Corrective Action Plans

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.

Finding 2023-004 Inadequate Internal Control over Federal Grant Reporting and Record Retention Federal award: Assistance Listing No. 21.027, Coronavirus State and Local Fiscal Recovery Funds Auditor Description of Condition and Effect During the audit, we noted that the Organization had not established and implemented sufficient controls over the preparation, review, submission, and retention of required federal grant reports. Specifically, the Organization could not provide sufficient documentation demonstrating that: • Financial and programmatic information in required reports was reconciled to the underlying accounting and project records; • All applicable reporting elements, including capital expenditures and contractor or subaward information, were evaluated for completeness; • Reports were reviewed and approved by appropriate personnel before certification and submission; • Reports were submitted by the applicable deadlines and evidence of submission was retained; and • Corrections or resubmissions were appropriately documented and supported. The absence of appropriately designed and implemented controls creates a reasonable possibility that materially inaccurate, incomplete, or untimely reports could be submitted, or that material noncompliance with federal reporting and record-retention requirements could occur and not be prevented, or detected and corrected, on a timely basis. Insufficient records may also prevent the Organization from substantiating reported information or demonstrating compliance during an audit, monitoring review, or other oversight. Auditor Recommendation Management should adopt written federal grant reporting procedures and implement a standardized process for preparing, reconciling, reviewing, approving, submitting, and retaining required reports. The process should address all applicable financial and programmatic reporting elements, including capital expenditures and contractor or subaward information, and should require retention of the reports, submission confirmations, supporting records, and documentation of any corrections or resubmissions for the period required by the award. Proposed Corrective Action The Organization agrees with the finding. Management will adopt written federal grant reporting and record-retention procedures, maintain a reporting calendar, and assign responsibility for preparation and review. Reported financial and programmatic information will be reconciled to the underlying accounting and project records, and a standardized checklist will be used to evaluate all applicable reporting elements. Management will document review and approval, retain evidence of timely submission, and maintain the reports, supporting records, and documentation of corrections or resubmissions in a centralized grant file for the retention period required by the award. Responsible Person: Anticipated Completion Date: June 30, 2027

Finding #2023-003: Management has not established a written cost allocation plan or policy as required by Uniform Guidance. Specifically, the Organization lacks documented procedures that define direct and indirect costs, describe how costs will be identified and classified, outline the methodology used to allocate indirect costs among active federal awards, and address the application of the 10% de minimis indirect cost rate. As a result, there is no formal framework to support the consistent allocation of costs to federal programs or to demonstrate compliance with federal requirements. Response: Management acknowledges and accepts the finding and recommendation. Management will work to ensure a proper written cost allocation policy as required by the Uniform Guidance is established by December 31, 2026.

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

2023-012-Subrecipient Monitoring Suggested Action: Enhanced contractual requirements that ensure greater subrecipient monitoring around greater support for any requests or assertions from our subrecipients. Responsible Official: Chief Operations Officer Completion Date: 6/30/2026

VIEWS OF RESPONSIBLE OFFICIALS In response to the single audit finding we will take the following actions. We will establish internal controls that provide certainty, effective monitoring data validation and accountability for those employees who approved expenditures. We will prepare written process in accordance with both state and federal regulations. We will prepare written process in accordance with both state and federal regulations. We will require relevant staff (Staff interacting with procurement, expenditures approval) a comprehensive training program on the requirements of CFR 200. IMPLEMENTATION DATE September 30, 2026 RESPONSIBLE PERSON Ivan Rentas, President

2023-012 Financial Statement Reconciliations/Tie-In Procedures Material Weakness Recommendation: The Housing Authority should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. These policies should require timely reconciliations to take place as defined under policy. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

Cash Management The College acknowledges the finding and will enhance its cash management practices by developing formal procedures outlining responsibilities, authorization requirements, and timelines related to federal drawdown and disbursements. In addition, the College will implement routine reconciliations of drawdown activity against recorded expenditures on a monthly or quarterly basis to improve monitoring and ensure compliance with federal requirements.

Recommendation We recommend that management: ▪ Implement procedures requiring complete supporting documentation for all costs charged to federal awards ▪ Ensure costs are reviewed for allowability, reasonableness, and allocability prior to recording ▪ Establish and document formal cost allocation methodologies ▪ Require approval and documentation of all journal entries affecting federal programs ▪ Provide training to staff on Uniform Guidance cost principles (2 CFR 200 Subpart E) ▪ Conduct periodic internal reviews to ensure compliance

"Recommendation We recommend that management: ▪ Implement formal procedures to ensure complete documentation of all program activities ▪ Maintain records demonstrating that activities are authorized and aligned with program objectives ▪ Establish centralized recordkeeping and retention policies ▪ Perform ongoing monitoring and review of program activities ▪ Train staff on federal compliance requirements and documentation expectations"

The City of Cascade Locks has an allowable cost procedure that was approved by Council on March 26, 2026. The City Administrator is responsible for adhering to this policy.

CORRECTIVE ACTION PLAN (Concerning Finding 2023-006) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Town Manager and Select Board will take the following actions to address finding 2023-006 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted, had approved and has implemented the new Internal Controls Policy that addresses this deficiency. This policy will includes sections on risk assessment and management, annual audit, chart of account, general ledger, reconciliation and verification, reserve funds and reserve accounts, investments, financial reporting, fraud, accounting software, online transactions and banking, documentation daily cash-ups, grants and projects, AR process, AP process, and payroll. Anticipated Completion Date: This was completed February 20, 2024.

Corrective Action Plan: Addressing Lack of Controls Due to Staffing Shortages Organization: Safe Harbor Crisis Center Date: December 3, 2025 Audit Finding: 2023-001 Non-Material Non-Compliance – Allowable Costs and Activities Corrective Actions: This plan outlines the steps to address the staffing shortage and implement necessary controls to ensure financial statement accuracy and compliance. Phase 1: Immediate Actions Prioritize Key Hires: The immediate priority is to recruit and hire a Controller with significant non-profit accounting experience. This individual will be crucial in designing and implementing the necessary internal controls. 1. Interim Support (If Needed): While searching for permanent staff, explore options for interim accounting support through a consulting firm or temporary staffing agency specializing in non-profit organizations. This can provide immediate assistance with critical tasks and help bridge the gap until permanent staff are in place and sufficiently trained. 2. Documented Job Descriptions: Develop detailed job descriptions for the Controller, Senior Accountant, and Staff Accountant positions. These descriptions should clearly outline the required qualifications, responsibilities, and reporting lines. Emphasis should be placed on experience with non-profit accounting principles (GAAP), fund accounting, and relevant regulations. 3. Recruitment Strategy: Implement a robust recruitment strategy that includes: ○ Posting job openings on relevant job boards (e.g., Idealist, LinkedIn, specialized non-profit job sites). ○ Networking with professional organizations (e.g., state non-profit associations, accounting professional groups). ○ Partnering with recruitment agencies specializing in non-profit finance. Phase 2: Staffing and Implementation 1. Hire Controller: Complete the recruitment process and hire a qualified Controller with proven non-profit accounting experience. 2. Hire Senior Accountant: Once the Controller is in place, begin the recruitment process for a Senior Accountant to support the Controller and manage day-to-day accounting operations. Experience with fund accounting and grant management is highly desirable. 3. Hire Staff Accountants: Recruit and hire the necessary number of Staff Accountants to handle transaction processing, reconciliations, and other accounting tasks. 4. Control Design and Implementation: The Controller, in collaboration with the Senior Accountant, will be responsible for designing and implementing the necessary internal controls. This includes: ○ Segregation of duties (e.g., authorization, custody, recording). ○ Approval processes for expenditures and journal entries. ○ Regular reconciliations of bank accounts and other key accounts. ○ Documentation of accounting policies and procedures. Phase 3: Review and Monitoring (Ongoing) 1. Training: Provide comprehensive training to all finance staff on non-profit accounting principles, internal controls, and the organization's specific policies and procedures. 2. External Review (Optional): Consider engaging an external accounting firm to review the implemented controls and provide recommendations for improvement. This can provide an independent assessment of the effectiveness of the controls. 3. Regular Monitoring: The Controller will be responsible for regularly monitoring the effectiveness of the internal controls and reporting any deficiencies to the Executive Director and the Board of Directors. 4. Policy Updates: The Controller will ensure that accounting policies and procedures are reviewed and updated regularly to reflect changes in regulations and best practices. Responsible Parties: ● Executive Director (Todd Hixson) : Overall responsibility for implementation of the plan. ● Board of Directors: Oversight and approval of the plan and budget. ● Controller: Responsible for designing, implementing, and monitoring internal controls. Timeline: Phases 1 and 2 were completed as of January 2025. As noted above, phase 3 is an ongoing process. Regular progress updates have been and will continue to be provided to the Executive Director, Finance Steering Committee, and the Board of Directors as appropriate. This Corrective Action Plan demonstrates Safe Harbor Crisis Center’s commitment to addressing the identified control deficiencies and strengthening its financial management practices. By implementing this plan, the agency will be better positioned to ensure financial accountability, transparency, and compliance in service of the mission.

2023-005 Indirect Cost Rate Agreement (NICRA) Recommendation: Auditors recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed. Specifically, auditors recommend that CIES modify internal controls to include a review and approval process for submission of all invoices submitted to grantors, including showing the indirect cost rate calculations. Criteria: 2 CFR 200.414(c) – Federal award recipients must negotiate an indirect cost rate with the cognizant agency for indirect costs, which is typically the federal agency that provides the most funding to the recipient. 2 CFR 200.403(d) – The negotiated rate must be applied consistently across all federal awards to ensure uniformity in cost allocation. 2 CFR 200.302(b)(3) – Recipients must maintain adequate documentation to support indirect costs charged to federal awards, ensuring compliance with the cost principles outlined in the regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Project invoices will be prepared by a member of the CIES administrative staff with enough details to show direct and indirect cost rate calculations. Invoices will be reviewed and approved by either the Chief Operations Officer or the Executive Director. Review and Signature approvals will be added to all invoices to meet the criteria identified in this finding. Name(s) of the contact person(s) responsible for corrective action: Michael Parker, Executive Director Planned completion date for corrective action plan: April 2026

FINDING 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Required IDOE templates (JotForm) are completed using AS400 budget detail reports and Position Control data, with revisions submitted during the September window to correct classifications and remove ineligible set-aside amounts. Adjustments were made to align ESSER I reporting and to avoid timing discrepancies by using budget detail rather than summary reports. The completed report will be reviewed for accuracy and approved prior to submission. Beginning in fall 2023, the reimbursement process was updated to include all required supporting documentation, such as transaction detail and summary reports. Each request is also reviewed and signed by the supervisor to document approval. On a recurring basis, the Director of Federal Grants generates the detailed expenditure report and budget summary. The detailed report is filtered to capture only the transactions occurring since the previous reimbursement request, making new expenditures easy to identify. These amounts are added to the cumulative reimbursement totals, which are then compared to the total disbursements shown on the summary report to ensure they align. Once the totals match, the reimbursement request is reviewed by the Chief Financial Officer and submitted to the awarding agency. Completion Date 6/30/25