Corrective Action Plans

WHPCA has hired a third-party accountant as well as implemented additional monitoring and review and approval procedures to strengthen its financial management.

WHPCA has hired a third-party accountant as well as implemented additional monitoring and review and approval procedures to strengthen its financial management.

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported on the Year 3 report ($572,289) did not agree to the underlying expenditure records ($558,956) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER I, ESSER II, and ESSER III amounts reported on the Year 4 report ($105,506, $510,158, and $1,156,254, respectively) did not agree to the underlying expenditure records ($138,662, $316,236, and $1,158,054, respectively) for the period of July 1, 2022 through June 30, 2023. Contact Person Responsible for Corrective Action: David Rowe, Business Manager Contact Phone Number: 765-298-6505 Views of Responsible Official: We concur with the finding, while noting that all expenditures and revenue from reimbursements balance within our system. Description of Corrective Action Plan: Verify that all expenditure account numbers match those utilized by AFR and Gateway reporting. Anticipated Completion Date: Begin immediately, ongoing.

2024-002 Filing of Federal Financial Reports Federal Departments: Department of Justice, Office on Violence Against Women Assistance Listing #: 16.526 Compliance and Internal Controls Significant Deficiency Category of Finding – Reporting Name of contact person: Vivian Huelgo, President and CEO Corrective Action: Esperanza has assigned the contract accountant to be responsible for preparing these reports and implemented review processes to ensure these reports are accurate. Completion Date: The Organization has already adopted this corrective action.

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($397,392 and $294,138, respectively) did not agree to the underlying expenditure records ($498,259 and $1,509,413, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II and ESSER III amounts reported on the Year 4 report ($400,501 and $294,129, respectively) did not agree to the underlying expenditure records ($412,324 and $287,065, respectively, for the period of July 1, 2022 through June 30, 2023). We noted that the 195 number of Full-time equivalent (FTE) positions on September 30, 2023 on the second report did not agree to the underlying records supporting number of 274 Full-time equivalent (FTE) positions on September 30, 2023. Contact Person Responsible for Corrective Action: Dawn Ray Contact Phone Number: 812.988.6601 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will have someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Anticipated Completion Date: Immediately upon the completion of the audit.

The Corporation will have a secondary review process in place to assure the information and timeline are correct before submission.

Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($347,591 and $337,851 respectively) did not agree to the underlying expenditure records ($135,355 and $159,811 respectively). Additionally, we noted that the ESSER II amount reported on the Year 4 report ($233,093) did not agree to the underlying expenditure records ($267,310) of the School Corporation. Contact Person Responsible for Corrective Action: Vicki Jones Contact Phone Number: 765-793-4877 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Annual report data will be submitted with the requested information and will be verified with a sign-off by the Superintendent. Anticipated Completion Date: July 2025

Finding Number: 2024-004 Condition: The College does not have a written cash management policy related to federal awards. Planned Corrective Action: In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards in order to implement the requirements of 200.305. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: As soon as possible moving forward starting December 18, 2024.

As part of the 2023-2024 FY audit, there was a finding of non-compliance on financial reporting for a late filing. The corrective action plan is to implement new policies to ensure timely financial compliance with all grant requirements. For questions, please contact Katie Harris, the Director of Finance. The board plans to enact these new policies as of June 30th, 2025.

In response to the findings on the andit of federal programs the district will implement the following: Each month when reporting our financials all federal grant accounts will be separated and will be reviewed for accuracy and to insure proper project codes are correct also expenditures for 1 % professional development will be reviewed for accuracy. All payment request for federal fund grants will be approved prior to submission by the Superintendent. Ann Wallace will provide this listing to the Superintendent for approval each month. Corrective Action Plan has been implemented July 25, 2024.

December 27, 2024 Finding Number: 2024-004 Material Weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) (Workforce Innovation and Opportunity Act- WIOA) Finding Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Planned Corrective Action: The Consortium has carefully reviewed our policies and procedures and have made the necessary changes to ensure that cash draws are based on expenditures already incurred and that they are supported by transactions recorded in the general ledger. Cash draws continue to be “necessary and reasonable”. We strive to improve the timing of our cash draws, our grant reconciliations and to continually monitor our cash management to ultimately eliminate this issue. Responsible Contact Person: Shamar Herron (Executive Director) Sherron@mwse.org Anticipated Completion Date: March 2025 Respectfully, Shamar Herron

December 27, 2024 Finding Number: 2024-003 Material Weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) (Wagner Peyser) Finding Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Planned Corrective Action: The Consortium has carefully reviewed our policies and procedures and have made the necessary changes to ensure that cash draws are based on expenditures already incurred and that they are supported by transactions recorded in the general ledger. Cash draws continue to be “necessary and reasonable”. We strive to improve the timing of our cash draws, our grant reconciliations and to continually monitor our cash management to ultimately eliminate this issue. Responsible Contact Person: Shamar Herron (Executive Director) Sherron@mwse.org Anticipated Completion Date: March 2025 Respectfully, Shamar Herron

All funds have been refunded to state agency and expense reports amended appropriately.

CORRECTIVE ACTION PLAN October 23, 2024 Kansas State Department of Education and Kansas State Department of Administration Unified School District Number 374 respectfully submits the following corrective action plan for the year ended June 30, 2024. Medill & Thooft, CPA Po Box 885 Ulysses, KS 67880 Audit Period: June 30, 2024 FINDINGS – FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Education Stabilization Fund Cluster Federal Assistance Listing Numbers: 84.425U Finding 2024-001 Recommendations: The District should have an employee compare the Board Clerk’s supporting documentation and the Education Stabilization Fund spreadsheet report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the report submitted should be printed, initialed by the secondary reviewer, stapled with the information used to compile the report and combined with all financial records for the fiscal year. Action Taken: We agree with the recommendation. Our targeted implementation date is November 2024. If the Kansas State Department of Education and/or Kansas State Department of Administration has questions regarding this plan, please call Rex Richardson at 620-675-2277. Sincerely yours, Rex Richardson Superintendent

Corrective Action: Management will continue to stress the importance of following the detailed procedures for preparation and review of the SEFA. The SEFA checklist is updated to include a thorough review of expenditure details to ensure no prior-year expenses are reported. Responsibility for compiling the SEFA was assigned to a Senior Program Accounting Manager who is tasked with assuring the schedule and all the support reconciliation are complete and accurate. Both the Director of Program Accounting and the Executive Director of Finance/Controller will review the SEFA for completeness, accuracy, and compliance with CFR Section §200.510(b). Estimated completion date: June 30, 2025 Individual Responsible for Corrective Action Plan: Contact: Reginald Gregory Title: Executive Director/Controller Phone Number: 202-772-4300

FINDINGS- MAJOR FEDERAL AWARD PROGRAMS Material Weakness U.S. DEPARTMENT OF EDUCATION- 2023 Elementary and Secondary School Emergency Relief Fund- AL Number 84.425 Finding No.: 2024-006 Condition: The District did not maintain records that contain information necessary to identify Federal expenditures supported by source documentation. Recommendation: The District should always maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal expenditures. All records must be supported by source documentation. Action Taken: The District concurs with the recommendation. The District will work to ensure that records are maintained that sufficiently identify the amount, source and expenditure of Federal funds for Federal awards. Grant expenditure reports will be reviewed to make sure Federal award expenditures are not double-reported. Anticipated Date of Completion: Ongoing

FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School District in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in 2 place to prevent, or detect and correct, errors. During tie out of the Year 3 report, a variance between the underlying records and reported expenditures of $187,649 was noted due to the lack of effective controls surrounding annual data reporting. 84.425U expenditures submitted within the Year 3 report were overstated by $187,649. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will implement a formal review process over data reporting to ensure compliance with reporting requirements for federal awards. A Grant Coordinator has been hired and is already in place. Both the Grant Coordinator and Treasurer will review and sign off of required reporting and ensure it is completed in a timely manner. Responsible Party and Timeline for Completion: Andrew Grismore - Grant Coordinator and Moriah Crane - Treasurer will be responsible. These corrective measures are already in place.

Corrective Action Plan: AlaHA will accomplish the following: 1) Send guidance to hospital systems with multiple facilities reported on their 941s that they should retain general ledger detail reconciliations to support the funds received. 2) Request the hospital involved in the exception cited for not having submitted general ledger evidence submit additional support for the reconciliation they submitted. 3) Should a similar tranche of funds become available in the future, AlaHA will ensure disbursements are not made before receipt of general ledger evidence to support the amount reported by the hospital. Target Date: For items 1 & 2 in the corrective action plan, November 6, 2023.

Corrective Action Plan: The District has developed and implemented a Federal Funds Manual. Anticipated Corrective Action Plan Completion Date: November 18, 2024 Contact Information: For additional information regarding this finding please contact Blaise Paul, Chief Business & Finance Officer, at 414-768-6140.

CORRECTIVE ACTION PLAN 2024-002 – Written Policies Required by Uniform Grant Guidance Corrective Action: Institute a formal grant policy in accordance with Uniform Grant Guidance. Responsible Party: Finance Director Date to Complete By: 1-31-25

Carl Biber Chief Financial Officer 317 Western Boulevard Jacksonville, North Carolina 28546 Anticipated Completion Date: June 30, 2025 Annually, the Authority will perform additional verifications of the completeness of the Schedule of Expenditures of Federal awards by confirming directly with the mortgagee the balance as of year-end and activity for the year then ended.

Action Taken in Response to Finding: In 2023, invoices were submitted using a format aligned with initial guidance from the Colorado Department of Human Services (CDHS), reflecting a per-learner, activity-based approach. Beginning in October 2024, updated guidance required invoices to be based on actual costs incurred, supported by documentation such as timesheets and receipts. As of October 2025, CDHS no longer required supporting documentation at the time of submission; however, supporting documentation continues to be maintained and is provided upon request for monitoring or audit purposes. Standardized Excel-based tools provided by CDHS are utilized for reimbursement submission (Invoice and Ledger). Transaction-level cost tracking was implemented to ensure allowable and eligible costs are recorded and supported. Financial and grant-related policies were standardized and incorporated into Financial Policies and Procedures in May 2024, with a comprehensive grant management framework implemented in May 2026. Control Enhancement: Beginning in 2025, all grant-related expenditures are recorded and tracked at the transaction level within the accounting system. Each transaction must include appropriate supporting documentation and be coded to the correct funding source. A standardized payroll-to-invoice reconciliation process has been implemented to ensure that all costs charged to federal awards are allowable, allocable, and properly supported. Monitoring & Review: • Costs are reviewed by the Senior Accountant prior to inclusion in reimbursement requests • A secondary monthly review is performed by the Director of Finance & Operations to validate allowability, completeness, and alignment with funding requirements • Exceptions are documented and resolved prior to submission Testing & Validation: • Beginning in June 2026, quarterly internal reviews will be conducted to test a sample of transactions for compliance with documentation and allowability requirements • Results will be documented and tracked, and any identified deficiencies will require corrective action Documentation & Evidence: • Supporting documentation is maintained in Microsoft Teams / SharePoint • Review and approval are evidenced via email approval and retained as part of the audit record Control Owner(s): • Director of Finance & Operations • Finance Team Responsible Party: Helen Young Hayes, Founder / Chief Executive Officer, in coordination with the Finance Staff Anticipated Completion Date: All corrective actions will be implemented as of June 30, 2026. Ongoing monitoring, quarterly testing, and policy updates will continue.

August 20, 2026 To: Clausell & Associates, P.C. From: Mary Harrison, Executive Director of CSRA Economic Opportunity Authority, Inc. Below is the Authority’s corrective action plan as it relates to the findings for the fiscal year ending September 30, 2023, Single Audit Act audit. Comment #2023-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED GENERAL Views of Responsible Officials and Planned Corrective Actions: We concur with this finding. Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Authority’s financial funding sources, the Authority will require additional specialize training for fiscal staff and improve in the segregation of duties to ensure adequate internal controls are fully implemented. The Executive Director 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 Executive Director will take the lead in financial reporting to ensure that all reporting meet GAAP and GAS requirements and to provide informative reports for Board and Management. All enhancements will be implemented by September 30, 2026. Concerning the preparation of external reports required by various funding sources (i.e., SF-425, DHS’s reports for LIHEAP, etc.), the Authority 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 September 30, 2026 Responsible Person: Mary Harrison, Executive Director, will be responsible for the corrective action. Comment #2023-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND SUPPORTIVE SERVICES FOR VETERAN FAMILIES PROGRAM FAL # 93.600 AND 64.003 (Questioned Costs - None) 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 grant accounting, 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 September 30, 2026. See also the response to Comment #2023-001. Implementation Date: The plan correction date will be completed no later than September 30, 2026. Responsible Person: Mary Harrison, Executive Director, will be responsible for the corrective action.

Item 2023.006 – Cash Management Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding Yes Action Taken Island Health Care will take the following actions to address this recommendation: • Prepare written procedures to document the process for Drawdown requests, including the initial review, documented approval process, submission to the funding agency, and the recording of the drawdown in the accounting system immediately after submission • Maintain detailed records of all drawdown requests, supporting documentation, approvals, and correspondence • Conduct regular internal reviews of drawdown activities to ensure compliance with procedures and maintain audit trail • Review drawdown procedures annually to ensure they remain current with funding agency guidelines and best practices

Reporting Recommendation: We recommend that the auditee implement procedures to ensure that Form 19-lA reimbursement requests are reviewed prior to submission to confirm that expenditures are charged to the correct approved budget line items. This may include maintaining a reconciliation between the general ledger, the approved grant budget, and the Form 19-lA, as well as implementing supervisory review and approval of reimbursement submissions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. 2026 Action taken in response to finding: Reoccurring bills such as utilities, loan payments, contract services and credit card payments do not require an expense request to be included for on going bills. We will review our procedures and update our financial policy. 2023 Our financial process includes at least two reviews prior to creating a bill in our accounting system, payments are reviewed by the director or the Deputy Director when signed. We do not use a auto signature all checks are reviewed. 2023 The Grantor billing is a P&L detailed report for that grant and provides reconciliation monthly This is sorted into grant line items designated billable and non-billable for compliance. Total program cost and billable to grant are tracked every month, by the grant finance manager for compliance prior to billing any grants. Timecards are reviewed, expense requests are reviewed and payments are reviewed. Prior to submission of the invoice to grantor. 2023 Grant finance manager pulls copy of timecards, bills and checks to ensure compliance with reimbursements are accurate. Name(s) of the contact person(s) responsible for corrective action: Cora Alyea Planned completion date for corrective action plan: July 2023