Corrective Action Plans

Finding Subject: 2025-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Debbie Bennett-Stearsman Contact Phone Number and Email Address: 812-319-9068 and dbennett-stearsman@warrickcounty.gov View of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As explained and demonstrated by the County Administrator to the SBOA at the time of the audit, the online reporting system for the U.S. Treasury quarterly reports had malfunctioned. When the County Administrator attempted to enter the correct amounts, the report would be rejected. The only way to get the quarterly reports to be accepted was by adjusting the numbers, resulting in the issues pointed out by the SBOA. As the SBOA is aware, the reports were on a time-sensitive deadline and had to be submitted. The County will follow up with the U.S. Treasury in the event of future problems with the online reporting system. The County Administrator did follow up with the U.S. Treasury in 2025. No response was given. In 2026, the U.S. Treasury provided a webinar stating that if the municipality could not close out or lock awards due to unbalanced figures, then the municipality should leave the project “unlocked.” There was no guidance on reopening previous quarterly reports to correct any mistakes. Therefore, the County Administrator could not correct previous reports. Anticipated Completion Date: September 30, 2026.

New cash management policies were approved at the September 2025 meeting of the Board of Directors. Advance funds, as well as accrued interest, were returned to the appropriate agencies according to the instructions of the program officers in early 2026. We continue to implement revised cash management procedures and monitoring controls to ensure drawdowns are limited to immediate cash needs and comply with 2 CFR 200.305.

Finding 2025-004: Noncompliance Over Activities Allowed or Unallowed/Allowable Costs/Cost Principles Name of Contact: Eileen Zaiser, Controller Corrective Action: Management will set-forth in writing its long-standing implicit policy that charges to federal awards will be disallowed without adequate documentation to support compliance with grant and regulatory requirements. Proposed Completion Date: October 1, 2026.

FINDING 2025-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Michael A. Watkins, Auditor Contact Phone Number and Email Address: 812-385-4927 / mwatkins@gibsoncounty-in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Deputy Auditor will prepare the report using the financial information available in LOW, and the Auditor will review and approve it before submitting it to the U.S. Treasury. Moving forward, the County Auditor will strengthen internal control procedures to ensure compliance with 2 CFR 200.303. These improvements will include protocols for communicating with the U.S. Treasury whenever system issues arise that could affect timely or accurate reporting. Anticipated Completion Date: January 1, 2027

FINDING 2025-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Amy L. Glackman Contact Phone Number and Email Address: 317-392-6310; aglackman@co.shelby.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Control procedures will be put into place effective immediately. The Auditor will provide copies of the Report to Council for review prior to submission to verify the dates and amounts are correct for the reporting period, this will also be reviewed by the Deputy Auditor. Anticipated Completion Date: December 31, 2026

Recommendation: The Town should implement procedures to reconcile all federal reporting to the general ledger. Response: A full reconciliation of the ARPA accounts has been performed and aligned with the previous compliance reporting. A chart of accounts conversion is under way which will segregate federal funds from one fund to six funds for comprehensive oversight in the general ledger.

BGCPR recognizes that it must keep and improve the asset capitalization processes and policies, particularly within the accounting system of record. It acknowledges the need to strengthen these processes to ensure accurate and compliant management of equipment acquisitions. To address this, during fiscal year 2025-26, BGCPR implemented a system capable of recording, classifying, and monitoring all capital assets in alignment with the criteria established under federal regulation 2 CFR §200. This improvement is essential to ensure that all asset capitalization activities meet regulatory standards and support greater financial transparency and accountability. As a corrective measure, BGCPR will take the following actions: a. A property and inventory coordinator was hired and is responsible for overseeing all aspects of property control and asset management. b. Full Implementation Property software to accurately all property of by BGCPR. The system includes information such as asset identification number, acquisition date, funding source, cost, useful life, depreciation, location, and other relevant details, serving as a support tool for the property records maintained in the accounting system. c. Prepare an updated Property Control Manual, which is pending final approval by senior management. Implement procedures for timely recording of acquisitions, transfers, disposals, and impairments to ensure that asset records remain current and accurate. d. Perfom and complete physical inventory for all Units and Central Office. e. All inventory counts have been entered into the system. f. All property acquired have been recorded in the property software. g. Currently we are in the process of valuation of the physical inventory to reconcile with the accounting records by December 31, 2026. h. Training was provided to personnel involved in asset management and inventory activities to ensure consistent application of established procedures. i. Perform periodic monitoring reviews by finance, compliance, or internal audits to validate adherence to property control policies and inventory requirements. Contact Person: Paul Barrera Carlos Rivera Enrique Vélez Cortes Lexa M. González Brown Team: Finance Team Anticipated Completion Date: December 31, 2026

Finding 2025-005 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Amber Jusefowytsch / Kim Newman / Anna Simmons Corrective Action Plan: A calendar of required reporting dates will be created with a one-month reminder to all involved parties to mitigate last minute issues with reporting compliance. Proposed Completion Date: This finding and corrective action plan have been reached near the end of FY26, the calendar will be implemented by December 31st, 2026 but we anticipate a similar finding for FY26.

FINDING 2025-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Contact Phone Number and Email Address: Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We have contracted Baker Tilly to do the SLFRF report. We now send them all needed information to compile the report. The Auditor then reviews prior to submission. Anticipated Completion Date: April 30, 2026 INDIANA STATE

FINDING 2025-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Sandra L Morton Contact Phone Number and Email Address: 812-481-7000 slmorton@duboiscountyin.org Views of Responsible Officials: We disagree with the finding that the 2025 Annual P & E report current obligations were overstated by $8,300,967, which was the amount of cumulative obligations. Explanation and Reasons for Disagreement: We do not believe there was a systemic lack of effective internal controls or noncompliance throughout the audit period. We determined that the funds were fully obligated and reported the amount based on that interpretation, as was done on the previous reports submitted.

FINDING 2025-002 Sherry Lockard, 812-283-1500, slockard@townofclarksville.com A. Coronavirus State and Local Fiscal Recovery Funds The Town concurs with the finding. The Town was not aware contracts had to be signed by December 2024 for all “obligations”. The Town was under the impression the obligations were submitted on the annual SLRF report, and that only the funds had to be spent for submitted obligations on the SLRF page by December 31, 2026. The Town was not able to obtain a contract that far in advance of the work to start, let alone be completed. At this time, we will await instructions from the Federal Agency as to what the Town needs to do regarding the expenses made after the ambiguous “obligation deadline”. For all future grants, the Town will designate the staff member who is in charge of that specific grant to create a checklist of requirements and to maintain that list until the grant is complete. (ATTACHMENT A)

Reporting California Department of Social Services CDSS does not agree with this finding and its characterization as an ACF-696 reporting inaccuracy. The discrepancy between the ACF-696 and the general ledger is primarily due to timing differences. The ACF-696 was due on July 30, 2025, and relies on preliminary figures that were prepared before final cost allocations and accruals were posted. In contrast, the general ledger is based on the final expenditure data, including all adjustments, and finalized in September 2025. Any discrepancies or adjustments from the June 2025 quarter were reported in the following quarter. The Administration for Children and Families has confirmed with CDSS Accounting that the current practice of reflecting these adjustments in the subsequent quarter for federal reporting is acceptable. CDSS began performing the reconciliation of the ACF-696 and the general ledger following the close of FY 2024–25. However, completion of this process was delayed due to an unprecedented volume of ongoing audit activities and the significant demands associated with supporting the Department, the California Health and Human Services Agency, the continual flux of federal funding changes, and federal shutdown preparedness drills. CDSS submitted a Budget Change Proposal in response to the previous audit finding 2024-015 to complete this reconciliation between ACF-696 and the general ledger. This request has been approved, and we are in the process of hiring for this position. Once this position is filled, responsibility for the reconciliation activities will be transferred to the newly assigned staff member to ensure consistent oversight, timely completion, and ongoing maintenance of the reconciliation process. Estimated Implementation Date: September 2026 Contact: - Rosali Bautista, Chief, Accounting and Reporting Bureau, Accounting and Fiscal Systems Branch, Finance and Accounting Division

FINDING 2025-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: Angela Hamrick Contact Phone Number and Email Address: 260-748-7012 ahamrick@newhaven.in.gov Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: When completing the Annual P & E report I will add an internal control of a separate employee reviewing the information to make sure the correct expenditures are listed within the correct period. We will have each employee who reviews the information to sign the completed report. Anticipated Completion Date: 6/24/26 INDIANA STATE

CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: COVID-19- Coronavirus State and Local Fiscal Recovery Funds Contact Person Responsible for Corrective Action: Valeriano F. Gomez Contact Phone Number and Email Address: 219-391-8220 Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: Previous corrective action read as follows: To ensure proper implementation of the policies and procedures in place related to SLFRF reporting, in future, no submittal of reports will be approved without the City Controller and a Senior Staff Accountant reviewing and approving the P & E reports…… issue arose when City Departments responsive for entering data in P & E reports and Staff Accountant documentation differed , adding to issue both groups were not together in same room to assist each other with reporting . Corrective Action Plan: 1. All future SLFRF Quarterly reports shall require advance meetings before the data entering day; to ensure correct reporting. Meetings shall include all personnel reviewing and entering information (City department personnel and Controllers office personnel, to include two from the Controller’s Office; Controller, or Deputy City Controller and Senior City Accountant. 2. These Staff meeting shall address any differences in reporting documentation, and prepare for any editing and revising data to correct issues from previous P & E reporting, in next available report (Sec. V. Editing and Revising Data P & E Report User Guide) 3. No data shall be entered / submitted on entry day for future Quarterly P & E reports without Controller personnel present and having reviewed and confirmed data. Anticipated Completion Date: Controllers Office and City Departments involved in reporting are presently working to address and correct issues in past reporting, completion is anticipated when upcoming 2nd Quarterly Report for 2026 is opened and issues are addressed.

FINDING 2025-002 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Karla Bauman Contact Phone Number and Email Address: (765) 647-4631, auditor@franklincounty.in.gov Views of Responsible Officials: INDIANA STATE BOARD OF ACCOUNTS 20 We concur with the finding. The expenditures overstated by $88,800 was a result of an adjustment that was done in April, 2025. The overstated current period obligations and cumulative obligations were reported as the annual or cumulative expenditure amount (project total) instead of obligations remaining under contract. Description of Corrective Action Plan: Upon reviewing the errors as described in Finding 2025-002, with the annual report that was filed for the reporting period April 1, 2025 thru March 31, 2026, expenditures were correctly stated. Corrections for any “obligations” will be made on the final close out report. Notes will be added to explain what was misreported under any project for current period obligations and/or cumulative obligations and what the correct amount should have been. Anticipated Completion Date: The expenditures were corrected with the report filed in April, 2026 for reporting period April 1, 2025 thru March 31, 2026. A note will be added to the close out report for the adjustment that was made in April, 2025 for a transaction done in March of 2025 in the sum of $88,800. All corrections for current period or cumulative obligations will be completed on the close out report with notes describing the error in previously reported. INDIANA STATE

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