Corrective Action Plans

We agree that the State and Local Fiscal Recovery Funds (SLFRF) Project and Expenditure Report was overstated by $1,059,739.66 for the grant period ended December 31, 2025. We contract with Bricker, Graydon, Wyatt LLP to complete the SLFRF reporting. We understand that we should review the report as it is completed by the law firm. Interest earned on SLFRF funds do not have to be remitted to the US Department of Treasury and is not subject to the SLRFR program use restrictions. Therefore, the issue deals primarily with reporting and classification. The County will review and reconcile all expenditures reported under the SLFRF grant receipts, interest earnings, expenditures, and amounts reported to the US Department of the Treasury. The County will ensure expenditures are accurately classified and reported according to the source of funds and applicable Treasury reporting requirements. We will review the report after it is prepared by the law firm and approve the reconciliation before the report is submitted. The reconciliation will specifically distinguish SLFRF award funds from interest earnings and other non-SLFRF revenues.

Management Response: Management will retain a complete support package for each Federal financial report, including the accounting records used at the time of preparation which will be provided by the outsourced accounting firm, the completed report, a reconciliation of reported amounts to the underlying accounting records, and explanations for any reconciling items. The preparer will assemble and document the support package before submission. A knowledgeable individual other than the preparer, which may include management or the outsourced accounting firm, will review the report and reconciliation for completeness, accuracy, and consistency with award requirements. Evidence of review, approval, and resolution of any differences will be retained with the support of reporting. Management will also evaluate subsequent accounting adjustments to determine whether previously submitted reports require correction or follow-up with the Federal agency. Proposed Completion Date – October 01, 2026 Contact – Ronny Sandoval, Board Chair Email: ronnys@irecusa.org

Management Response and Action Taken: Drawdown with No Subsequent Payment • MHA will reconcile and match all end-of-year grant receivables with the invoices and subsequent payment in the ensuing year. • MHA will confirm payments are made timely, within the required three-day period. Duplicate Invoices • MHA will include a direct sign-off, date, and matching requirement on our invoice package that reconciles the draw down date, amount to the invoice payment amount, invoice number(s) and date paid. • MHA will log all invoices prior to drawdown to ensure any duplicate invoices are identified prior to drawdown. Name of Responsible Person(s): Ken Cross, Head of Finance Projected Completion Date: November 30, 2026

Federal Finding 2025-002 – Allowability of Costs Name of Contact Person: Dianne King, CEO/GM Corrective Action: NEA will develop and implement a procedure on when and how to segregate unallowable costs from allowable costs. The procedure will include identification of federally-unallowable costs and the method used to ensure unallowable costs are fully removed from any accounts or job cost pools associated with federal awards. This procedure will be incorporated into NEA’s overall existing accounts payable procedures. Proposed Completion Date: March 31, 2027

Management acknowledges the finding and agrees that written procedures for determining the allowability of costs were not formally documented as required. As the Cooperative continues to mature its federal grant management practices, this gap has been identified and addressed. Written procedures for determining the allowability of costs have been developed and are now in place to be used for any future grants. Finance management will monitor adherence to these procedures and incorporate them into the broader financial policies framework to ensure continued compliance with applicable federal requirements going forward.

Management agrees with the finding. Management will spend additional time reviewing CFR Part 200 for familiarization. Policy templates will also be reviewed, and assistance will again be requested to develop/finalize the necessary policies in accordance with Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

2025-004 – Finding: Material Weakness in Internal Controls over Compliance: Cash Management Responsible official: Rose Braden, President Context and Cause: SEC did not document a separate review of cash draws by someone other than the party preparing and recording them. Recommendation: Management should establish and implement procedures requiring cash draws to be reviewed and approved by an authorized individual, independent of the cash draw preparation function. The review should be documented. Corrective Action Planned: SEC will update processes and policies. A documented review process will be added to the cash draw process. Implementation date: December 31, 2026

2025-003 – Finding: Material Weakness in Internal Controls over Compliance: Allowable Costs and Allowable Activities Responsible official: Rose Braden, President Context and Cause: SEC did not document a separate review of allowable costs and allowable activities for disbursements by someone other than the recording accountant. Recommendation: Management should establish and implement procedures requiring invoices to be reviewed and approved by an authorized individual, independent of the recording function, with knowledge of the requirements of the program. The review should be documented. Corrective Action Planned: SEC will update processes and policies. A documented review process will be added to the disbursement process. Implementation date: December 31, 2026

The reporting process for federal & state awarded funds will be reviewed with all parties involved in these funds.

FINDING 2025-006 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-677-3959 clane@vincennes.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All reports will be prepared by the clerk’s office and will be reviewed for errors and omissions by someone who is knowledgeable about the reporting requirements prior to submission. Anticipated Completion Date: The corrective action plan will be implemented by December 31, 2026.

FINDING 2025-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Allowable Costs/Cost Principles and Period of Performance Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-677-3959 clane@vincennes.in.gov Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The clerk’s office will work with the grant administrators and departments to assist in identifying non-compliant activities to ensure that funds are being used appropriately and according to the federal guidelines for the grant. We will consult with the relevant personnel to ensure understanding of allowable and disallowed costs as well as period of performance and help departments who may need additional training. Anticipated Completion Date: The corrective action plan will be implemented by December 31, 2026.

In 2026, written procedures governing the allowability of costs charged to Federal awards and procurement activities involving Federal funds were developed, documented, and implemented. Responsibility for implementing and maintaining these procedures has been assigned to the Finance Department. The procedures address applicable Federal requirements for determining allowable costs and procurement activities and will be reviewed periodically and updated as necessary to maintain compliance with applicable Federal requirements.

If we receive federal funds in the future, we will stay abreast of current and changing policies and procedures.

Management agrees with the finding. Management will spend additional time reviewing CFR Part 200 for familiarization. Policy templates will also be reviewed, and assistance will again be requested to develop/finalize the necessary policies in accordance with Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

The Authority concurs with the finding. Management acknowledges that Captial Fund Program Revenue and the related accounts receivable were recognized prior to HUD approval of the applicable Annual Statement/Budget. The Authority will adjust the financial records to properly reflect Capital Fund revenue and receivables based on the staus of HUD-approved funding. Management will implement procedures requiring verification and documentation of HUD approval of Capital Fund Program Annual Statements/Budgets prior to recording related grant receivables and revenue. Supporting documentation of HID approval will be maintained and reviewed as part of the year-end closing process to ensure that Capital Fund revenue and receivables are recognized only when the Authority has established entitlement to the funding. These procedures are intended to strengthen internal controls ove Capital Fund grand accounting and prevent a recurrence of the condition noted.

1. MISSING INVOICES During a change of fee accounts, invoices for January, February, & March 2025 were lost in mail. We now scan all invoices directly to accountant.

Planned Corrective Action: Summitview will reinforce the developed system for retaining all invoices, payment records, and supporting documentation associated with federal awards.

FA 2025-001 Improve Controls over Cash Management Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Repeat of Prior Vear Finding: Description: Cash Management Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education 84.371 C - Comprehensive Literacy Development S371C190016 None None The School District erroneously but unintentionally requested reimbursement twice for the same expenditures and received duplicate payments from GADOE that resulted in cash drawdowns in excess of immediate cash needs for the Comprehensive Literacy Development program. Corrective Action Plans: Prior to submitting grant drawdown and reimbursement requests in GAO RS/Grants application of the GA DOE portal, the Finance Director will review all documentation related to grant expenditures including but not limited to: budget reports, grant drawdown request sheets, YTD DE147s and grant payment advices. Grant budget managers will not submit payment requests in GAORS or the Grants application in the GA DOE portal prior to the Finance Director reviewing the requests. Cash in excess of immediate needs will not be requested from GA DOE. The Finance Director will review and monitor cash balances of grant funds monthly for excessive cash balances. In the event a grant fund has an excessive cash balance, the Finance Director will immediately initiate the process to ensure the funds wi ll be returned to the GA DOE promptly. Estimated Completion Date: Corrective action was completed at the sunset of the Comprehensive Literacy Development program in September of 2025. Contact Person: Dr. Andreana Jones, Superintendent Telephone: 706-986-0396 Email: ajones@)taliaferro.k12.ga.us

FINDING 2025-003 Finding Subject: Federal Award Findings and Questioned Costs Contact Person Responsible for Corrective Action: Sarah Rice Contact Phone Number and Email Address: 765-855-5515, srice@town.centerville.in.us Views of Responsible Officials: Option 1: “We concur with the finding.”  Drinking Water State Revolving Fund – Written Policies/Procedures to Determine Allowability of Costs using Federal Grant Funds- I will be getting in touch with our council president to make sure we come up with a policy on how to use federal funding with clear guidance on what costs are constituted as direct and indirect charges. Anticipated Completion Date: February 28, 2027 INDIANA

Management has reviewed the finding above and concurs. A corrective action plan addressing the deficiencies will be completed and submitted within 60 days of the report.

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2025-010: 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, 2026. 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 2025-006: 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, 2026. 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 2025-005: 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, 2026. 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.

The City concurs with this finding and will strengthen controls over federal award reporting by reviewing previously reported ARPA expenditures against the City’s accounting records and supporting documentation and submitting corrections, as necessary; implementing a documented quarterly reconciliation and independent review process requiring reports to be reviewed by an individual other than the preparer prior to submission; maintaining supporting documentation for expenditure allocations and classifications; establishing written procedures for federal award reporting; and providing additional training to staff responsible for grant reporting to help ensure compliance with federal reporting requirements.

FEMA Public Assistance Advances and Completed Reimbursement Management position. Management accepts the need to address the reported documentation and control deficiency. The original $666,000 and subsequent advances have been fully reimbursed to the Municipality’s FEMA fund; completed reimbursement is distinct from resolution of the historical finding. Management response. The original $666,000 was reimbursed in full to the Municipality’s FEMA fund bank account before the issuance of the Single Audit Report for the fiscal year ended June 30, 2025. The Municipality provided the supporting evidence of these reimbursements to the independent auditors for their review and examination before issuance of their report. The reimbursement occurred after June 30, 2025 and is reported as subsequent corrective action. No principal remains outstanding on these municipal interfund advances. The reimbursement evidence is available, upon request, for review and examination by the cognizant agency for audit, if designated, or the applicable oversight agency for audit; FEMA; COR3; and any other pertinent regulatory or oversight entity and its authorized representatives. Héctor Rubén Caraballo Díaz, Director of Finance, will coordinate timely access to the supporting records and municipal personnel under 2 CFR 200.337. The Municipality will protect sensitive information in public filings while providing authorized reviewers the records needed for their examination. The supporting package includes the municipal advance chronology, COR3 reimbursement and credit documentation, and the May 11, 2026 bank confirmation for a cash transfer to the FEMA account. Management’s full-repayment representation reflects the combined settlement of the advances and related credits. Management confirms that no principal remains outstanding for the original $666,000. Management’s representation of full reimbursement is not a representation that FEMA or COR3 has issued a final allowability or closeout determination. The transfer confirmation records approval and transmission; the resolution file will also retain evidence of the receiving-account posting and the reconciliation supporting the application of credits. These records substantiate completed repayment and preserve the distinction between settlement of principal and compliance with the original award conditions. Finding 2025-008 retains $666,000 in questioned costs for insufficient documentation of the final use and disposition of the original advance. Management’s reimbursement disclosure supplements that finding and does not depend on a change to its wording. Reimbursement does not retrospectively authorize the original use of restricted cash or automatically eliminate the historical finding. The responsible agency or pass-through entity will determine the disposition of questioned costs and any required remedy under 2 CFR 200.521. Management requests full consideration of the reimbursement evidence and appropriate credit for amounts already restored. Restoration to the municipal FEMA fund is not, by itself, repayment to the grantor or formal agency resolution. Corrective Action 1. Completed: reimburse the original $666,000, and provide the supporting evidence to the independent auditors for review and examination before report issuance. Preserve the evidence, dated transmittal, recipients, and index of documents provided. Delivery for examination is not represented as auditor agreement with management’s conclusions. 2. Complete the reviewed reconciliation of advances, COR3 credits, and the May reimbursement to bank and interfund records, and retain the separate tracing of the original use. Document credit eligibility, the source of legally available repayment funds, any excess, and the fiscal year 2026 entries. This reconciliation documents completed interfund settlement and the amounts for which management requests credit in agency resolution. 3. Preserve the posting of the May transfer in the receiving FEMA bank account, the reciprocal municipal ledger entries, and the dated delivery of the evidence to the auditors. For each COR3 credit applied, document the project, underlying eligible expenditure, original municipal funding, entitlement to reimbursement, and absence of duplicate recovery. A COR3 receipt by itself does not demonstrate repayment of an interfund advance. 4. Prohibit advances of FEMA cash for unrelated municipal operations. Permit an interfund reimbursement only after review establishes the specific award, eligible cost previously paid, lawful purpose, available support, and absence of duplicate reimbursement. 5. Retain a transaction-level account of the original $666,000 advance and its ultimate use, distinct from the later restoration. Identify the affected disaster and award, disbursements, eligible-cost support, and any unsupported use. Present the original questioned amount, amounts restored, any amount the agency sustains, and additional remedies separately; repayment will not be netted against the historical finding to imply that no reportable condition occurred. 6. Maintain monthly FEMA bank, project, interfund, and reimbursement reconciliations, with separate preparer and reviewer approval. Resolve exceptions promptly and retain the evidence supporting each release of funds. 7. Provide the reconciled resolution file to COR3 and request written disposition of Finding 2025-008 and its $666,000 questioned cost. Evaluate and address substantiated interest, grant repayment, accounting adjustments, or other remedies required by applicable rules or a written agency determination, preserving available review or appeal rights. Obtain instructions identifying the required recipient, award, amount, and credit for the completed restoration; do not assume that an interfund reimbursement extinguishes a separate grant repayment obligation. 8. Assess Federal cash balances, disbursement timing, and any applicable interest or excess-cash return requirement under the governing award and payment rules. Document the period and legal basis of any amount due rather than estimating interest without authority. The restoration will not be used to support duplicate Federal reimbursement or an unsupported new draw. 9. Keep the reimbursement evidence available for regulatory examination now. Submit the evidence already available to COR3 by September 30, 2026, identify supplemental reconciliation work due October 31, 2026, and complete the resolution submission by November 30, 2026 or any earlier agency deadline. Preserve the distinction between documents already delivered to the auditors and later supplements; do not describe subsequent workpapers as having been provided before report issuance. Implementation Milestones Required Action Owner Completion Evidence Target Date Reimburse original and subsequent advances to the FEMA fund. Finance Director Advance chronology, COR3 credits, May 11 transfer evidence Completed May 11, 2026 Provide reimbursement evidence to the independent auditors. Finance Director Evidence for review and examination; dated preissuance transmittal; regulatory access Completed before report issuance Approve transfer controls and reconcile the completed settlement. Finance Director Approved procedure, signed reconciliation, ledger support Sep. 30, 2026 controls; Oct. 31, 2026 reconciliation and tracing Provide available reimbursement evidence to COR3; complete resolution file and request written disposition. Finance and FEMA Program Staff / Resolution file, transmittal, agency correspondence Sep. 30, 2026 initial evidence; Nov. 30, 2026 complete file; decision external Demonstrate monthly preventive controls. Finance and FEMA Program Staff / Three consecutive reviewed monthly reconciliations Dec. 31, 2026 Responsible official. Héctor Rubén Caraballo Díaz, Director of Finance Anticipated completion. Principal reimbursement completed May 11, 2026; evidence delivered to the auditors before issuance. Documented preventive controls and three monthly reviews by December 31, 2026. Formal resolution of any retained questioned costs remains subject to COR3 or FEMA under 2 CFR 200.521. Evidence of completion. Retain evidence of full settlement of the original $666,000 and subsequent advances, the application of credits, reconciliation to the FEMA fund and municipal ledgers, and preissuance delivery to the auditors. Demonstrate preventive controls for three monthly cycles. Track any retained questioned cost and additional remedy until the responsible agency documents its disposition, with appropriate recognition of restored amounts. Auditor revision of the finding is not a closure condition.