Corrective Action Plans

2024-012 Financial Statement Reconciliations/Tie-In Procedures Material Weakness Recommendation: The Housing Authority should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. These policies should require timely reconciliations to take place as defined under policy. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

Finding Number 2024-111 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action Management agrees with this finding. To mitigate this issue going forward, the established network drive for FFR supporting documentation retention will now be reviewed at closeout of each FFR to ensure all detailed schedules are centrally retained and accessible prior to certification. Anticipated Completion Date 6/30/2026 Responsible Contact Person Kimberly Courtney, Director of Accounting

Finding Number 2024-110 Subject Heading (Financial) or AL no. and program name (Federal) 93.268: Immunizations Cooperative Agreements Planned Corrective Action Management agrees with this finding. To mitigate this issue going forward, the established network drive for FFR supporting documentation retention will now be reviewed at closeout of each FFR to ensure all detailed schedules are centrally retained and accessible prior to certification. Anticipated Completion Date 6/30/2026 Responsible Contact Person Kimberly Courtney, Director of Accounting

Finding 2024-005: Reporting (Title V, CFDA 93.U01) Material Weakness (Repeat Finding: 2021-005, 2022-005, 2023-005) Condition: The Organization could not provide required Title Vreports, including the financial report, activity narrative, third-party income report, GPRA/GPRAMA, urban data standards report, and property inventory. Corrective Action: • Build a federal reportingcalendar listing every required Title Vreport, its due date, data source, and responsible preparer. • Assign a designated preparer and a second-level reviewer for each report prior to submission. • Retain a copy of each submitted report, with the submission confirmation, in a centralized compliance file. • Provide staff training on Title V reporting obligations and the underlying contract requirements. Responsible Party: Chief Financial Officer/ Grant Director Anticipated Completion Date: Reporting calendar in place by October 15, 2026; first fully compliant reporting cycle Q1 2027

Finding 2024-004: Procurement and Suspension and Debarment (Title V, CFDA 93.U01) Material Weakness (Repeat Finding: 2021-004, 2022-004, 2023-004)Condition: Because Title V expenditures lacked transaction-level detail, the auditor could not select procurement transactions for testing or verify that vendors were screened for suspension/debarment prior to contract award. Corrective Action: • Adopt a written procurement policy aligned with Uniform Guidance thresholds (micro-purchase, simplified acquisition, formalprocurement); this policy is in progress and pendingboard approval. • Require and document a System for Award Management (SAM.gov) check, or an equivalent vendor certification, before anyfederally funded contract or purchase order is issued. • Retain SAM.gov screening printouts/certifications with the procurement file for each Title V vendor. • Apply the GLrestructuring from Finding 2024-003 so procurement transactions are individually identifiable for testing. Responsible Party: Chief Financial Officer Anticipated Completion Date: Procurement policy adopted by November 15, 2026; SAM screening process in effect for all new Title V vendors by December 1, 2026

Finding 2024-003: Activities Allowed and Unallowed, Allowable Costs, Period of Performance (Title V, C FDA 93. U0 1) Material Weakness (Repeat Finding: 2021-003, 2022-003, 2023-003) Condition: Title V expenditures were recorded through summary journal entries without transactionlevel detail, preventing the auditor from selecting a valid sample or testing compliance. A disclaimed opinion on compliance was issued for this major program. Questioned costs are undetermined due to scope limitation. Corrective Action: • Restructure the chart of accounts/ GL coding so every Title V transaction is individually recorded and traceable to source documentation, rather than aggregated into journal entries. • Require program/grant coding at the point of transaction entry (accounts payable, payroll allocation, purchasing) rather than after the fact. • Implement a quarterly internal review reconciling Title V ledger detail to the approved Title V budget and contract terms. • Provide finance staff training on Uniform Guidance recordkeeping requirements (2 CFR §200.302, §200.333) specific to federal award transactions. Responsible Party: Chief Financial Officer Anticipated Completion Date: GL restructuring to be implemented concurrent with the Organization's new fund accounting system (Blackbaud Financial Edge NXT), implementation kickoff August 13, 2026; complete by March 31, 2027, with the first fully traceable Title V transaction month in April 2027

Management will improve internal processes and controls to include the following: Creation of a subset of general ledger codes for unallowed program costs, Management review of program expenditure requests prior to payment, and Annual Uniform Guidance compliance training.

Management will improve internal processes and controls to include the following: Monthly review of program expenditures for overall grant period, Quarterly reconciliation of voided checks against program drawdown invoices, and Annual Uniform Guidance compliance training.

FINDING 2024-009 Finding Subject: ESSER Grant Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ESSER program has concluded and corrections were made following leadership changes. Financial activity was reviewed and adjusted where possible. Reimbursement requests are now tied to general ledger activity with full documentation. The prior practice of correcting errors through transfers has been discontinued. Controls implemented apply to all future grants and monitoring is ongoing. Anticipated Completion Date: May 2026

FINDING 2024-008 Finding Subject: Special Education Cluster (IDEA) Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation partnered with Mazi Education for oversight. Separate funds are maintained for each project year. Payroll mapping has been corrected and reimbursement requests are based on ledger activity with supporting documentation. Transfers are documented and restricted. Monitoring procedures ensure ongoing compliance. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance control activities, and provide ongoing monitoring to ensure compliance with Special Education grant requirements and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

FINDING 2024-006 Finding Subject: Title I Grants Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation partnered with Mazi Education to provide oversight of grant compliance. Separate funds are maintained for each grant and project year. Payroll mapping has been corrected to ensure proper allocation. Reimbursement requests are based on general ledger activity and supported by documentation. Transfers are restricted and documented. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance control activities, and provide ongoing monitoring to ensure compliance with federal grant requirements and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

We agree with the recommendations offered for the relevant programs and will establish and implement policies that provide for documentary evidence of review of applicable reports by qualified individuals to ensure the timely submission of required reports to applicable federal agencies that can be easily reconciled to the underlying accounting records. The anticipated completion date is October 2026.

Root Cause Analysis: The root cause of this finding was a misapplication of the approved indirect cost rate to the appropriate Modified Total Direct Cost (MTDC) base in connection with drawdown calculations. Although The EPI Center had an approved indirect cost rate and related policy in place, the operational procedures and system configurations necessary to consistently apply the methodology were still being refined and operationalized. The EPI Center notes that a formal, written Indirect Cost Rate Policy consistent with Uniform Guidance (2 CFR Part 200) was in place at the time of award. However, during the initial year of administering a federal award as fiscal agent, the procedures outlined in the policy were not fully operationalized. This resulted in a misapplication of the approved indirect cost rate. The overdraw resulted from applying the indirect cost rate to budgeted, rather than actual, direct expenditures. Management has since recalculated allowable indirect costs based on actual expenditures and has implemented enhanced controls to ensure accurate application of the MTDC base and compliance with federal requirements going forward. Response, with details: ☒Corrective Action Plan ☐Clarification Management acknowledges the misapplication of the approved indirect cost rate and has taken immediate steps to correct the calculation and ensure full alignment with federal requirements. Specifically, The EPI Center has recalculated indirect costs based on allowable expenditures within the Modified Total Direct Cost (MTDC) base and is actively engaging with the U.S. Department of Education to determine the appropriate resolution of the overdrawn amount. Management confirms that all underlying expenditures charged to the program were allowable, allocable, and supported by appropriate documentation, and no unallowable costs were identified. Corrective Actions Management has implemented the following corrective actions to address the issue and strengthen internal controls: 1. Training and Capacity Building (Completed - April 2026) Finance staff and senior leadership have completed targeted training on the application of indirect cost requirements under Uniform Guidance to reinforce compliance expectations. 2. Recalculation and Resolution of Overdraw (Implementation Initiated) The EPI Center has recalculated allowable indirect costs by applying the restricted 8 percent indirect cost rate for Teacher and School Leader Incentive Program (TSL) grants to actual expenditures incurred during the reporting period. The program officer has been informed of the miscalculation and resulting overdraw. The EPI Center will follow all applicable agency protocols upon receiving formal guidance from the U.S. Department of Education. Management is actively coordinating with the U.S. Department of Education to resolve the calculated overdraw and will comply with all agency guidance, including repayment of any amounts determined to be unallowable. Controls are now in place to ensure that all future drawdowns are calculated based on the approved indirect cost rate applied to the MTDC base and are subject to documented review prior to submission. 3. Standardized Indirect Cost Calculation Worksheets (Completed - April 2026) A standardized indirect cost calculation worksheet will be required and reviewed prior to approval of all drawdown requests. 4. Independent Oversight (Completed – June 2025) The EPI Center has engaged a third-party controller who will review and independently validate indirect cost calculations prior to submission, providing an added layer of oversight and control. Responsible Party: Finance and Compliance Manager, Third-party Controller, CEO Timeline for Completion: May 2026

Finding 2024-009: Reporting – Material Weakness Condition: As a result of the audit procedures, it was noted that the Organization did not maintain copies of performance-related reports submitted to the grantor for the Title V program. Corrective Action: Management is implementing a formal process to retain all supporting documentation for performance-related reports submitted to grantors in accordance with Federal requirements. NACA is also hiring and training a Grant Director to strengthen oversight of grant reporting, compliance, and documentation requirements. As part of the monthly and grant reporting process, staff will ensure that copies of all submissions are saved. A review step will also be added to confirm that all required documentation has been retained prior to final submission. Management will continue to evaluate and adjust processes as needed to ensure compliance and completeness. Name of Person Responsible: Walter McCullough, CFO and finance staff Anticipated Date of Completion: May 31, 2026

Finding 2024-008: Cash Management – Material Weakness Condition: As a result of the audit procedures, it was noted that the Organization did not retain copies of cost reimbursement reports submitted to the grantor for the Urban Health Clinic, Substance Abuse Prevention, and Title V programs. Corrective Action: Management is implementing a formal process to retain all cost reimbursement reports submitted to grantors in accordance with Federal record retention requirements. NACA is also hiring and training a Grant Director to strengthen oversight of grant reporting, reimbursement processes, and documentation requirements. This will include establishing a centralized and organized filing system, to ensure all submitted reimbursement reports are maintained and accessible. As part of the monthly reimbursement and grant reporting process, staff will ensure that copies of all submissions are saved and reconciled to the accounting records. A review step will also be added to confirm that all required documentation has been retained and properly organized prior to final submission. Management will continue to evaluate and adjust processes as needed to ensure compliance and completeness. Name of Person Responsible: Walter McCullough, CFO and finance staff Anticipated Date of Completion: May 31, 2026

UCM will develop and implement written procedures requiring that all financial reports submitted to federal awarding agencies or pass-through entities are prepared using actual expenditures recorded in UCM’s accounting system. Reported amounts will be reconciled to the general ledger and supported by appropriate documentation before submission, including general ledger detail, payroll records, accounts payable records, allocation schedules, invoices, receipts, proof of payment, and other records supporting the reported costs. UCM will implement a federal financial reporting checklist to document preparation, reconciliation, and review each report. The checklist will require verification that reported costs agree to actual expenditures, are recorded in the correct reporting period, are charged to the correct federal award, are supported by documentation, and are consistent with award terms and Uniform Guidance requirements. A qualified individual independent of the report preparation process will review and approve reports before submission, and evidence of review will be retained. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Independent Reviewer (CEO, Finance Committee Chair, or another qualified reviewer) Anticipated Completion Date: December 31, 2026

VIEWS OF RESPONSIBLE OFFICIALS We are resolving these deficiencies by leveraging the new Government ERP system, scheduled for launch in July 2026. This platform will provide the essential functionality to properly configure our Chart of Accounts, ensuring that all TANF and PTTA administrative expenditures are automatically segregated by federal award and Assistance Listing Number (ALN). This system will be the foundation for accurate, traceable, and reconcilable financial reporting, supported by robust internal controls and multi-level supervisory oversight. Action Steps: 1. ERP Chart of Accounts Configuration – Configure the ERP system with a granular Chart of Accounts that strictly segregates TANF and PTTA administrative expenditures, ensuring every transaction is coded to the correct federal grant and ALN. 2. Automated Reporting Workflow – Utilize the ERP's financial reporting modules to generate ACF-196TR reports directly from the General Ledger, ensuring reported expenditures are 100% traceable to source transactions. 3. Digital Reconciliation Workpaper – Require the ERP to generate an automated "Reconciliation Package" for every ACF-196TR submission, which links reported line items directly to General Ledger accounts, eliminating discrepancies. 4. Staff Training & ERP Stabilization – Execute comprehensive training for all finance staff on the new ERP accounting structure, reconciliation modules, and federal reporting requirements, ensuring the system is utilized for full audit compliance. 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

VIEWS OF RESPONSIBLE OFFICIALS The Department of the Family and PR-DDS acknowledge the audit finding regarding the differences identified between the balances reported on Form SSA-4513, the PRIFAS accounting records, and the supporting documentation for unliquidated obligations. To address this issue, the following corrective actions will be implemented: 1. Monthly meetings will be held between the Department of the Family’s Finance staff and PR-DDS administrative and fiscal personnel to review and monitor all outstanding obligations and any differences identified between the PRIFAS records and the reports prepared for the Social Security Administration (SSA). 2. A formal monthly reconciliation will be performed between the balances reported on Form SSA-4513 and the financial records maintained in PRIFAS. Any discrepancies identified will be analyzed, documented, and supported with appropriate evidence. 3. Differences between the PRIFAS records and valid obligations that are not reflected in the system will be explained and documented in the comments section of Form SSA-4513, as applicable. 4. The review process for unliquidated obligations will be strengthened through periodic evaluations to identify obligations that should be modified, liquidated, or canceled in accordance with SSA requirements. 5. Written internal procedures will be developed for the preparation, review, and approval of Form SSA-4513, including the retention of supporting documentation necessary to substantiate the reported balances. Management further notes that certain obligations related to Medical Evidence of Record (MER) and Applicant Travel (AT) are authorized and monitored by PR-DDS before the related disbursements occur. These obligations are not recorded in the PRIFAS accounting system until payment is processed by the Special Payments Office (OPE). As a result, temporary differences may exist between the balances reflected in PRIFAS and the unliquidated obligations reported on Form SSA-4513. To address this situation, PR-DDS and the Department of the Family’s Finance Office have established a monthly reconciliation process to identify, document, and explain all temporary differences between PRIFAS records and the obligations maintained by PR-DDS. In addition, any significant differences will be properly disclosed and explained in the comments section of Form SSA-4513 and supported by the appropriate documentation. IMPLEMENTATION DATE The monthly meetings and formal reconciliation process began during Fiscal Year 2026 and will continue an ongoing basis. Expected Completion Date: September 30, 2026 RESPONSIBLE PERSON Ramón Luis Vargas Escalante Chief Accountant of Finance

VIEWS OF RESPONSIBLE OFFICIALS ADFAN appreciates the observations presented in the audit and acknowledges the importance of strengthening its reporting processes. The agency recognizes that staffing limitations within the Finance Division have affected the ability to perform timely reviews and ensure adequate segregation of duties. Additionally, the Finance Procedures Manual referenced during the audit was approved in 2009 and is currently undergoing a comprehensive revision to reflect the agency’s present operational structure and accounting practices. ADFAN is committed to improving its internal controls, enhancing staff training, and implementing the necessary measures to ensure full compliance with federal reporting requirements moving forward. IMPLEMENTATION DATE December 31, 2026 RESPONSIBLE PERSON Yazmín Cruz Colón, Budget Director

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive internal control framework. We are prioritizing the development of formal written policies, the standardization of regional data reporting, and the implementation of a rigorous oversight system to ensure all TANF programmatic reports are complete, accurate, and filed on time. Action Steps: 1. Revise the Protocol of “TANF – Reporting Procedures Manual" that defines the full data lifecycle: collection, regional validation, quality control, supervisory review, and submission. 2. Regional Standardization – Establish mandatory, standardized templates for all regional offices to report programmatic data, ensuring uniformity and minimizing data entry errors. 3. Reporting Calendar & Oversight – Implement a master’s "Federal Reporting Calendar" that tracks all due dates for ACF-199, ACF-209, and other reports, with automated alerts sent to management 30 days prior to submission. 4. Training & Certification – Launch a mandatory training curriculum for all staff involved in reporting, focusing on 45 CFR Part 265 standards, data accuracy, and the consequences of reporting failures. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Blanca M. Medina Díaz Administrator Gerhil Medina Baez Auxiliary Administrator Operational Services Johana Hernandez Andaluz TANF Program Director

VIEWS OF RESPONSIBLE OFFICIALS To resolve this, we are integrating these reporting requirements into the new Government ERP system, scheduled for launch in July 2026. This platform will provide the capability to generate accurate General Ledger data and automated financial reports, ensuring that all LIHEAP performance data is traceable to verified accounting sources and subject to multi-level supervisory approval workflows. Action Steps: 1. ERP-Driven Financial Reporting – Configure the ERP system to generate General Ledger reports that align precisely with LIHEAP financial data requirements. The ERP will serve as the "Single Source of Truth," eliminating discrepancies between accounting and reporting. 2. Automated Reconciliation Workflows – Utilize the ERP’s native reconciliation engine to automatically match expenditure records against reported LIHEAP budget obligations, ensuring figures are accurate and validated before submission. 3. Segregation of Duties (SOPs) – Formalize protocols where the ERP system enforces mandatory "Preparer-Approver-Certifier" roles. This ensures that performance data compiled by program staff is independently validated against ERP financial records by a supervisor. 4. Training on ERP Reporting – Train all staff on how to use ERP reporting modules for financial data extraction and the new protocols for reconciling this data with programmatic LIHEAP performance metrics. 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 Nesvia Fontanez Marín Principal Accountant Federal Reports

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a rigorous compliance framework to ensure all reported Maintenance-of-Effort (MOE) expenditures are internally consistent, fully supported by source documentation, and reconciled prior to submission. We will formalize these processes through new protocols and dedicated oversight to guarantee the integrity of our federal 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 Nesvia Fontanez Marín Principal Accountant Federal Reports

VIEWS OF RESPONSIBLE OFFICIALS To resolve these systemic issues, the Government of Puerto Rico is transitioning to a new Enterprise Resource Planning (ERP) system, scheduled for live launch in July 2026. This modern platform will centralize our financial data and provide the necessary automation to ensure that all federal reports are accurate, traceable to source documentation, and subject to multi-level supervisory approval workflows. Action Steps: 1. ERP Implementation & Workflow – Deploy the new ERP system to centralize all financial accounting. The system will be configured to require distinct user roles for the preparation, review, and certification of federal reports. 2. Automated Traceability – Utilize ERP reporting tools to ensure all administrative expenditures are linked to valid source documentation (e.g., invoices, payroll registers), providing a clear audit trail from report to General Ledger. 3. Implement report validation tool – No federal report may be submitted until an independent, designated official has digitally validated the report against source accounting records. 4. Reconciliation SOPs – Formalize a written SOP requiring monthly reconciliations of reported federal expenditures against the ERP database. These reconciliations will be retained as evidence of review for audit purposes. 5. Training & Accountability – Conduct mandatory training for all staff on new reporting workflows and the importance of segregation of duties, ensuring all personnel understand their responsibility in maintaining accurate financial data. 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

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to a fundamental restructuring of our cash management lifecycle. By migrating drawdown processes into our ERP system, we will ensure that every request is supported by system-generated documentation, enforced through systematic segregation of duties, and fully reconciled against the general ledger in real-time. Action Step: 1. ERP-Based SOP Manual-Implement of the Procedure Manual of ERP system. This manual will supersede legacy documentation and clearly map every procedural step to a specific ERP function. 2. Systemic Segregation ERP is configurated to enforce mandatory "Preparer" and "Approver" roles. The system will prevent a single user from both creating and authorizing a drawdown request, ensuring logical segregation of duties. 3. Automated Reconciliation-Implement a system-level control where the ERP automatically reconciles drawdown requests. Any variance will trigger a "Pending Review" flag, preventing unauthorized processing. 4. Real-Time Supervisory Review-Require supervisors to conduct an audit of all drawdown documentation directly within the ERP interface. No request will be released for funding without a digital system approval following a reconciliation review IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget

VIEWS OF RESPONSIBLE OFFICIALS ADFAN concurs with the finding. The agency acknowledges the requirement to maintain written procedures in accordance with 2 CFR §200.302, including procedures related to cash management and the determination of allowable costs under federal awards. The condition identified was impacted by limited staffing resources within the Finance Area, which affected the timely completion and formalization of the required written procedures. In addition, the Finance Procedures Manual is currently under review and revision to ensure compliance with Uniform Guidance requirements and to strengthen internal controls over federal programs. As corrective action, ADFAN is completing the update and formalization of the Finance Procedures Manual, which will incorporate the written procedures required by Uniform Guidance. Upon completion, the revised manual will be formally approved, communicated to relevant personnel, and implemented across the agency. Management will also continue assessing staffing needs and resource allocation within the Finance Area to support the ongoing maintenance and monitoring of financial policies and procedures. IMPLEMENTATION DATE December 31, 2026 RESPONSIBLE PERSON Rafael López Arocho Assistant Administrator on Administration