Corrective Action Plans

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Finance Director Phone: (787) 788-0404 Original Finding Number: 2025-005 Statement of Concurrence or Nonconcurrence: We concur we the finding. Corrective Action: Adopted Measures • Expense Synchronization: A protocol will be implemented requiring contracted consultants to record and report incurred expenses only when a validated disbursement voucher is available, thereby ensuring the integrity of the financial flow. • Reconciliation: The office will conduct a detailed comparison between the draft quarterly report and the general ledger to identify and correct any discrepancies prior to final submission. • Compliance Timeline: An internal deadline will be established for the submission of the report, ensuring attainment of the minimum percentage required under the Quality Activities category through accurate financial data. Expected Outcome To ensure that all financial information submitted is complete, accurate, and fully aligned with the Municipality’s accounting records, thereby eliminating the risk of audit findings. Implementation Date: March 2026. Responsible persons: • Person responsible for the implementation: Mr. Carlos Flores, Federal Program’s Subdirector • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director

The organization has developed and implemented a standardized documentation process to ensure that all data submitted is fully supported and traceable to source documentation. Responsible staff have been trained to retain and reference appropriate supporting records for each data element prior to submission. A supervisory review step has been added to verify that documentation is complete, accurate, and clearly tied to the reported data before final submission.

The Senior Accounting and Finance Director and the Director of Operations have scheduled a weekly meeting to address training needs for front-line staff and to develop methods for monitoring data collection and ensuring accountability for data entry. Although procedures and training manuals were developed, staff turnover resulted in the processes and procedures not being consistently followed.

VIEWS OF RESPONSIBLE OFFICIALS Management reviewed the reporting process and identified that the discrepancy resulted from reliance on PMS drawdown and cash-basis payment activity rather than cumulative accrualbased expenditures recorded in SAP. Internal procedures have been revised to ensure that Line 10.e reflects total cumulative expenditure recorded on an accrual basis, consistent with the accounting records. Implemented or Planned Corrective Measures: 1. Management Action: The interim SF-425 for Grant 02TD0022301 was formally reviewed on February 11, 2026, corrected to properly reflect cumulative expenditures in Line 10.e, and resubmitted through the Payment Management System (PMS). 2. Management Meeting: On February 25, 2026, a formal meeting was held with the Fiscal Team, Program Director, Sub-Director, Budget/Fiscal Analyst, and Fiscal Consultant to review the finding and establish the enhanced corrective plan. 3. Corrective Measure Related to Root Cause: The reporting process has been revised to ensure that all SF-425 reports are prepared using cumulative accrual-based expenditure data directly extracted from SAP, consistent with accrual accounting principles and 2 CFR §200.302(b)(2). This enhancement strengthens internal controls over financial reporting in accordance with 2 CFR §200.303 4. Implementation of a formal reconciliation process between the general ledger (SAP), supporting expenditure reports, and the SF-425 prior to submission. 5. Comprehensive Preventive Review: Management initiated a comprehensive review of all SF-425 reports submitted from July 1, 2025, to the present. This review includes reconciliation of Lines 10.e and 10.f to SAP general ledger data to confirm compliance with accrual-based reporting standards. The review will be completed no later than March 30, 2026. Results will be formally documented in accordance with the Federal Reporting Procedures Manual and presented to the Governing Board at its meeting on March 30, 2026. 6. Structural Improvements Implemented: 1. Budget/Fiscal Analyst formally responsible for extracting cumulative data from SAP, preparing SF-425, and completing standardized reconciliation of Lines 10.e and 10.f. 2. Fiscal Consultant responsible for independent review, validation of compliance with 2 CFR §§200.302 and 200.303, certification, and submission in PMS. 3. Implementation of a standardized reconciliation worksheet. 4. Training for fiscal personnel scheduled for March 5, 2026, covering revised procedures and Uniform Guidance requirements. 7. Governance and Monitoring: • Adoption of the formal Federal Reporting Procedures Manual. • Establishment of an Annual Federal Reporting Calendar reviewed monthly. • Monitoring by the Sub-Director with documentation in fiscal meeting minutes. • Formal presentation of the audit finding and revised procedures to the Governing Board on March 30, 2026. 8. All corrective actions are expected to be fully implemented no later than March 30, 2026. IMPLEMENTATION DATE March 30, 2026 RESPONSIBLE PERSONS Margot Vélez Meléndez, Director of Head Start Program

Department: Defense, Veterans and Emergency Management Title: Internal control over DG – PA program financial reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will publish revised Federal financial reporting procedures. The Department will train relevant staff. The Department will implement new Federal Financial Reporting procedures with increased staff resource allocations. Completion Date: April 30, 2026, June 30, 2026, and July 1, 2026, respectively Agency Contact: Sunny Cyr, MEMA Business Office Director, DVEM, 207-707-2507

Department: Health and Human Services Administrative and Financial Services Title: Internal control over Foster Care and Adoption Assistance cash management needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS Financial Service Center will update the IV-E cash on hand analysis to ensure the cash balances are tracked separately by each of the following Title IV-E programs: Foster Care, Adoption Assistance, Prevention Program and Guardianship Assistance. Completion Date: March 31, 2026 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626

Department: Health and Human Services Administrative and Financial Services Judicial Branch Title: Internal control over Child Support Services expenditures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS and the Maine Judicial Branch will update the Cooperative Agreement to strengthen policies, procedures, and oversight in order to ensure that expenditures are based on actual costs. Completion Date: March 31, 2026 Agency Contact: Jerry Joy, Director, Division of Support Enforcement and Recovery, DHHS, 207- 624-6985

Department: Defense, Veterans and Emergency Management Title: Internal control over National Guard cash management and the related financial reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will improve policies and procedures to follow up on outstanding reimbursement requests to facilitate a more timely reimbursements from the Federal government. The Department will improve policies and procedures, including reconciling reimbursement activity to the State’s accounting system. The Department will improve and maintain effective internal control over Federal awards to provide reasonable assurance that the Department is managing awards in compliance with federal statutes, regulations and the terms and conditions of awards. The Department will review, update and document supervisory oversight. Completion Date: June 30, 2026 (first, second and third items), and May 30, 2026 (fourth item) Agency Contact: Diane Dunn, Commissioner, DVEM, 207- 430-5158

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2025-304: Grants to States for Medicaid – Medical Status Code Errors. This is the department’s Corrective Action Plan.  Recommendation (2025-304): Grants to States for Medicaid – Medical Status Code Errors. We recommend the Wisconsin Department of Health Services ensure the accuracy of the medical status code by: • Implementing and testing the needed updates to CARES to correct the errors in the assigned medical status code; • Completing an assessment of the effect of the identified errors in the medical status code on accounting entries, required federal reporting, and making any necessary corrections; and • Prepare and maintain documentation of its annual review and assessment. Wisconsin Department of Health Services Planned Corrective Action: The Division of Medicaid Services (DMS) identified issues with Medical Status codes prior to the beginning of the audit. DMS directed the Enrollment & Eligibility System vendor to identify and implement a system correction. Concurrently, the LAB identified the issue as part of their current year audit fieldwork. The correction was included in the February 2026 system update which is expected to address the concerns underlying this finding. Additionally, DMS will complete an assessment of potential effects on required federal reporting and make any adjustments. Anticipated Completion Date: June 30, 2026 Persons responsible for corrective action: Hannah Stephens, Section Manager Bureau of Fiscal Accountability and Management, Division of Medicaid Services, hannah.stephens@dhs.wisconsin.gov

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of the Treasury [2025-038] (Activities Allowed or Unallowed and Allowable Costs/Cost Principles) Coronavirus State and Local Fiscal Recovery Funds Assistance Listing: 21.027 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: Although significant progress has been made and the invoice in question was short-paid for unallowable charges, there was a mistake in a formula calculation which caused the contractor to be underpaid by $313. We will continue with our strengthened review process and verify the documentation as well as the formulas in the spreadsheet prior to reimbursement. Anticipated Completion Date: June 30, 2026 The contact persons responsible for corrective action: . Trey Reed, Director, Bureau of Business Management at 803-898- 3522 . Marshall Rock, Director, Facilities, Bureau of Business Management 803-898-3510

FINDING 2025-008 Finding Subject: COVID-19 - Education Stabilization Fund – Condition of Records Federal Agency: Department of Education Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls will be put in place to ensure all COVID 19 ESSER Funds are reported accurately to the State and Federal Department of Education. Reimbursements will be attached to State Email for disbursement. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

FINDING 2025-005 Finding Subject: Child Nutrition Cluster - Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service director responsibilities is to overseeing all function of the Food Management Company. Food Service Director will be required to draft internal controls and detail instruction for the school corporation to ensure all documentation procedures match the FSMC invoice. The school corporation will upgrade all POS software throughout the district. Students will be required to scan Student IDs to account for all meals served. Counts will be check weekly to ensure Federal report is accurate. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Jill VanDriessche Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. We believe this finding to be the result of an isolated incident that was reported to SBOA and Title. Description of Corrective Action Plan: The Business Manager/Treasurer provides to the corporation grant administrator monthly grant reports, as well as a grant tracking spreadsheet. The appropriations for each grant are entered into Komputrol, according to the budget located in the approved grant documents. The appropriations are presented to the Grant Administrator for approval. All spending from each grant is approved by the corporation grant administrator. Any wages paid via the corporation payroll that is charged to grant funds is approved by the business manager/treasurer and the corporation grant administrator. The Payroll Specialist/Deputy Treasurer completes the payroll and sends the distribution account records to the Business Manager/Treasurer and Grant Administrator. Any payroll claims for payment via grant funds is required to have three signatures for approval. We believe the system of internal control in place has been strong and in compliance since March 2025. Anticipated Completion Date: March 1, 2025 and ongoing

FINDING 2025-005 Finding Subject: Child Nutrition Cluster, Special Tests and Provisions, School Food Accounts Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke, Brittany Sabinas, Amanda Bender Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Since January 2025, the internal controls that resulted in this finding have been corrected. The finding stated that “The lack of internal controls and noncompliance over Special Tests and Principles, School Food Accounts is an isolated incident.” The Business Manager/Treasurer receives deposit emails from the Indiana State Comptroller. The Business Manager codes the deposit for the Accounts Payable Specialist to receipt. The Business Manager completes a monthly bank reconciliation that is reviewed by the Deputy Treasurer and Accounts Payable Specialist as part of the month end process. Anticipated Completion Date: January, 2025 and ongoing

FINDING 2025-004 Finding Subject: Child Nutrition Cluster, Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Amy Kraszyk Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Since January 2025, the internal controls that resulted in this finding have been corrected. The finding stated that “The lack of internal controls and noncompliance over Allowable Activities and Allowable Costs/Cost Principles is an isolated incident.” The Food Service Director and the Business Manager/Treasurer meet monthly to review the school lunch accounts and to concur with the month end balances. The Deputy Treasurer approves all monthly fund transfers completed by the Business Manager. Anticipated Completion Date: January 1, 2025 and ongoing

DEPARTMENT OF THE TREASURY Coronovirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend that the Town implement stronger internal controls over federal reporting, including establishing a formal reconciliation process between the general ledger and the Project and Expenditure Report, requiring Town Administrator's review and approval of all federal reports prior to submission, and providing additional training to staff on Federal reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will strengthen its reconciliation procedures requiring the Director of Finance to reconcile all federal expenditures reported in the Project and Expenditure report to the general ledger. Name of the contact person responsible for corrective action: Kelly Baldwin, Director of Finance Planned completion date for corrective action plan: April 1, 2026.

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Ronaldo Ortiz Velázquez, Mayor Contact Person: Mrs. Eunice Díaz, Finance and Budget Director Phone: (787)738-3211 Original Finding Number: 2025-004 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: During the testing of reports, the Quarterly Progress Reports of five (5) projects, corresponding to two (2) quarters of fiscal year 2024-2025, were evaluated. It was found that in two (2) projects, the quarterly reports did not match the accounting records or the project documentation. Therefore, for the purposes of this audit, the municipal accounting controls and procedures did not ensure that the reported information was accurate, up-to-date, and fully reconciled with the financial records. In light of the above, the reports will be reconciled with the accounting records, and the discrepancies found will be identified, documented, and adjusted in the system where the error originated, as appropriate. Furthermore, from this point forward, once the Quarterly Reports (QPR) are issued, a copy must be sent to the Program Accountant, the Finance Director, and myself for validation and reconciliation prior to official filing, thus preventing situations like this to occur. This process will form part of the internal control required to ensure that the reported information is accurate, current, complete, and consistent with the accounting records, in accordance with applicable federal requirements. Implementation Date: From March 2026. Full implementation is expected in fiscal year 2026-2027. Responsible Person: Mrs. Natasha Vázquez Federal Programs Director

Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program including implementation of formal policies, reconciliation procedures, and enhanced oversight of interfund activity to ensure that established internal control policies are being followed on a timely basis. Steve Arlinghaus, Executive Director, is responsible for implementing this corrective action by June 30, 2026.

Corrective Action Plan - Federal Award Finding Finding 2025-001 Federal Agency Name: US DOT, Federal Railroad Administration Assistance Listing: 20.325 Program Name: Consolidated Rail Infrastructure and Safety Improvements (CRISI) Initial Year Finding Occurred: Fiscal Year 2025 Reporting Finding Summary: The auditor identified an instance in which one quarterly SF-425 (report) did not reflect cumulative federal cash receipts and disbursements as required by the reporting instructions. Instead, the report reflected only the current quarter's ended federal cash activity. No additional reporting errors were identified by the audit, and the other reporting lines were prepared correctly. Auditor’s Recommendation: The auditor recommends that management continue to strengthen review procedures over SF-425 preparation, including documented review of cumulative cash reporting and verification of all report attributes, particularly during periods when backup personnel are responsible for report preparation. Management’s Response: Management concurs that an error occurred on one SF-425 report for a single reporting period. The error occurred during a sta􀆯ing transition and involved a field that FRA does not require, and that had not historically been populated. Additionally, FRA and FTA use the same SF-425 form but apply di􀆯erent reporting conventions; FTA requires the field to be reported quarterly rather than cumulatively, which contributed to the confusion. As noted in the audit finding, this was a reporting error only. There were no questioned costs, no billing inaccuracies, and no impact on the underlying financial activity. Corrective Action: Management has implemented the following actions to prevent recurrence: • Updated internal procedures to clearly distinguish FRA and FTA reporting requirements. • Implemented a two-step review process in which one sta􀆯 member prepares all federal financial reports and a second sta􀆯 member performs an independent review prior to submission. • Expanded procedure on reporting when primary sta􀆯 are unavailable, including cross training and adding backup for both reporting and review. These actions strengthen internal controls, ensure consistency across federal reporting, and reduce the risk of future reporting discrepancies. Responsible Individual: Heather McKillop, Chief Financial O􀆯icer Anticipated Completion Date: March 2026

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2025 FINDING NUMBER 2025-004 U.S. DEPARTMENT OF HOMELAND SECURITY DISASTER GRANTS – PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) (ALN 97.036) PASS-THROUGH AGENCY CENTRAL OFFICE OF RECOVERY, RECONSTRUCTION AND RESILIENCY OF PUERTO RICO (COR3) FEDERAL EMERGENCY MANAGEMENT AGENCY (FEMA) REPORTING (L) SIGNIFICANT DEFICIENCY (SD) / NONCOMPLIANCE (NC) Corrective Action: The Municipality acknowledges the differences identified between the expenses reported in the Quarterly Progress Reports (QPRs) and the accounting records. To address this issue, the Municipality will implement a reconciliation process between the accounting records and the QPRs prior to their submission to the pass-through entity. Additionally, management will perform a supervisory review to ensure that the reported expenses agree with the accounting records and supporting documentation. Statement of Concurrence and Responsible Person: We concur with the auditors’ finding. Miguel Fonseca Federal Programs Director Implementation Date: Fiscal year 2026-2027

Corrective Action: Before any expenditure is obligated, all revisions/amendments will be approved in MCAPS first. The business Manager, Federal Programs Director, and Superintendentwill ensure MDE's approval is tangible before any obligations. We will implement a tool that allows this process to be measured daily. Responsible Parties: Avery Johnson, Business Manager Tiffany Willis, Federal Programs Director Corrective Action Start Date: February 18, 2026

Corrective action plan: HHSC has taken steps to improve the consistency and reliability of financial reporting related to Maintenance of Effort (MOE) expenditures, specifically, amounts reported on the ACF 204, submitted by HHSC Budget and the ACF 196R, submitted by HHSC Federal Reporting (FR). To address potential discrepancies and strengthen internal controls, HHSC Federal Reporting has implemented and documented a formal reconciliation process. This process involves the following key components: • Implementation and documentation of a formal reconciliation process that compares all MOE expenditures for HHSC, TEA, and TWC reported on the ACF 204 to those reported on the ACF 196R before report submission. The process outlines specific steps for data cross-referencing and validation to ensure completeness and accuracy. • Research, resolve, and correct any discrepancies identified during the reconciliation process before the reports are finalized and submitted for management review. • Reinforcement of management review and documentation of the reconciliation between the ACF-204 and ACF-196R will be incorporated into the approval process prior to report certification. Implementation date: February 28, 2026 Responsible person: Alan Flynn, Manager, Federal Reporting

The City will review the requirements for written policies and will adopt policies, as needed, or will revise its current policies as needed to comply with Uniform Guidance.

We have a multi-pronged action plan. We will clarify and review our accounting policies and procedures regarding payroll allocations with staff; We will create a more thorough documentation process of the basis for each allocation; We will review the assumptions used for allocations during the year and update them (as needed); We will include regular monitoring and review of payroll allocations.

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Corrective Action Plan: As of the reporting period ended December 31, 2025, changes requested by agencies to obligations or expenditures have been updated. DAS will obtain, or expand where possible, the written justification for capital expenditures over $10 million for the projects identified. Contact: Philip Olsen Anticipated Completion Date: January 31, 2026