Corrective Action Plans

Condition: The Organization did not have a formal cash management policy in place for the period under audit. Planned Corrective Action: The Organization implemented a Federal Awards Administration Policy which includes a formal cash management policy in February 2025. Contact person responsible for corrective action: Valeria Watson Anticipated Completion Date: February 2025

Title: Capital Fund Program Grant Draws Program Name: Public Housing Capital Fund ALN:14.872 Description: During our audit procedures over revenue recognition for the Capital Fund Program (CFP), we identified drawdowns of federal funds for which the client was unable to provide adequate supporting documentation. Specifically, the expenditures associated with the draw requests lacked invoices, contracts, or other substantiating records to demonstrate that the costs were allowable, allocable, and incurred in accordance with applicable federal requirements. Planned Corrective Action: Today’s Marlboro County Housing Authority management acknowledges the auditor’s finding that documentation to support certain CFP drawdowns was incomplete or missing and concurs that this represents a failure to comply with Uniform Guidance documentation requirements under 2 CFR §200.302 and §200.403. The Authority recognizes the importance of maintaining complete and accurate supporting records—such as invoices, contracts, and payment documentation—to substantiate costs charged to federal programs and ensure allowability and allocability under the Capital Fund Program. Effective October 1st, 2024, all draw requests under the Capital Fund Program ARE supported by: • Approved contracts or purchase orders • Invoices or other source documents • Proof of payment (e.g., canceled checks, ACH confirmations) • Documentation clearly linking each expense to an approved activity in the CFP Annual Statement

Re: FY23-24 Federal Single Audit Finding (2024-001) Name(s) of Contact Person(s) Responsible for Corrective Action: Sean Perez, Finance Director; Jeff Gilbreath, Executive Director Hawaiʻi Community Lending (HCL) is diligent and ensures all grant requirements are met for Federal, State, and private funding awards. Due to the transitioning of its Finance Directors upon the start of the FY23-24 audit, the proper procedures to correct the CDFI ERP project account were miscommunicated, and the Schedule of Expenditures for Federal Awards (SEFA) were not reduced to reflect the proper adjustments. The corrective action being taken by HCL leadership is to ensure all loans disbursed and charged to restricted grants are reviewed thoroughly by the Finance Director. The Finance Director will review all eligibility requirements that are met, to include the eligible mapping area, as required and provided by the funder. This thorough review of eligibility will ensure that all loans charged to restricted funding will be properly allocated and charged correctly. In addition to the thorough review mentioned above, HCL will develop procedures to review the SEFA, in detail, which is prepared by a third-party accounting vendor. The procedures will include an extensive review of expenditures by the Finance Director and subsequent review and approval by the Executive Director to ensure all expenses are eligible and allocated properly to our federal grants. Once the SEFA has been fully reviewed and approved by the Finance Director and Executive Director, it will be forwarded to the auditors. Additional staff may be involved in the review and eligibility confirmation process to ensure accuracy. Internal audits of expenditures will also be completed on a quarterly basis. The anticipated completion date of this corrective action plan is June 30, 2025. Mahalo, Jeff Gilbreath Executive Director Hawaiʻi Community Lending

Finding 2024-030 Rehabilitation Services Vocational Rehabilitation Grants to States, ALN 84.126 - Accuracy of Financial Reports Management Views LEO agrees with the finding. Planned Corrective Action The LEO Finance Division will implement the following: 1. Improvements to documented procedures for the Vocational Rehabilitation Financial Report (RSA-17) preparation to ensure consistency and accuracy of financial report submissions. 2. Specific RSA-17 training for applicable staff and management in order to enhance knowledge of reporting requirements. 3. An additional layer of management review on RSA-17 financial reports prior to submission. Anticipated Completion Date September 30, 2025 Responsible Individual(s) Heidi Parker, LEO Chris Johnson, LEO

All grant-related information is being thoroughly tracked by the employees currently responsible for submitting reimbursement claims. At this time, Janna Wright and Stacy Swindle are the only staff members filing claims. Their process includes running a Flexible Period Report from Munis, generating a Statement of Revenues and Expenditures from the legacy system for payroll, printing copies of checks, invoices, timesheets, and any other transaction listed on the reports. They also maintain detailed tracking spreadsheets to monitor both expenses and claims, and they collaborate with Directors to ensure accuracy. Once grant funds are received, the payments will be entered into Munis in a timely manner to maintain accurate financial records.

Condition: During compliance testing of the District's accounting records to the expenditure report filed with the Illinois State Board of Education, we noted the District overclaimed $18,940 of expenditures at 6/30/24. Upon review of the general ledger and quarterly expenditure report, it was determined that the District erroneously overstated their claim amount on two function object codes by a cumulative amount of $18,940. Under 2300-200 (23-4300-00), total expenditures were $3,147 but District claimed $12,999, resulting in an overclaim of $9,852. Under 1000-200 (24-4300-00), total expenditures were $31,255 but District claimed $40,343, resulting in an overclaim of $9,088. Plan: Management will periodically review the itemized budget and ensure claimed expenditures fall within or file amendments as necessary for any changes. Anticipated Date of Completion: 6/30/2025. Name of Contact Person: Justin Whitten, Business Manager. Management Response: Management will work together with staff to ensure that grant budgets and claimed expenditures are periodically reviewed and amended as necessary.

Condition: During compliance testing of the District's accounting records to the expenditure report filed with the Illinois State Board of Education, we noted the District overclaimed $727 of expenditures at 6/30/24. Upon review of the general ledger and quarterly expenditure report, it was determined that the District erroneously overstated their claim amount on two function object codes by a cumulative amount of $727. Under 2560-100, total expenditures were $256,193 but District claimed $256,699, resulting in an overclaim of $506. Under 2560-200, total expenditures were $81,610 but District claimed $81,831, resulting in an overclaim of $221. Plan: Management will periodically review the itemized budget and ensure claimed expenditures fall within or file amendments as necessary for any changes. Anticipated Date of Completion: 6/30/2025. Name of Contact Person: Justin Whitten, Business Manager. Management Response: Management will work together with staff to ensure that grant budgets and claimed expenditures are periodically reviewed and amended as necessary.

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the review and approval of expenditures and maintenance of supporting documentation surrounding federal awards. Action Plan:  See the “Conduct Training Sessions for Expenditures Personnel” and “Audit of all FY25 YTD Expenditures” sections of management’s action plan for finding 2024-001  Review and update the Allowable Funds document o Locate the latest Allowable Funds Guide created by KIPP Delta. o Review and update the guide as necessary. o Store the updated guide in a central cloud location for responsible personnel to access easily. o Process completed as of April 17, 2025.  Develop a Federal Funds Workflow in Avid for POs and invoices: o A designated finance team member must review all federally funded purchases to improve the federal funds purchasing process. Steps include:  Create a separate workflow in Avid for POs and invoices to track federal purchases.  Ensure a purchase order is created before an invoice is submitted and paid.  Attach all required documentation to the PO, as with all other expenditures.  Verify that the expenditure complies with the Allowable Funds guide o Anticipated completion date of May 30, 2025.

Finding 2024-002: Review of Compliance Matrices and Narratives The single audit report included the following recommendation: We recommend that Amtrak establishes a more defined timeline for the events that would trigger the update and review of the compliance matrices and compliance narrative, which could include execution of any new federal awards or amendments to existing federal awards. Additionally, Amtrak should establish a process where the modifications to the provisions are assessed for materiality/applicability and include documentation of the respective conclusions as part of the review process. Management Response/Status of Action Plans: Amtrak acknowledges the need to augment process documentation around the controls over the preparation and updates to the compliance matrices. The company is in the process of updating these controls now and will incorporate the identified findings in developing more robust controls. The company specifically notes the need to add more documentation on considerations for what provisions are updated in the compliance matrices and the evidence of review. The review procedures and controls are being enhanced to include a checklist to improve the review. This checklist will be completed by both the compliance matrix creator (upon creation) and the compliance matrix reviewer/approver (upon review and final approval). The contact for this item is Lucia Butts, AVP Funding and Grants and Meghan Histand, Director of Discretionary Grants. Amtrak anticipates fully remediating this finding by September 2025.

Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) The single audit report included the following recommendation: We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner Management Response/Status of Action Plans: Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The contact for this item is Lucia Butts, AVP Funding and Grants. Amtrak anticipates fully remediating this finding by September 2025.

Views of responsible officials and planned corrective actions: The Clinic will be seeking professional consultation and guidance on a process to support and enforce monthly reconciliations of the amounts submitted for the grant with the amounts booked within the system, using appropriate grant-tracking schedules. Relevant staff will be retrained, and a monthly review will be completed by an appropriate professional and submitted to the Chief Executive Officer (CEO). Personnel responsible for implementation: Deborah Lerner, CEO and Board of Directors Date of implementation: July 1, 2025

Finding 2024-027 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-023 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. D. Established a Contract and Compliance Unit responsible for overseeing the filing of the FFATA report. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

Finding 2024-026 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: Yes; 2023-022 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

Finding 2024-024 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: Yes; 2023-020 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

Finding 2024-023 U.S. Department of Health and Human Services AL No. 93.778 Medical Assistance Program (Medicaid; Title XIX) Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-019 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. D. Established a Contract and Compliance Unit responsible for overseeing the filing of the FFATA report. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

Finding 2024-021 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-016 Auditee’s Corrective Action Plan: The Federal Financial Report (FFR) is a cumulative report covering the entire project or award period, which for this grant spans from March 1, 2020, to February 28, 2025. As a result, the cumulative amounts reported on the FFR will not align with the amounts recorded in the general ledger for fiscal year 2024. BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. D. Established the Contract and Compliance Unit responsible for overseeing the filing of the FFATA report. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

Finding 2024-020 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Earmarking Repeat Finding: No Auditee’s Corrective Action Plan: BCHD fiscal will revise its internal processes to ensure compliance with 2 CFR 200 and the OMB compliance supplement (Part IV) by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include training on earmarking requirements. B. Established a Contract and Compliance Unit which responsibilities include ensuring program and fiscal staff are informed of all grant compliance requirements. C. Establish a process for periodic review by BCHD Fiscal internal audit team of grant expenditure reports and general ledger details to ensure compliance with the earmarking requirements. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

Finding 2024-019 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Cash Management Repeat Finding: No Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

The reconciliation process implemented in Finding 2024-001 includes a formal method of matching drawdowns to allowable expenditures. Each grant will continue to be tracked in a separate cost center and La Casa will document the reconciled expenditures in the general ledger to amounts drawn from each grant. The monthly reconciliation will be reviewed by the CFO to ensure that revenue is recognized in accordance with ASC 958-605 and that federal expenditures reported on the SEFA and financial statements comply with 2 CFR §§200.302, 200.303, and 200.305. The CFO will utilize the reconciliations to prepare the SF-425 filings and confirm that cumulative drawdowns reconcile to allowable costs and recorded revenues. All supporting documentation will be retained electronically and included in monthly close procedures.

U.S Department of Treasury 2024-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommended that the organization implement a review and approval process for all quarterly progress report 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 guidelines and procedures for the review and approvalprocess. •Regularly monitoring and auditing the review process to ensure compliance. Explanation of disagreement with audit finding: Management concurs with the finding. Action taken in response to finding: Additional fiscal staff has been hired to assist with various fiscal tasks including grant compliance and reporting. The guidelines are being updated, the checklist expanded, and documentation of secondary approval of reports is being retained. Grant guidelines, procedures, and checklists will be utilized to ensure compliance is maintained. Name(s) of the contact person(s) responsible for corrective action: Pete Winton Planned completion date for corrective action plan: The above action plan will be implemented in fiscal year 2025.

Finding No. 2024-001 NONCOMPLIANCE WITH US GAAP – VARIABLE INTEREST ENTITIES (VIE) We acknowledge the audit finding and appreciate the auditor’s diligence in identifying the issue. After evaluating the matter, we agree that the effect on the consolidated financial statements is immaterial and does not impact the fair presentation of our financial position, results of operations, or cash flows. Additionally, after assessing the costs and benefits of remediation, we have determined that the corrective action required to fully address this issue is not cost-effective at this time. The resources required would outweigh the potential benefits, particularly given the immaterial nature of the issue and the lack of impact on users of the financial statements. We, will continue to monitor this area as part of our internal controls framework and will reassess if conditions change or if the issue becomes material in future periods.

CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 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 sections 200.328 and 200.329 of the Uniform Guidance.CORRECTIVE ACTION PLAN: The School District concurs with the above noted finding. The School District has employed a new Business Manager whose responsibilities include the oversight of the financial management system and the posting of all transactions into that system. Procedures will be put into place during the remaining months of the 2024-2025 fiscal year, and all subsequent years, for ensuring federal program expenditures are properly coded within the District’s financial management system so as allow for proper reporting related to those expenditures.

Action Taken: HEA's leadership team, including our Director of Finance, will develop an updated version of our accounting and procedures manual that includes written policies related to all applicable compliance areas under Uniform Guidance. This will be a priority for the leadership team and will be developed by May 30, 2025 and reviewed by HEA board members by June 30, 2025. HEA's leadership team will work with staff to ensure all policies and procedures are implemented in our new fiscal year (beginning in July 2025). Contact Person: Sarah Metzler, HEA President/CEO; Aliah Carolan-Silva, HEA VP of Research; Cindi Dixon, HEA Director of Finance Expected Completion Date: July 2025

FINDING 2024-003 Finding Subject: COVID- 19 – Education Stabilization Fund – Reporting Summary of Finding: The School Corporation submitted one ESSER III report where the expenses per the report did not tie to the ledger or the Schedule of Expenditures of Federal Awards by approximately $300,000. Contact Person Responsible for Corrective Action: Matt Miles Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will ensure ESSER reports are saved and tie to the accounting records and will improve record keeping of supporting documentation. If any edits are made to the reports, the Curriculum and Accounting Departments will document the reason for all changes. Management in each department will review all ESSER reports and sign off on all documentation. Anticipated Completion Date: Corrective action steps have been implemented and will be refreshed.

Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures. Management expects to present the policies to the board for approval at the May 2025 board meeting.