noncompliance Finding Summary: During testing, it was identified that the Organization did not increase the monthly deposit to the replacement reserve in a timely manner, which resulted in an underfunded account. Responsible Individuals: Management Corrective Action Plan: Management will implement a process to ensure that the required monthly deposits be updated timely. Anticipated Completion Date: September 30, 2026

Corrective Action Plan December 19, 2025 U.S. DEPARTMENT OF EDUCATION Crowder College respectfully submits the following corrective action plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Mr. Joseph Brenner, Vice President of Finance Crowder College 601 Laclede Avenue Neosho, MO 64850 (417) 451-3223 Independent public accounting firm: KPM CPAs, PC, 1445 E Republic Rd, Springfield, Missouri 65804 Audit Period: Year Ended June 30, 2025 The finding from the June 30, 2025, audit of the financial statements is below. The findings is numbered with the number assigned in the schedule. FINDING - MAJOR FEDERAL AWARD PROGRAM AUDIT 2025-001 Special Test and Provisions - Return of Title IV Funds Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR §668.22 as it relates to calculations of return of Title IV funds. Corrective Action Taken: The College reviewed all accounts affected by this error and identified 15 students whose accounts required adjustments. Upon review, the financial aid representative determined that excess funds were returned when the R2T4 calculations were completed. Financial Aid has since corrected the accounts and requested the additional funds owed. To prevent this issue from recurring, a representative from the Financial Aid Office will be included on the calendar committee. Additionally, Financial Aid Policies and Procedures have been updated to require calendar changes to be promptly updated in PowerFaids to ensure accuracy. Anticipated Completion Date: Fall semester 2025 and ongoing. Sincerely, Joseph Brenner Vice President of Finance

Incorrect Resolution of ISIR Aggregate Limits Flag Planned Corrective Action: All financial aid staff received a copy of the FAFSA Specifications Guide, Volume 7 – Comment Codes applicable to the current academic year, and are required to reference this guide for each student file they review to ensure that all comment codes requiring resolution are properly addressed. Additionally, the Assistant Director of Financial Aid distributes daily ISIR import reports to all financial aid staff. Any ISIRs requiring resolution are identified within these reports as well as within the corresponding student files in our system. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler, and Assistant Director of Financial Aid, Alyssa Shealor Anticipated Date of Completion: June 30, 2026

Incorrect Pell Calculations Planned Corrective Action: The Office of Financial Aid will obtain enrollment reports for each term and session to ensure that Pell Grant eligibility is accurately determined and awarded to students based on their enrollment intensity. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler Anticipated Date of Completion: June 30, 2026