Corrective Action Plans

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

The Clerk has. on occasion. had issues accessing the system on the last day due to heavy traffic, causing reports to be submified late. Going forward, reports will be accurately compiled and submitted at least l0 days prior to the report due date to avoid issues with connectivity.

The current Board of County Commissioners acknowledges the finding, and I will improve reconciliation and review procedures used in preparing federal reports. County officials involved in grant reporting will work together to ensure repotted obligations and expenditures are reconciled to supporting records before submission.

The current Board of County Commissioners acknowledges the finding. The Board will continue working with county officials, consultants, and auditors involved in grant administration to improve reconciliation and reporting procedures. Additional review steps will be performed to ensure obligations and expenditures reported to federal agencies are supported by county records and accurately reported.

FINDING 2024-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Contact Person: Nick Creevy, Director of Operations and Planning – Stan Heil – Chief Financial Officer -FCC Contact Phone Number: (812) 948.4110 (812) 542-0506 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Prior to submission, quarterly reports will be printed and reviewed by secondary staff in Office to review submission correctness. This Corrective Action Plan will be coordinated with the Nick Creevy, Director of Operations and Planning and Stan Heil, recently selected Chief Financial Officer for the Floyd County Commissioners. The new CAP will include review by both parties, and submitted timely. The P&E Reports will be verified to the County’s financial records prior to submission. The County Commissioners have also retained the former Director of Operations to guide both Nick Creevy and Stan Heil in the submission of these reports. The final submission of the Quarterly reports will be verified not only to the County’s financial records, but also to ensure the adherence to the above requirements for reporting. Anticipated Completion Date: This method will be instituted at the July 2025 quarterly (QTR II/2025)report submission time frame. The updated values for prior reporting will be updated in the September 2025 Quarterly submission.

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

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.