Corrective Action Plans

The audit highlighted insufficient monitoring of subrecipients. To address this, a subrecipient monitoring policy has already been drafted and is being reviewed by the Executive Director. In addition to this, a subrecipient framework is being developed. This framework will standardize risk assessments, routine monitoring procedures and reporting requirements to ensure compliance with federal guidelines. Staff training on these monitoring practices will be completed prior to implementation.

The Children Service Department will seek legal advice on the implementation of a policy that meets the requirements set for in 2 CFR 200.302(b)(7) for determining the allowability of costs in accordance with Subpart E-Cost Principles.

The Commissioner’s office will consult with legal counsel to update polices to meet requirements of 2 CFR 200.

On behalf of Bebashi – Transition to Hope, I am submitting this corrective action plan in response to the material weakness finding identified in our recent federal audit. The finding noted a lack of effective internal controls over the maintenance of accurate accounting records, including the trial balance, general ledger, and the Schedule of Expenditures of Federal Awards (SEFA) and state financial assistance. These deficiencies resulted in material audit adjustments to the current year’s financial statements, multiple versions of the trial balance due to reconciling issues, and audit delays related to unreconciled supporting documentation. We take these findings with the utmost seriousness. As stewards of federal funds, it is our fiduciary duty to maintain strict compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200), as well as applicable state financial requirements. Corrective Action Plan 1. Strengthening Internal Controls o We are implementing enhanced internal control procedures to ensure timely reconciliation of the trial balance and general ledger. o Monthly reconciliations will now be prepared by the Finance Department, reviewed by the Chief Operating Officer, and formally approved by the President & Chief Executive Officer prior to closing. o Quarterly oversight reporting will also be provided to the Bebashi Board of Directors. 2. Accounting System Improvements o We will establish a standardized process to ensure one official version of the trial balance is maintained, with all adjustments tracked and documented in accordance with Generally Accepted Accounting Principles (GAAP). o We are upgrading our financial reporting system to include automated reconciliation checks, audit trails, and controls that will minimize the risk of discrepancies. 3. Staff Training and Accountability o Finance staff will undergo mandatory annual training on federal compliance, SEFA preparation, and reconciliation best practices. o Roles and responsibilities will be clearly defined, with a segregation of duties to prevent misstatements and errors. 4. Audit Readiness and Documentation o A comprehensive audit binder will be prepared and maintained to ensure that supporting documentation reconciles with the trial balance prior to submission. o A compliance calendar will be developed to track critical deadlines, reconciliation reviews, and reporting requirements. 5. Board and Executive Oversight o The Bebashi Board of Directors, through its Finance and Audit Committees, along with the President & CEO, will provide governance oversight of this corrective action plan. o Quarterly progress reports will be submitted to the Board, and the CEO and Board will formally document oversight in meeting minutes to ensure accountability and compliance. Responsible Party: The Finance Director, in collaboration with the Chief Operating Officer and with final accountability to the President & CEO as well as the Bebashi Board of Directors, will be responsible for implementing and monitoring this corrective action plan. Anticipated Completion Date: All corrective measures will be completed within ninety (90) days of the date of this letter, with ongoing monitoring and governance oversight by the CEO and Board of Directors to ensure sustainability. We regret the deficiencies that led to this finding and are committed to taking the corrective actions necessary to strengthen our financial management systems. Bebashi – Transition to Hope is dedicated to full compliance with federal and state requirements and to safeguarding the integrity of public funds entrusted to us. Respectfully submitted, Sincerely, Sebrina Tate President & Chief Executive Officer Bebashi – Transition to Hope On behalf of the Bebashi Board of Directors

Finding 2024-002 Material Weakness in Controls over Compliance and Material Noncompliance – Allowable Costs Federal Program: 93.137 Community Programs to Improve Minority Health Year: 2024 Federal Agency: Department of Health and Human Services Condition – Payroll expenses for one employee were inadvertently recorded twice for the fiscal year, resulting in an overstatement of personnel costs charged to the federal award. Further, indirect costs were charged in excess of the budgeted and approved amount under the grant agreement. Corrective Action Plan – Henry Ford Health agrees with this finding. The payroll expense was corrected in the Schedule of Expenditures of Federal Awards and will be corrected in September 30, 2025, Federal Financial Report. Prospectively the payroll for the employee in question will be processed through our automated payroll time and effort process, rather than through manual journal entries, thus reducing the risk of error. Additionally, set up and review procedures have been enhanced to improve the controls related to recovery of indirect costs. Anticipated Completion Date – December 31, 2025. Contact Person – J. Douglas Clark, Senior Vice President and Chief Accounting Officer.

With regard to Federal Award Finding 2024-002, Procedures for Match Requirements, in the audit report for Mountain Home Montana, Inc. for the year ended December 31, 2024, we offer the following response: Mountain Home will immediately implement written policy and procedures to ensure compliance with federal grant matching requirements. The new policy and procedures are attached.

DAWI acknowledges the finding and will implement the following: 1. Cash Management Policy: We will update this policy to require signed documentation of reimbursement requests. a. We will then follow this policy and retain signed documentation of reimbursement requests. 2. Matching Policy: We will develop a match policy to include documented review and signed document retention for matching contributions, ensuring compliance with CFR §200.306. a. We will then follow this policy and retain signed documentation of matching contributions. Proposed Completion Date – October 31, 2025

April 30, 2025 To: Clausell & Associates, P.C. From: Camille Vickers, Executive Director of West Central Georgia Community Action Council, Inc. Below is the Council’s corrective action plan as it relates to the findings for the fiscal year ending September 30, 2024, Single Audit Act audit. Comment #2024-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION 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 and capacity to provide adequate financial reporting. With Board review and approval of the Council’s financial funding sources, the Council will provide additional training to support the new fiscal officer. The fiscal officer 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. All enhancements will be implemented by July 31, 2025. Concerning the preparation of external reports required by various funding sources, the Council will ensure adequate training is provided 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 July 31, 2025. Responsible Person: Camille Vickers, Executive Director, will be responsible for the corrective action. Comment #2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED LIHEAP FALN 93.568 (Questioned Costs – Undetermined) 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 Council’s financial funding sources, the Council will provide additional training to support the new fiscal officer. The fiscal officer 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. All enhancements will be implemented by July 31, 2025. Concerning the preparation of external reports required by various funding sources, the Council will ensure adequate training is provided 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 July 31, 2025. Responsible Person: Camille Vickers, Executive Director, will be responsible for the corrective action.

2024-2 Allowable costs-credit cards – Assistance Listing Number 11.307 Recommendation: We recommend that management implement a more robust internal control system to ensure all federal expenditures are supported by proper documentation. Explanation of disagreement with audit finding: We believe the costs referred to were indeed for allowable expenses under the federal program. We will however start to maintain all original source documentation. Action taken in response to finding: Management has required all original source documentation be maintained regardless of dollar amount. Name of contact person responsible for corrective action: Anthony Wigglesworth, Executive Director Corrective action plan has been implemented in 2025.

The Administrator and Fiscal Officer will work to ensure all reports for grant funding are completed.

FINDING 2024-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-882-6426 clane@vincennes.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All reports will be prepared by the clerk’s treasurer’s office and will be reviewed by someone who is knowledgeable about the reporting requirements prior to submission. They will review reports for errors and omissions. After this additional review, the report will be submitted. Anticipated Completion Date: This corrective action plan will go into effect immediately.

FINDING 2024-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-882-6426 clane@vincennes.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Clerks office will identify non- compliant activities to ensure that funds are being used appropriately and according to federal guidelines and principals. We will consult with the relevant personnel to ensure understanding of allowable and unallowable activities and identify areas that may need additional training. We will enhance our review and approval process and provide clear documentation requirements to our departments. Anticipated Completion Date: This corrective action plan will go into effect immediately.

Finding 2024-002 Finding Subject: Economic Development Cluster – Reporting Summary of Finding: Material Weakness, Other Matters The data submitted in the SF-425 report submitted by the city for the reporting period ending on 9/30/24 contained the following errors: • Cash Receipts Understated by $1,037,155 • Cash Disbursements Understated by $1,037,155 The lack of internal controls and noncompliance was isolated to the award 06-79-06420 EDA-Davis Road Construction project. Contact Person Responsible for Corrective Action: Weston Reed Contact Phone Number and Email Address: 765-456-7380 wreed@cityofkokomo.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: City of Kokomo will design and implement a procedures where the Federal Financial Report and the Quarterly progress report will be reviewed by the director of development to ensure that there is oversight and that the report is complete and accurate. Anticipated Completion Date: December 31, 2025

Management agrees with the finding. Management has downloaded 2 CFP Part 200 for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly. Contact Person: Renee LaFleur, Executive Director Anticipated Date of Completion: December 31, 2025

Condition: The Organization’s expenditure reports filed with the grantor for the cost reimbursement-based grant were overstated, and the Organization was overpaid by $182,167, of which $26,730 was received after yearend. The overpayment has not yet been refunded back to the grantor, over a year after the performance period of the grant had ended. Recommendation: The Organization should coordinate with the grantor the return of the unspent funds. The Organization should reevaluate its grant expenditure reporting procedures to better mitigate the risk of inaccurate filing and improper reimbursement. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding and recommendation. The anticipated completion date for the corrective action is October 30, 2025.

WEST MICHIGAN FOOD PROCESSING ASSOCIATION CORRECTIVE ACTION PLAN DECEMBER 31, 2024 West Michigan Food Processing Association respectfully submits the following corrective action plan for the year ended December 31, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit period: Year ended December 31, 2024. District Contact Person: Marty Gerencer, Contracted Executive Director The findings from the December 31, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding: Federal Awards and Questioned Cost Finding 2024-01 Recommendation: We recommend that West Michigan Food Processing Association develop and implement comprehensive written policies and procedures to address the requirements of the Uniform Guidance. These should be tailored to the Association’s structure and operations and cover all applicable federal compliance areas. Management should also establish a process to periodically review and update these documents to ensure continued compliance. Action to be taken: The Association concurs with the facts of this finding and is implementing procedures to prevent this in the future. Finding: Financial Statement Audit Finding 2024-02 Recommendation: We recommend implementing a compensating control to mitigate this risk, such as: ➢ Requiring documented approval by a board member or other authorized individual prior to processingdisbursements, or ➢ Providing a board member or finance committee member with view-only online access or automatedbank alerts to review all cleared transactions. Action to be taken: The Association concurs with the facts of this finding and is implementing procedures to prevent this in the future.

Finding 2024-012 – Material Weakness – Maintenance of Effort Condition The Maintenance of Effort (MOE) calculation is calculated annually by the Wisconsin Department of Public Instruction (WI DPI) based on the information submitted in the PI-1505 report. There was a $16,977,949 variance between what was reported in the PI-1505 and the District's accounting records for the revenue source code 751. Due to this variance, we recalculated the MOE based on the District's accounting records. The MOE on a per pupil basis would have still been met. Corrective Action Plan The Office of Finance is committed to timely and accurate financial reporting. As we aim to improve our financial reporting due to DPI, our ACFR preparation and our SEFSA preparation, we will ensure that our reporting reconciles and there are no variances. We are working to improve, as mentioned in all the findings above, related to financial reporting. We recognize that this is critical for funding purposes for our district and it is our intent that this finding is remedied for FY25 reporting. Name(s) of Contact Person(s) Responsible for Corrective Action: Chief Financial Officer Anticipated Completion: 06.30.2026

Name of Contact Person: Teri Quinlan, Accounting Manager Corrective Action: The City agrees with the auditors’ finding and recommendation. The City has implemented, and is in the process of documenting, new procedures and review processes to ensure expenditures for federal programs are recognized in the appropriate fiscal year’s Schedule of Expenditures of Federal Awards (SEFA). Proposed Completion Date: October 13, 2025

The Board of Health will adopt updated written policies periodically in accordance with the Uniform Guidance to help improve internal controls over federal compliance for the findings listed in this number.

The Project acknowledges the finding regarding the interproject payable. Management has developed the following corrective action plan: Repayment of Payable - The outstanding payable balance ot the related HUD project will be repaid in full by September 30, 2025. Documentation of repayment will be maintained and made available for audit verification. Elimination of Interproject Borrowing - Effective immediately, the Project has ceased the practice of borrowing funds from other HUD-assisted projects. Future interproject transactions will not be initiated unless expressly authorized by HUD. Polidy Development and Implementation - The Project will adopt a written policy governing cash management and interproject transactions by September 30, 2025. The policy will prohibit interproject loans without HUD approval and establish procedures for timely monitoring of accounts payable. Training and Oversight - Project staff responsible for financial reporting will receive training on HUD requirements and Uniform Guidance within 120 days. In addition, management will review monthly financial reports to ensure no interproject balances exist.

Finding 2024-004: Written Policies and Procedures • Planned Corrective Action: We will adopt formal policies and procedures that document our current practices and also meet the requirements of the Code of Federal Regulations (CFR). • Anticipated Completion Date: September 30, 2025. • Responsible Contact Person: Rick Smith, Executive Director

Management concurs with the finding and will revise procedures to ensure detailed, timely recording of USDA Foods distributions. Staff will receive training on documentation requirements, and management will implement periodic compliance reviews. These corrective actions are expected to be completed by March 1, 2025.

Finding 2024-03 Insufficient Documentation of Other Direct Expenses Condition: During testing of direct costs charged to the federal program, the Organization did not maintain sufficient documentation to fully support all expenditures claimed. In one instance, a receipt supporting a claimed expense was missing. In three additional cases, although the expenditures were generally supported, the documentation did not clearly reflect how the amounts allocated to the major federal program were determined. While these issues were isolated and the known and likely questioned costs were immaterial, the lack of complete documentation represents noncompliance with federal requirements for allowable costs. Corrective Actions Taken or Planned: The Organization will develop written guidelines specifying the required supporting documentation for each type of direct expense. Set up vendors in QuickBooks. We will hire and train Finance Manager to manage and track revenue and expenses, QuickBooks, grant reporting etc. All receipts and expenses will be scanned in and kept electronically. The Organization will provide training on documentation requirements, proper record submission, and compliance expectations.

Finding 2024.003 – Cash Management Recommendation The Center should develop written procedures to review all drawdowns that occur to ensure accuracy. Not a repeat finding. Action Taken Since September 2023, the Center has implemented weekly grants management reviews with the grants team and key executives. Action items are tracked through meeting agendas, minutes, and NMH’s project management platform, Monday.com. Meetings include invoice approvals for grant-funded expenditures, and review of allocations, payroll dates, and stipends for drawing down calculations. The meetings going forward will document the amounts for federal grants drawdowns and will be logged within Monday.com and through an external verification spreadsheet. Starting May 2025, an updated verification spreadsheet along with an itemized attestation was implemented.

Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager