Corrective Action Plans

COMMONWEALTH OF PUERTO RICO CORRECTIVE ACTION PLAN MUNICIPALITY OF NARANJITO FOR THE FISCAL YEAR ENDED JUNE 30, 2025 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Orlando Ortíz Chevres - Mayor Contact Person: Mrs. Meyleen Hernández, Finance Director Phone: (787) 869 – 2200 Finding Reference Number: 2025-003 Federal Award: Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing No. 21.027) Compliance Requirement: Reporting (L) Type of Finding: Significant Deficiency (SD), Instance of Noncompliance (NC) Description of Finding: In our Reporting Test, we evaluated the Project and Expenditure Report submitted to the U.S. Department of Treasury during fiscal year 2024-2025. During our audit procedures, we identified differences between the amounts reported as current period expenditures, and the amounts recognized in the accounting system. Additionally, during the fiscal year the Municipality received new funds called Service of Excellence to Citizens also related to the Coronavirus State and Local Fiscal Recovery Funds Program. This allocation was granted through the Puerto Rico Fiscal Agency and Financial Advisory Authority. In our Reporting Test, we evaluated six (6) reports and could not validate their submission. Auditor’s Recommendations: We recommend training for the authorized personnel who administer the program, to better understand the reporting requirements and prepare timely reports. The Municipality should establish a monitoring system to ensure compliance with requirements established by the passthrough agency such as: submitting the reports during the required time frame and where the fund expenses will be reported as incurred. This will ensure better control of the program. Corrective Action: The authorized personnel understand the reporting requirements. We are in the process of training additional personnel to have more resources to comply with all reporting requirements. The Finance Department is working with external consultants to address this situation, and be able to comply with all reports as required. Name of Contact Person: Meyleen Hernández Rivera, Finance Director Projected Completion Date: June 30, 2026

FINDING 2025-005 Finding Subject: Special Education – Procurement Suspension & Debarment Contact Person Responsible for Corrective Action: Dr. Wendy Skibinski Contact Phone Number and Email Address: 317-205-3332 x 77230 wskibinski@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Special Education will ensure that all procurement procedures are followed for both the simplified acquisition method and the small purchase method. Documentation will be retained to verify that required procedures were followed. Anticipated Completion Date: September 30, 2026

FINDING 2025-001 Finding Subject: Child Nutrition Cluster – Procurement Suspension & Debarment Contact Person Responsible for Corrective Action: Annette Guenther Contact Phone Number and Email Address: 317-205-3332 x 77209 aguenther@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Child Nutrition will ensure that all procurement procedures are followed for both the simplified acquisition method and the small purchase method. Documentation will be retained to verify that required procedures were followed. Anticipated Completion Date: September 30, 2026

Section III – Federal Award Finding and Questioned Costs Finding 2025-002 – Eligibility Federal Program: Child and Adult Care Food Program (ALN 10.558) Views of Responsible Officials: NDS management met with CACFP staff to review procedures intended to enhance oversight of student eligibility determinations on February 10, 2026. The Assistant Administrator for the Child and Adult Care Food Program, Ms. Dawn McCoy, (dmccoy@ndsarch.org) will be responsible for ensuring adherence to these updated procedures.

FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Procurement Suspension and Debarment Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: 812-254-5536 calford@wcs.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: To address this repeat finding, the Business Manager will now review all federal purchase requests before any funds are committed. We will ensure the correct procurement method is used by requiring and filing at least three competitive quotes for any small purchase between $10,000 and $150,000. For any transaction $25,000 or greater, the Business Manager will verify the vendor’s eligibility on SAM.gov and keep a date-stamped screenshot in the file as proof of the search. This centralized oversight and mandatory documentation process will ensure we maintain a proper history of procurement and prevent further noncompliance. Anticipated Completion Date: 02/01/2026

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and the suspension and debarment requirements. The Cooperative did not have adequate procedures in place to ensure that the requirements for the simplified acquisition threshold and for small purchases were met for each applicable procured good or service or to ensure that vendors were not suspended or debarred prior to entering a covered transaction. Contact Person Responsible for Corrective Action: Susan Loftain Contact Phone Number and Email Address: (260) 693-2007 loftains@sgcs.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: Procurement: All vendors procured through NEISEC we will need to take action to secure bids and quotes and keep copies and make we are within compliance Suspension and Debarment: We will be sure to complete our own verifications and not rely on NEISEC to check on suspension and debarment Anticipated Completion Date: Immediately

The Department agrees with the recommendation. The Department will review, assess, and, where necessary, update existing procedures for FFATA reporting relating to the requirement that state subawards for $30,000+ be submitted within 30 days of committed budget. This will include ensuring that the confirmation date is documented. This process will be a coordinated effort between the Office Transportation Safety (OTS) and the Center for Accounting. This will include updating our reconciliation process to include additional data, reviewing and updating reconciliation and review procedures as needed, and reconciling Grants awarded in prior fiscal years that are still active and ensuring they have been appropriately reported. The findings related to this recommendation are in part the result of a federal reporting system limitation, and a federal system conversion. The legacy reporting system, FSRS, had a system limitation, which prevented the full amount of the award being reported in the case of three awards. Additionally, this conversion resulted in some data conversion issues impacting one additional award.

The Department agrees with this finding and will provide any training needed to staff members to ensure that all components of the FFATA are completed accurately, timely and with proper reviews. This training will include leadership reviewing NHTSA/Federal guidelines and SAM.Gov training on FFATA reporting and requirements, documenting controls and ensuring the approvers have access to all supporting schedules, forms and systems and that they understand the subawards, and process for late submissions if needed.

The Department agrees with the finding and will ensure that staff follow all internal policies and procedures to maintain accurate and complete FFATA reporting. To achieve this, staff will review existing procedures and make any necessary updates regarding report compilation. Additionally, we will review control points to ensure they are consistently followed and approved by the team supervisor and team manager.

The Department will continue to follow the current Policy and Procedure related to the Single Audit reviews and has allocated an individual to review the Single Audits. This includes issuing a management decision letter if required, in accordance with the timeline established in federal guidance.

CDPHE fiscal procedures have been updated to reflect changes to the reporting process, specifically noting the recent federal website change and adding the requirement of a secondary level of review. By July 31, 2026, all outstanding FFATA reports will be filed with the federal government and the monthly review process in the updated fiscal procedures will be implemented.

The Department will strengthen its internal controls over federal reporting by implementing policies and procedures that include a monitoring process to ensure that FFATA reporting occurs as required for subawards of $30,000 or more in SAM.gov by the end of the month following the month the subawards are made.

The Department will document and implement internal monitoring policies and procedures, including the performance of reconciliations of reports, to ensure that the required PR28 and Quarterly Performance Reports are accurate and complete. This will include maintaining documentation of evidence of the review and approval of each report prior to its submission to the federal government.

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Meghan Damron Contact Phone Number and Email Address: 219-650-5300, mdamron@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our procurement for the future. Description of Corrective Action Plan: Although Merrillville Community School Corporation left Northwest Indiana Special Education Cooperative (NISEC) as of July 1, 2024 we continue to use our procurement process following our school board policies. NISEC has reported that for the 2023-2024 school year the corrective action plan was initiated by the below process. As a member of the Northwest Indiana Special Education Cooperative (NISEC), the School Corporation usually expends contracted services out of our general education fund. For the fiscal year of 2023-2024 we included our contracted speech services into our federal grant funds. During the audit the School Corporation was notified that we didn’t following the procurement procedures when expending out of the federal grant. This finding was due to the School Corporation not going out and receiving multiple bids for contracted companies that provide services to our students. The School Corporation uses three contracted companies to provide Speech Pathologist and Speech Language Assistants. We have used these three companies for many years and have built great working relationships with these providers. After receiving the finding and discussing with the auditor we created a memo that we took to our board. In the memo we explain why we use the three contracted vendors instead of going out for bids. Finding Speech pathologist and Assistant are very difficult in the school setting and we have created great working relationships with these three contracted companies. Within the memo we list all of the contracted vendors we use and why we work directly with them instead of going out for bids. At the beginning of each school year we will take a new memo with any contracted companies that we will be using during the school year. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate" BOARD OF SCHOOL TRUSTEES Judy C. Dunlap James Donohue DeLena N. Thomas Alex Dunlap III Robert J. Krause President Vice-President Secretary Member Member INDIANA STATE BOARD OF ACCOUNTS 31 MERRILLVILLE COMMUNITY SCHOOL CORPORATION 6701 Delaware Street, Merrillville, IN 46410 (219) 650-5300 FAX (219) 650-5320 www.mvsc.k12.in.us Anticipated Completion Date: The Northwest Indiana Special Education Cooperative created the memo as soon as we received the finding and took the memo to the board. We have procedures in place now that any vendor that will exceed the simplified acquisition threshold, we will obtain bids or create a memo if bids are not an option. We took the memo to our October 9,2024 board. This was completed fully as of July 1, 2024. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate"

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person(s) Responsible for Corrective Action: Mendy Shrout & Billy Boyette Contact Phone Number and Email Address(es): (765) 795-4664 / mshrout@cloverdale.k12.in.us & bboyette@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement We will be updating the Policy 6325 for Micro purchases from $10,000.00 to $50,000.00. We are in policy review now. Suspension and Debarment All new vendors entered into the system are checked by the Corporation Treasurer through the Office of Inspector General search, printed and kept on file in the Corporation office. Further, all vendors used by the Food Service department have been updated to be current. Anticipated Completion Date: March 1, 2026

FINDING 2025-003 Finding Subject: Teacher and School Leader Incentive Grants – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Teacher and School Leader Incentive Grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

Finding 2025-001 Reporting Federal Agency- U.S. Department of the Treasury Program Name - Coronavirus State and Local Fiscal Recovery Funds (SLFRF} Federal Assistance Listing Number: 21.027 2 CFR 200.303 requires that a non-federal entity must "(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States and the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The terms and conditions of the funding require the recipient to submit quarterly Project and Expenditure Reports to the U.S. Department of the Treasury {Treasury). Information required to be included in these quarterly reports includes projects funded, expenditures, obligations, and other information. Treasury's Coronavirus State and Local Fiscal Recovery Guidance requires that "Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1." Responsible Officials: The City of Charleston utilizes an outside agency to compile and submit the required quarterly reports to the Department of Treasury for the State and Local Fiscal Recovery Funds. City officials provide the details of the projects funded, expenditures, obligations, and all other required information to the outside agency, who will then compile and submit the report. Upon review of prior period reports, City officials discovered that the expenditure amount for one of the projects was less than the amount provided to the outside agency for the report. The City brought this to the attention of the outside agency, then increased the project expenditures of the report in question so that the project to-date.

FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Procurement: For two vendors, the School Corporation did not obtain price or rate quotes as required. The School Corporation did not maintain documentation to support the rationale and justification to limit competition, and there was no documentation of the history of the Procurement which would include the rationale for the method of procurement, the selection of the vendor, and the basis for price. Suspension and Debarment: Two vendors were identified for which the School Corporation was required to verify the suspension and debarment status, however no such verification could be provided for audit. Contact Person Responsible for Corrective Action: Food Service Director, Joshua Deck Contact Phone Number and Email Address: (812) 649-2591 / josh.deck@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement: The Food Service Director will maintain a binder/Google Drive folder with documentation of price and/or rate quotes and documentation of the attempts made from at least three vendors that fall within the small purchase threshold. If price and/or rate quotes cannot be obtained from at least three vendors, documentation of the reasoning will be maintained. Suspension and Debarment: The Food Service Director will ensure that all vendors are not suspended or debarred by either ensuring the suspension and debarment verbiage is included in the contracts, providing a clause to the vendor to sign that they are not suspended or debarred, or checking the SAM.gov website. Documentation of these records will be maintained for audit. Anticipated Completion Date: Effective FY 2025/2026

FINDING 2025-001 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Samantha Berrier Contact Phone Number and Email Address: 219-962-2909, sberrier@rfcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The offices of the Northwest Indiana Special Education Cooperative (NISEC), on behalf of River Forest Community School Corporation, its member school, has implemented a corrective action plan to ensure that the proper methodology for procurement is followed. Additionally, a system of internal controls has been established to ensure that vendors are procured using the required methods. The Northwest Indiana Special Education Cooperative created a corrective action plan to develop procedures to obtain bids when any vendor will exceed the simplified acquisition threshold. As part of this corrective action plan they have included procedures to follow if a noncompetitive procurement would be applicable. These procedures include documenting the rationale for using this alternative method and requesting approval from the Board of School Trustees when doing so. Anticipated Completion Date: October 9th, 2024

FINDING 2025-002 Finding Subject: Child Nutrition Cluster-Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Missy Schultheis Contact Phone Number and Email Address: 812-354-8478 mschultheis@pcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will review and update the existing procurement policy to ensure it clearly outlines the procedures for different purchasing methods including the specific thresholds. We will establish a procedure requiring the retention of all documentation supporting procurement decisions. We will develop a process to verify that vendors/contractors are not suspended or debarred by any federal or state agency prior to entering into a "covered transaction" or contract. Anticipated Completion Date: This be implemented in the 2025-2026 school year and will continue for future years.

State Agency: State Education Department Program Name: Rehabilitation Services – Vocational Rehabilitation Grants to States ALN #: 84.126 Single Audit Contact: Maria Stamoulis Title: Audit Manager Telephone: (518) 473-2810 E-mail Address: Maria.Stamoulis@nysed.gov Audit Report Reference: 2025-003 Anticipated Completion Date: 12/31/2026 Corrective Action Planned: New York State Education Department (SED) has updated the payment procedures to require additional review prior to processing and will provide training to staff involved in preparing or processing payment forms to understand the appropriate application of cost centers to align with the Period of Performance for Federal awards, including the Vocational Rehabilitation grant. Additional controls planned include the alignment of purchase orders with the Federal fiscal year to ensure cost centers are appropriately assigned to services.

2025-001 Costs Incurred Beyond the Period of Performance Criteria: According to 2 CFR §§200.1, 200.308, 200.309, 200.344, and 200.403(h), a non-Federal entity may only charge allowable costs incurred during the approved budget period of the Federal award’s period of performance, and any costs incurred before the Federal award was made that were authorized by the Federal awarding agency or pass-through entity. All financial obligations incurred under the Federal award must be liquidated within the required time period. Costs incurred outside the approved period of performance are unallowable and constitute questioned costs. Client’s Response: During the grant cycle, the Organization submitted for an extension but did not receive confirmation of said extension. During the current fiscal year, the Organization has implemented additional controls to ensure that all grant funding is expended within the timeframe allotted. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444

Twin Oaks will revise procedures to calculate the MTDC in accordance with Uniform Guidance and apply the indirect cost consistently for all programs and to review the indirect cost allocations performed. Again, because of the timing of this audit report, there may be repeat findings for 2025 but should be eliminated going forward. Benjie Read and Felecia Read will work together to calculate the current MTDC by October 31, 2026.

Finding Number 2024-025 Subject Heading (Financial) or AL no. and program name (Federal) 93.658 – Foster Care Planned Corrective Action Oklahoma Human Services (OKDHS) concurs with the recommendation. OKDHS has been working to centralize and strengthen its contract and subrecipient monitoring processes to improve consistency in the identification, documentation, risk assessment, and monitoring of subrecipient relationships across the agency. As part of this effort, OKDHS is updating its procedures and standardized documentation to better ensure that subawards include required federal award information, program responsibilities and deliverables are sufficiently defined, required documentation is obtained and retained, and subrecipient risk assessments and monitoring activities are completed and documented consistently. OKDHS will implement updated, centralized contract and subrecipient monitoring procedures, including standardized tools and documentation requirements designed to address the conditions identified in the finding. The updated process will clarify responsibilities for documenting subrecipient risk assessments, required federal award information, contractual requirements, deliverables, and ongoing monitoring activities. Anticipated Completion Date 9/30/2026 Responsible Contact Person Kayla Urtz

Finding Number 2024-033 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action The Agency agrees that additional oversight activities could have provided greater visibility into provider use of Stabilization Payments and has incorporated lessons learned into subsequent provider assistance initiatives through enhanced monitoring, documentation expectations, and recovery procedures for confirmed noncompliance. However, OKDHS respectfully disagrees with several conclusions contained within the finding, including the characterization of questioned costs and the extrapolation of provider-specific exceptions across the broader population of Stabilization Payment recipients. The Child Care Stabilization Payment Program was established under the American Rescue Plan Act to provide emergency financial assistance intended to stabilize the child care industry during the COVID-19 public health emergency. Stabilization Payments were awarded using an approved payment methodology based upon provider eligibility, licensed capacity, and applicable STAR level. As previously communicated to the Administration for Children and Families (ACF), OKDHS does not concur with the assertion that the monitoring activities identified by SAI were required under the Stabilization Payment Program. The applicable Notice of Award specifically excluded significant portions of the traditional federal post-award administrative requirements, including most post-award requirements and the federal cost principles. Accordingly, OKDHS does not believe the Stabilization Payment Program should be evaluated using the same oversight framework applicable to traditional reimbursement or discretionary grant programs. Providers receiving Stabilization Payments were required to certify that funds would be used only for allowable purposes established by the American Rescue Plan Act and applicable program guidance and were responsible for maintaining supporting documentation for those expenditures. When information indicating potential misuse of funds is identified, OKDHS reviews the circumstances and pursues recovery actions as appropriate. While documentation obtained from providers may assist in evaluating provider compliance, the absence of documentation during the audit does not, by itself, establish that Stabilization Payments were improperly awarded or expended for unallowable purposes. OKDHS also respectfully disagrees with the treatment of unsupported expenditures as equivalent to known unallowable expenditures. Unsupported expenditures reflect circumstances in which documentation was unavailable for audit review and do not establish that funds were expended for unallowable purposes. As a result, the Agency believes the questioned costs materially overstate actual federal exposure. Finally, OKDHS does not concur that provider-specific exceptions may be extrapolated across the broader provider population. The exceptions identified by SAI reflect individual provider documentation and spending practices rather than a common agency-level eligibility, payment methodology, or processing error. Accordingly, the Agency does not believe the audit evidence supports extrapolating these exceptions to estimate program-wide questioned costs. Although the Stabilization Payment Program has concluded, OKDHS has strengthened oversight of subsequent provider assistance initiatives by enhancing monitoring procedures, documentation expectations, and recovery processes for confirmed provider noncompliance. The Agency will continue reviewing cases identified through audit activities and pursue recovery of confirmed unallowable expenditures in accordance with applicable federal requirements. Anticipated Completion Date N/A Responsible Contact Person Kayla Urtz