Corrective Action Plans

Finding 2025-001: Review of Compliance Matrices and Narratives – Special Tests and Provisions The single audit report included the following recommendation: EY recommends that Amtrak update the control design with enough precision to ensure that reviews and updates to the compliance matrices are made on a regular cadence to ensure that any updates, amendments or changes are monitored and updated timely. Management Response/Status of Action Plans: Amtrak recognizes the need to improve our controls over the updates of the compliance matrices and will review its control processes. The company specifically notes the need to update its compliance matrices in a regular cadence and after every amendment. Amtrak will develop a process document to create or update compliance matrices that will be used as a guide by compliance matrices preparers and reviewers when one is created or updated. The contact for this item is Lucia Butts, AVP Funding and Grants. Amtrak anticipates fully remediating this finding by September 2026.

Management’s Response Community Council of Idaho, Inc. acknowledges the finding related to untimely reconciliations, material audit adjustments, and delayed financial statement issuance. Management agrees that improvements are necessary to strengthen internal controls over financial reporting, ensure timely account reconciliations, and improve the overall financial close and audit preparation process. Management recognizes that turnover within the business office during the audit year significantly impacted continuity, institutional knowledge, and the timely completion of reconciliations and closing procedures. Subsequent to year end, management has initiated corrective actions designed to improve financial reporting accuracy, accountability, and timeliness. Corrective Actions to Be Implemented 1. Implementation of Formal Monthly Closing Procedures Management will implement a standardized monthly financial close process with defined timelines, responsibilities, and review procedures. The monthly close process will include: Completion of all balance sheet reconciliations, Review of grant and contract revenue accounts, Review of property and equipment activity, Reconciliation of debt schedules, Reconciliation of pharmaceutical inventory balances, Recording of depreciation and interest expense, and Verification that all material journal entries are posted timely. A monthly close checklist will be developed and maintained to ensure consistency and accountability. 2. Timely Reconciliation of Grant and Contract Accounts Management will strengthen procedures surrounding grant and contract accounting to ensure receivables and revenue are reconciled monthly and supported by appropriate documentation. Actions include: Reconciling grant receivable balances to supporting reimbursement requests and funding agency records, Reviewing deferred revenue and earned revenue calculations monthly, Investigating and resolving variances timely, and Implementing supervisory review of grant reconciliations. 3. Enhanced Review and Oversight Controls Management will implement additional review controls over financial reporting and account reconciliations. These controls will include: Documented supervisory review and approval of reconciliations, Review of significant or unusual journal entries, Periodic review of financial statements and supporting schedules by senior finance leadership, and Earlier audit preparation and interim review procedures to identify issues prior to year end. 4. Strengthening Staffing and Organizational Structure Management and executive leadership have evaluated the operational needs of the business office and have taken steps to improve staffing stability and oversight capacity. Actions include: Clarifying accounting roles and responsibilities, Enhancing cross-training within the finance department, Providing additional training related to grant accounting and reconciliations, Utilizing external resources or consultants, as needed, to support complex accounting areas and transition periods. 5. Improvement of Clinic Reporting Processes Management will continue evaluating clinic reporting systems and procedures to ensure operational growth is adequately supported by accounting and financial reporting processes. This includes: Improving coordination between clinic operations and accounting, Standardizing reporting procedures, Evaluating system-generated reports for accuracy and completeness, and Implementing additional reconciliation and review controls related to clinic financial activity. 6. Audit Readiness and Timeliness Improvements Management will establish an audit preparation timeline with interim deadlines to support timely completion of the annual audit and compliance with federal reporting deadlines. The organization will: Prepare schedules and reconciliations in advance of audit fieldwork, Conduct periodic internal reviews of audit support documentation, Improve coordination with external auditors throughout the year, and Monitor progress toward required reporting deadlines. Contact Person Responsible for Corrective Action: Implementation oversight will be shared among executive leadership, finance management, program leadership, and those charged with governance. Anticipated Completion Date: Corrective actions began subsequent to year end and are expected to be substantially implemented during fiscal year 2026, with ongoing monitoring and refinement thereafter.

The City acknowledges the finding. The City will continue strengthening procedures to identify, track, reconcile, and report federal award activity throughout the fiscal year. Procedures will include maintaining documentation sufficient to identify the federal agency/ program, Assistance Listing number, award identifiers, expenditures, loan balances where applicable, subrecipient information, and required SEFA disclosures and notes. Management will also maintain centralized tracking records for federal award activity to support timely preparation of future SEFAs.

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.