Corrective Action Plans

The Finance Staff will perform quarterly reconciliations of expenditures to ensure accurate reporting of amounts. Personnel responsible for implementation: Carmen Tsui, Grant Accountant Completion Date: June 30, 2026

The Board of County Commissioners will ensure that the reports are accurate and reported in the proper period.

FINDING 2025-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Tom Warthen Contact Phone Number and Email Address: 317-831-1608 twarthen@mooresville.in.gov Views of Responsible Officials: The Town of Mooresville Management agrees that we failed to adopt adequate internal controls by not having a procurement policy in place regarding the use of federal funds and that by not doing so, we failed to recognize the need to obtain three quotes for small purchases. Description of Corrective Action Plan: The Town of Mooresville will adopt a procurement policy for the use of federal funds to ensure that all federal grants are handled appropriately, and all grant requirements are met to the best of our ability going forward. Anticipated Completion Date: To allow time for a policy to be written and adopted by Council and the potential need for outside assistance in creating said policy, the Town of Mooresville anticipates having this policy in place within 60 days of the exit conference.

The City will create a federal cash management policy. A review of cash will be done monthly.

VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the Activities Allowed or Unallowed// Allowable Costs/Cost Principles (ALN 10.553, 10.555, 10.559, 10.582, 84.010, 84.027, 84.425D, 84.425U. The PRDE recognizes that the recoup procedures established in the "Manual de Procedimiento de Nómina" are in place; however, the Department acknowledges that the detail of Accounts Receivable shows $3,756,580 corresponding to invoices generated during the audit year. The PRDE is working with the existing manuals, along with the new changes being implemented, to strengthen the recoup process for these overpayments. As such, the PRDE has implemented several procedures which have helped in this collection process. The PRDE is committed to strengthening its documentation practices and internal oversight mechanisms to ensure full compliance with 2 CFR § 200.403(g) and other applicable federal requirements. The PRDE further acknowledges that this is a repeat finding (prior year Finding 2024-005) and accepts the auditors’ recommendation to establish and implement formal procedures to obtain and review subrecipient audit reports in a timely manner, follow up on relevant audit findings, and maintain documentation of all monitoring activities performed IMPLEMENTATION DATE Fiscal Year 2025-2026 RESPONSIBLE PERSON Giovanni Siarez Deputy Director of Payroll Wilfredo Falcón Negrón Human Resources Area Director Office Time Attendance & Leave Evelyn E. Rodríguez Cardé Finance Director

Corrective Action Plan Year Ended December 31, 2025 Finding 2025-001 – Procurement and Suspension and Debarment Condition: Texas Biomed did not comply with procurement requirements per the Uniform Guidance. Specifically, Texas Biomed did not comply with informal procurement methods for small purchases and noncompetitive procurement requirements. Texas Biomed also did not comply with its own procurement policy in relation to procurements of small purchases and noncompetitive procurements. Texas Biomed did not maintain records for certain procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, and the performance of a cost or price analysis, when required. Corrective Action Plan: To ensure compliance and adherence to purchasing policies and procedures, Texas Biomed introduced a Purchasing Compliance Program in November 2025. This program included training and oversight procedures for procurement. The training included ongoing quarterly purchasing training for end users and purchasing staff and new hire training. The purchasing team maintains training documents and ensures new and existing employees have the most current policy, procedures, and requirements to guide them through the purchasing process. The oversight procedures are performed by the Assistant Director of Supply Chain Management and include auditing of purchase orders over the micro-purchase threshold to ensure proper documentation is present. We believe these steps address the procurement findings that have been identified; however, additional controls have been implemented to further ensure compliance. In January 2026, an additional approval step was added to the purchase requisition approval workflow in the procurement system for all federal procurements above the micro-purchase threshold. This step documents review and approval by the Assistant Director of Supply Chain Management or the Director of Finance after reviewing the procurement to ensure compliance with procurement requirements and policies. In addition, Texas Biomed is developing a new sole source justification form for the end users to use. This will include more detail to better document sole source justification, and the end-users will be advised of the new format and how to use it. The Assistant Director of Supply Chain Management also leads efforts of continuous improvement to update and communicate the Purchasing Compliance Program to all Texas Biomed staff. Key dates shall include: • Enhanced new hire training November 2025 • Oversight procedures developed November 2025 • Quarterly training sessions January, April, July and October 2026 • New user training April 2026 • New sole-source template developed and deployed July 2026 Responsible Parties: Eva Zepeda, Director, Finance; Eric McGowin, Assistant Director, Supply Chain Management Completion Date: Corrective action to address internal controls and noncompliance was implemented as of November 2025. Management continues to implement best practices in procurement, including the procedures mentioned above.

FINDING 2025-003 Mr. Tim Johnson - President Elected 1/2/2025-12/31/2028 Mrs. Becky Comoglio - V. President Elected 1/2/2025-12/31/2028 Mr. Ryan Zeck - Secretary Elected 1/2/2023-12/31/2026 Mrs. Kristi Hull - Member Elected 1/2/2023-12/31/2026 Mr. Rick Lee - Member Elected l/2/2025-12/31/2028 Finding Subject: Special Education Cluster - Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Jackquan Gray, Business Manager Contact Phone Number and Email Address: 574-626-2525 grayj@lewiscass.net Views of Responsible Officials: We Concur with the Finding. Description of Corrective Action Plan: o Create a clear procedure for all small purchases as it relates to procurement. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. o Implement a policy requiring verification of all vendors/contractors for "covered transactions" prior to entering into the contract or issuing payment. A "covered transaction" includes contracts for goods and services expected to equal or exceed $25,000. o The standard procedure should be to check the System for Award Management (SAM} exclusions (www.sam.gov) for all vendors involved in covered transactions funded with federal awards. o Establish proper segregation of duties within the procurement and payment processes to ensure no single person controls an entire transaction. Implement a review process to check for compliance with the new procedures before a purchase order is issued or a payment is made. Anticipated Completion Date: This new policy will take place immediately and the process will be followed when there is a need to check vendors in such circumstances.

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