Corrective Action Plans

2025-007 – Late Audit Report Corrective action plan: Management reviewed existing accounting staffing structure, revised position descriptions, and have advertised to fill two of three open positions. Management feels with these revised position descriptions, more focus on accounting operations and procedures. Personnel responsible for corrective action: Heather King, Interim Chief Executive Officer Estimated corrective action completion date: June 2026

In Finding 2025-002, it was reported that the Organization did not properly apply the sliding fee discounts to certain patients who visited the Organization during the year ended November 30, 2025. Management recognizes the importance of complying with sliding fee guidelines and the Organization’s sliding fee policy. During the year ended November 30, 2025, the Organization experienced a significant amount of turnover in staff, including 61 terminations and 41 new hires. In response to Finding 2025-002, proper training will be given to employees and sliding fee discounts will be reviewed on a monthly basis by a supervisor to ensure compliance with the sliding fee policy.

Care Alliance Health Center, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2025. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: October 31, 2025 The findings from the October 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Federal Award Findings: Finding 2025.001 - Special Tests and Provisions - Sliding Fee Scale Documentation Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken FY 2025 Corrective Actions and Objectives Documented Process, Procedures and Policies • By June 30, 2026, Care Alliance will update, standardize, and implement a unified, documented workflow for full-fee collection at check-in for all encounters. • Key Performance Indicators (KPI) • ≥90% of self-pay encounters have documented collection attempt • 100% of quarterly review cycles by October 31, 2026. • By April 15, 2026, Finance and Operations will develop a concise list of commonly used CPT/HCPCS procedure codes with associated full fee amounts for Patient Services Representatives (PSRs). The list will be updated quarterly. • KPIs • 100% staff acknowledgment of list each quarter • ≥85% accurate fee quotes of random sampling • By May 1, 2026, Finance and Operations will review and update finance policies governing full-payment determination and collections (FS 106 Sliding Fee Scale Discount Program and FS 107 Billing, Credit, and Collection). • KPIs • 100% staff acknowledgment of updated policies • ≥95% compliant monthly audit of SFS documentation (random sampling) Training and Education • By June 30, 2026, Care Alliance will provide training to front desk staff members responsible for determining eligibility and applying sliding fee discounts. Training will cover documentation requirements, verification of family size/income, and correct SFS application. • KPIs • 100% Staff Training and Education Sign- Off • 100% Completion of annual competency for SFS • By May 31, 2026, Operations will implement a process that ensures Sliding Fee Scale (SFS)/self-pay indicators, Federal Poverty Level (FPL) are accurately entered and maintained for all visits, across all guarantor accounts. • KPIs • ≥90% of self-pay encounters have documented collection attempt • ≥85% accurate fee quotes of random sampling • By April 30, 2026, PSR will use standardized documentation during collections (amount owed, partial payments, attempts, patient ability to pay) for every applicable visit and incorporate into monthly audits. • KPIs • ≥90% documentation compliance of sampled encounters • By July 31, 2026, Finance will clarify treatment and procedures of bad debt previously written off and integrate post-write-off recovery efforts into policy and monthly reporting. • KPIs • 100% staff acknowledgment of updated policies Review and Auditing By May 1, 2026, and continuing throughout FY26, the Revenue Cycle Manager and Controller will conduct monthly audits to verify that all Sliding Fee Scale (SFS) discounts are accurately calculated, properly supported, and fully documented in accordance with FS 106. Additionally, the Controller will conduct quarterly reviews to evaluate overall compliance, identify areas for improvement, and assess the effectiveness of the sliding scale fee program in meeting patient needs and federal guidelines. Responsible Parties and Reporting Cadence • Controller and Director of Operations: Owns policy updates (FS 106/FS 107), quarterly documentation reviews, and oversight of FPL table updates. • Revenue Cycle Manager: Monitors adherence to workflow, conducts monthly audits, and drives corrective actions with Clinical Support Manager. Maintains the common procedures fee list and coordinates quarterly updates. • Clinical Support/Patient Access Manager (PSR Manager): Oversees PSR training, documentation compliance, and daily operations. Provides staff coaching and remediation based on monthly audit results. If there are any question regarding this plan, please e-mail Dr. Derrick Howell at dhowell@carealliance.org. Sincerely, Dr. Derrick Howell CFO

Authority's Response and Planned Corrective Action: The Authority acknowledges the deficiencies identified in the Section 8 Housing Choice Vouchers program and will implement internal control procedures to ensure compliance with federal regulations. Jeff Stewart, Executive Director, is responsible for implementing this corrective action by September 30, 2026.

2025-07 Special Tests and Provision - Rent Reasonableness Federal Agency - US Department of Housing and Urban Development Continuum of Care Program -Assistance Listing# 14.267 Hennepin County Contract HS00001366 Year ended June 30, 2025 Material Weakness in Internal Control over Compliance, Noncompliance Other Matter Recommendation - Agate Housing and Services, Inc. strengthen internal controls to ensure all expenditures to ensure rent reasonableness determinations are completed and documented for all program participants prior to the disbursement of rental assistance funds. Management should implement a procedure to verify required documentation is present before payment approval. Corrective action - Agate Housing and Services, Inc agrees with the finding and is in the process of strengthening its controls over maintaining documentation of all landlord verifications and rent reasonableness verifications, and retaining such documentation. Name of contact person(s) responsible for corrective action - Elizabeth Macha rt, Director of Housing Programs and Sara Wenzel, Associate Director Time Limited Housing Completion date - Fiscal year ending June 30, 2026

2025-004 Special Tests and Provisions - Rent Reasonableness Federal Agency - US Department of Housing and Urban Development Continuum of Care Program - Assistance Listing# 14.267 Hennepin County Contract HS00001366 Year ended June 30, 2025 Material Weakness in Internal Control over Compliance Recommendation - Agate Housing and Services, Inc. implement internal controls requiring program staff to validate compliance with rent reasonableness requirements and maintain adequate documentation to support final rent determinations. Corrective action - Agate Housing and Services, Inc agrees with the finding and is in the process of strengthening its controls over the verification of landlords and rent reasonableness and retaining such documentation. Name of contact person(s) responsible for corrective action - Elizabeth Macha rt, Director of Housing Programs and Sara Wenzel, Associate Director Time Limited Housing Completion date - Management and the housing team implemented the above procedure December 2025.

Special Tests and Provisions – Material Weakness in Internal Controls over Compliance (Replacement Reserve Disbursement – HUD Approval Requirement) Management Response Management acknowledges that a disbursement of $15,000 was made from the replacement reserve account without obtaining prior written approval from HUD, as required under the Capital Advance Regulatory Agreement. Management recognizes that appropriate controls were not in place to prevent disbursement of restricted reserve funds without required approval, resulting in noncompliance. Management has initiated communication with HUD to disclose the transaction and request guidance on the appropriate resolution. The organization will comply with all directives issued by HUD and will continue to follow up as necessary to ensure timely resolution. Corrective Actions Implemented / To Be Implemented • A formal control will be implemented requiring documented written HUD approval prior to any disbursement from the replacement reserve account. • All reserve disbursements will require documented HUD approval prior to processing and will be subject to Controller review to ensure compliance with HUD requirements. • Replacement reserve accounts will be formally designated as restricted funds within internal financial procedures. • A formal policy governing replacement reserve disbursements will be established. • Alternative funding sources will be used when HUD approval is not available. • Training will be provided to relevant staff on HUD requirements and reserve controls.Training Training on reserve account procedures will be conducted by May 1, 2026, with refresher training annually. Responsible Staff: Controller – Oversight of compliance Chief Executive Officer (CEO) – Final accountability Implementation Date: Corrective actions related to implementation of review controls will be implemented immediately. Resolution will follow HUD guidance.

FINDING 2025-005: Wage Rate Compliance Response: The District will review all contracts to ensure that they include the Davis-Bacon requirements for wage rate compliance and require certified copies of wages paid to contractors to retain as required by Federal Law.

Finding 2025-006 Finding Summary: Pursuant to 20 USC 2011h, the District is required to report graduation rate data for all public high schools for the District for each graduating cohort. To remove a student from the cohort, the District must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. Elko County School District did not have sufficient internal controls to ensure all documentation for the removal of students from the cohort was maintained. Corrective Action Plan: The District will provide training to all registrars and create a consistent form that will be available to all school sites for tracking purposes Responsible Individual: Ray Smith Director of Special Education Anticipated Completion Date: June 2026

Corrective Action: The University agrees with the findings. Management will perform a review of Title IV refunds to ensure credit balances are refunded to students within the required 14-day timeframe. In addition, management will review the existing system of controls related to the timely refund of credit balances. Further, management will reinforce control ownership and provide targeted training to individuals responsible for compliance. The actions will help to ensure that appropriate controls are in place and responsibilities are clearly defined, and instances of noncompliance are mitigated to support controls. Contact Person: Terry Nixon, Assistant Comptroller, Student Business Services Anticipated Completion Date: June 15, 2026

FINDING 2025-002: Wage Rate Compliance (Repeated 2024-003) Response: The vendors noted in the audit had completed their work before the conclusion of the fiscal year 2024 audit, and the District was unable to obtain all required payroll and wage-rate documentation from those contractors before the 2023-2024 audit was finalized. To prevent recurrence, the following procedures will be implemented: • A contractor checklist will be implemented to document the type of work to be performed, the funding source, and whether Davis-Bacon wage requirements or Montana prevailing wage rates apply before work begins. • Accounts payable staff will verify that all required contractor documentation is received and retained before final payment is issued.

Ignacio School District has already taken steps in changing the overall process of managing our Federal Award grants and year-end closing entries. Our district has implemented regularly scheduled monthly Requests For Funds and budget reviews for each grant to confirm that the grants are being spent according to their approved applications. This includes, but is not limited to assuring that the district charges a de minimis indirect cost rate and submits End of Year Financial Reports to CDE in a timely manner. The district has assigned responsibility of Federal Grant oversight to new personnel. To assure a segregation of duties, there are three district office personnel involved in the management and oversight of the grants. The district has also been trained on proper closing entry procedures for all year-end closing entries and SEFA requirements.

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), University Registrar (Charee Ellison) Corrective Action: The University concurs with this finding. Shaw University acknowledges the finding regarding variances between institutional records and the status reported in NSLDS. For students 1-3 listed for campus enrollment details, the students withdrew then subsequently re-enrolled. The University, to date has had static to confer degrees which do not coincide with the required timeframe of NSLDS reporting. The University will change degree conferral dates to better coincide with timely NSLDS reporting. Management will continue to monitor this process to ensure ongoing compliance. Anticipated Completion Date: May 15, 2026

Finding Number: 2025-103 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Enforcing secure system access protocols, including multi-factor authentication The institution will implement multi-factor authentication (MFA) across all financial aid and student information systems to: ● Protect Title IV data from unauthorized access ● Align with federal information security expectations ● Ensure compliance with institutional cybersecurity policies Anticipated Completion Date: 8/31/2026 Responsible Contact Person: Angela Reese

Finding Number: 2025-102 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Generating automated alerts to ensure compliance with federal return-of-funds deadlines To ensure compliance with 34 CFR § 668.22(j): ● The institution will utilize system-generated alerts to track all R2T4 deadlines ● Staff will follow standardized procedures aligned with federal timelines ● Supervisory review will be required prior to final processing of all returns Anticipated Completion Date: 8/31/2026 Responsible Contact Person: Angela Reese

Finding Number: 2025-101 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Tracking and documenting R2T4 calculations, including secondary review and approval Tom P. Haney Technical College will implement systemic and procedural corrective actions designed to ensure full compliance with Title IV requirements. The institution will procure and implement the Point-of-Sale (POS) module within the FOCUS School Software system to establish automated internal controls. The system will: ● Require documented review and approval workflows for all R2T4 calculations ● Maintain electronic audit trails for all transactions and approvals ● Provide automated notifications and deadline tracking to ensure timely return of funds ● Generate compliance reports for ongoing monitoring The Financial Aid Office will revise and formalize written policies to include: ● R2T4 calculation, review, and approval procedures ● Timelines for return of funds ● System access and authentication requirements All policies will be maintained in accordance with federal recordkeeping requirements under 34 CFR § 668.24. All financial aid and relevant administrative staff will receive training on: ● R2T4 regulatory requirements ● Use of the FOCUS POS system ● Updated institutional policies and procedures Training will be documented and retained for audit purposes. Anticipated Completion Date: 8/31/2026 Responsible Contact Person: Angela Reese

FINDING 2025-004 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure the proper documentation is in place for any students removed from the graduation cohort. Anticipated Completion Date: We anticipate that this correction will be in place by August 2026

Management acknowledges the audit finding related to the absence of a formally documented written information security program. While VEEB has implemented certain administrative and technical safeguards to protect sensitive information, these practices have not been consolidated into a single, written information security program as required. Management is committed to addressing this matter and plans to formalize its existing information security practices into a written information security program that is appropriate to the size, complexity, and risk profile of the organization. Management expects to complete the development and implementation of the written program during the upcoming fiscal year. Management believes that this condition does not reflect a failure to safeguard information, but rather a documentation gap that will be remedied through the actions described above.

Finding Number: 2025-002; Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all client files contain documentation ensuring compliance with Rent Reasonableness requirements. Anticipated Completion Date: 6/30/26; Responsible Contact Person: Kristen Runion, HCV Supervisor

Finding Number: 2025-001; Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all clients complete an annual family income reexamination in accordance with Eligibility, Reporting, and Housing Assistance Payment requirements. Anticipated Completion Date: 6/30/26; Responsible Contact Person: Kristen Runion, HCV Supervisor

Management Response The University concurs with this finding. Management has initiated a review of all relevant institutional academic calendars to ensure that the correct payment period start and end dates are accurately configured within the Colleague system. The Spring 2025 withdrawal population is being reviewed to determine whether additional R2T4 recalculations and returns of Title IV funds are required. Necessary corrections will be processed promptly. Going forward, the University will implement procedures to verify that system-configured term dates agree to the officially approved academic calendar prior to each academic term to ensure compliance with federal R2T4 requirements. Corrective Action The University is currently reviewing all R2T4 calculations for the Spring 2025 withdrawal population to ensure calculations were accurate. Necessary corrections will be processed promptly. The University is implementing procedures to verify that system-configured term dates agree to the officially approved academic calendar. The procedures include a review and signoff process to ensure multiple individuals review the information for accuracy. Contact Person Responsible Name – Justin Pichey Title – Director of Financial Aid Phone – 410-532-5735 Email - jpichey@ndm.edu Anticipated Completion Date – April 30, 2026

Management Response The University concurs with this finding. Management has reviewed its processes for monitoring and issuing Title IV credit balance refunds and has implemented procedures to ensure refunds are processed within the required 14-day timeframe. The Financial Aid and Student Accounts offices will review credit balance reports on a regular basis to identify students eligible for refunds and confirm timely disbursement. In addition, staff have been reminded of federal requirements related to credit balance refunds. Management will monitor this process periodically to ensure ongoing compliance. Corrective Action The University reviewed the federal requirements for refunds with applicable members of the Business Office and Financial Aid departments to ensure a thorough understanding of the refund rules. The University enhanced its weekly credit balance review process to require explicit review by the Controller and Director of Financial Aid if uncertainty exists on whether a student is eligible for a refund. This review must be completed within the 14 day period with either the refund issued or the loan removed from the student’s account. Contact Person Responsible Name – Richard Jones Title – Controller Phone – 410-532-5367 Email – rjones13@ndm.edu Anticipated Completion Date – April 30, 2026

Management Response The University concurs with this finding and has implemented corrective actions to prevent recurrence. The entrance counseling loan processing rule parameters within the Colleague financial aid module have been updated to prevent loan authorization and disbursement if entrance counseling has not been received and posted to the student's loan record. The system update was implemented in February 2026. In addition, the University reviewed loans processed during the affected period to confirm no additional instances of noncompliance occurred. Financial aid staff have been reminded of federal entrance counseling requirements, and management will periodically monitor system controls to ensure continued compliance. Corrective Action In February 2026, the University updated the entrance counseling loan processing rule parameters within the Colleague financial aid module. From February 2026 forward, the rule parameters would prevent a loan from disbursing if the entrance counseling was not performed. The University reviewed loans processed during the period July 2024 – Feb 2026 to ensure there were no additional loans processed without entrance counseling. Contact Person Responsible Name – Justin Pichey Title – Director of Financial Aid Phone – 410-532-5735 Email - jpichey@ndm.edu Anticipated Completion Date – March 31, 2026

The organization has implemented additional levels of review and pre­screening of slide patient data to ensure accuracy and that the data is complete. Routine reviews done by front desk supervisors will be further documented in order to provide additional training to staff as needed. Results of monthly audits performed by service line leaders will be reported to senior leadership. An internal audit will be done by the compliance team and presented to leadership on a quarterly basis. All appropriate admitting staff will go through training to reinforce our slide process and review procedures for all FQHC services.

Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026