Corrective Action Plans

Finding 2025-012: Untimely ARP ESSER Reporting Corrective Action: The District will establish a formal federal reporting compliance process to ensure timely, complete, and accurate submission of all required ARP ESSER and other federal reports. Specific Actions: • Develop a centralized federal compliance calendar that includes all required deadlines, including ARP ESSER FS-10F Final Expenditure Reports. • Create written procedures for periodic review and tracking of upcoming federal reporting deadlines. • Assign responsibility to designated staff to monitor reporting requirements and coordinate timely submission. • Conduct supervisory review of all federal reports prior to submission to ensure completeness and accuracy. • Provide training to staff responsible for federal reporting on deadlines, procedures, and compliance requirements. Responsible Party: School Business Manager Anticipated Completion Date: Procedures implemented by March 31, 2026, with ongoing monitoring thereafter.

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

Recommendation The Organization should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding No Action Taken A new federal cash draw down form has been created that will ensure all cash draw downs are reviewed and approved by the CEO. If there are any question regarding this plan, please e-mail Diane Manning at dvdlmanning@usmhs.org.

Finding No: 2025-004 Condition: The District receives Title I funding and determines eligibility for schoolwide programs based on attendance numbers derived from free and reduced lunch counts. During the audit, we noted that the district’s process for compiling these attendance numbers involves the grant manager obtaining a report from the Business Office, which is generated from the food service platform as of a specific day. However, the district was unable to reproduce the report used to complete the Title I application and supporting documentation for the reported figures was not available for review. Plan: The District will maintain all reports used to compile attendance figures for the Title I grant. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Mark Orszula, CSBO

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – ALN NOS. 84.027 AND 84.173 2025-001 Internal Control Over Compliance With Federal Allowable Costs Requirements Finding Summary 2 CFR § 200.302(b)(3) requires Independent School District No. 911 (the District) to maintain records that adequately identify the source and application of funds for federally funded activities in accordance with 2 CFR 200 Subpart E – Cost Principles. The District did not have sufficient controls to assure adequate and timely documentation of time and effort was created and retained to support salary costs charged to federal programs and ensure compliance with this requirement. Corrective Action Plan Actions Planned – The District will review policies and procedures for maintaining time and effort documentation for its employees in its federal programs to ensure compliance with the Uniform Guidance in the future. Official Responsible – Director of Finance and Operations, Christopher Kampa. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Director of Finance and Operations, Christopher Kampa, will assure appropriate internal controls and procedures are updated and in place to ensure adequate time and effort documentation is maintained to support all employee salaries charged to federal programs in the future.

Planned Corrective Action: The district will implement controls for monitoring reporting grant requirements and grant expenditures to ensure compliance with reporting and period of performance requirements for federal grants. Anticipated Completion Date: 6/30/26 Responsible Contact Person: Hiwot Abraha

The Board agrees with this deficiency. However, the Board has not received Federal financial assistance in over 20 years that would require the Board to be subject to a Single Audit. The Board will internally develop written financial management system requirements or hire an outside grant writing manager to assist in developing written fiscal policies.

FINDING 2025-002 Finding Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: The School Corporation was unable to provide proper documentation for 5 out of the 25 claims selected for control testing. The School Corporation was unable to provide proper documentation to support the determination of the amount of the teachers total salary that was allocated to the federal award. Contact Person Responsible for Corrective Action: Melissa Raaf Contact Phone Number and Email Address: (812) 649-2591 / missy.raaf@sspencer.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: In the future the School Corporation will ensure that all proper documentation is saved in a binder or electronically. Anticipated Completion Date: Effective FY 2025/2026

The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 1 6, 2022, to administer the federal grants to ensure that the Town would comply with all federal program requirements. The Town was led to believe that they were in compliance with all federal program requirements. The Town will develop, formally adopt, and implement written policies and procedures to comply with Uniform Guidance (2 CFR 200).

Significant Deficiency Item 2025-007 - Cash Management - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 H80CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 HBHCS46163-03-01 During our audit, we noted that there is no evidence of review and approval of drawdowns from the Health Center Program Cluster and the supporting records. Recommendation: We recommend that LBUCC implement a policy that requires all drawdowns and supporting documents to be reviewed and that such review and approval be documented. Action Taken: LBUCC revised the drawdown policy which now includes a review and approval from the CFO and the process is documented. Effectivity Date: Implemented 12/3/2025.

2025-001 Reporting US Department of Education – AL #s10.553, 10.555, 10.559 and 10.582 Child Nutrition Cluster Condition: The District submitted monthly child nutrition reimbursement claims that contained inaccurate meal counts for multiple months during the fiscal year. Specifically, the District overstated reimbursable meal counts due to errors in including non-reimbursable meals served. Additionally, the claims were not subject to an independent review prior to submission to ensure accuracy and completeness. Name of Contact Person: Ann Berman, Business Manager Plan of Action: The District will revisit the internal control processes surrounding the grant reporting and reimbursement process to ensure meal count information submitted is within program requirements of Child Nutrition Cluster programs. In the event there are questions surrounding meal count and other information subject to reporting, the District will continue to rely on timely guidance from external governmental accounting consultants, the Oregon Department of Revenue, and the Oregon Department of Education.

Management's Response/Planned Corrective Action: The Controller will ensure a process of dual review/approval on reporting is followed going forward to aid in identifying any reporting inconsistencies or misunderstanding of reporting instructions. This will be undertaken immediately.

Finance department will set up the coding process and begin including Departments that match project codes for all federal programs. Corrective Action Owner: Lisa Peacock, Comptroller with assistance from the Senior Accountant, and report to Francesca Rattray, CEO

Corrective Action Plan for Federal Award Audit Finding 2025-001 Finding Title: Allowable Costs/Cost Principles – Improper expenditure recognition Federal Program: Title II, Part A, Teacher & Principal Training and Recruiting Assistant Listing Number: 84.367A Federal Agency Name: U.S. Department of Education Passed-Through Agency Name: Texas Department of Education Type of Finding: Significant Deficiency in Internal Control over Compliance Description of Corrective Action The District acknowledges the internal control system did not timely detect the improper recognition of expenditures in the incorrect fiscal period. It is important to emphasize that the expenditures identified were ultimately removed from the current year activity and were excluded from the year-end reimbursement request. The District commits to strengthening its year-end closing procedures and providing comprehensive training to address the noted deficiency in monitoring and review. The following actions will be taken: Mandatory Staff Training on Expenditure Cut-off and Accruals The District will develop and implement mandatory, targeted training for all personnel responsible for processing, recording, reconciling, and reviewing federal grant expenditures, with a specific focus on year-end cut-off procedures and proper expense recognition (accruals versus prepaid expenses). Implementation of Formal Grant Expenditure Cut-off Review Procedure A formalized closing procedure will be implemented for all federal awards, ensuring a mandatory, documented review of expenditures and payables near the fiscal year-end. Persons Responsible Timothy Momanyi, Chief Financial Officer Thania Gonzalez, Assistant Superintendent of Business and Finance Anticipated Completion Date The initial staff training will occur by May 31, 2026. The full implementation of the new procedures, with documented adherence by all responsible staff, will be complete by June 30, 2026, ensuring the new controls are fully operational before the close of the 2025-2026 fiscal year.

Finding: 2025-001 Incomplete Tenant Records - Section 8 HCV Program (ALN 14.871) Condition: 1. For one (I) tenant, income verification was not performed for the current During our review of forty ( 40) tenant files under the Section 8 Housing Choice Voucher (HCV) Program, we identified multiple instances of missing documentation and compliance lapses: year, and prior year income was rolled forward. The HUD-50058 (Family Report) form was reviewed in the PIC system but was not present in the tenant file. 2. For one (I) tenant, the Approved Lease, HUD-52517 (Request for Tenancy Approval), and HUD-52641 (HAP Contract) forms were not present in the tenant file. Recommendation: We recommend that the Housing Authority strengthen internal controls over tenant file documentation by implementing a standardized checklist to ensure all required forms and records are consistently retained. Staff should receive periodic training on HUD documentation and compliance requirements to reinforce expectations and reduce errors. Management should also conduct routine internal reviews to verify that income verification and lease documentation are properly completed and maintained. These measures will help ensure that tenant eligibility and payment determinations are adequately supported and compliant with federal regulations. Planned Corrective Action: To address these findings, the Housing Authority will implement a standardized checklist for all tenant file changes, ensuring that all required forms and records are consistently retained. The Program Administrator and staff will conduct monthly reviews of completed re-examinations to verify that all necessary documentation is present and properly filed. All paperwork related to annual re­exams, transfers, move-ins, and interims will be scanned into the Lindsey software system within five working days of receipt, prior to physical filing. The Program Administrator will organize monthly training sessions on HCY/S8 program requirements, with participation tracked to ensure all staff attend. Weekly spot checks will be performed to confirm that the checklist is being used appropriately. These actions will be supported by updated training materials, access to the Lindsey software, and dedicated staff time for audits and training. To mitigate risks such as incomplete documentation, missed scanning deadlines, or low training attendance, the Housing Authority will implement pre-audit checklists, set automated reminders for staff, and make training mandatory. Management will monitor the implementation of these corrective actions and conduct follow-up reviews to ensure sustained compliance with HUD regulations.

2025-002 – Lack of Written Policies and Procedures. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Village. As a result of this condition, the Village did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Village review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Village has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Village Council before the end of fiscal year 2026. Responsible Person. Vicki Burrell, Village Clerk. Anticipated Completion Date: February 2026.

Finding 2024-002 – Untimely and Inaccurate Preparation of the Schedule of Federal Awards (SEFA) (Sig-nificant Deficiency) Financial Reporting / Internal Control Over Compliance CFDA Title and Number: 97.036 Public Assistance Program – Disaster Grants Name of Federal Agency: Federal Emergency Management Agency (FEMA Internal Control over Compliance: Skills Knowledge and Education (SK&E) CFDA Title and Number: 66.202 Wastewater Treatment Plant Name of Federal Agency: U. S. Environmental Protection Agency Internal Control over Compliance: Skills Knowledge and Education (SK&E) Criteria: The Uniform Guidance (2 CFR §200.510(b)), requires the auditee to prepare a Schedule of Federal Ex-penditures of Federal Awards (SEFA) that accurately reports federal expenditures for each federal award, including the Assistance Listing number, federal agency, pass-through entity (if any), and amount expended for the fiscal year. In addition, (2 CFR §200.302(b)), requires financial management systems that provide for accurate, current, and complete disclosure of federal award expenditures and support reliable financial reporting and reconciled to the general ledger. Condition: The auditee did not timely or accurately prepare the Schedule of Expenditures of Federal Awards. Specifically: • The initial SEFA provided to auditors was significantly later than the requested date, and required signifi-cant auditor inquiry and assistance to complete. • Management did not demonstrate an understanding of the dates and amounts of federal expenditures to be reported on the SEFA. • The SEFA provided to auditors did not include all federal awards. • Required Assistance Listing numbers were not included for federal programs. • The format of the SEFA was not easily reconcilable to the general ledger, and required auditor-identified corrections and adjustments in order to fairly present federal expenditures in accordance with federal re-quirements. Cause: The condition resulted from: • An insufficient understanding of SEFA preparation requirements, including which expenditures to report and how federal awards should be presented; and • Inadequate internal controls over the preparation, review, and reconciliation of the SEFA to the account-ing records. Effect or Potential Effect: As a result of these conditions: • There was an increased risk that federal expenditures were incomplete, inaccurate, or improperly re-ported. • Management’s ability to determine total federal expenditures, for the fiscal year, including evaluation of Single Audit applicability, was impaired. • The entity relied on auditor assistance to identify omitted awards, reconcile amounts and bring the SEFA into compliance with federal reporting requirements, indicating a lack of effective internal controls over federal financial reporting. Questioned Cost: None noted here. Repeat of a Prior-Year Finding: No Recommendation: We recommend the entity strengthen its internal controls over federal financial reporting by: • Developing and documenting procedures for the timely preparation of the SEFA, including identification of all federal awards, correct Assistance Listing numbers, and determination of reportable expenditures. • Establish a process to reconcile the SEFA to the general ledger and to supporting records to ensure com-pleteness and accuracy. • Providing training to appropriate personnel regarding Uniform Guidance SEFA requirements and the de-termination of federal expenditures for reporting and audit threshold purposes. • Establish cutoff procedures to capture year-end accruals/deferred items and ensure completeness of ex-penditures for the SEFA. Views of Responsible Officials: Port of Brookings Harbor acknowledges this finding. Management recognizes that it did not fully understand SEFA reporting requirements. Management is committed to enhancing its under-standing of federal reporting requirements and strengthening internal controls to ensure future SEFA’s are prepared accurately, completely, and in a timely manner. Corrective Action Plan: While the Port disagrees with the characterization that the SEFA preparation was untimely, the Port acknowledges that inaccuracies were present in the report. The inaccuracies occurred because the Port believed it was following the direction and guidance contemplated in the Municipal Auditing Services Proposal provided by Umpqua Valley Financial, LLC, which indicated time would be dedicated to assisting the Port with grant administration regulations and related compliance requirements. Nevertheless, the Port accepts responsibility for strengthening its internal processes and will immediately develop and implement formal procedures for timely and accurate SEFA preparation. In addition, the Port will provide Uniform Guidance and SEFA training to appropriate perso,mel to improve compliance and federal financial reporting practices. The Port has attached a copy of the Municipal Auditing Services Proposal from Umpqua Valley Financial, LLC to demonstrate that the Port proactively sought guidance well in advance of the completion of the fiscal year and prior to the commencement and finalization of the audit process. Port Management remains committed to improving its understanding of Uniform Guidance requirements and strengthening its federal financial reporting and grant compliance practices moving forward. Sincerely, Travis Webster Port Manager

The Village will establish formal UG policies and procedures.

The City will review the requirements for written policies and will adopt policies, as needed, or will revise its current policies as needed to comply with Uniform Guidance.

Management has reviewed the finding and recommendations. We note that this item was identified as a repeat issue primarily due to the timing of the prior year's audit. Because the FY23 findings were delivered after FY24 had already concluded, the Organization did not have the opportunity to incorporate the auditors' feedback during the FY24 audited period. However, the Organization took immediate, proactive steps to deploy enhanced internal controls for FY25 to ensure continuous alignment with federal standards. To ensure strict adherence to 2 CFR § 200.302(a), we are actively implementing a more regular reconciliation process between government grant revenue claimed and actual revenue earned. As a key part of this initiative, the Organization has developed and deployed new internal financial tools designed to incorporate automation into our daily workflows. By utilizing these automated tools-such as standardized templates for recording cash receipts and systematically clearing Accounts Receivable-we have significantly enhanced the accuracy of our data entries and reduced the risk of manual misstatements. Our ongoing objective is to leverage these tools to establish clear, standardized documentation procedures, ensuring that all financial reports and claims are consistently generated from a reconciled general ledger. Management remains fully committed to dedicating the necessary time and resources to mature these financial controls and ensure robust compliance with federal regulations.

The Parish has written a Standard Operating Procedure for "Grant Maangement - 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.

The City acknowledges the finding. The City will strengthen procedures to identify, track, reconcile, and report federal award activity throughout the fiscal year so that a complete and accurate SEFA can be prepared in a timely manner for future audit periods. Procedures will include maintaining award documentation sufficient to identify the federal agency/program, Assistance Listing number, award or loan identifiers, expenditures or loan proceeds, outstanding federal loan balances, sub-recipient amounts if any, and required SEFA notes.

Organization Response: Management acknowledges the auditors’ comments, with the clarification below, and has taken the actions listed below. The overstatement noted in this finding was a misstatement. The omission noted in this finding references funds received from state and county agencies. Therefore, the funds were recorded consistent with the information and documentation provided by the pass-through entity (Cascade County) which did not clearly identify the original funding source as the federal entity. To ensure internal controls over funding sources and expense reporting, the grant award and processing policy has been reviewed and updated to include due diligence of original funding sources.

CORRECTIVE ACTION PLAN The Town of Uxbridge, Massachusetts respectfully submits the following corrective action plan for the year ended June 30. 2024. Audit period: July 1, 2023 through June 30, 2024 The finding from the June 30, 2024, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Audit Finding Reference: 2024-003 Document Policies and Procedures Over Federal Awards Views of responsible officials: The Town agrees with the recommendation to implement written policies and procedures to be in accordance with the Uniform Guidance. Planned Implementation Date of Corrective Action: The Town plans to implement recommendations for the next fiscal year. Official Responsible for Implementing Corrective Action: Kurt Ginthwain Finance Director/Town Accountant

Finding No. 2024-001 Implement System-Based Tracking of Federal Expenditures Finding: During our review of the SEFA, we noted that CAIR-CA utilizes workbooks outside of its accounting software to track federal expenditures. The workbooks do not reconcile directly with the general ledger (GL), so management performs a separate reconciliation to support the SEFA amounts. This approach was similarly observed in the prior year's audit. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already updated the accounting system to incorporate grant-specific tracking codes to further align with federal reporting standards. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. As part of a layered approach to internal controls, excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: November 20, 2025