Corrective Action Plans

Finding 2024-004: Written Policies and Procedures • Planned Corrective Action: We will adopt formal policies and procedures that document our current practices and also meet the requirements of the Code of Federal Regulations (CFR). • Anticipated Completion Date: September 30, 2025. • Responsible Contact Person: Rick Smith, Executive Director

Management concurs with the finding and will revise procedures to ensure detailed, timely recording of USDA Foods distributions. Staff will receive training on documentation requirements, and management will implement periodic compliance reviews. These corrective actions are expected to be completed by March 1, 2025.

Finding 2024-03 Insufficient Documentation of Other Direct Expenses Condition: During testing of direct costs charged to the federal program, the Organization did not maintain sufficient documentation to fully support all expenditures claimed. In one instance, a receipt supporting a claimed expense was missing. In three additional cases, although the expenditures were generally supported, the documentation did not clearly reflect how the amounts allocated to the major federal program were determined. While these issues were isolated and the known and likely questioned costs were immaterial, the lack of complete documentation represents noncompliance with federal requirements for allowable costs. Corrective Actions Taken or Planned: The Organization will develop written guidelines specifying the required supporting documentation for each type of direct expense. Set up vendors in QuickBooks. We will hire and train Finance Manager to manage and track revenue and expenses, QuickBooks, grant reporting etc. All receipts and expenses will be scanned in and kept electronically. The Organization will provide training on documentation requirements, proper record submission, and compliance expectations.

Finding 2024.003 – Cash Management Recommendation The Center should develop written procedures to review all drawdowns that occur to ensure accuracy. Not a repeat finding. Action Taken Since September 2023, the Center has implemented weekly grants management reviews with the grants team and key executives. Action items are tracked through meeting agendas, minutes, and NMH’s project management platform, Monday.com. Meetings include invoice approvals for grant-funded expenditures, and review of allocations, payroll dates, and stipends for drawing down calculations. The meetings going forward will document the amounts for federal grants drawdowns and will be logged within Monday.com and through an external verification spreadsheet. Starting May 2025, an updated verification spreadsheet along with an itemized attestation was implemented.

Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager

August 15, 2025 To: Clausell & Associates, P.C. From: Tabirus Lockhart, Chief Financial Officer of Enrichment Services Programs, Inc. Below is the Agency’s corrective action plan as it relates to the findings for the fiscal year ending July 31, 2024, Single Audit Act audit. Comment #2024-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED GENERAL (Repeat) Views of Responsible Officials and Planned Corrective Actions: We concur with this finding - Management is in the process of assessing the organizational structure, capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2024. Concerning preparation of external reports required by various funding sources (i.e., SF-425, DHS’s reports for LIHEAP, LIHWAP, etc.), the Agency will ensure adequate training is performed to improve the skills and knowledge of key personnel. Policies and procedures will also be revised to support external reporting. Implementation Date: The plan correction date will be completed no later than December 31, 2025. Responsible Person: Tabirus Lockhart, CFO, will be responsible for the corrective action. Comment #2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP, and SLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Management and staff are in the process of assessing and updating the policies and procedures over the accounting and reporting of federal and state grants and contracts. In connection with training staff on the new and updated accounting system, we are providing ongoing training on the requirements of the Uniform Guidance and the specific requirements for each individual grant award as outlined in each applicable Compliance Supplement issued by Office of Management and Budget (OMB). We are currently reconciling all cash accounts and completing and amending, where necessary, all SF-425 reports and other external reports required by each funding source (state and federal). We anticipate completing this corrective action by December 31, 2025. See also the response to Comment #2024-001. Implementation Date: The plan correction date will be completed no later than December 31, 2025. Responsible Person: Tabirus Lockhart, CFO, will be responsible for the corrective action.

June 26, 2025 JGD & Associates LLP 9191 Towne Centre Drive Suite 340 San Diego, California 92122 Re: Corrective Action Plan Dear JGD & Associates LLP, The following are responses to the program audit findings from the most recent audit of Adjoin. 1. Current Year Findings 2024-001 a. Program Name: Supportive Services for Veterans Families: CFDA 64.033 b. Criteria: Failure to comply with the grant agreement’s terms and applicable regulations: The Organization did not comply with grant compliance requirements such as tracking administrative expenses charged to the program outside of the general ledger and in other matters noted in licensing reviews. c. Condition: The Organization has failed to comply with grant requirements due to lack of proper tracking of administrative expenses, limited compliance policies including approval over supplemental pay wages, and lack of proper training over verification and documentation processes. d. Response: The organization has been successfully running the SSVF program for 11+ years and tracking/calculating administrative costs utilizing offline Excel spreadsheets since inception which provided a low cost and flexible solution for our accounting team. However, as an outcome of our last SSVF audit and due to the size and scope of our SSVF operations, the VA is requiring Adjoin to cease maintaining offline spreadsheets and ensure that all SSVF grant costs are logged in the general ledger. We're partnering with JMT Consulting (our Sage Intacct solution provider) for their assistance in implementing a new Dynamic Allocation Module to our Sage platform allowing click thru capabilities to all of the administrative costs that hit the grant (not to exceed 10%). We're committed to rolling out this functionality and are excited about the efficiencies it will bring to the team along with ensuring compliance with VA requirements. 2. Prior Year Finding 2023-001 None noted. Contact person responsible for corrective action: Pat Phelan, CFO Completion date: August 31, 2025 If you have any questions regarding this plan, please contact Pat Phelan, CFO, 858- 292-2030, pat.phelan@adjoin.org. Sincerely, Pat Phelan CFO Adjoin

Management Response: We have had significant turnover in HR and Payroll and documentation was not maintained properly. We have a new HR Director and new Payroll Manager who will work closely together and are aware of record keeping and maintaining files for compliance. A checklist has been created to ensure all required documents are on file. Anticipated Completion Date: We are conducting a file review and will ensure all documents are in order by September 30, 2025. Responsible Party: HR Director, Payroll Manager, Benefits Coordinator and Business Manager will have oversight.

Finding 2024-005 Internal Controls Over Compliance for Subrecipient Monitoring 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding The City will adopt the referenced policies in order to comply with Uniform Guidance. 3. Official Responsible Ms. Sony Lubrecht, Finance Director, is the official responsible for ensuring corrective action. 4. Planned Completion Date December 31, 2025. 5. Plan to Monitor Completion The City Council will be monitoring this Corrective Plan.

2024-007 Missing Supporting Documentation for Federal Reimbursement Claims Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. A process for retaining claims and supporting documentation has been implemented.

Action Taken: Management agrees with the finding noted above. Management will also note that as a repeated finding we do not so much offer a corrective action plan as we do a summarization of steps already taken to close this finding for fiscal 2025. A new and highly qualified Chief Financial Officer with over 30 years of public housing experience was hired by the agency in April of 2024. The CFO has fully staffed the department with competent and qualified individuals including a new and fully qualified Controller and Director of Finance. All individuals hired have received targeted training from both internal and external sources. In June 2024 the new financial management team implemented a policy/procedure for the records requirement and payment timeframes for all capital fund draw downs. This policy requires the hand signing of eLOCCS forms and reconciliation of individual draws at the time of drawdown. During fiscal 2025 the entire Finance staff was trained extensively on all matters related to HUD accounting. Specific training was directed to the Capital Fund program, its eligibility standards, accounting processes, and drawdown procedures. This training was conducted by a nationally recognized HUD-specific trainer. The Authority has hired a qualified, experienced internal auditor. The internal auditor has completed a 100% testing sample on capital fund draws made in fiscal 2025. His observations were rectified, and the policy revised where needed. The sampling assured that supporting documentation was sufficient for audit, that it matched the amounts drawn, and that invoices were paid within HUD dictate s timeframes. Management feels that with this policy and enhanced testing in place the finding will not be repeated in 2025. Management expects closure of this finding, under the direction of the Chief Financial Officer, for the Fiscal 2025 audit.

View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.

Recommendation: We recommend that the Parish enhance and document internal controls over financial reporting, as described in our recommendations described under item 2024-001, to prevent noncompliance of the Uniform Guidance as required. Corrective Action: The Parish has written a Standard Operating Procedure for “Grant Management - Financial Reporting & Reconciliation” which outlines the role of the Finance Department in monitoring grant activities including measures to ensure correct general ledger coding for budget planning, complete and accurate recording of grant expenditures and revenues, and administrative review to confirm reconciliation of grant activities against the general ledger on a monthly basis. This corrective action was approved and implemented effective 6/30/2025

In response to the Auditor’s recommendations and as corrective action, the responsible staff or department will locate, and document all required reports that were filed in accordance with the grant agreement requirements, including reconciliations with the Municipality’s official accounting subsidiary ledgers. Furthermore, the Municipality will design, document, establish, and provide the necessary training, along with written guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

Following the Auditor's recommendations and as corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

The Municipality will designate the appropriate personnel to systematically identify, compile, and securely retain all required reports as stipulated in the grant agreement, ensuring reconciliation with the official accounting records and subsidiary ledgers. Furthermore, the Municipality will develop and implement a comprehensive training program, accompanied by detailed written guidelines and procedures, to equip all staff involved in managing federal funds with the necessary knowledge and tools to maintain compliance and enhance accountability.

FINDING 2024-004 Finding Subject: Water and Wast Disposal System for Rural Communities - Reporting Contact Person Responsible for Corrective Action: Beth Jones Contact Phone Number and Email Address: 812 723-2739, clerk@paoli.in.gov Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: The town is contracted with Baker Tilly Financial Advisors and the Clerk Treasurer will provide all pertinent information to Baker Tilly in order for them to prepare the Statement of Budget, Income, and Equity- Form 442-2; and the Balance Sheet - Form 442-3) that is required by the USDA for the Sewer Bonds. Once the reports are completed by Baker Tilly, the Clerk Treasurer will review the reports and then submit them to the USDA. This will be done annually. Anticipated Completion Date: Effective immediately

Condition: The District claimed expenditures that did not agree with their underlying accounting records. Plan: The District will hire a full-time employee to execute the completion of all State and Federal grants. Addidtional training and reources will be provided to ensure the District remains in compliance. Anticipated Date of Completion: 'June 30, 2025. Name of Contact Person: Dr. Kevin J. Nohelty, Superintendent. Management Response: The District will review the itemized budget and ensure claimed expenditures fall within the grant. If necessary, amendments will be filed accordingly.

Condition: The District claimed expenditures that did not agree with their underlying accounting records. Plan: The District will maintain records that accuaratetly support reported expenditures on the expenditure claims effective immediately. Anticipated Date of Completion: 'June 30, 2025. Name of Contact Person: Dr. Kevin J. Nohelty, Superintendent. Management Response: The District will periodically review the itemized budget and ensure claimed expenditures fall within planned grant expenditures or file amendments as necessary.

Finding 2024-001 Internal Controls Over Compliance for Cash Management, Allowable Costs, Procurement, and Conflicts of Interest 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Subsequent to year-end, the City addressed this matter by formally adopting written policies meeting the referenced requirements of the Code of Federal Regulations. 3. Official Responsible The City Administrator is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2025. 5. Plan to Monitor Completion The City Council will be monitoring this Corrective Plan.

Finding 2024-004 Internal Controls Over Compliance for Cash Management, Allowable Costs, Procurement, and Conflicts of Interest 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding The City will adopt the referenced policies in order to comply with Uniform Guidance. 3. Official Responsible Nicole Coler, City Clerk/Treasurer, is the official responsible for ensuring corrective action. 4. Planned Completion Date December 31, 2025. 5. Plan to Monitor Completion The City Council will be monitoring this Corrective Plan.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. The Group will prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Group staff are trained on the requirements related to federal award reconciliations and SEFA preparation which mitigates the risk of noncompliance in the future.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. The Group will prepare and maintain an accurate Schedule of Expenditures of Federal Awards (SEFA) in accordance with 2 CFR Part 200.510 to ensure proper documentation and compliance with federal reporting requirements. Group staff are trained on the requirements related to federal award reconciliations and SEFA preparation which mitigates the risk of noncompliance in the future.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will work with management to design and implement internal controls related to federal program grant management, including assignment of responsibility for grant oversight to specific individuals or departments.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will work with management to implement internal controls over tracking of expenditures related to federal award grants, especially personnel costs, and the related reimbursed cost to ensure compliance with federal requirements.