Corrective Action Plans

Subrecipient Monitoring Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP has implemented a comprehensive policies and procedures document covering the entire subrecipient lifecycle, which includes internal controls such as a checklist, review of risk before issuance, a biannual sub monitoring review of financial audit, and authorized purposes review. ● How compliance and performance will be measured and documented for future audit, management and performance review. The internal controls will be added by OSP to enhance sub monitoring to include a review of the budget-to-actuals for subrecipients' invoices for alignment to the project. Additional guidelines will be included in the invoice review process for the principal investigators as well. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Subrecipient Monitoring Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP has implemented a comprehensive policies and procedures document covering the entire subrecipient lifecycle, which includes internal controls such as a checklist, review of risk before issuance, a biannual sub monitoring review of financial audit, and authorized purposes review. ● How compliance and performance will be measured and documented for future audit, management and performance review. Per the UNLV OSP policy, documentation is required throughout the lifecycle and will be used for future audits. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management staff, independent of preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN Office of Grants and Contracts Post-Award Management has advised the grant’s principal investigator (PI) that underlying documentations must match the data reported on the Annual Performance Reports submitted to the award sponsor. The CSN GEAR UP PI and GEAR UP First Year College Advisor have refined the reporting and record keeping process to ensure accurate reporting and supporting documentation is kept in compliance with the grant. The Senior Accountant of Grants and Contracts also reviews the data before each report is submitted to the sponsor. ● How compliance and performance will be measured and documented for future audit, management and performance review. CSN GEAR UP PI and GEAR UP First Year College Advisor will continue to ensure accurate reporting and supporting documentation is kept in compliance. CSN Office of Grants and Contracts Post-Award Management will continue to communicate with PIs to ensure all reports have been reviewed for adequate and accurate supporting documentation prior to submission to the sponsor. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Program Director, who is the Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) Principal Investigator (PI), is accountable for exercising oversight and responsibility. GBC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o Establishment of a formal review and approval workflow requiring secondary review by the Grants Office of participants numbers prior to submission of any financial or performance report. This will require: (1) Identification of the reporting period; (2) Review of all source documents supporting reported totals; and, (3) Mathematical reconciliation of reported figures o Training provided to grant program staff and administrative personnel on documentation standards and reporting accuracy expectations. o All corrective actions were implemented immediately upon identification of the finding and will be fully in place within 30 days of notification. The revised procedures are now standard practice for all grants reporting participant numbers. ● How compliance and performance will be measured and documented for future audit, management and performance review. o Reports may not be submitted to the pass-through entity without documented secondary review and written approval from the Grants Director or the Grant and Asset Coordinator. o Interim and final program reports will be reviewed to ensure: (1) Participant totals match underlying documentation; (2) Source documentation is retained and accessible; and, (3) Approval signatures are present prior to submission. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and the Director of Business Operations are responsible for oversight of grant compliance. NSU – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; NSU has reviewed the finding and has put additional measures in place to ensure compliance. Staff responsible for preparing reports were retrained and multi-layered quality checks have been implemented to safeguard integrity of data entered in shared databases. NSU’s multi-layered quality checks include written confirmations from staff involved in service activities and backup of documentation within NSU’s local storage to support the numbers being reported. The latter represents a move away from using a database that is accessible to multiple institutions to a centrally controlled location within NSU. This process outlined herein was implemented in August 2025 and ensures that the source documentation reconciles with reports and is available for auditing purposes. ● How compliance and performance will be measured and documented for future audit, management and performance review. To ensure compliance, NSU staff who are responsible for the program and technical reporting have reviewed and updated internal policies and procedures relating to reporting. Performance targets and benchmarks have been reestablished and will be measured at set intervals. Any errors detected will be documented and remedied. Additionally, errors will serve as the basis for continuous improvement processes and retraining as needed. These will be documented in performance reviews. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The NSU GEAR UP Principal Investigator and First-Year College Advisor Supervisor are responsible and accountable for ensuring reporting is supported by underlying records. TMCC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; TMCC reports on the number of participants for all services rendered under the GEAR UP grant through both the Interim Progress Report (IPR) and the Final Progress Report (FPR). The identified issue concerns a discrepancy between the reported participant count on the IPR and the underlying supporting records. To ensure data accuracy going forward, TMCC will implement an additional review of participant reporting. Prior to the submission of progress reports, a second technical reviewer within the GEAR UP team would verify the participant counts entered into GEARS (GEAR UP’s designated data-reporting platform) against the supporting documentation (the attendance sheet). Should a discrepancy be identified, the GEAR UP team will follow up with the individual responsible for the data entry on GEARS to reconcile the difference. This may include requesting correction of data entry errors or obtaining additional documentation to support the reported participant count, as appropriate. Additionally, attendance sign-in sheets will be collected and retained by TMCC staff to allow for direct verification prior to reporting. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured by the implementation of a second reviewer for the participant data reported through GEARS and included in the progress reporting. This review can be documented through an internal checklist, internal communication, or other appropriate records demonstrating that the participant data was reviewed and validated prior to the submission of progress reports. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Primary responsibility for accurate participant reporting will remain with the TMCC First Year College Advisor (FYCA) or other designated staff responsible for preparing grant performance reports. Responsibility for completing the secondary verification review will be assigned to a designated GEAR UP technical reviewer or program staff member who is independent of the initial data entry and report preparation. If repeat or similar observations occur, program leadership will evaluate adherence to established procedures and implement additional corrective actions, which may include staff retraining, revision of internal procedures, or reassignment of reporting responsibilities, as appropriate. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP will continue to work with PIs to ensure there is a documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. Additionally, if reports require financial expenditures, the Office of Sponsored Programs will require validation before submission. Communication dissemination will occur twice within the academic year. ● How compliance and performance will be measured and documented for future audit, management and performance review. UNLV OSP will continue communications through Research Weekly (an internal communication newsletter) to remind PIs to ensure timely submission of progress reports and retention of records such as, lab notes, testing, populations served, activities performed, etc. to demonstrate activities supported by the grant. UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with the applicable Deans. UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; All participant counts reported in Interim Progress Reports will be supported by retained underlying source documentation that directly reconcile to the reported totals. Standard documentation expectations and retention requirements will be communicated to program staff. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance will be measured through pre-submission review of reported participant data against underlying records and through post-submission spot checks conducted by Program Director. Documentation supporting reported counts will be retained in the official project file and made available for future audit, management review, and internal monitoring. Evidence of reconciliation will be documented via checklists or certifications retained with the report. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Program Director WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Sponsors have determined grant practices and required reporting documentation, which have not been consistently required or expected of subrecipients. WNC will maintain its own sign-in sheets and documentation for all grant-sponsored activities to ensure compliance with overall grant requirements. The corrective action was implemented in July 2025. ● How compliance and performance will be measured and documented for future audit, management and performance review. The GEAR Up coordinator will create and maintain sign-in sheets or other documentation for every grant-sponsored activity. The coordinator will maintain records in accordance with federal and state guidance and will ensure that supporting documentation is sufficient to support the reported figures. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Final responsibility and accountability fall on the GEAR Up coordinator and grant administrator. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Cash Management Responses WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP will continue to work with PIs to ensure there is a documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. Additionally, if reports require financial expenditures, OSP will require validation before submission. Communication dissemination will occur twice within the academic year. ● How compliance and performance will be measured and documented for future audit, management and performance review. UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with the applicable Deans. UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management staff, independent of preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management Staff, independent of preparer, will review each subaward report required. The review process will include verifying that all subaward information required by FFATA is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify the information in each report is accurate. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Pre Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Subrecipient Monitoring Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP has implemented a comprehensive policies and procedures document covering the entire subrecipient lifecycle, which includes internal controls such as a checklist, review of risk before issuance, a biannual sub monitoring review of financial audit, and authorized purposes review. ● How compliance and performance will be measured and documented for future audit, management and performance review. The internal controls within the annual audit review process will require a response and escalation, as needed, for multiple follow-ups to enhance sub monitoring. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Reporting Responses TMCC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Two additional layers of review have been added to ensure that every RFR/Invoice is reviewed. On 4/14/25 an extra invoice review was added to Workday ensuring that they have to go through a review by someone other than the creator. During this step, the attachments including RFR and the approval email by the controller is also reviewed for accuracy. The Grant Accountant also established a log in August of 2025 that includes the Due Date, Date sent to the Controller for Approval, the Approval date and the submission date. ● How compliance and performance will be measured and documented for future audit, management and performance review. Emails documenting the review of the RFRs are kept as proof of review and saved in our files as well as Workday. The tracking document will also be made available for future review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Grant Accountants will be responsible for ensuring that we are in compliance with the corrective actions UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP does have separation of duties from the originator of the subaward to the review of the subaward agreement in entering all of the data points into Sam.gov for FFATA reporting; however, UNLV OSP will create a process document that explicitly notes this for future documentation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Cross checking of the issued subaward (originator) is reviewed and entered into the federal portal by the submitter. As the federal portal requires one party to enter and submit, OSP management perceives this to be very low risk but will ensure reviews occur. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Subrecipient Monitoring Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o DRI implemented controls to require the documentation of risk assessment procedures for all subawards issued beginning in November 2024. Depending on the results of the risk assessment, monitoring procedures are designed to ensure compliance. o DRI will review all subawards issued in prior years that are still active. For any that may be missing required information, communication will be sent to the subrecipient by March 31, 2026. o DRI will ensure future monitoring activities are adequately documented. Currently, procedures do require those knowledgeable of subaward activities to review and approve subaward invoices. Procedures will be updated beginning in February 2026 to include an intermittent review of supporting documentation for invoices received based on the subrecipient’s level of risk. o DRI will update procedures to ensure subrecipient audit reports are collected timely beginning in February 2026. ● How compliance and performance will be measured and documented for future audit, management and performance review. Documentation will be maintained in DRI’s pre-award system or in the accounting system, as appropriate, to ensure compliance. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. NSU – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Nevada State University (NSU) has implemented procedures and staff training to ensure that a risk assessment tool/checklist is completed prior to issuance of a subaward. ● How compliance and performance will be measured and documented for future audit, management and performance review. NSU will conduct a risk assessment using a checklist prior to issuing a subaward. NSU will request and review prospective subrecipients’ annual financial statements and audit reports and will verify suspension and debarment status. Based on the results of this review, NSU will adjust subrecipient monitoring as appropriate. All risk assessments, reviews, and monitoring activities will be documented and maintained in the subrecipient files and in Workday. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Director of Grants Award Services will be responsible with additional oversight by the Associate Vice President of Fiscal Services. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP has implemented a comprehensive policies and procedures document, in place as of July 2025, covering the entire subrecipient lifecycle and includes internal controls such as a checklist, review of risk before issuance, a biannual sub monitoring review of financial audit, and Authorized purposes review. Additional reviews of the policy and procedures are conducted throughout the fiscal year to ensure the related practices are relevant and effective, with adjustments made as necessary. ● How compliance and performance will be measured and documented for future audit, management and performance review. Per the UNLV OSP policy, documentation is required throughout the lifecycle and will be used for future audits. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; All required subaward documents will be retained in a centralized database for easy access and compliance tracking. Subaward Specialist will review subrecipient audit reports timely to ensure a management decision letter will be issued within six months of the clearinghouse acceptance date if required. ● How compliance and performance will be measured and documented for future audit, management and performance review. Once subrecipient letters of certification have been issued, management will perform a monthly reconciliation to ensure completeness and timely follow-up. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Pre Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion Context: The School Corporation did not obtain the weekly payroll reports certifications from a company that performed renovations to replace HVAC equipment and install windows in the building. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $696,118 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Nathaniel Day Contact Phone Number: 317-462-4434 . Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will comply with Bacon Davis on future projects using federal funds.

Bienestar (Wellbeing) For All; ESNMS: Title V DOE Grant (Ensuring Success for the New Majority Student) – Assistance Listing No. 84.031S Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University implemented a formal policy and procedure to verify that a vendor is not debarred or suspended in the System for Award Management (SAM) database. The procedure, effective May 2025, outlines roles, responsibilities, and documentation requirements to ensure consistent compliance. Name(s) of the contact person(s) responsible for corrective action: Diane DiStaulo, Director of Accounting Operations, (201) 761-7415 Planned completion date for corrective action plan: Completed

Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The Authority will continue to review internal controls and work to design modifications that will increase internal control and the ability to detect material misstatements. Officer Responsible for Ensuring CAP: Executive Director Planned Completion Date: January 2026

Corrective Action Plan: The Division will implement a review process to ensure the accuracy of the inventory management and reporting process. Anticipated Date: April 2026 Name of Person Responsible for Implementation: Al Agpoon, Controller

Program: AL 21.029 – COVID-19 Coronavirus Capital Projects Fund – Subrecipient Monitoring Corrective Action Plan: For the current year, no new awards have been issued; therefore, the following reflects the continued implementation of the prior-year corrective action. Prior to the second round of CPF awards, the department created a standardized “Budget Template” that has been incorporated into the grant application process. This tool allows for a more robust documented review of reasonable and estimated costs. The updated budget process has already been applied to the 2024 Capital Projects Fund awards. The Commission has a standardized reimbursement template that further strengthens this process by allowing us to compare verified actual costs to the original budgeted costs. The implementation of this enhanced process allows us to build a documented dataset of historical project data and associated costs, which will continue to expand as reimbursement requests reflecting actual costs are received. Contact: Carrie Gans Anticipated Completion Date: Completed and approved by The Department of Administrative Services in June of 2025.

Program: AL 21.029 – COVID-19 Coronavirus Capital Projects Fund – Reporting Corrective Action Plan: DED will create a policy that requires the Division Director and/or lead program manager, legal counsel and Compliance Team Manager to review all Federal Financial Assistance agreements immediately after execution to determine whether a FFATA report is required. Contact: Audrey Sautter, DED Compliance Team Manager Anticipated Completion Date: End of Quarter 2, 2026

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Corrective Action Plan: As of the reporting period ended December 31, 2025, changes requested by agencies to obligations or expenditures have been updated. DAS will obtain, or expand where possible, the written justification for capital expenditures over $10 million for the projects identified. Contact: Philip Olsen Anticipated Completion Date: January 31, 2026

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Subrecipient Monitoring Corrective Action Plan: DNR will enhance subrecipient monitoring procedures to specifically include documented reviews of subrecipient procurement policies and procurement files to ensure compliance with applicable federal requirements and the subrecipient’s own written policies. DNR will revise subaward templates and procedures to ensure that all required federal award information and applicable terms and conditions, including closeout requirements, are consistently included in subaward agreements at the time of issuance. DNR will develop and implement formal written procedures for subrecipient Single Audit monitoring. DHHS will continue to improve subrecipient monitoring where necessary. NDCS will revise its policy to include a requirement for verifying subrecipient qualifications for federal funds. Additionally, NDCS will notify all subrecipients that proper payroll and benefit documentation must be submitted to ensure accurate cost allocation. NDCS will ensure that all required subaward documentation is provided to each subrecipient. This documentation will include: a. The subrecipient’s Unique Entity Identifier (UEI) b. Federal Award Identification Number (FAIN) c. Federal Award Date d. Federal award project description e. The name of the Federal agency, pass-through entity, and contact information for the awarding official of the pass-through entity f. Assistance Listings title and number g. A requirement that the subrecipient permit the pass-through entity and auditors to access the subrecipient’s records and financial statements h. Appropriate terms and conditions concerning closeout NDCS will incorporate these requirements into its subaward process to ensure compliance with federal regulations. Contact: Erv Portis, Shelby Mikulak, Heather Arnold, Jenise Trautman Anticipated Completion Date: June 30, 2026

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowability Corrective Action Plan: DHHS will work with Federal Partners on reviewing allowability of methodology used. Contact: Patrick Werner Anticipated Completion Date: June 30, 2026

Program: AL 21.023 – COVID-19 Emergency Rental Assistance Program – Reporting Corrective Action Plan: The categorization issue was corrected on the ERA2 Closeout report. Contact: Philip Olsen Anticipated Completion Date: January 28, 2026

Program: AL 17.225 – Unemployment Insurance – State – Allowability & Eligibility Corrective Action Plan: NDOL will reinforce adjudication controls. This includes working with our vendor on wage and other crossmatches to continue making enhancements, so they are as effective as possible. NDOL will also reinforce the importance of obtaining separation information from employers, and employer responses will be reviewed and documented to support accurate eligibility determinations. NDOL agrees that the identification and treatment of excessive wages is an area that warrants additional consideration and will continue to evaluate procedures to ensure wages are applied appropriately. NDOL will also develop additional training related to benefit charging to ensure staff are familiar with applicable requirements and procedures. NDOL remains committed to continuous improvement and will adjust procedures, training, and system functionality as needed. Contact: Andi Bridgmon Anticipated Completion Date: 9/30/2026

Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.991 – Preventative Health and Health Services Block Grant – Allowability & Subrecipient Monitoring Corrective Action Plan: DHHS has implemented enhanced subrecipient monitoring procedures designed to strengthen oversight and documentation requirements. Corrective actions include: - Termination of the subaward agreements with the Karen Society of Nebraska. - Issuance of a formal demand for repayment and initiation of collection actions for disallowed costs. - Implementation of a standardized Subrecipient Monitoring Procedures Manual outlining documentation expectations, desk review requirements, and risk-based monitoring activities. - Strengthened front-end invoice review processes to require sufficient financial source documentation prior to reimbursement. - Increased coordination between program and fiscal staff when a subrecipient receives funding from multiple programs or divisions. - Ongoing monitoring and verification of corrective actions through routine monitoring activities and future audits. Contact: Ryan Daly Anticipated Completion Date: November 20, 2025

Program: AL 93.575 – COVID-19 Child Care and Development Block Grant – Allowability Corrective Action Plan: In 2025, The Agency developed a subrecipient monitoring tool to ensure effective controls and processes are in place. The Agency will review all findings and take appropriate actions when warranted. Contact: Nicole Vint Anticipated Completion Date: June 30, 2026

Program: AL 93.575 – COVID-19 Child Care and Development Block Grant – Period of Performance Corrective Action Plan: N/A Contact: Heather Arnold Anticipated Completion Date: Complete