Corrective Action Plans

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

Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the Organization develop and implement formal policies and procedures to ensure required performance reports are prepared, reviewed, and submitted in a timely manner. Such procedures should include clearly defined roles and responsibilities, tracking of reporting deadlines, and documented evidence of supervisory review and approval prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was related to a one-time ARPA grant during a period of staff transition, where performance reports were not consistently documented as reviewed and approved prior to submission. Since then, management has implemented formalized procedures for grant reporting. All performance reports are now prepared by designated program staff, tracked against reporting deadlines, and subject to supervisory review and approval by the Executive Director prior to submission. These procedures establish clear roles and responsibilities and ensure timely, documented review and submission of required reports. Name(s) of the contact person(s) responsible for corrective action: Monique Valenzuela, Executive Director and Theo Everhearts, Senior Director of Finance. Planned completion date for corrective action plan: June 2024

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.

Finding Number: 2024-004 Planned Corrective Action: The Housing Authority along with Leggins Casterline & Company LLC accounting will continue working to rectify the accounting issues resulting from the former Executive Director and have all submissions done in a timely manner. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director

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.

Finding #2024-005 – Lack of Written Grant Procedures over Federal Programs Criteria: Under Federal Uniform Guidance, all non-Federal subrecipient entities must establish and maintain written policies and procedures over Federal programs. Written grant procedures are required in the areas of verifying allowable costs, cash management, and conflicts of interest, while procurement, subrecipient monitoring, and reporting procedures should also be included. Condition: During their audit procedures, the auditors noted that the City did not have comprehensive written grant procedures governing key compliance areas. Cause: The City’s management has relied on informal practices and institutional knowledge rather than formulating a grant procedures manual. Effect: Without written procedures, there is an increased risk of noncompliance with Uniform Guidance, including improper cost charging, non-compliant procurement, untimely drawdowns or cash on hand, inadequate subrecipient oversight, and ineffective internal controls. This exposes the City to the risk of questioned costs, potential repayment of federal funds, audit findings, and other possible impacts. Recommendation: The auditors recommend that the City develop, approve, and implement a consolidated Federal grant procedures manual. The procedures should not be a replication of the Federal requirements but instead step-by-step processes that are necessary to be in compliance with the Federal guidelines. Response: The City will begin the process of drafting and approving a Federal grant procedures manual in order to be in compliance with Federal requirements going forward.

Views of Responsible Officials and Planned Corrective Action While the Organization concurred with the prior year (2023-002) and current year renumbered recommendation (2024-002), the Organization notes the corrective actions that have been implemented, specifically, related to the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance, that emphasizes accountability and compliance in managing federal funds and subrecipients, and that have been in practice, from the effective date(s) noted below, to the present period of the report dated June 17, 2026: A. Subrecipient Monitoring and Management. Implemented internal process changes, effective November 1, 2024, specifically, prospectively, and consistently the: 1. Use of a checklist, to comprehensively assess risk of determining subrecipient or contractor classification, before entering into any subrecipient agreement; 2. Provision of identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards; 3. Submission of programmatic and financial reports as specified in the subrecipient agreement; 4. Review of a single audit in accordance with 2 CFR Part 200, Subpart F for subrecipients that expend $750,000 or more in federal funds during a fiscal year, if applicable; and 5. Review of their audit report(s) and addressing any finding(s) related to their federal award(s), including the related appropriate corrective actions, when applicable. B. Retroactive Subrecipient Portfolio Risk Assessment and Correction(s). The Organization performed a risk assessment of the existing subrecipient portfolio to identify risks, for the audit periods July 1, 2022 – June 30, 2023, and July 1, 2023 – June 30, 2024. The objective of this risk assessment was to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, compliance and quality assurance goals. The completion of the Organization’s portfolio risk assessment resulted in correction of identified non-compliant subrecipient agreement(s). C. Subrecipient Policies and Procedures. By December 31, 2024, the Organization updated and implemented financial policies and procedures aligned to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance, including checklists, flowcharts, samples, data sheets, data sharing agreements, etc.; and the current practices of the Organization to the present period of the report dated June 17, 2026, is consistent with such developed subrecipient policies and procedures.

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

management has taken the following actions: Defined Roles and Responsibilities: A primary audit coordinator will be designated to oversee all audit-related requests. Clear ownership has been assigned to appropriate personnel for each audit area to ensure accountability for timely responses.  Formal Review Procedures: All audit support will undergo a supervisory review prior to submission to ensure completeness, accuracy, and appropriateness of documentation.  Enhanced Oversight: Management will conduct periodic status meetings during the audit process to monitor progress, resolve bottlenecks, and ensure deadlines are met.  Training and Communication: Accounting and relevant personnel will receive additional guidance regarding audit expectations, timelines, and documentation standards to improve overall responsiveness and quality.

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.

Finding 2024-008 - Uniform Guidance Subrecipient Monitoring - Significant Deficiency/Noncompliance Condition/Context: As part of our follow-up on previous audit findings and based on our current year testing, it was noted that the County is not formally documenting its monitoring activities over its subrecipients in compliance with the Uniform Guidance. Corrective Action: The Office of Financial Management will implement a process to document all subrecipient activities in compliance with the Uniform Guidance. Responsible for Implementing Corrective Action: Office of Financial Management 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 2024-003: 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

THE CONTRACTS WILL UPDATED WITH THE FEDERAL ASSISTANCE NUMBER BEGINNING WITH THE 2025 CONTRACTS

Undocumented Subrecipient Monitoring Recommendation: We recommend that the Alliance establishes a formal policy for subrecipient monitoring in accordance with requirements outlined in 2 CFR §200.331 and 2 CFR §200.332 to ensure its sub-recipients are properly monitored. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Alliance did monitor the subrecipients, but the documentation was not properly saved. This policy has since been revised to save the monitoring documentation to the grant management software. Name of the contact person responsible for corrective action: Lisa Wolf Planned completion date for corrective action plan: July 1st 2026

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's Response: AMHE has established policies and procedures for the creation, approval, submission and retention of all required reports. On September 27, 2018 AMHE updated and adopted the Financial Management Policy and Procedures. Page 6, Section 8, Financial Reports states: "The TDHE must be able to produce accurate, current, and complete disclosure of the financial results of each of the financially assisted activities made in accordance with the financial reporting requirements of the grant or sub-grant. The TONE shall use the financial reports as tools to manage, control, ensure compliance, monitor, and inform the TDHE on its financial activities. Reports to Grant Agencies: The TDHE shall complete and submit all reports to Federal, State, and local grant agencies in accordance with, and in the format and timelines required by the agency. The Executive Director will oversee all administrative and financial reports, including the HUD Standard Form 425, the INP and the APR, before the due dates designated by HUD, as such forms and deadlines may change from time to time." AMHE will do better in adhering to our Financial Management Policy and Procedures moving forward and getting the reports submitted in a timely manner. Estimated Completion Date: Immediately AMHE will adhere to the practice of the Financial Reporting of the Financial Management Policy and Procedures. This will be addressed with AMHE staff prior to 6/30/26. Responsible Party: Comptroller and Interim Director.

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 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

Finding #SA2024-005: Performance Audit Deficiencies Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Pass Through Entity: County of San Mateo Federal Award Identification Number: SFLRP0201 • Name(s) of the contact person: Kenneth Stiles, Finance Manager • Corrective Action Plan: The City will strengthen its procedures for the administration and oversight of federal awards to ensure compliance with applicable federal requirements. Staff will review and update existing grant management procedures, implement additional monitoring and documentation controls, and provide training to personnel involved in federal grant administration. The City will also evaluate opportunities to utilize external resources or consultants, as needed, to support compliance efforts and address identified deficiencies. • Anticipated Completion Date: August 2026

Finding #SA2024-002: Subrecipient Monitoring and Subgrant Reporting on Schedule of Expenditures of Federal Awards Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Pass Through Entity: County of San Mateo Federal Award Identification Number: SFLRP0201 • Name(s) of the contact person: Kenneth Stiles, Finance Manager • Corrective Action Plan: The City will strengthen its subrecipient monitoring practices to comply with 2 C.F.R. § 200.332. Specifically, the City will: 1. Conduct a suspension and debarment check on SAM.gov prior to awarding subrecipient agreements. 2. Update its standard subrecipient agreement template to include a requirement that subrecipients notify the City of any noncompliance or misuse of federal funds. 3. Require subrecipients to submit quarterly programmatic and financial reports to demonstrate proper use of funds and progress toward performance goals. 4. For subrecipients expending $750,000 or more in federal funds, obtain and review their Single Audit reports annually. If below the threshold, request and retain a written statement confirming the subrecipient is not subject to Single Audit requirements. 5. Maintain all documentation related to subrecipient monitoring for a minimum of five years and use a standardized checklist to track compliance. 6. Ensure subgrants are reported on the Schedule of Expenditures of Federal Awards. • Anticipated Completion Date: July 2026