Corrective Action Plans

Finding Number 2024-031 Subject Heading (Financial) or AL no. and program name (Federal) 93.575 – CCDF Cluster Planned Corrective Action OKDHS agrees that certain administrative errors identified through program reviews and audit activities, including confirmed payment calculation errors, eligibility determination issues, attendance verification deficiencies, and provider noncompliance, require corrective action. The Agency has initiated reviews and recovery efforts for confirmed overpayments and instances of provider noncompliance and continues to strengthen monitoring, award calculations, documentation requirements, and recovery procedures for provider assistance programs. However, OKDHS respectfully disagrees with several conclusions contained within this finding, including the characterization of questioned costs, the treatment of unsupported expenditures as unallowable expenditures, the attribution of provider actions directly to the Agency, the extrapolation methodology, and conclusions regarding the overall design and effectiveness of the Desert Grant Program. The Desert Grant Program was developed using emergency American Rescue Plan Act (ARPA) funding to rapidly increase child care capacity in underserved areas of Oklahoma within federally established obligation and liquidation deadlines. As previously communicated to the Administration for Children and Families (ACF), the applicable Notice of Award expressly excluded substantial portions of the traditional federal grant administration requirements, including most pre-award requirements, most post-award requirements, and the federal cost principles. Accordingly, OKDHS does not concur that the program should be evaluated using the same framework applicable to traditional federal grant programs or that retrospective disagreement with the program's design, funding methodology, or implementation strategy constitutes evidence of noncompliance. The Agency further does not concur with the treatment of unsupported expenditures as equivalent to unallowable expenditures. Providers receiving Desert Grant funding certified that grant funds would be used only for allowable purposes, agreed to maintain supporting documentation, and acknowledged their obligation to repay funds if they failed to comply with program requirements. While the absence of documentation during audit testing may warrant additional review, it does not independently establish that funds were expended for unallowable purposes. Likewise, the closure of a provider or other post-award business outcomes do not, by themselves, establish misuse of grant funds or Agency noncompliance. The Agency continues to evaluate these cases individually and pursue recovery when the facts demonstrate noncompliance with the terms of the award. OKDHS also respectfully disagrees with conclusions regarding the overall effectiveness or sustainability of the Desert Grant Program. The audit contains numerous observations regarding alternative funding methodologies, incremental payment structures, business planning considerations, sustainability assumptions, and other program design decisions. While these observations may identify opportunities for future program improvement, they represent differences in program design philosophy rather than evidence that the Agency failed to administer the federal award in accordance with applicable requirements. The Agency does not believe retrospective assessments regarding how the program could have been structured differently constitute a basis for questioned costs. Finally, OKDHS does not concur with the extrapolation methodology reflected in this finding. The questioned costs combine fundamentally different exception types, including confirmed administrative errors, unsupported expenditures, provider documentation deficiencies, provider closures, provider spending decisions, and observations regarding program design. These categories arise from different causes, involve different responsibilities, and require different corrective actions. Accordingly, OKDHS does not believe combining these distinct exception types into a single projected questioned cost accurately reflects actual noncompliance or federal exposure associated with the program. Although the Agency respectfully disagrees with significant portions of the finding, OKDHS has strengthened oversight of provider assistance initiatives by enhancing award calculations, documentation expectations, provider certifications, monitoring activities, analytical review procedures, and recovery processes. The Agency will continue reviewing Desert Grant awards, recovering confirmed overpayments and unallowable expenditures where appropriate, and incorporating lessons learned into future program implementation. Anticipated Completion Date On Going Responsible Contact Person Kayla Urtz

Finding Number 2024-015 Subject Heading (Financial) or AL no. and program name (Federal) AL #10.558 CHILD AND ADULT CARE FOOD PROGRAM (CACFP) AL #84.010 TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.4 25U) Planned Corrective Action The LEA did not upload sufficient supporting documentation to substantiate the amount claimed. Additionally, the reviewer did not conduct an adequate review of the supporting documentation submitted with the claim. To address this finding, the agency will provide additional training to reviewers on claim review procedures, required supporting documentation, and documentation verification standards. The agency will also strengthen internal review procedures to help ensure claims are properly supported and consistently reviewed prior to approval. Anticipated Completion Date Jul-26 Responsible Contact Person Tammy Smith

Finding Number 2024-054 Subject Heading (Financial) or AL no. and program name (Federal) 20.205 - Highway Planning and Construction Planned Corrective Action The Agency went live in PeopleSoft Financials with online voucher entry to pay invoices for operating accounts and the 747 process (Load Vouchers from Remote) for invoices for capital accounts. Both these interfaces have built in edit capabilities to detect and deter duplicate invoices. During the PeopleSoft implementation, division staff were trained on keeping Invoice logs for all their payments. Also, reports have been built to be run by Financial Services Accounts Payable staff monthly to pull all possible duplicate payments for review. Anticipated Completion Date 07/02/2025 Responsible Contact Person Sam Ddamba

Finding Number 2024-047 Subject Heading (Financial) or AL no. and program name (Federal) 20.205 - Highway Planning and Construction Planned Corrective Action ODOT Contract Compliance Division (CCD) is updating the Guidelines for the Administration of Consultant Contracts, Standard Operating Procedures (SOPs) and training staff on correct procedures for filing documentation. Discussion was held with the ACEC Admin Working Group on 4/7/2026, that FAR Audits were not being submitted timely, and additional guidance would be issued by ODOT. ODOT CCD is partnering with the ODOT Audit Office for FAR Audit Requirements and the development of Self-Certification and Safe Harbor Rate Programs. FAR requirements will be discussed at the annual ACEC Partnering Conference in September 2026. ODOT will provide copies of updated Guidelines and SOPs as they are developed. Anticipated Completion Date 12/31/2026 Responsible Contact Person Jennifer Hankins

Finding Number 2024-016 (Repeat 2023-018) Corrective Action Plan Procurement, Suspension and Debarment — AL 93.323 (U.S. Department of Health and Human Services) • Formalize into established written policies and procedures the monitoring of the suspension and debarment status of vendors and contractors, designed on the verification methods provided in 2 CFR § 180.300 — checking SAM.gov, collecting a certification, or including a clause in the covered transaction. • Continue performing suspension and debarment verification checks prior to entering into covered transactions as part of the standard procurement checklist, and retain documentary evidence of each check in the procurement file. • Continue to guide and make aware the compliance team and all departments of the requirement, and include it in procurement staff training. • Perform periodic compliance testing of the checklist and the retained evidence, with exceptions reported to management for corrective action. • Pursue resolution of the questioned costs of $509,463 through the audit resolution process with the grantor agency. Management’s position is that the condition is an internal control deficiency and that questioned costs of $0 are warranted under the definition in 2 CFR § 200.1, including paragraph (3)(i), as the entire population comprises allowable transactions and verification against the SAM.gov exclusions list confirmed that no vendor or contractor was suspended, debarred or otherwise excluded. Anticipated Completion Date 9/30/2027 Responsible Person (Contact Details) Mr. Peni Tikoisireli Financial Advisor Email: peni.tikoisireli@dofa.gov.fm Mr. Happyman Makamure Email: happyman.makamure@dofa.gov.fm

Finding Number 2024-013 (Repeat 2023-009) Corrective Action Plan Subrecipient Monitoring — AL 15.875 (U.S. Department of the Interior) • Establish and formally document the subrecipient monitoring framework, policies and procedures, aligned to the pass-through entity requirements of the Uniform Guidance and to the classification agreed with DOI, for implementation from the effective date agreed with DOI/OIA. • Update the annual subrecipient agreement transmitted to the FSM State Governments and signed by the President and the Governors as allottees, facilitated by the Office of Compact Management, to expressly incorporate the clauses required by the 2023 Amended Compact, the identification of the subaward, and acknowledgement of the requirements imposed on the sub-grantees. • Perform and document, prior to approval of each subaward, verification of the sub-grantee’s awareness of the requirements imposed upon it and its ability to meet the financial management standards of the Fiscal Procedures Agreement. • Perform and document an annual risk assessment of each subrecipient, together with the resulting monitoring activities, including review of the subrecipients’ audit reports and follow-up on findings affecting the program. • Maintain records of the date of receipt and date of disbursement of funds to the FSM State Governments, evidencing that disbursements are made within the month of receipt through the required wire-out approval process. • Pursue resolution of the questioned costs of $94,422,154 through the audit resolution process with DOI/OIA. Management’s position is that the conditions are internal control deficiencies arising from the absence of formally documented policies and procedures and that questioned costs of $0 are warranted under the definition in 2 CFR § 200.1, including paragraph (3)(i), as all samples were provided, vouched and cleared, and the amounts represent Compact sector grant allocations approved through JEMCO. Anticipated Completion Date 9/30/2027 Responsible Person (Contact Details) Ms. Melynda Irons Acting Assistant Secretary, Treasury Email: melynda.irons@dofa.gov.fm Mr. Peni Tikoisireli Financial Advisor Email: peni.tikoisireli@dofa.gov.fm Ms. Julyn Lawrence Email: julyn.lawrence@gov.fm Ms. Senny Phillip Assistant Secretary, Investment Email: senny.phillip@gov.fm

Finding Number 2024-010 Corrective Action Plan Cash Management — AL 15.875 (U.S. Department of the Interior) • Develop, approve and issue a dedicated written cash management procedure specifically addressing the time elapsing between the receipt of infrastructure project funds and their disbursement, setting out the disbursement process and target timeframes consistent with Article IV, Section 5(b)(ii) of the Fiscal Procedures Agreement. • Maintain documentation of the date of receipt and the date of disbursement for each drawdown, so that compliance with the procedure and the minimization of elapsed time can be evidenced and monitored. • Institute periodic monitoring and reporting of elapsed time between receipt and disbursement, with exceptions escalated for management action. • Train Treasury staff and the authorized signatories in the wire-out approval process on the new procedure and the applicable FPA requirement. • Pursue resolution of the questioned costs of $1,643,137 through the audit resolution process with DOI/OIA. Management’s position is that the condition is an internal control deficiency and that questioned costs of $0 are warranted under the definition in 2 CFR § 200.1, including paragraph (3)(i), as the FPA prescribes no day-count standard, all disbursements were made within the month of receipt through the required approval process, and the payments were eligible, fully supported and reasonable. Anticipated Completion Date 9/30/2027 Responsible Person (Contact Details) Ms. Julyn Lawrence Email: julyn.lawrence@gov.fm Ms. Senny Phillip Assistant Secretary, Investment Email: senny.phillip@gov.fm

2024-003 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA011008 and 2019 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness Management’s or Department’s Response: Imperial County Workforce Development Office (ICWDO) agrees with the finding. Views of Responsible Officials and Corrective Action Plan: The questions from finding 2021-008 relate to a formalization of the fiscal processes and protocols. ICWDO operates under WIOA guidelines and follows Imperial County’s fiscal policies. Internal policy will be formally updated to reflect compliance with WIOA regulations, as well as Imperial County policies. These policies will include formal controls and procedures to evaluate each subrecipient’s risk of noncompliance. Once the formal procedure is drafted, it will go through the ICWDO Policy Committee for comment and direction, and then finally reviewed and approved for implementation by the full Workforce Development Board. Additionally, for any future Memorandums of Understanding (MOUs) between this Imperial County department and any outside agency, there will be an additional step to include review by Imperial County Counsel to reflect that recital around the funding source will specify the following required information: • Federal Award Identification Number • Federal award date of award to recipient by the Federal agency • Name of Federal awarding agency • CFDA Number • Specific identification of whether the award is research and development ICWDO will develop internal policies for formalizing all subrecipient monitoring process. ICWDO operates under WIOA guidelines for monitoring; therefore a formal internal policy for future contracts will be developed and implemented using the usual review and approval procedures followed by the department. ICWDO will develop a formal internal documentation system, with appropriate checks and signatures, for the evaluation and assessment of each subrecipient’s risk of noncompliance. ICWDO will utilize this formal process to properly document the risk assessment of all subrecipients. ICWDO anticipates to implement the corrective action by December 31, 2025. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2025

Finding Number 2024-004 Corrective Action Plan (CAP) CSG will draft and implement a policy on Cash Management specifically regarding cash disbursement to vendors for infrastructure projects. • CSG will assign a designated person to request drawdowns for Infrastructure projects. This same individual will keep track of this request and will notify the appropriate individuals at Chuuk State Finance who will authorize the disbursement of the check/s to the vendor. • A specific timeframe in which CSG will minimize the time between cash drawdown received from FSM National Government and disbursement to vendors will be established upon consultation with grantor agency. Anticipated Completion Date December 31, 2026 Responsible Person (Contact Details) Jonas Paul, Director (DAS) jpaulckdas@gmail.com Kayviann Hallers Umwech, Internal Control (DAS) kayviannhallers@gmail.com Roxalyn Kaminanga, Chief (DAS) roxalynkaminanga@gmail.com

Develop and document formal policies and procedures for grant management, including repo1iing, monitoring, and compliance. Implement these policies and ensure that each office is using them correctly.

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a robust internal control framework specifically dedicated to FFATA compliance. We are developing comprehensive protocols that define clear roles, responsibilities, and standardized procedures to ensure all applicable subawards are identified, monitored, and reported to the FSRS in strict accordance with 2 CFR Part 170. Action Steps: 1. Protocol Development - Create a new "FFATA Compliance Protocol" that details the specific steps for subrecipient determination, data collection, and FSRS submission, while revising existing procurement SOPs to integrate these checks. 2. Roles & Responsibilities – Formalize the assignment of duties: (a) The Grants Management Officer will classify the entity as a subrecipient or contractor; (b) the Compliance Coordinator will extract the required data; and (c) the Finance Director will perform a final review before FSRS submission. 3. Subrecipient Determination Checklist – Implement a mandatory "Subrecipient Determination Checklist" based on 2 CFR §200.331 criteria, required for every new agreement exceeding $30,000. 4. Specialized Staff Training – Conduct mandatory training for procurement and grant personnel on FFATA regulations, the specific criteria for subrecipient classification, and the internal steps required for FSRS reporting IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos – Auxiliary Administrator for Finance and Budget Carlos Martinez Colón – Finance Director Vanessa Ayala Gerena – Director of Budget Gerhil Medina Baez – Auxiliary Administrator Operational Services Johana Hernandez Andaluz – TANF Program Director

FINDING 2024-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Burzynski Thaddeus Contact Phone Number and Email Address: 219-755-3200, burzytx@lakecountyin.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The County will develop and implement a proper system of internal controls and segregation of duties. This will ensure accuracy and correctness of all quarterly P & E Reports in the future. Anticipated Completion Date: December 2026

FINDING 2024-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Burzynski Thaddeus Contact Phone Number and Email Address: 219-755-3200, burzytx@lakecountyin.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As this finding is shared between The Lake County Board of Commissioners and the Lake County Parks & Recreation Department, both departments will develop procedures to ensure the appropriate procurement methods are used for vendors that are within the Small Purchase Threshold. Both departments will also ensure that vendors are not suspended or debarred when expanding federal funds. Lastly, appropriate documentation will be maintained to ensure compliance with procurement, suspension and debarment in the future. Anticipated Completion Date: December 2026

This has been corrected with current staff. We are making sure that all reports are filed on time and correctly. Responsible Official: Director of Finance Expected Completion Date: The report was corrected 4/14/2026 with the completion of the 2025 SLFRF Compliance Report.

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

Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted finding and address it accordingly. Evaluation of this finding and Cayuga Centers’ procurement policies will be completed no later than November 2025 and any improvements needed for compliance or recommended as best practice will be adopted. As an initial action step, Cayuga Centers has developed a compliance checklist for all significant and recurring purchases. This checklist requires evidence of competitive bidding, vendor selection, and justification for sole-source procurement. Staff involved in purchasing have received, or will receive, training on federal and organizational procurement policies. The Compliance Department will conduct quarterly reviews of procurement records to ensure adherence to established procedures.

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.

Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Procurement – Suspension and Debarment Audit Findings: Material Weakness, Noncompliance Condition: The City did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. The City had not designed or implemented adequate policies or procedures to ensure that proper procurement procedures for small purchase and simplified acquisition procurement thresholds were followed. Context: For one out of three samples selected for the small purchase procurement threshold, three quotes and rationale for selecting the vendor were not documented. Small purchase procurements require three competing quotes and rationale for selection of the vendor. The procurement was for park improvement design services. The City was unaware that professional services are required to follow the federal procurement process. Per grant requirements, all grant funded expenditures require appropriate procurement, regardless of whether it is a good or service. For two out of three samples selected for suspension and debarment testing, the City did not have support that vendors procured under CSLFRF funding were not suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: The City had already been checking and documenting the check for suspension and disbarment of all vendors – however, the check was being performed at the time of vendor onboarding, which may have been in a previous period. Management agrees with the finding and has already started taking the steps to implement a procedure for checking procurement and suspension and debarment for each contract that expends American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Funds or any other Federal funds at the time of award. Responsible party and timeline for completion: The Controller is responsible for overseeing the implementation of the corrective action plan and will ensure the appropriate personnel are involved in the procurement and suspension and debarment process. The corrective action plan is in effect immediately. Further, the Controller will conduct an internal audit on or around June 30, 2026, to ensure that the new procedures have been implemented correctly.

Finding 2024-011 Material Weakness and Material Noncompliance Finding, Reporting – Special Reporting Condition: For Coronavirus State and Local Fiscal Recovery Funds (ALN# 21.027), none of the quarterly Project and Expenditure Reports were submitted as required, and instead the City elected to submit an annual Project and Expenditure Report that was submitted past the deadline for the fourth quarterly report. Contact Person: Kara Prunty, Assistant Director of Finance – Grants, City of Danbury Corrective Actions Completed: We agree with the finding. The City has implemented a centralized SLFRF quarterly reporting process under a designated grants/finance lead, including a recurring quarterly close schedule and a two-level review (preparer and approver) prior to submission. All submitted reports, supporting documentation, and submission confirmations are retained in a central repository.

Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence. County Clerk: I was not the County Clerk in office at this time. To correct this issue. the County plans to develop a SOP to timely and accurately track and report on federal funds. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners. County Treasurer: The County was under the understanding that once we established we were reporting as Loss Revenue, we would not have to submit the report annually. The final reporting was submitted prior to deadline.

FA 2024-002 Strengthen Controls over Journal Entries Compliance Requirement: Activities Allowed or Unallowed Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program COVID-19-10.555 – National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: Unknown Description: The policies and procedures of the School District were insufficient to ensure that journal entries made for the Child Nutrition Cluster were properly documented. Corrective Action Plan: All journal entries transferring cash from the School Nutrition Fund to the General fund will be done on a more frequent basis and include the detail of amounts used to arrive at the amount of the transfer. Estimated Completion Date: October 17, 2025 Contact Person: Danny Durham, Director of School Nutrition Telephone: 478-994-2031 Email: danny.durham@mcschools.org

FINDING 2024-010 Finding Subject: Special Education Cluster (IDEA) - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Susie Swango, Director of Special Education Contact Phone Number and Email Address: swangos@nlcs.k12.in.us (812) 277-3220 ext. 16243 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement - Small Purchases The school corporation will follow all Federal Requirements for small purchase procedures including obtaining price or rate quotations from an adequate number of qualified sources. We will document the procurement method we are using and attach supporting documentation for rate and price quotes by source. Suspension and Debarment Prior to entering into subawards and covered transactions with federal award funds, the school corporation will verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. All purchases $25,000 or greater will involve the following process - (1) checking SAM.gov to see if there are any exclusions, (2) require Vendor supply certification that they have not been suspended or debarred OR clause will be added to agreement or contract signed by Vendor as certification. Anticipated Completion Date: December 1, 2025

FINDING 2024-009 Finding Subject: Special Education Cluster (IDEA) - Period of Performance Contact Person Responsible for Corrective Action: Susie Swango, Director of Special Education Contact Phone Number and Email Address: swangos@nlcs.k12.in.us (812) 277-3220 ext. 16243 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Director of Business and Director of Special Education have implemented a system of internal controls around grant reimbursement submissions. Grant reimbursements are submitted only after a month is officially closed in the books and the expenses are reviewed by the Special Education Director prior to submission. Reimbursements will be filed monthly, with both Directors monitoring the allowable timeframe for expenditures and liquidation and signing off on the reimbursement. Anticipated Completion Date: June 30, 2026

Finance staff will implement a review process prior to submission of the Coronavirus State and Local Fiscal Recovery Fund Annual Project and Expenditure Report in order to ensure accurate reporting. In addition, the City will reconcile internal records with reports prior to submission and submit corrected reports as needed, but no later than with the final report Anticipated completion date 12/31/2025 Responsible Contact Person: Tessa DeLine, Finance Director

Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted finding and address it accordingly. Evaluation of this finding and Cayuga Centers’ procurement policies will be completed no later than November 2025 and any improvements needed for compliance or recommended as best practice will be adopted. As an initial action step, Cayuga Centers has developed a compliance checklist for all significant and recurring purchases. This checklist requires evidence of competitive bidding, vendor selection, and justification for sole-source procurement. Staff involved in purchasing have received, or will receive, training on federal and organizational procurement policies. The Compliance Department will conduct quarterly reviews of procurement records to ensure adherence to established procedures.