Corrective Action Plans

Finding #2024-003: Internal Control Over Compliance and SEFA Reporting Contact Person Responsible: Jennifer Patrick, Project Manager Milk River Joint Board of Control Corrective Action Planned: 1. Develop SEFA preparation procedures, including grant identification, Assistance Listing Number verification, and reconciliation to the general ledger. 2. Establish a dual review process where the SEFA is reviewed and approved by a party independent of the preparer prior to submission to auditors. 3. Perform an annual reconciliation of SEFA totals to audited financial statements before audit fieldwork. Completion Date: This item was corrected during the 2024 audit process. A tracking spreadsheet has been implemented for 2025 to ensure proper identification, classification, and reporting moving forward. This control will remain in place as an ongoing activity for all federal funding to ensure continued compliance with reporting requirements. Disagreement with Finding: MRJBOC agrees with the finding; however, we would like to clarify that the reporting discrepancy was primarily the result of timing and classification factors. Specifically, certain funding initially received through the State of Montana was not identified as federal pass-through funding until after the SEFA was completed. Once it was determined that the funding required federal reporting under SEFA guidelines rather than state grant reporting, adjustments were necessary to properly reflect the award information. MRJBOC recognizes the importance of accurate grant identification and reporting and will implement the corrective actions outlined to strengthen internal controls, grant tracking procedures, and SEFA preparation processes moving forward. We have also taken steps to ensure a clear understanding of the findings and will continue to monitor and address them in future fiscal years. I certify this Corrective Action Plan has been prepared in accordance with 2 CFR §200.516 and addresses all audit findings for the year ended December 31, 2024.

The department will adopt written policies with the Uniform Guidance for federally funded grant programs accepted by the department.

Condition: Federally funded expenditures were comingled with expenditures paid for with non federally funded sources in the accounting records. Plan: Separate general ledger accounts for federally funded grant expenditures will be accurately maintained. Anticipated date of completion: June 30, 2026. Name of contact person: Dustin Day, Superintendent. Management response: The corrective action plan was discussed with the business manager and the superintendent. After discussion, the plan was approved by the superintendent.

Finding Number: 2024-005 Anticipated Completion Date: March 31, 2026 Responsible Contact Person: Brad McCain, Chief Financial Officer Planned Corrective Action: Management is strengthening controls over tracking, documenting, and reconciling federal grant expenditures to ensure compliance with period of performance requirements. Actions include implementing improved grant-level tracking within the financial system, reconciling general ledger activity to reimbursement invoices and the SEFA on a routine basis, and retaining documentation to support the allowability and timing of costs charged to federal programs. Management will also formalize procedures for payroll reallocations across programs to ensure traceability and compliance with grant requirements. Documentation will be required to be attached to all journal transactions demonstrating the linkage between the underlying payroll records to the correct grant programs.

Finding 2024-004 – Insufficient Skills, Knowledge and Training, and Leadership (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 Agriculture Federal 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 ManagementCriteria: Under Uniform Guidance 2 CFR §200.303, non-federal entities must establish and maintain effective internal control over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the award terms and conditions. This includes ensuring that:  Personnel administering federal awards possess adequate skills, knowledge, and experience.  Management and leadership provide appropriate oversight of federal award activities.  Financial management systems adequately support accurate reporting, documentation, retention, and reconciliation of federal expenditures in accordance with 2 CFR §200.302. Condition: During the audit of federal awards, the entity did not demonstrate sufficient skills, knowledge, or experience of the staff and leadership responsible for administering and overseeing federal programs. Specifically:  Adequate supporting documentation for federal award expenditures was not maintained or provided.  Leadership oversight of federal award compliance activities was limited, and management review of grant activity were not evidenced. These conditions resulted in weaknesses in financial reporting, compliance monitoring, and documentation related to federal awards. Cause: Partnership for the Umpqua Rivers has not ensured that staffing levels, qualifications, and experience are sufficient to support federal award administration and compliance. In addition, leadership lacks adequate knowledge of federal award requirements to provide effective governance, oversight, and monitoring of compliance activities. Formal training and documented procedures for federal awards management have not been prioritized. Effect or Potential Effect: As a result of these deficiencies:  Partnership for the Umpqua Rivers is at increased risk of non-compliance with Uniform Guidance requirements.  Federal expenditures may be unsupported, inaccurately reported, or unallowable.  Errors or compliance violations may not be detected or corrected in a timely manner.  The entity may be subject to questioned costs, repayment of federal funds, or additional scrutiny from grantor agencies. Questioned Cost: None identified 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. No financial files for Accounts Payable, invoices, or reporting were available to the current financial staff. Not adequately retaining supporting documents and invoices to support the expenditures of the general ledger and requests for reimbursement for grants, the organization records may be insufficient for testing and review, for internal controls or meeting federal documentation and reporting requirements. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers:  Ensure staff responsible for federal awards receive appropriate training on Uniform Guidance requirements, grant financial management, documentation, and compliance monitoring. Assign federal award oversight to personnel with sufficient experience and qualification or obtain external grant management and accounting support as needed.  Establish written policies and procedures for federal award administration, including expenditure documentation, reconciliation, compliance review, and management approvals.  Require leadership to perform and document periodic oversight and monitoring of federal awards, including review of reconciliations reimbursement requests, and compliance metrics.  Implement ongoing monitoring and internal control assessments to ensure compliance with federal award requirements. 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

Finding 2024-003 – Lack of Internal Controls over Expenditure Documentation (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 Agriculture Federal Program Name: Natural Resources Conservation ServiceName 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: Title 2 CFR §200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the awards in compliance with federal statutes, regulations, and the terms and conditions of the award. Additionally, 2 CFR §200.302(b)(3) requires entities to maintain records that adequately identify the source and application of funds, including supporting documentation for expenditures, and 2 CFR §200.430 requires documentation for compensation for personal services. Condition: During our review of expenditures charged to the federal programs, the entity was unable to provide invoice copies or other sufficient supporting documentation for certain expenditures tested. As a result, we could not verify the allowability, accuracy, and proper approval of these costs in accordance with federal requirements. In addition, records were unavailable for Personnel expenditures that were charged to grant awards, and no support or evidence of time per grant was available. Cause: Partnership for the Umpqua Rivers does not have effective internal controls in place to ensure that invoice documentation and other supporting records are retained, centrally filed, and readily available for audit and monitoring purposes. In addition, management did not perform ongoing monitoring to verify that required documentation was maintained prior to reimbursement or reporting. Effect or Potential Effect: because supporting documentation was not available, expenditures from detail documentation could not be substantiated. This increases the risk that the unallowable, unsupported, or inaccurate costs may be charged to the federal program and reported in the Schedule of Expenditures of Federal Awards (SEFA). Questioned Cost: Yes, $332,409 related to Personnel costs, equipment and other purchases that were not documented with detailed support. 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. No financial files for Accounts Payable, invoices, or reporting were available to the current financial staff. Not adequately retaining supporting documents and invoices to support the expenditures of the general ledger and requests for reimbursement for grants, the organization records may be insufficient for testing and review, for internal controls or meeting federal documentation and reporting requirements. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit.Recommendation: Partnership for the Umpqua Rivers should implement policies and procedures requiring invoice copies and supporting documentation to be maintained for all grant expenditures. Management should strengthen record retention practices, provide training to staff on documentation requirements, and implement periodic internal reviews to ensure compliance. 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

2024-003 Allowable Costs/Cost Principles: Written Financial Policies The Biddeford-Saco-Old Orchard Beach Transit Committee acknowledges the need to formally adopt certain written financial management policies as outlined in federal regulations. The new finance manager is currently working to draft and formalize these policies and procedures with a targeted completion date of March 31, 2026. We will present them to the Board of Directors for review and official adoption.

FINDING 2024-014 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation in the form of dated expenditure reports for all federal grant reimbursements and for the final expenditure reports. The Business Office will implement a system of internal control and review where after each month is reconciled and closed, the Federal Grants Administrator will review the program expenditures, ensuring they are correctly posted prior to filing the reimbursements. All reimbursements will be reviewed and signed off on by the Federal Grants Administrator and an additional reviewer prior to submission for reimbursement. In addition, the final expenditure reports will be reviewed and signed off on by Grants Administrator and an additional reviewer prior to submission. Anticipated Completion Date: The school district began the practice above on January 1, 2024, and anticipate it will be completed by June 30, 2026.

F A 2O24-OO3 Strengthen Controls over Financial Reporting Compliance Requirement: Reporting lnternal Control lmpact: Material Weakness Compliance lmpact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education CFDA Numbers and Titles: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: S0104220010 (Year:2023), S010A230010 (Year.2024) Questioned Costs: $0.00 Repeat of Prior Year Finding: FA 2023-004, FA 2022-004, FA 2021-002, FA 2019-002 Description: The School District did not file accurate completion reports for the Title I Grants to Local Educational Agencies program. Corrective Action Plans: . CFO will make sure expenditures are correctly recognized on all completion reports . An independent CPA person has been hired and review completion reports before they are submitted Estimated Completion Date: Decembet 31, 2025 Contact Person:Torrence H. Freeman lll. CFO Telephone: 706-665-8577 Email:tfreeman@talbot.kl2 aus

2024-005 – Insufficient Financial Management Finding: Our audit procedures disclosed that the Organization drew down more revenues than expenditures incurred. Recommendation: We recommend that Homeward Bound Adirondack, Inc. establish oversight practices to ensure that all revenues and expenses are recorded appropriately and reconciled to the proper drawdown requests Action Taken: We are creating a policy and procedure to include the bookkeeper submitting the weekly expenses to the Executive Director for review and sign off prior to executing the draw downs to ensure proper allocation of costs. The Executive Director has contacted the Fox grants team concerning this matter.

Along with hiring the above consultants, VFC also hired a new Finance, Grants and Administration Manager. This person is now ensuring that all expenditures have receipts and are properly approved by the Interim Executive Director. In addition, revised policies and procedures for both supporting and approval documentation will be included in the updated accounting policies and procedures manual. The expected completion date is December 31, 2025.

See response to finding 2024-001 for information about newly hired consultants. The budget vs. actual reports are now being prepared on a regular basis and documentation will be maintained to demonstrate compliance. The expected completion date is September 30, 2025.

Finding 2024-009 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds passed-through the State Water Resources Control Board Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: A00059, 2024Finding Summary: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control and Instance of Non-Compliance Corrective Action Plan: The city is in the process of updating its Purchasing Policy and will include language on allowable costs and cost principles that are compliant with Title 2 C.F.R. Section 200. The process may be delayed with the absence of a Purchasing Manager. Responsible Individual(s): Finance Director (short-term part-time staff); Deputy Finance Director (Vacant); Purchasing Manager (Vacant) Anticipated Completion Date: December 2026

Finding 2024-002 Delta Regional Authority ( material weakness): Management recognizes the significance of properly segregating transactions relating to restricted grant programs in our accounting software. To address this issue, we will: 1. Reprogram Accounting Software: We will work with our software vendor to reprogram or adjust our accounting software to ensure that it can effectively segregate transactions related to restricted grants from other general ledger activities. 2. Revise Account Code Structure: We will review and redefine our general ledger account code structure to create more detailed categories that support accurate tracking and reporting of restricted funds. 3. Training for Staff: We will provide training for relevant staff on the updated accounting procedures to ensure they understand how to correctly use the new accounting software features and reporting structures. 4. Hire grant accountant: We have contracted a Grants Accountant who has already began organizing and file maintenance of grant records as well as working with the CFO, staff accountant and Grants Administrator to consolidate files, records, and supporting documentation for all active grants affecting the current fiscal year and FY 2025. II. Other Cause and Effect Management acknowledges that these weaknesses were caused by oversight from responsible employees and recognizes the risks associated with material misstatements and potential fraudulent activity. To mitigate these risks, we will enhance our internal controls, ensure accountability, and promote a culture of compliance and vigilance within the organization. Conclusion Management is committed to improving our internal controls over financial reporting to ensure compliance with federal regulations and enhance the accuracy of our financial statements. We appreciate the recommendations provided and will implement these corrective actions in a timely manner to strengthen our financial practices and restore stakeholder confidence. We will keep the board informed of our progress in addressing these material weaknesses. Management is dedicated to resolving these material weaknesses in a timely manner and will implement the recommended actions to strengthen our internal controls over financial reporting. We will keep the Board updated on our progress and provide necessary training for our staff to ensure adherence to new procedures. We appreciate the auditors' recommendations and are committed to making the necessary improvements to foster greater transparency and accountability in our financial reporting practices. Finding 2024-002 Delta Regional Authority (Material Weakness) – Accounting has worked with the Abilla System program coordinators and have set up codes within the accounting system to identify grants, restricted and unrestricted, for more effective reporting and identification.

During the FY2024 audit, Mana Maoli began implementing improvements to strengthen documentation practices for federal expenditures. These improvements include: Incorporating a centralized electronic system for retaining invoices, receipts, and other supporting documentation. Reinforcing existing approval procedures as part of the disbursement workflow. Providing targeted staff reminders and guidance on documentation expectations related to federal awards. Conducting periodic spot-checks of documentation to confirm consistency and identify any areas needing clarification. These steps are designed to strengthen controls using the organization’s existing capacity and tools. Mana Maoli will continue monitoring the process and making incremental refinements as needed. Anticipated completion date: June 30, 2026

Finding 2024-001: Grant Program: Department of Health and Human Services – National Institutes for Health Research and Development Cluster – Cancer Control – Assistance Listing #93.399 – Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. Montana Cancer Consortium (MCC) has updated the Financial Process Procedure to include language related to receipt management, allowable and disallowed grant expenses, and timing of payment requests. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators

The Village will adopt all necessary policies.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-011: Reporting - Insufficient Policies to Ensure Completeness and Accuracy of Reports (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Management will implement a standardized reporting checklist and will ensure that all reports undergo supervisory review and sign-off prior to submission Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2025. Plan to Monitor Completion of CAP: Management will conduct quarterly reviews of submitted reports and related documentation.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-007: Activities Allowed or Unallowed / Allowable Costs - Insufficient Budget-to-Actual Reviews (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: A monthly review checklist and variance analysis template will be adopted. Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2025. Plan to Monitor Completion of CAP: The internal audit function will conduct semiannual reviews to confirm adherence to established review procedures.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-006: Activities Allowed or Unallowed / Allowable Costs - Inadequate Chart of Accounts Segregation for Unallowable Costs (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Management will implement a comprehensive redesign of the chart of accounts, including the creation of new account codes and subaccounts to clearly identify unallowable costs. In addition, management will ensure that staff receive training on the revised coding structure. Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2025. Plan to Monitor Completion of CAP: The Finance Department will conduct quarterly internal reviews to ensure the proper use of the revised account codes and to verify the accuracy of cost classifications.

Views of Responsible Officials and Planned Corrective Action We will give instructions to the accounting staff in charge of the preparation of the quarterly progress reports of the Program, in order to comply with the FEMA reporting requirements. Responsible Official: Mrs. Irma M. Vargas Aguirre, Finance and Budget Director Implementation Date: December 31, 2025

Condition: ALC has not implemented all policies and procedures required by 2 CFR Part 200, specifically for cash management, allowability of costs, procurement, compensation, and fringe benefits. Planned Corrective Action: The American Loggers Council will develop written policies and procedures to comply with 2 CFR Part 200, specifically for cash management, allowability of costs and procurement. Policies and procedures related to compensation and fringe benefits currently do not apply to the Organization because they do not have any employees. These policies and procedures will be reviewed and approved by the executive director and executive committee. Contact Person: Scott Dane Anticipated Date of Completion: December 2025

Finding 2024-237: The Division could not provide supporting documentation for amounts reported on the Rehabilitation Services Administration (RSA) reports required under the Rehabilitation Services- Vocational Rehabilitation Grants to States. Related to Prior Finding: N/A Agency’s view: Agree 1.1 Corrective Action Plan: Establish Accurate Reporting Procedures: Develop and implement procedures for preparing, reviewing, and approving all RSA financial reports, including step-by-step reconciliation. 1.2 Ensure Documentation and Audit Trail: Maintain comprehensive supporting documentation for all amounts reported, including detailed reconciliations, adjustments, and source data, in accordance with requirements for traceable and verifiable records. 1.3 Strengthen Internal Controls and Oversight: Implement Strategic Leadership review of all reports prior to submission to the Rehabilitation Services Administration to confirm data accuracy and compliance with reporting requirements. 1.4 Complete a Restatement of RSA-17 Reports: Review previously submitted RSA-17 reports for fiscal years 2022–2024, determine accurate expenditure amounts, and coordinate with RSA to correct and resubmit revised reports, if necessary. Anticipated Corrective Action Date: 04/01/2026 Responsible for Corrective Action: Eric Bjork, Fiscal Officer

Finding 2024-230: The Department did not provide documented support to verify the accuracy of a LIHEAP performance report. Agency’s View: The Department Agrees with this Finding Corrective Action: A process was developed that includes obtaining and documenting approval by the Bureau Chief. This process was shared with LSO following receipt of the FY23 review findings. Supporting documents can be provided again as needed. Anticipated Corrective Action Date: Completed 03/25/2025 Responsible for Corrective Action: Kristin Matthews, Programs Bureau Chief, Self Reliance kristin.matthews@dhw.idaho.gov 208-334-5553

Finding 2024-201: Multiple errors were identified in the amounts reported on the Rehabilitation Services Administration (RSA) reports required for the Rehabilitation Services-Vocational Rehabilitation Grants to States. Related to Prior Finding: N/A Agency’s view: Agree Corrective Action Plan: These errors in quarterly and final RSA-17 reports are acknowledged, and immediate measures are being taken to address root causes: Accurate Financial Reporting: ICBVI will develop detailed procedures to ensure all amounts reported on federal forms are reconciled to supporting documentation in the accounting system (Luma) prior to submission. Review and Oversight: A two-person review process will be formalized, ensuring every report is checked for accuracy by a knowledgeable reviewer before submission. Documentation and Training: Supporting documentation for all line items will be archived securely. Staff will receive training in federal grant reporting standards. Anticipated Corrective Action Date: 1-15-26 Responsible for Corrective Action: Corey Bresina, Administrative Services Manager, 208-639-8369, cbresina@icbvi.idaho.gov