Corrective Action Plans

Community Development Block Grants Cluster Entitlements/Special Purpose – Assistance Listing No. 14.218 Recommendation: It is recommended the County modify its procedure to include: • Improve reconciliation procedures to verify hours per pay period recorded in quarterly spreadsheet agrees to hours recorded in the KRONOS system. • Record grant wages using the pay rate at the beginning of the quarter if recorded on a quarterly basis or use pay rates for each pay period if recorded on a pay period basis. Explanation of disagreement with audit finding: Management concurs with the auditor’s recommendations. Action taken in response to finding: • Document the audit process in a formalized SOP and cross train all reviewers from SRGA Admin, Budget, and Fiscal. • Create a checklist to accompany each personnel draw to ensure that after rates are verified that SRGA Admin certify that no RPAs or pay adjustments were approved during the pay periods reported and if there were, a second pay rate is entered for that draw and hours are split according to accurate rates/dates. • Document the cure process in the SOP to ensure that any errors found after the fact will be corrected with HUD to remain compliant and to ensure that no funds drawn in error are retained. • Include a date verification process prior to submission of the draw to ensure that staff did not duplicate any dates. This verification will be an audit of the Time Tracking Review completed by Admin staff. Ongoing training and coaching will be administered should duplicate entries be found on final draw reports. • Audit of all personnel draws for both allocations of CDBG-DR grants will be completed using the new SOP and verification tools before the end of FY2026. Name of the contact person responsible for corrective action: Nicole Turner, Director Planned completion date for corrective action plan: The above action plan will be implemented immediately; an audit of all personnel draws will be conducted using new process and checklists by the end of FY2026.

Description of Finding: Management should develop written procedures as required by 2 CFR Part 200.302(b)(7) Management Response: Management of Homer Electric Association concurs with the auditors’ finding regarding the absence of written procedures for determining the allowability of costs in accordance with 2 CFR Part 200.302(b)(7). Corrective Action: While the Association applies applicable federal cost principles when administering grant-funded activities and no unallowable costs were identified, these practices were not formally documented in written procedures during the audit period. Management acknowledges that written procedures are required to ensure consistency, continuity, and clear guidance for personnel involved in federal grant administration. To address this matter, management will develop and implement written procedures for determining the allowability of costs charged to federal programs. These procedures will reference applicable Uniform Guidance cost principles and outline review and approval responsibilities to ensure compliance prior to costs being charged to federal awards. The procedures will be communicated to appropriate staff and incorporated into the Association’s grant administration practices. Management believes these corrective actions will strengthen internal controls over federal financial management and support continued responsible stewardship of grant funds for the benefit of the Association’s members. Projected Completion: A Federal Awards Management Policy has been drafted for executive review with formal adoption anticipated prior to June 1, 2026 Responsible Official(s): Chief Financial Officer

Year Ended June 30, 2025 Finding Number: 2025-001 Finding Title: Material Weakness in Internal Control over Financial Reporting and Compliance Name of Contact Person: Beverly Smith, COO Corrective Action Plan: The Organization has engaged an external CPA firm subsequent to year-end to assist with reconciling grant revenue, receivable, and cash accounts and to support improvements in financial reporting processes. Management acknowledges that these corrections occurred after year-end and were not part of the Organization’s internal control process and contributed to delays in the completion of the audit. In addition, the Organization has hired new key accounting personnel to strengthen internal financial reporting capacity and oversight. Going forward, the Organization will implement formal procedures requiring monthly reconciliation of all significant accounts, including cash and grant-related accounts. Responsibilities for preparation and review of reconciliations will be clearly assigned, and all reconciliations will be documented and reviewed by management in a timely manner. In addition, the Organization will implement enhanced controls over cash activity and journal entries, including review procedures designed to identify and prevent duplicate or erroneous entries. Management will also increase oversight of the financial reporting process to ensure that account balances are accurate and supported throughout the year. Anticipated Completion Date: June 30, 2026

2025-002. Allowable Costs/Cost Principles – (Excess Reimbursement Due to Inaccurate Final Expenditure Reporting) United States of Department of Education, Passed Through New York State, Department of Education: COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D Pass-through Entity Number: 5891-21-1490 COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief ALN: 84.425U Pass-through Entity Number: 5880-21-1490 COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief ALN: 84.425U Pass-through Entity Number: 5884-21-1490 Condition: The District submitted Form FS-10F final expenditure reports that included amounts for open encumbrances that were not fully expended after the final reports’ submission; the cumulative expenditures in the District’s accounting records for two of the Education Stabilization Fund (ESF) grants (CRRSA ESSER II, pass-through entity number 5891-21-1490, and ARP ESSER III, pass-through entity number 5880-21-1490) were less than the amounts claimed by the District on the FS-10Fs. The FS-10F for a third ESF grant (ARP SLR Learning Loss, pass-through entity number 5884-21-1490) included a duplicated amount for purchased services that was the result of a duplicated journal entry in the District’s accounting records. As a result, the expenditures reported on the FS-10F final expenditure reports exceeded the actual expenditures incurred and recorded by the District, and the District received reimbursements from the pass-through entity, New York State Education Department (NYSED) for expenditures it did not incur. Recommendation: The District should strengthen its internal controls over grant reporting and reimbursement processes to ensure that expenditures reported on the FS-10F final expenditure reports are accurate, allowable, and fully supported by the accounting records. Journal entries affecting federal grants expenditures The District should perform a comprehensive reconciliation of the FS-10F to the general ledger prior to submission, and again after the grant period ends to confirm all reported amounts were ultimately expended, and establish a formal process to review and clear outstanding encumbrances included in grant reports, ensuring any amounts not realized as expenditures are removed or adjusted. Additionally, the District should develop procedures to identify and track subsequent adjustments, including reclassifications of unallowable costs, and ensure that such changes are timely communicated and corrected with the New York State Education Department, and to require documented supervisory review and approval of all final expenditure reports and their subsequent reconciliations with supporting documentation and final accounting records. Planned Corrective Action: The District will strengthen internal controls over grant reporting to ensure that all expenditures reported on Form FS-10F are accurate, fully expended, and supported by the general ledger. Prior to submission, the District will perform a detailed reconciliation between the FS-10F and accounting records, verifying that only actual expenditures—not open encumbrances—are reported. A post-period reconciliation will also be conducted to confirm that all reported amounts were ultimately realized as expenditures. The District will establish a process to identify and track subsequent adjustments, including reclassifications or corrections, and will promptly communicate any necessary amendments to the New York State Education Department (NYSED). Starting from the next grant final cost submission, effective May 1, 2026, a structured review and approval process will be enforced: the Administrative Assistant responsible for grants will serve as the first-level reviewer during FS-10F preparation, and the Financial Officer will serve as the second-level reviewer prior to final submission. All final reports will require documented supervisory approval and supporting documentation, including actual invoices and purchase order amounts, to ensure accuracy and compliance. Responsible Contact Person: Mr. Idowu K. Ogundipe, CPA Assistant Superintendent for Business Freeport Union Free School District 235 North Ocean Avenue Freeport, New York 11520 Tel: (516) 867-5212 Email: iogundipe@freeportschools.org Anticipated Completion Date: May 1, 2026

GDOL’s current UI Tax system was developed in 1982 using mainframe legacy technology. Due to its age and structural limitations, many automated financial record-keeping processes and corrective controls cannot be easily implemented. As a long-term solution to strengthen internal controls and enhance overall UI program administration, GDOL has contracted with a vendor to implement a more efficient method for maintaining documentation of taxes due and received. Migration to the modernized system is anticipated in late 2026. A review of the thirteen accounts identified the source of each payment, the amounts remitted, and the associated tax account allocations. Our records showed all payments, except for one, were submitted electronically via ACH Debit or ACH Credit. These ACH transactions are reflected as components of the total daily ACH Debits or Credits shown on the agency’s bank statement spreadsheets for the dates associated with the payments. The Contribution Tax amount represents only a portion of the total tax due. Therefore, the payment amount and the Contribution Tax amount may differ.

Finding 2025-002 – Cash Management (Reimbursement Request Error) Significant Deficiency in Internal Control Over Compliance and Noncompliance Corrective Action Plan: The Town will strengthen internal controls over reimbursement requests by implementing a reconciliation process between requested amounts and supporting documentation prior to submission. A secondary review and approval will be required for all reimbursement requests. Responsible Official: Clerk/Treasurer Mayor Planned Completion Date: May 2026

Management has reviewed this finding and has indicated a corrective action plan will be developed to address this finding and recommendation.

The Town will implement written procedures requiring the development and maintenance of project‑specific budgets for all federal awards, including FEMA emergency response and recovery projects. Project budgets will be prepared in accordance with approved scopes of work and used to monitor expenditures throughout the life of the award. The Town will provide training to applicable staff on federal grant budgeting requirements and designate responsibility for budget preparation and monitoring.

FINDING 2025-016 Name of Responsible Individual: Director of Post Award Compliance and Training Christina Flood, Budget Analyst Corrective Action: Monthly Settlement Reports are used to reconcile actual expenses. An outdated spreadsheet was previously used to convert travel expenses, which resulted in incorrect exchange rate calculations. The team has implemented an updated conversion process. Going forward, the Sponsored Program Office Team will review and approve the exchange rates to ensure they are reasonable, accurate, and applied consistently. Anticipated Completion Date: June 30, 2026

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

We agree with the finding and we will be reviewing and implementing the recommendations accordingly. We are committed to ensuring no duplication of costs across reporting periods and compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan will be implemented by June 30, 2026.

Recommendation: We recommend the SNP reviews its internal controls and policies to ensure all students receiving benefits have an application, or other supporting documentation, on file to support their eligibility. Action taken in response to finding: Management acknowledges the finding and will revise and formalize internal controls as follows: • Eligibility Documentation Procedures: Develop a standardized checklist to confirm required documentation is obtained, reviewed and retained prior to approval. • Centralize Review and Approval Process: A designated reviewer will be responsible for verifying completeness and accuracy of all eligibility determinations. Approval will be formally documented. • Record Retention Controls: Management will establish controls to ensure that all eligibility documentation is: Properly maintained, readily accessible for audit or review and retained in accordance with federal, state and organization-wide policy. • Personnel Training: Training will be conducted annually and upon onboarding new personnel. Name of the contact person responsible for corrective action: Sean Jernigan, Chief of Operational Vitality, Department of Catholic Schools, Archdiocese of Los Angeles Planned completion date for corrective action plan: • Procedure and checklist implementation: Within 30 days of financial statement issuance • Staff training: Within 60 days of financial statement issuance • Full implementation and evidence of operation: 90 days of financial statement issuance

March 10, 2026 To: Clausell & Associates, P.C. From: Tabirus Lockhart, Chief Financial Officer of Enrichment Services Programs, Inc. Below is the Agency’s corrective action plan as it relates to the findings for the fiscal year ending July 31, 2024, Single Audit Act audit. Comment #2024-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED GENERAL (Repeat) Views of Responsible Officials and Planned Corrective Actions: We concur with this finding - Management is in the process of assessing the organizational structure, capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2024. Concerning preparation of external reports required by various funding sources (i.e., SF-425, DHS’s reports for LIHEAP, LIHWAP, etc.), the Agency will ensure adequate training is performed to improve the skills and knowledge of key personnel. Policies and procedures will also be revised to support external reporting. Implementation Date: The plan correction date will be completed no later than December 31, 2025. Responsible Person: Tabirus Lockhart, CFO, will be responsible for the corrective action. Comment #2025-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, CSBG, ASTHO, CACFP, and CSLFRF FAL # 93.600, 93.568, 93.569, 93.185, 10.558, 21.027 (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 the new and updated accounting system, we are providing ongoing training on the requirements of the Uniform Guidance and the specific requirements for each individual grant award as outlined in each applicable Compliance Supplement issued by Office of Management and Budget (OMB). We are currently reconciling all cash accounts and completing and amending, where necessary, all SF-425 reports and other external reports required by each funding source (state and federal). We anticipate completing this corrective action by June 30, 2026. See also the response to Comment #2025-001. Implementation Date: The plan correction date will be completed no later than June 30, 2026. Responsible Person: Tabirus Lockhart, CFO, will be responsible for the corrective action.

2025-00I Condition: The center did not maintain adequate documentation to support compliance with Federal requirements related to allowable costs, period of performance, and procurement standards. Auditor's Recommendation: We recommend The Center review and revise its documentation policies and procedures to ensure that compliance is met with regards to federal awards. Management response: Management agrees with the finding and has collaborated with grant personnel to implement standardized personnel activity reporting and cost allocation documentation for all federal grants. The Center will strengthen controls to ensure that only allowable costs incurred within the approved grant period are charged to federal awards. In addition, procurement procedures have been revised to ensure compliance with 2 CFR §§ 200.317-200.327. Corrective actions have been implemented or are in progress and apply to all federal awards moving forward beginning in FY2026.

Management will be refreshing training and cross-training for staff to ensure accurate calculation of rental assistance and timely completion of interim certifications whenever required. Additionally, we will provide a refresher training to staff on HUD Section 8 documentation standards.

The University will strengthen its cash management procedures to ensure that federal funds requests (drawdowns) are limited to immediate cash needs and that funds are disbursed within required timeframes. Enhancements will be made to the existing reconciliation process to ensure it provides sufficient detail to accurately link drawdowns to the corresponding disbursements and payroll charges, supported by adequate documentation. Additionally, Pre‑ and post‑disbursement reviews will be implemented to verify timing, accuracy, allowability, and prevent duplicate requests. Policies and procedures will be reinforced, and internal controls strengthened through segregation of duties, supervisory review, and documented approval processes. All records will be centrally maintained, and staff will receive targeted training to ensure consistent compliance. Furthermore, the University will also implement ongoing monitoring and periodic internal reviews to promote sustained compliance and address repeat findings. All corrective actions will be implemented within 30–60 days.

The University acknowledges the audit finding and remains committed to maintaining compliance with the cash management requirements outlined in 2 CFR 200.302 (b)(3), which stipulates that recipients must maintain records that sufficiently identify Federal awards and ensure that drawdowns are properly supported and authorized prior to submission. During the audit period, at least one drawdown was approved, one day retroactively, after submission but prior to receipt of funds. This occurred prior to the remediation period. No exceptions were identified in the remediation period, and the finding is considered remediated. The instance arose during a leadership transition with the Office of Research Administration. Since that time, the entire drawdown process, review and approval has been clarified under new leadership, and additional oversight has been implemented to ensure approvals are documented prior to submission. As part of the drawdown process review, the University developed a standardized drawdown template, which streamlines how the Federal award expense information is gathered, compared to approve budgeted amounts and reviewed for approval. The template documents the preparer, the approver and the dates of both for the respective drawdown. The Office of Research Administration received training on the use of the template in January and February 2026 and implementation is planned for February 2026. Primary responsibility for implementing the correction action plan for this finding rests with Angela Tagliaferri, Assistant Vice President of Post-Award Services and Financial Compliance, 216-368-6269.

Corrective Action Plan Finding No. 2025-004 Condition – The District submitted an expenditure report for $19,165,569 for the quarter ending March 31, 2025, which included amounts that were properly obligated but not yet expended as of the report date. The District reported $14,638,097 in ESSER funds on the Schedule of Expenditures of Federal Awards (SEFA), resulting in an unsupported difference of $4,527,472. Plan – The District will implement additional review processes to ensure material errors are detected and corrected. The District requested all ESSER obligated funds as of March 2025 as directed by the state. Anticipated Date of Completion: 03.06.26 Name of Contact Person: Delfaye Jason, Chief School Business Official

The District plans to design and implement a formal month-end reconciliation and claim certification process that includes: matching food service vendor meal counts to internal District records, dual review and approval, timely corrections, training and cross-training, and monitoring.

The Town will design and implement policies and procedures required by the Uniform Guidance.

We will change the way we prepare grant expenditure reports internally to ensure that journal entries are not counted twice. We will also have grant expenditures reports reviewed by someone other than the preparer before submission.

Per the recommendation to adopt a procedure to determine the allowability of cost per 2 CFR 200.302(b){7), our existing financial management policy covers the allowable cost principles in various sections within the policy. However, we will add in a section to our policy per the federal rule giving a procedure on documenting and determining if specific costs are allowable or not and in conformance. This action should be resolved before October 31st.

Finding 2025-004 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Participation of Private School Children Summary of Finding: The School Corporation did not provide supporting documentation for the amounts disbursed for Participation of Private School Children. No time sheets or logs were provided to support the hours paid to employees for working with the Private School Children. Contact Person Responsible for Corrective Action: Randi Libby, Chief Operating Officer Contact Phone Number and Email Address: (260)431-2030, rlibby@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement procedures to ensure consistent documentation supporting Title I services provided to non-public school students. All Title I staff providing services to non-public schools will be required to submit consistent, detailed timesheets documenting hours and/or days worked by non-public school, activity, and grant year. Timesheets will be completed, reviewed, and approved prior to payroll processing. The Payroll Manager will not process payroll for Title I non-public services unless the required timesheets are submitted and approved. Approved timesheets will be retained in the payroll files and organized by payroll dates, and will be made available for audit review. Anticipated Completion Date: July 1, 2026 _________________________ _Randi Libby (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)

JCCA CORRECTIVE ACTION PLAN March 23, 2026 Health Resources and Services Administration Jewish Child Care Association of New York (d/b/a JCCA) and Affiliated Organization respectfully submits the following corrective action plan for the year ended June 30, 2025. ____________________________________________________________________________________ CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT FINDINGS Finding 2025-001 – Account Analyses MATERIAL WEAKNESS Recommendation We recommend that the Agency implement policies, procedures and controls to ensure that all accounting records are analyzed and reconciled on a monthly basis. Action Taken BTQ Financial is spearheading a comprehensive stabilization project to refine the chart of accounts and reconstruct historical tracking for the permanent endowment fund. BTQ already has in place a rigorous monthly closing schedule. This includes establishing automated reconciliation protocols for program service revenue, endowment tracking, and inter-company accounts to ensure GAAP compliance and timely board reporting. These policies, procedures, and controls to ensure that all accounting records are analyzed and reconciled on a monthly basis have already been incorporated into FY2026 monthly close process. Finding 2025-002 – Information Technology – General Control Activities SIGNIFICANT DEFICIENCY Recommendation We recommend the Agency follow their policy for password age. We also recommend the Agency perform a risk assessment over the information technology environment. We recommend a written risk assessment and penetration test to be performed annually and vulnerability scans to be performed quarterly. Action Taken The Agency has configured NetSuite and Active Directory to programmatically enforce password aging and complexity requirements that strictly mirror our established IT Security Policy. Furthermore, we have moved beyond interview-based assessments to an annual cadence of formal, written risk assessments and penetration testing, supported by continuous monthly vulnerability monitoring through our Security Operation Center (SOC). An interview-based risk assessment was performed in Q3 2025, and monthly vulnerability scans are managed by Arctic Wolf, our Security Operation Center (SOC) service provider. To further strengthen our posture, we will initiate an annual cadence of formal external and internal penetration tests starting in Q2-Q3 2026. FINDINGS – FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, Unaccompanied Alien Children Program (Assistance Listing Number 93.676), FAIN # 90ZU0603, 90ZU0567, and 90ZU0536, for FY 2025 - Significant Deficiency Finding 2025-003 – Reporting Recommendation We recommend that management of the Agency implement procedures to track all federal reporting deadlines and ensure that reports are reviewed and submitted timely. This could include maintaining a centralized grant reporting calendar and implementing supervisory review prior to submission. Action Taken With the outsourcing to BTQ now fully operational, a centralized Federal Grant Reporting Calendar has been established. This calendar includes automated alerts for all 30/60/90-day deadlines. BTQ has also implemented a dual-level supervisory review process to ensure that all future reports are validated against the general ledger and submitted well in advance of federal deadlines. This protocol has been strictly applied to all federal reporting for the FY2026 cycle. U.S. Department of Health and Human Services, Unaccompanied Alien Children Program (Assistance Listing Number 93.676), FAIN # 90ZU0603, 90ZU0567, and 90ZU0536, for FY 2025 - Significant Deficiency Finding 2025-004 – Cash Management Recommendation We recommend that management of the Agency implement formal controls over the drawdown process that includes establishing procedures requiring documented supervisory review and approval of all drawdown requests and ensuring drawdowns are based on immediate cash needs so that federal funds are expended within a reasonable amount of time. Action Taken The Agency, in collaboration with BTQ Financial, has implemented a formalized "Drawdown Authorization Protocol." This new workflow improves upon the existing, and adds a standardized approach to every drawdown request, documented supporting schedules (showing immediate cash needs), and formal approval from BTQ’s PM, SVPF, VPF, or AVPF. This ensures a clear audit trail and prevents the accumulation of excess federal cash on hand. If the Health Resources and Services Administration has questions regarding this plan, please call Kenneth Shieh, Chief Administration Officer at (718) 747-4367. Sincerely yours, Kenneth Shieh, Chief Administrative Officer

Management’s Response: Management concurs with the auditors’ finding and recommendation and will conduct a reconciliation between FEMA project worksheets and disaster event expenditures posted to Workday to ensure accurate reporting on the SEFA.