Corrective Action Plans

The Board of County Commissioners have hired a grant administrator to assist with the reporting process. We will ensure that the reports are accurate and reported in the proper period.

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.

Period of Performance 2025-002 Plan: The University reinforced the existing procedures related to awards subject to modified or shortened periods of performance, including additional oversight of expenditures charged near revised award end dates. Post-Award monitoring and controls related to award end-date management and expenditure allowability will continue to be evaluated and strengthened, as appropriate. Expected Implementation Date: 07/01/2026 Contact: LaShawnda V. Hall Assistant Vice President for Research Financial Operations Accounting Services for Research Sponsored Projects (ASRSP) Northwestern University 1800 Sherman Ave, Suite 6-6000 Evanston, IL 60201 lashawnda.hall@northwestern.edu Phone: 847.491.4716

Finding 2025-003: Procurement, Suspension and Debarment The single audit report included the following recommendation: EY recommends that Amtrak include legal expenses within their procurement, suspension and debarment policy as outlined within each of the grant agreements. Management Response/Status of Action Plans: Pursuant to Section 26(j) of Amtrak’s annual grants, Amtrak’s policy is to fund most law firm engagements with Program Income without applying grant requirements that apply to other procurements. In FY2025, this was the case for all law firm engagements charged to operating activities. Also, in FY2025, Amtrak had a portion of its legal expenditures charged to capital projects based on the nature of the legal work performed. These capital projects were funded with federal grants. For legal expenditures which are by their nature related to projects funded by grants, Amtrak acknowledges the need to have the proper procurement process including competitive review and/or securing the contractor/law firms’ acceptance of required Supplemental General Provisions/flow-down based on the grants. By the end of FY2026, the Law Department will review and update its internal procedures to better prevent recurrence of legal expenditures that did not have proper competitive review and/or securing the contractor/law firms’ acceptance of required Supplemental General Provisions/flow-downs from being charged to projects funded by grants. As part of that review, Amtrak will consider whether it may be appropriate to utilize the Company’s broader procurement policies. The contacts for this item are Lucia Butts, AVP Funding and Grants and Thomas Bloom, Deputy General Counsel and Corporate Secretary. Amtrak anticipates fully remediating this finding by September 2026.

Diabetes, Digestive, and Kidney Diseases Extramural Research (ALN 93.847) Recommendation: We recommend that the Organization reviews the dates of costs incurred before charging costs to their Federal award and that evidence of this review is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented procedure enhancements to its review and processing of grant-related costs to better detect and prevent costs being charged outside of the period of performance. Including: the period charged for costs is based on expected receipt date of the goods or services being charged; a threestep/tiered review process of costs to be charged prior to the processing of such costs; a periodic review of the periods in which costs were charged for proper period alignment. Name of the contact person responsible for corrective action: Mahtab Khan Planned completion date for corrective action plan: May 2026

The Creek County Clerk’s Office will work with the SEFA preparer to ensure that the correct paid dates are being used when reporting. This should eliminate the actual expenditures differences. We will work to educate all offices involved in the reporting process on financial statement and SEFA.

The YWCA has implemented (January 2025) the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month, and year noted by the Staff Accountant prior to entry into accounts payable.

Finding: 2025-032 - DMVA management did not issue a management decision for a finding relating to one Disaster Grants subrecipient’ s single audit. Questioned Costs: None Assistance Listing Number: 97.036 Assistance Listing Title: Disaster Grants Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree. briefly explain why): DMVA concurs with the finding. Corrective Action (corrective action planned): DMVA acknowledges the importance of issuing timely and adequate management decisions to ensure subrecipients take corrective action. Due to a misunderstanding in the guidance provided, DMVA failed to issue the required management decision. The management letter has since been issued to the subrecipient. Internal procedures were updated in fiscal year 2025 to eliminate a single point of failure in this requirement. The Administrative Director, in conjunction with the Finance Officer, will assess the strengthened internal procedures to ensure they meet requirements. Completion Date (list anticipated completion date): 06/30/2026 Agency Contact (name of person responsible for corrective action): Bob Ernisse, Pamela Wiederspohn

Finding: 2025-047 - The amount of FY 25 SNAP benefits reported to United States Department of Agriculture as issued by the State’s Electronic Benefits Transfer (EBT) contractor, Fidelity National Information Services (FIS), was 1,235,577 more than the amount of authorized benefits reported in data from the Division of Public Assistance’s Eligibility Information System (EIS). Furthermore, FIS could not provide a reliable audit trail of issuances. Questioned Costs: AL 10.551: 1,235,577 Assistance Listing Number: 10.551, 10.561 Assistance Listing Title: Supplemental Nutrition Assistance Program (SNAP) Cluster Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department agrees with the finding but does not concur with the questioned costs. The Division of Public Assistance completes reconciliations between FIS daily transaction records and EBT Account Management Agent (AMA) data to ensure issuance accuracy. Corrective Action (corrective action planned): A workgroup identified the root causes of the discrepancies. A revised reporting process is being implemented to ensure all EBT payments are accurately captured, improving completeness and accuracy Daily reconciliations are now in place to support ongoing accuracy and reduce reliance on ad hoc reporting. As a result, the report previously developed for this audit by the EBT contractor, FIS, is not expected to be needed moving forward. Completion Date (list anticipated completion date): The department anticipates the finding will be resolved in FY2026. Agency Contact (name of person responsible for corrective action): Pam Halloran, Assistant Commissioner

Repeat Finding 2024-004 The City will continue strengthening its policies, procedures, and internal controls to ensure that all subawards are reported in full compliance with FFATA. The City reported subawards using the subaward obligation date, which is the date the agreement is fully executed, rather than the July 1st performance start date. As a result, obligation dates vary depending on when each agreement is signed.

Repeat Finding 2024-002 The City will continue strengthening its policies, procedures, and internal controls to ensure that all amounts passed through to subrecipients under subawards, as defined in 2 CFR 200.1 are reported in accordance with the FFATA federal regulations. In addition, the City will use obligation date for FFATA reporting.

The District will monitor the equipment purchased with federal fund to make sure they are recorded and tracked properly.

Finding 2025-001 Condition: Expenditures were not reconciled to the general ledger for reporting submitted to the U.S. Department of the Treasury. Corrective Action Planned: Report differences to the U.S. Treasury will be corrected in the next report. Anticipated Completion Date: 4/30/2026 Contact: Matt Parent, Town Accountant

Finding 2025-001 Condition: Expenditures were not reconciled to the general ledger for reporting submitted to the U.S. Department of the Treasury and Bristol County, Massachusetts. Corrective Action Planned: To ensure the accuracy of ARPA reporting, and all Federal Grants, a reconciliation process will be implemented and followed by all involved. Anticipated Completion Date: April 30, 2026 Contact: Nicole Pearsall, Town Accountant

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Finance Director Phone: (787) 788-0404 Original Finding Number 2025-002 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: Objective of the plan: The objective of this Corrective Action Plan is to address the observations identified in the audit and establish preventive measures to avoid future recurrences. Corrective Actions: 1. Schedule restructuring: • Create a detailed calendar with clear dates to define intermediate delivery deadlines to avoid delays (collection of information, analysis, writing, review, and submission) 2. Implementation of alerts and reminders: • Set up automatic alerts and email reminders for key dates (for example, 3 days before each deadline) 3. Review and Quality Control: Establish an internal review of reports before final submission to ensure that the information reported is accurate and complete. The revision includes compliance with the requirements established by the agency. Compliance Monitoring: • Biweekly meetings: The team will have biweekly meetings to have updates regarding the progress and achievement of the deadlines. • Email notifications: Emails will be sent to document the timely submission of reports and when needed, waivers will be requested explaining situations that may have delayed the process to prepare accurate and complete reports on time. Evaluation: • Monthly evaluations will be performed to measure the compliance of the submission of the reports on the timeframe established by the agency. • Adjustments to the processes according to the response of the team. Implementation Date: Fiscal Year 2025-2026. Responsible persons: • Person responsible for the implementation: Mr. Carlos Flores, Federal Program’s Subdirector • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director

All Federal purchases based upon current board policy ($10,000) quotes will be obtained and submitted with the requisition. This will now include purchased services as well as supplies and equipment.

Recommendation We recommend implementing a Program Improvement Plan between the Title IV-E team and Fostering Connections to ensure that adoption cases potentially eligible for extended subsidies are processed promptly upon consideration, with the necessary agreements executed in a timely manner, i.e., before the children in question turn 18. Management Response Corrective Action The Office of Performance and Accountability Director will work with the Adoption and Kinship Unit Supervisor to establish a biannual review of payments to adoptive parents to verify if cases need to be closed. Due Date of Completion: June 30, 2026 Responsible Person(s) Office of Performance and Accountability Director

Finding Number: 2025-002 Equipment Property Management Recommendation: The University needs to enhance the precision of the controls over equipment purchases to ensure that a property record is created within the system containing the required information, inclusive of the federal award, for all federally funded equipment. Management concurs with the auditor’s recommendation. The University has taken immediate steps to comply with 2CFR 200.313 and implemented the following actions: Planned Corrective Action (1): The University has established a bi-weekly reconciliation process for federally funded assets to strengthen compliance and ensure the timely and accurate inclusion of all federally funded asset purchases in the asset register. Anticipated Completion Date: Completed Responsible Contact Person: Eric Hughey, Fiscal Manager, Asset Accounting & Surplus/Nataliya Samodov, GCA Director Planned Corrective Action (2): The University has implemented an additional control through exception reporting and follow-up with responsible parties to ensure that all registered assets are tagged at the time of installation. Anticipated Completion Date: Completed Responsible Contact Person: Eric Hughey, Fiscal Manager, Asset Accounting & Surplus/Nataliya Samodov, GCA Director

Corrective Action Plan: For Benefits Adjudication: Standard procedures for verifying claimant eligibility for unemployment benefits remain in place. Adjudication staff have been reminded to double-check start dates and eligibility documentation to prevent the recurrence of similar errors. For Benefit Payment Control (BPC): The Department remains committed to strengthening accountability and proactively identifying any potential training gaps within the team. To support this effort, the Department has recently implemented monthly random case reviews conducted by supervisors, followed by individualized email feedback to staff to reinforce expectations and provide timely coaching. Additionally, supervisors are now required to track all audits and document follow up actions to ensure consistent monitoring and early identification of any emerging trends. These measures are intended to enhance quality assurance, support staff development, and maintain the high standards expected within the Department. Anticipated Completion Date for Corrective Action: Completed February 2026 Contact Person Responsible for Corrective Action: For Benefits Adjudication: Name: Traci A. Brown Title: Assistant Deputy Director - Benefits Adjudication Address: 30 East Board Street, Columbus, Ohio 43215 Phone Number: 614-387-3647 E-Mail Address: Traci.Brown@jfs.ohio.gov For Benefit Payment Control (BPC): Name: BJ Knutson-Cruset Title: Bureau Chief Address: 6680 Poe Ave, Dayton, Ohio 45414 Phone Number: 937-264-5742 E-Mail Address: bj.knutson-cruset@jfs.ohio.gov

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dr. Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: An updated Procurement Policy will be developed and adopted. This policy will outline our process for obtaining multiple quotes for small purchase vendors. Quotes will be reviewed and approved by Superintendent/CFO. All vendors will be vetted through the SAM.gov website for suspension or debarment by the Corporation Treasurer prior to ordering. Any vendor that cannot be vetted through SAM.gov will be required to selfcertify that they have not been suspended or debarred. A vendor list will be updated yearly by the Corporation Treasurer and reviewed and signed off by the Superintendent/CFO. Anticipated Completion Date: Board policy will be adopted by April 1, 2026. Vetting of vendors will begin immediately (1/20/2026).

FINDING 2025-008 Finding Subject: COVID-19 - Education Stabilization Fund – Condition of Records Federal Agency: Department of Education Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls will be put in place to ensure all COVID 19 ESSER Funds are reported accurately to the State and Federal Department of Education. Reimbursements will be attached to State Email for disbursement. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All purchases that exceed the micro purchase threshold will require three quotes to ensure the vendor is in compliance and all quotes will be attached to the APV. Purchases exceeding $150,000 will require the formal bidding process. This will ensure all documents are available upon request. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

Federal Agency: U.S. Department of Health and Human Services State Department/Agency: Kansas Department of Children and Families Federal Program Name: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Award Number: 2301KSTANF, 2401KSTANF, and 2501KSTANF Period: October 1, 2023 – September 30, 2025 Compliance Requirement: Reporting - Federal Funding Accounting and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Condition: Kansas Department of Children and Families (Department) was unable to provide FFATA reports for various subawards. Recommendation: We recommend that the Kansas Department of Children and Families implement procedures to identify all subawards subject to Federal Funding Accountability and Transparency Act (FFATA) reporting requirements, including subawards passed through to both in‑state and out‑of‑state subrecipients. DCF should provide training to relevant staff on FFATA requirements and establish a review process to ensure required FFATA reports are submitted accurately and timely for all applicable subaward. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: Department for Children and Families (DCF) will update FFATA reporting procedures to include second-tier FFATA reporting for subawards given by other subrecipient Kansas state agencies awarded by an Interagency Agreement. The Interagency Agreement template for subrecipients will be updated to include language detailing any possible subawards given by other state agencies. The subrecipient state agency will determine if the relationship is a subrecipient, vendor or beneficiary for funds passed through to other organizations. If federal funds passed through have a subrecipient relationship, then the other state agency will notify the DCF of subaward amount. DCF staff will provide the other state agency with the federal portion for each subaward and FFATA reporting forms needing completed. The other state agency will complete the FFATA reporting forms for each subaward receiving $30,000 or more federal funds and provide those forms to DCF. DCF staff will submit accurately and timely the FFATA requirements for each subaward given by another subrecipient Kansas state agency. Name(s) of the contact person(s) responsible for corrective action: Brian Carlgren, Director of Grants, Contracts and Payables and James Heckard, Deputy Director of Pre-Award Management Planned completion date for corrective action plan: June 30, 2026

Federal Agency: Department of Health and Human Services State Department/Agency: Kansas Department of Health and Environment Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Award Number and Period: NU50CK000549 (7/1/2019 – 7/31/2027) & NU51CK000384 (8/1/2024 – 7/31/2029) Compliance Requirement: Reporting - Federal Funding Accounting and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: During the audit period, the entity did not submit required FFATA reports for certain first‑tier subawards subject to FFATA reporting requirements. As a result, required information was not reported in SAM.gov by the last day of the month following the month in which the subaward obligation occurred. Recommendation: We recommend that management implement policies and procedures to ensure compliance with FFATA reporting requirements. This should include identifying all federal awards and subawards subject to FFATA, establishing a process to track reporting deadlines, and providing training to personnel responsible for grant administration to ensure FFATA reports are submitted timely and accurately in SAM.gov. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: Currently, all sub awardee payments are being processed by KDHE; however, moving forward, the fiscal analyst will work with the program to make sure that they have the needed information if another state agency is going to be processing the payments on KDHE’s behalf. Moving forward, the fiscal analyst will contact the program to get amounts for any subrecipient agreements/awards, which KDHE will not be the agency processing the payments for, so that any required FFATA reporting can be submitted. Name(s) of the contact person(s) responsible for corrective action: Shelley Russell, Fiscal Management Public Services Executive IV and Danette Cox, Fiscal Analyst Planned completion date for corrective action plan: Immediately. New processes will be used if another state agency will be processing the payments on KDHE’s behalf.

Federal Agency: U.S. Department of Homeland Security State Department/Agency: Kansas Division of Emergency Management Federal Program Name: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing Numbers: 97.036 Award Period: July 1, 2024 through June 30, 2025 Award Number: Various Compliance Requirement: Reporting - Federal Funding Accounting and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) report, it was noted that the Kansas Division of Emergency Management (KDEM) did not timely report certain subawards to FSRS for the fiscal year. Recommendation: We recommend that KDEM continue to implement its corrective action plan from the prior year. Management should continue to enhance its procedures and internal controls to ensure that subawards are accurate, reported timely and reviewed timely to FSRS. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: KDEM Fiscal and Compliance office will continue to implement corrective action plan from SFY24. A report will be downloaded of newly obligated projects from Grants Portal every two weeks to ensure projects are reported timely for FFATA requirements. Currently fiscal staff is collecting this information on a weekly basis and submitting it at the beginning of next month. For example, all February projects are reported at the beginning of March. Name(s) of the contact person(s) responsible for corrective action: Jennifer Deal, Fiscal & Grants Management Section Chief and Lupe Olaya, Grants Compliance Coordinator Planned completion date for corrective action plan: Currently in place.