Corrective Action Plans

August 15, 2025 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 #2024-002 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, LIHWAP, CSBG, ASTHO, CACFP, and SLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) 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 December 31, 2025. See also the response to Comment #2024-001. 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.

June 26, 2025 JGD & Associates LLP 9191 Towne Centre Drive Suite 340 San Diego, California 92122 Re: Corrective Action Plan Dear JGD & Associates LLP, The following are responses to the program audit findings from the most recent audit of Adjoin. 1. Current Year Findings 2024-001 a. Program Name: Supportive Services for Veterans Families: CFDA 64.033 b. Criteria: Failure to comply with the grant agreement’s terms and applicable regulations: The Organization did not comply with grant compliance requirements such as tracking administrative expenses charged to the program outside of the general ledger and in other matters noted in licensing reviews. c. Condition: The Organization has failed to comply with grant requirements due to lack of proper tracking of administrative expenses, limited compliance policies including approval over supplemental pay wages, and lack of proper training over verification and documentation processes. d. Response: The organization has been successfully running the SSVF program for 11+ years and tracking/calculating administrative costs utilizing offline Excel spreadsheets since inception which provided a low cost and flexible solution for our accounting team. However, as an outcome of our last SSVF audit and due to the size and scope of our SSVF operations, the VA is requiring Adjoin to cease maintaining offline spreadsheets and ensure that all SSVF grant costs are logged in the general ledger. We're partnering with JMT Consulting (our Sage Intacct solution provider) for their assistance in implementing a new Dynamic Allocation Module to our Sage platform allowing click thru capabilities to all of the administrative costs that hit the grant (not to exceed 10%). We're committed to rolling out this functionality and are excited about the efficiencies it will bring to the team along with ensuring compliance with VA requirements. 2. Prior Year Finding 2023-001 None noted. Contact person responsible for corrective action: Pat Phelan, CFO Completion date: August 31, 2025 If you have any questions regarding this plan, please contact Pat Phelan, CFO, 858- 292-2030, pat.phelan@adjoin.org. Sincerely, Pat Phelan CFO Adjoin

Management Response: We have had significant turnover in HR and Payroll and documentation was not maintained properly. We have a new HR Director and new Payroll Manager who will work closely together and are aware of record keeping and maintaining files for compliance. A checklist has been created to ensure all required documents are on file. Anticipated Completion Date: We are conducting a file review and will ensure all documents are in order by September 30, 2025. Responsible Party: HR Director, Payroll Manager, Benefits Coordinator and Business Manager will have oversight.

Finding 2024-005 Internal Controls Over Compliance for Subrecipient Monitoring 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding The City will adopt the referenced policies in order to comply with Uniform Guidance. 3. Official Responsible Ms. Sony Lubrecht, Finance Director, is the official responsible for ensuring corrective action. 4. Planned Completion Date December 31, 2025. 5. Plan to Monitor Completion The City Council will be monitoring this Corrective Plan.

2024-007 Missing Supporting Documentation for Federal Reimbursement Claims Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. A process for retaining claims and supporting documentation has been implemented.

Action Taken: Management agrees with the finding noted above. Management will also note that as a repeated finding we do not so much offer a corrective action plan as we do a summarization of steps already taken to close this finding for fiscal 2025. A new and highly qualified Chief Financial Officer with over 30 years of public housing experience was hired by the agency in April of 2024. The CFO has fully staffed the department with competent and qualified individuals including a new and fully qualified Controller and Director of Finance. All individuals hired have received targeted training from both internal and external sources. In June 2024 the new financial management team implemented a policy/procedure for the records requirement and payment timeframes for all capital fund draw downs. This policy requires the hand signing of eLOCCS forms and reconciliation of individual draws at the time of drawdown. During fiscal 2025 the entire Finance staff was trained extensively on all matters related to HUD accounting. Specific training was directed to the Capital Fund program, its eligibility standards, accounting processes, and drawdown procedures. This training was conducted by a nationally recognized HUD-specific trainer. The Authority has hired a qualified, experienced internal auditor. The internal auditor has completed a 100% testing sample on capital fund draws made in fiscal 2025. His observations were rectified, and the policy revised where needed. The sampling assured that supporting documentation was sufficient for audit, that it matched the amounts drawn, and that invoices were paid within HUD dictate s timeframes. Management feels that with this policy and enhanced testing in place the finding will not be repeated in 2025. Management expects closure of this finding, under the direction of the Chief Financial Officer, for the Fiscal 2025 audit.

View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.

Recommendation: We recommend that the Parish enhance and document internal controls over financial reporting, as described in our recommendations described under item 2024-001, to prevent noncompliance of the Uniform Guidance as required. Corrective Action: The Parish has written a Standard Operating Procedure for “Grant Management - Financial Reporting & Reconciliation” which outlines the role of the Finance Department in monitoring grant activities including measures to ensure correct general ledger coding for budget planning, complete and accurate recording of grant expenditures and revenues, and administrative review to confirm reconciliation of grant activities against the general ledger on a monthly basis. This corrective action was approved and implemented effective 6/30/2025

In response to the Auditor’s recommendations and as corrective action, the responsible staff 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.

Following the Auditor's recommendations and as corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.

The Municipality will designate the appropriate personnel to systematically identify, compile, and securely retain all required reports as stipulated in the grant agreement, ensuring reconciliation with the official accounting records and subsidiary ledgers. Furthermore, the Municipality will develop and implement a comprehensive training program, accompanied by detailed written guidelines and procedures, to equip all staff involved in managing federal funds with the necessary knowledge and tools to maintain compliance and enhance accountability.

FINDING 2024-004 Finding Subject: Water and Wast Disposal System for Rural Communities - Reporting Contact Person Responsible for Corrective Action: Beth Jones Contact Phone Number and Email Address: 812 723-2739, clerk@paoli.in.gov Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: The town is contracted with Baker Tilly Financial Advisors and the Clerk Treasurer will provide all pertinent information to Baker Tilly in order for them to prepare the Statement of Budget, Income, and Equity- Form 442-2; and the Balance Sheet - Form 442-3) that is required by the USDA for the Sewer Bonds. Once the reports are completed by Baker Tilly, the Clerk Treasurer will review the reports and then submit them to the USDA. This will be done annually. Anticipated Completion Date: Effective immediately

Condition: The District claimed expenditures that did not agree with their underlying accounting records. Plan: The District will hire a full-time employee to execute the completion of all State and Federal grants. Addidtional training and reources will be provided to ensure the District remains in compliance. Anticipated Date of Completion: 'June 30, 2025. Name of Contact Person: Dr. Kevin J. Nohelty, Superintendent. Management Response: The District will review the itemized budget and ensure claimed expenditures fall within the grant. If necessary, amendments will be filed accordingly.

Condition: The District claimed expenditures that did not agree with their underlying accounting records. Plan: The District will maintain records that accuaratetly support reported expenditures on the expenditure claims effective immediately. Anticipated Date of Completion: 'June 30, 2025. Name of Contact Person: Dr. Kevin J. Nohelty, Superintendent. Management Response: The District will periodically review the itemized budget and ensure claimed expenditures fall within planned grant expenditures or file amendments as necessary.

Finding 2024-001 Internal Controls Over Compliance for Cash Management, Allowable Costs, Procurement, and Conflicts of Interest 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding Subsequent to year-end, the City addressed this matter by formally adopting written policies meeting the referenced requirements of the Code of Federal Regulations. 3. Official Responsible The City Administrator is the official responsible for ensuring corrective action. 4. Planned Completion Date June 30, 2025. 5. Plan to Monitor Completion The City Council will be monitoring this Corrective Plan.

Finding 2024-004 Internal Controls Over Compliance for Cash Management, Allowable Costs, Procurement, and Conflicts of Interest 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Action Planned in Response to Finding The City will adopt the referenced policies in order to comply with Uniform Guidance. 3. Official Responsible Nicole Coler, City Clerk/Treasurer, is the official responsible for ensuring corrective action. 4. Planned Completion Date December 31, 2025. 5. Plan to Monitor Completion The City Council will be monitoring this Corrective Plan.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. The Group will prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Group staff are trained on the requirements related to federal award reconciliations and SEFA preparation which mitigates the risk of noncompliance in the future.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. The Group will prepare and maintain an accurate Schedule of Expenditures of Federal Awards (SEFA) in accordance with 2 CFR Part 200.510 to ensure proper documentation and compliance with federal reporting requirements. Group staff are trained on the requirements related to federal award reconciliations and SEFA preparation which mitigates the risk of noncompliance in the future.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will work with management to design and implement internal controls related to federal program grant management, including assignment of responsibility for grant oversight to specific individuals or departments.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will work with management to implement internal controls over tracking of expenditures related to federal award grants, especially personnel costs, and the related reimbursed cost to ensure compliance with federal requirements.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will implement internal control procedures to establish separate accounts, classification, use of cost centers and project codes to clearly distinguish expenditures by funding source, especially federal and state funds, as well as revenues received.

Supportive Services for Veteran Families Assistance Listing No. 64.033 Recommendation: We recommend that the Corporation strengthen its internal controls over cash disbursements. This should include retention of payments supported by valid invoices and proof of payment documentation as well as periodic internal audits to ensure compliance with the documentation requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All purchase-related supporting documentation will be transitioned to paper files to eliminate confusion created by the electronic record-keeping system, and to ensure that all staff requiring access to such documentation can immediately and easily retrieve them. Records will be maintained in the Finance Department office for seven years. Name of the contact person responsible for corrective action: Karen Harshman Planned completion date for corrective action plan: 06/12/2025

DEPARTMENT OF HOMELAND SECURITY Disaster Grant Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Recommendation: We recommend that the organization implement a review and approval process for all quarterly progress submissions. This should include: Training staff on the importance of the review and approval process. Ensuring adequate staffing levels to handle the review process. Developing clear guidelins and procedures for the review and approval process. Regularly monitoring and auditing the review process to ensure compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The City will implement a review and approval process for all quarterly progress report submissions within it ERP (Enterprise Resource Planning) software system. The City will train its staff on the importance of the review and approval process. The City will ensure adequate staffing levels to handle the review process. The City will develop clear guidelines and procedures for the review and approval process. The City will regularly monitor and audit the reivew process to ensure compliance. Name(s) of the contact person(s) for corrective action: Guillermo Polanco. Planned completion date for corrective action plan: 09/30/2025

Department of Homeland Security Federal Emergency Management Agency Disaster Grant Public Assistance – FEMA – Assistance Listing No. 97.036 Recommendation: Provide clear, updated guidance and periodic training sessions on earmarking rules and how to apply them. Conduct reviews of earmarking compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: New procedures will be implemented that strengthen internal controls to ensure that all grant revenues are recorded properly. Name(s) of the contact person(s) responsible for corrective action: Lindsey Barwick, Accounting Manager Hardee County Clerk of Courts & Lorie Ayers, General Services Director Hardee County Board of County Commissioners Planned completion date for corrective action plan: September 30, 2025

Condition: A weakness existed in the overall reconciliation/tie-in procedures performed over the Tribe’s financial statement accounts for the fiscal year ended September 30, 2024. Financial accounts were either reconciled untimely or in some cases, accounts were not reconciled at all. Most of these accounts should be reconciled on a monthly basis. The major areas where reconciliation procedures were weak included: A)   Beginning Balances B)    Account Receivables C)    Grant Receivables/Unearned Revenues D)   Accounts Payable E)    Payroll and Other Current Liabilities Recommendation: The Tribe should adopt written reconciliation and tie-in procedures into its financial policies and procedures manual. Action Taken: We agree with the auditor’s recommendation. We expect this to be complete within 120 days past the issuance of this report