Corrective Action Plans

Management's Views and Corrective Action Plan 2025-001- Compliance with Federal Funding Accountability and Transparency Act (FFATA) Reporting Sponsoring Agency: National Endowment for the Humanities Award Name: American Experience, A Man Called White Award Number: TR-297125-24 Assistance Listing Title: Promotion of the Humanities Public Programs Assistance Listing Number: 45.164 Award Year: 2024-2025 Management's Views and Corrective Action Plan WGBH Educational Foundation (“the Foundation”) concurs with this finding. During fiscal year 2025, the Foundation identified a control failure with their established FFATA reporting control. After thorough review of active subaward agreements, the Foundation identified one contract that was not reported timely. Due to the grant's termination date of April 2, 2025, the Foundation was not able to file the report through SAM.gov. However, the Foundation promptly reached out to the National Endowment for Humanities (NEH) for assistance with filing. At this time, the Foundation has not received a response from NEH on next steps. The Foundation has since enhanced its control to include a three-way reconciliation using system generated reports to validate completeness of the Foundation’s monthly list of executed subaward agreements prior to reporting deadline. In addition to the reconciliation, the Foundation has implemented a FFATA process checklist which captures the process steps, applicable contract execution date(s), report submission date(s) and sign off/approval of the monthly process. A secondary review and approval of the process have been included in the updated control. The enhanced control was implemented for the September 2025 FFATA reporting. Contact person: Katie Dillon Managing Director, Production Finance and Grants Compliance 617-300-3829

Finding 2024-006 – Compliance; Internal Control over Compliance, Reporting (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of AgricultureFederal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Under 2 CFR 200, recipients must submit performance and financial reports as required by the terms and conditions of the award and must retain records sufficient to demonstrate compliance (see (§200.301Monitoring and reporting program performance, and §200.328 Financial reporting, §200.329 Monitoring and reporting program performance, and §200.334 Retention requirements for records). The grant agreements for awards above require timely submission of performance / progress reports by specified due dates, with documentation maintained to support the submitted information. Condition: For the fiscal year ended June 30, 2024, the auditee could not provide sufficient evidence that required reports for the programs listed were prepared, reviewed, and submitted in accordance with grant terms. Specifically:  No provided required financial reports, and Partnership for the Umpqua Rivers lacked copies or evidence of submission, and support for reported amounts requested.  Auditors were not provided with performance/progress reports and were instructed that Partnership for the Umpqua Rivers had no retained copies, review sign-offs, or submission confirmation.  Where payments were received, support for the required reports or metrics were not retained and could not be supplied to auditors for reconciling to underlying records. Cause: Management has not implemented formal reporting controls, including:  A documented reporting calendar with due dates and responsible staff,  Reconciliation of report amounts to the accounting records,  Retention procedures for report copies, underlying support, and submission confirmations, and  Supervisory review evidenced by signatures or workflow approvals. Effect or Potential Effect: Absent evidence of timely, accurate reporting and adequate record retention:  The organization is at risk of noncompliance with federal award conditions,  Inaccurate financial or performance information may be reported to the funding agency, and  The entity may be subject to remedial actions, including heightened monitoring, repayment of questioned amounts, or potential suspension of funding. Questioned Cost: None directly noted, but potential risk if reports were incomplete or inaccurate.Context: During our audit, it was found that the Partnership for the Umpqua Rivers experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. Award files provided to auditors did not contain information related to reporting of activity, expenditures, or progress of the awards. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers:  Establish a formal reporting and retention policy aligned with 2 CFR 200 and grant terms.  Implement a centralized reporting calendar that tracks due dates, preparers, reviewers, and submission methods.  Require reconciliations of financial reports to the general ledger and supporting schedules, retain the reconciliation with the reporting package.  Create standard workpapers for performance metrics for each award.  Configure the grant portal or document management system to retain submission confirmations, reports, receipts, and version -controlled copies of all reports for awards.  Document supervisory review through sign-offs prior to submission and with evidence retained.  Provide training to staff on Uniform Guidance requirements and record retention (§200.334). District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: ____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _____________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

Response to finding 2024-004 – Reporting Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2024-004. During the audit period, recordkeeping was not centrally maintained, and key documents were often stored under individual employee drives rather than within a shared, organization-controlled system. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, the Organization had limited capacity to implement formal reporting controls; however, foundational corrective steps were initiated in 2025 to support full compliance during the 2026 operating year. This finding continued into the 2024 audit period due to the decentralized recordkeeping practices described above. Corrective Action taken in 2025: The Operations Manager conducted a full triage of existing accounts and transferred organizational documents into centralized CSforALL Drives. Files were reorganized by year and subject matter to ensure accessibility, consistency, and proper retention. This restructured system now provides a unified location for all grant-related documents, reporting records, and compliance materials, establishing a baseline for future Uniform Guidance reporting requirements. Corrective Action Planned for 2026: Beginning in 2026, CSforALL will implement formalized policies and procedures to ensure records are maintained in accordance with applicable compliance requirements and that all Uniform Guidance reports are submitted timely. The Operations Manager and Accounting team will oversee ongoing documentation, retention, and periodic internal review to ensure the reporting structure remains organized, accessible, and compliant throughout the 2026 operating year and beyond.

FINDING 2024-001 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: There were no controls in place to ensure that the School Corporation complied with the reporting requirements. The reimbursement request reports were prepared and submitted by the Food Service Director without any oversight, review or approval process to ensure accuracy of the reports. There was no oversight to make sure that the number of meals served matched the report filed. The lack of internal controls was systemic throughout the audit period. Contact Person Responsible for Corrective Action: Amanda Myers Contact Phone Number and Email Address: 765-832-3551/amyers@svcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Amanda Myers, Food Services Director, will continue to receive the information for the monthly meals served from the cafeteria managers at each school. Once she enters the information, the HS cafeteria manager will review the numbers to ensure that the information was entered correctly. The reimbursement forms and information that was entered will be submitted to the finance department to ensure the reimbursement process is correctly receipted. Anticipated Completion Date: Immediate.

Response to finding 2023-005 – Reporting Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2023-005. During the audit period, recordkeeping was not centrally maintained, and key documents were often stored under individual employee drives rather than within a shared, organization-controlled system. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, the Organization had limited capacity to implement formal reporting controls; however, foundational corrective steps were initiated in 2025 to support full compliance during the 2026 operating year. Corrective Action taken in 2025: The Operations Manager conducted a full triage of existing accounts and transferred organizational documents into centralized CSforALL Drives. Files were reorganized by year and subject matter to ensure accessibility, consistency, and proper retention. This restructured system now provides a unified location for all grant-related documents, reporting records, and compliance materials, establishing a baseline for future Uniform Guidance reporting requirements. Corrective Action Planned for 2026: Beginning in 2026, CSforALL will implement formalized policies and procedures to ensure records are maintained in accordance with applicable compliance requirements and that all Uniform Guidance reports are submitted timely. The Operations Manager and Accounting team will oversee ongoing documentation, retention, and periodic internal review to ensure the reporting structure remains organized, accessible, and compliant throughout the 2026 operating year and beyond. Page

The Morgan County Economic Development Office acknowledges status reports submitted by the required due date for the CDBG program.

Assistance listing numbers and program names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021 – Emergency Assistance to Non-Public Schools (CRSSA EANS) Agency: Arizona Department of Education (ADE) Name of contact persons and titles: Michelle Udall, ADE Associate Superintendent Dr. Sarka White, ADE Deputy Associate Superintendent Anticipated completion date: November 30, 2024 Agency’s response: Concur ESSER Reporting will be validated by at least 2 people before submitting to U.S. Department of Education. This validation will include the reconciliation of data from the LEA to ADE's report. ADE is finalizing policies and procedures for validating the data prior to submission. ADE has already begun implementing a reconciliation system to ensure accurate reporting in the EANS annual performance report. This system tracks obligations by category, expenses, and appropriate earmarking of nonpublic schools (e.g., DUNS/UEI, grades served). ADE is finalizing general policies and procedures for how this data is compiled, interpreted, and reported based on the initial implementation and corrections of the EANS program.

This is repeat Finding from 2022. Key personnel have since been replaced at the RPC and those in in the new positions understand the importance of proper and timely reporting and accurate financial records. The Auditor’s Office will meet with the new executive director, the current (new) finance director, and board members to emphasize the importance of deadlines and financial accountability when working with Grants. Additional Controls will be emphasized to assist with timely filing, as well as Invoice Entry to ensure duplicate payments are not made.

Views of Responsible Officials: The Center will create a technology system so that Finance Managers can ensure the timeliness of reporting and correct documentation when reporting deadlines are unable to be met. Name and Title of Responsible Official(s): Vibha Bhatia, Vice President of Finance and Operations Anticipated Completion Date: October 31, 2024

Views of Responsible Officials: NFHA has a process for review of programmatic reports that can be discerned by review of emails and documents. However, NFHA will ensure that all Federal award grant reports, both financial and programmatic, have documented evidence of review and approval prior to submission to the relevant agencies.

The City agrees with the finding. The City will improve internal controls over the Performance and Expenditure report review process and ensure this review addresses all aspects of the reports and is completed prior to submission. Corrective action was taken in spring of 2024 when the issue was identified during the 2023 audit. Responsible Official: Catrina Asher, Finance Director Planned completion date for corrective action plan: March 31, 2024.

Views of Responsible Officials: Management acknowledges the importance of timely reporting. RFE/RL is committed to improving timeliness by engaging an outside accounting firm to bring the company into compliance with current reporting requirements, increasing staff capacity, implementing a new reporting software tool, documenting sustainable reporting procedures and working with our funder on agreed upon reports and deadlines.

Assistance Listings number and program name: 10.691 Good Neighbor Authority Contact person: Lucinda Andreani, Deputy County Manager and Flood Control District Administrator Anticipated completion date: June 30, 2024 Concur. The Coconino County Flood Control District (FCD) acknowledges the annual financial and performance reports were not filed in accordance with the contract. The cash draw reports were completed for the award according to the contractual requirements. Therefore, the federal agency was aware of all expenditures made under the award. The FCD will submit all missing annual financial and performance reports. With assistance from the Finance Department, the FCD will develop procedures to ensure all reporting requirements are met. These procedures will include internal timelines, designated roles and responsibilities, and a tracking mechanism. Additionally, fiscal capacity will be created through the training of an additional staff member in reporting to serve as backup so contractual reporting requirements can be fulfilled when unforeseen challenges arise such as declared emergencies and flood events.

Views of Responsible Officials: Management agrees with the finding and the following action will be taken to improve the situation. Management will review and update the reporting tracker monthly to ensure all reports are submitted on time. To ensure additional controls, the reviewer of the tracker will be independent of the report preparer. Name and Title of Responsible Official: Barbara Ledyard, Vice President of Finance and Administration Anticipated Completion Date: December 29, 2023

The Morgan County Economic Development Office acknowledges status reports submitted by the required due date for the CDBG program.

Corrective Action: The University Procurement office will develop specific procurement policies to be utilized when Federal funds are used. Procurement staff will also be trained on how to procure goods and services when Federal funds are utilized. UCM staff and faculty will be trained on the approved Federal procurement process. Anticipated Completion Date: February 1, 2023 Contact Person: Robert Walla, Procurement Director

CORRECTIVE ACTION PLAN Institutional Response to 2022-001: Significant Deficiency ? Procurement Federal Assistance Listing No. 84.425F ? 84.425M US Department of Education, ESF Section 2 -Higher Education (Higher Education Emergency Relief Fund HEERF) University Response: The University concurs with the above-mentioned finding that proper procurement practices were not followed for two purchases utilizing HEERF funds. Corrective Action: The University Procurement office will develop specific procurement policies to be utilized when Federal funds are used. Procurement staff will also be trained on how to procure goods and services when Federal funds are utilized. UCM staff and faculty will be trained on the approved Federal procurement process. Anticipated Completion Date: February 1, 2023 Contact Person: Robert Walla ? Procurement Director

Finding No. 2022-001 Corrective Action Plan University Response: The University concurs with the finding that proper procurement practices were not followed for one of the three purchases identified as non-compliant. For one of the other two purchases identified as non-compliant, the University sourced the expenditure from the largest provider for higher education audio and visual products nationally, which competitively offer special discounting and pricing to private and public institutions of higher education when possible. On the other purchase, the University sourced with one of three vendors previously used for this type of work that was able to provide the services needed in the required timeframe during the pandemic, when other vendors could not meet the demand. These services were needed for additional cleaning and sanitizing to avoid contacting a life threatening virus. Corrective Action: The University will develop specific procurement policies to be utilized when Federal funds are used and appropriate staff will be trained on these policies. Responsible Official: Kris Pace, Controller Anticipated Completion Date: June 30, 2023

Finding No. 2022-003 Significant Deficiency Personnel Responsible for Corrective Action: Anthony D?Agostino, CEO of St. Patrick Center Anticipated Completion Date: March 31, 2023 Corrective Action Plan: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.

Views of Responsible Officials: Mary's Center is currently formalizing the existing checklist of all Programmatic Reports required for each of our Federal Grants. This checklist is being reviewed and updated by our Director of Grants. In addition, there is now a bi-weekly meeting in place between the Programmatic and Finance teams to address any changes or updates to grants. Lastly, a Grants liaison was recently employed at Mary's Center. This person will act as the conduit between our Programmatic and Finance teams and help maintain this checklist on a going forward basis.

Regional Planning Commission (RPC) has hired a new Executive Director effective March, 2023. RPC also hired a new Finance Director effective September, 2023, who is experienced in public finance and general reporting requirements. Both staff members are dedicated to ensuring proper procedures and performance going forward. Both staff members will review and sign off on the timely and accurate filing of all grant reporting documentation and requirements.