Corrective Action Plans

2025-001 REPORTING ALN 20.106 Airport Improvement Program U.S. Department of Transportation Federal Aviation Administration Federal Award No. 3-12-0046-064-2024 2024/2025 Funding Recommendation: The Airport, a component unit of the City, should develop a process to ensure reports are submitted timely for all awards including re-assigning tasks when personnel are on leave. Corrective Action: Airport management has set up a process whereby the quarterly reports are reviewed by another team member to ensure the reports are completed and submitted in the time frame required by the Federal Aviation Administration. This review will be completed by the Accounting Manager who understands the importance of submitting the information and, if they are not completed, will complete and submit the reports. Any issues or omissions observed by the Accounting Manager with submitting the required reports will be reported to the Director of Finance and Administration for further follow-up with the staff member who is primarily responsible for this task Responsible party: Mike O’Dell, Director of Finance & Administration Date Expected to be Corrected: March 17, 2026

2025-002 DISALLOWED COSTS ALN 97.083 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program U.S. Department of Homeland Security Federal Emergency Management Agency (FEMA) Federal Award No. EMW-2022-FF-00868 2024/2025 Funding Recommendation: Independent review of program reimbursement requests and reports should be consistently performed and documented prior to submission the grantor. Corrective Action: The City agrees with this finding and will establish internal procedures for review of program reimbursement requests before submission to the grantor. The Grant Compliance Manager will prepare the reimbursement requests and semi-annual reports and provide to the Director of Finance for review and approval prior to submission. This corrective action will take effect immediately. Responsible party: Rebecca Thibert, Grant Compliance Monitor Date Expected to be Corrected: March 17, 2026

Reviews of Grant Reports Recommendation: The City should have controls in place to ensure all reports are reviewed prior to submittal and the review is documented. Management Response: Management agrees with the finding. Management will implement procedures to document independent review of all reports submitted to the U.S. Treasury to ensure completeness, accuracy, and timeliness. Anticipated Completion Date: Immediately Responsible Contact Person: Yannick Ngendahayo, Finance Director

Cognizant Agency: U.S. Department of Health and Human Services (HHS) Western Arizona Council of Governments (WACOG) respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024 – June 30, 2025 The finding from the schedule of findings is discussed below. FINDING—FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF AGRICULTURE 2025-001 Child and Adult Care Food Program – Assistance Listing No. 10.558 Recommendation: WACOG should enhance internal procedures related to the continued review and monitoring of vendors used under cooperative contracts. Management should implement standardized checklists and maintain a centralized repository for documenting vendor due diligence activities, including prequalification evaluations and suspension and debarment verifications. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Vendor due diligence will be performed every three years, encompassing the assessment of two prequalified contractors and verification that vendors are not suspended or debarred via sam.gov, as required by CFR 200 and consistent with WACOG’s purchasing policies and procedures. Records will be maintained in alignment with the record retention policy and provided to auditors upon request. These records will include procurement staff suspension verifications as well as documentation of all vendor due diligence processes. Program staff responsible for procurement will store these records in a centralized repository, with an additional copy submitted to the fiscal department. Names of the contact persons responsible for corrective action: Susan Dempsey, Deb Schlamann, and Gina Whittington Planned completion date for corrective action plan: June 30, 2026. If HHS has questions regarding this plan, please call Susan Dempsey at 928-217-7130 or Deb Schlamann at 928-217-7146.

The Organization will develop and implement formal, documented monitoring procedures designed to ensure the accuracy of financial and programmatic reporting, as well as to track and maintain compliance with matching, level of effort, and earmarking requirements.

The Organization will develop and implement formal written policies and procedures to ensure that payroll charges to federal awards are based solely on actual costs incurred, in compliance with federal requirements. As part of this effort, the Organization will require all employees whose salaries are charged in whole or in part to federal awards to complete time and effort documentation for each payroll period. This documentation will accurately reflect the actual hours worked on federal program activities as well as other activities, as applicable. Supervisors or designated management personnel will review and approve all time and effort reports on a timely basis. Evidence of this review, including signatures or electronic approvals, will be maintained in accordance with record retention policies. The approved time and effort documentation will serve as the basis for allocating personnel costs to federal awards. The Organization will ensure that payroll charges are adjusted, if necessary, to align with actual time worked. Documentation supporting these allocations will be retained and made available for audit or review. Training will be provided to all relevant staff to ensure understanding and consistent application of the new procedures. Implementation of these policies and procedures will occur June 15 2026, and ongoing monitoring will be conducted to ensure compliance.

Condition: The District incurred program expenditures that were not charged in accordance with the approved grant budget. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. The District will strengthen internal controls to ensure expenditures are reviewed for compliance with the approved grant budget prior to being claimed for reimbursement. Going forward, the District will compare expenditures to the approved budget detail and ensure costs are charged to the appropriate budget category.Responsible Person: Dr. Mable Alfred, Interim Superintendent. Anticipated Completion Date: June 30, 2026

Condition: The District claimed expenditures that did not have adequate supporting documentation, such as invoices, receipts, purchase orders and proof of payment. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Grant expenditures will be reviewed and approved by appropriate personnel prior to reimbursement requests being submitted. Responsible Person: Dr. Mable Alfred, Interim Superintendent. Anticipated Completion Date: June 30, 2026

A. OBJECTION On December 29, 2025, following LPSB’s submission of its Response to the Draft Findings of Kolder, Slaven, and Company, LLC (“KS&C”) relating to its 2024-2025 Annual Audit, LPSB received two additional findings characterized as Disclaimers of Opinion. The issuance of these post-response Disclaimers of Opinion regarding the findings highlights KS&C’s apparent lack of objectivity and its failure to adhere to generally accepted government auditing standards in conducting the 24-25 audit. A Disclaimer of Opinion “is expressed when the auditor is unable to obtain sufficient appropriate audit evidence on which to base the opinion, and the auditor concludes that the possible effects on the financial statements of undetected misstatements, if any, could be both material and pervasive.”1 According to LLA, “a local auditee that provides for an audit report with a disclaimer of opinion” is regarded as being in noncompliance with its reporting requirements to LLA under the audit law (Louisiana Revised Statute 24:513). LLA further expects the CPA to include in such a report a finding that provides a full explanation for the disclaimer of opinion.2 The two supplemental responses provided are, however, substantially lacking the “full explanation” mandated by the Legislative Auditors for the serious allegations being presented by KS&C. As with its other findings, these recent findings fail to cite any specific conditions present during the audit period that would have precluded KS&C from forming a conclusion. Therefore, as with the original findings, LPSB, on January 6, 2026, again requested that KS&C provide supporting evidence for its claim that it was unable to obtain “evidence regarding significant financial statement balances, transactions, and disclosures.” KS&C responded by stating that these new findings were based on Finding 16 - Invoices Paid Without Sufficient Supporting Detail (IC & C), Finding 26 - Management Override of Established Internal Controls (IC), Finding 31 - Unsupported Experience-Based Pay Increases (IC), and other undisclosed matters. Notably, none of these specific findings are instances where KS&C was prevented from forming a conclusion. To the contrary, the original findings identified by KS&C reflect otherwise. For instance, in Finding 16, KS&C notes it “tested 539 and identified 213 in which invoices were paid without sufficient documentation.” Despite KS&C’s assertions, LPSB has at no point failed to provide information to KS&C upon request (see Corrective Action sections below). In fact, KS&C issued 33 Findings, each purportedly substantiated by documentation. As stated in LPSB’s Response, a request was made by LPSB for KS&C to produce the referenced specific supporting documentation. However, KS&C declined to provide the documentation. Auditing standards stipulate: “Auditors should document supervisory review, before the report release date, of the evidence that supports the findings and conclusions contained in the audit report.”3 They further require: “Auditors should document any departures from the GAGAS requirements and the effect on the audit and on the auditors’ conclusions when the audit is not in compliance with applicable GAGAS requirements because of law, regulation, scope limitations, restrictions on access to records, or other issues affecting the audit.”4 Despite LPSB, in its Response and communications prior thereto pointing out erroneous references to the law and facts, KS&C refused to modify its findings. Instead, it introduced these two ambiguous Disclaimers of Opinion, alleging that LPSB failed to provide necessary information for KS&C to reach a conclusion. However, a cursory review of its original findings clearly reflect that KS&C did reach conclusions, which they assert were based upon conditions found during their investigation. Which is it? Are KS&C’s findings supported or not? KS&C’s ex post Disclaimers of Opinion not only misrepresent LPSB’s cooperation and full disclosure of information, but they are also predicated upon the unfounded assertion that LPSB’s “representations, including written representations required under auditing standards, could not be relied upon due to concerns regarding the reliability of management representations.” After 33 years of engagement with LPSB audits, KS&C has now made the unwarranted claim that LPSB’s representations are unreliable, without pointing to a specific instance of unreliability. Ironically, it is the auditor’s own representations that are demonstrated to be unreliable, as evidenced by the submission of these two vague and contradictory Disclaimers of Opinion. “[A] CPA cannot enter into the engagement with a pre-conceived notion that the local auditee is doing everything wrong. Going into an engagement with [this] attitude impairs the independence of the CPA firm.” The two findings, submitted after LPSB responded to its original findings, do not meet the standards set forth in the Louisiana Governmental Audit Guide. They contradict the original findings, misrepresent LPSB’s cooperation throughout the audit, insert slanderous statements as to the reliability of LPSB’s representations, and fail to provide a full explanation for the disclaimer of opinion. KS&C should remove these findings from its report. 1 LGAG 400-1160, Types of Auditor’s Opinions 2 LGAG 400-1160, Types of Auditor’s Opinions 3 GAO-24, Sections 6.31 (emphasis added) 4 GAO-24, Sections 6.32 B. CORRECTIVE ACTION Prior to the financial audit, Lafayette Parish School Board (LPSB) staff prepared reports and documentation for at least 185 requests that were made by the external auditors. These requests consisted of, but were not limited to, all General Ledger data and information on all Major and Non Major Funds (i.e. General Fund, Construction Funds, Debt Service Funds, and Special Revenue funds), worksheets, personnel records, copies of checks, copies of invoices, grant reimbursement requests, expenditure detail reports, capital asset data and reports, accounts payable data and reports, the type of computer equipment used (including the software and operating systems), construction related documents, copies of contracts, insurance invoices, schedules of judgments and agreements, check registers, calendars, securities pledged, accounts payable details, financial statements, schedule of construction contracts, retirement reports, listing of new hires, purchase orders, check requests, financial reconciliations, sales tax reports and documents, other insurance related documents, insurance policies, monitoring reports, AFR report, arbitrage documentation, copies of deposits receipts, copies of budgets, outstanding checks, revenue reports, expenditure reports, and balance sheet reports. Under the Department of Education agreed upon procedures audit, LPSB staff provided Class size data, PEP data and a user guide. Under the Statewide Agreed Upon procedure, LPSB staff provided proof of required trainings such as ethics, bond insurance policies, list of all bank accounts, a listing of employees, officials employed during the year, and a list of deposit and collection sites. Other requests from our external auditors may come via email throughout the audit process and responses are provided likewise. All of the items listed above, and other items that were not listed above, are routinely provided each year. For several decades this has been the standard and nothing has changed in terms of provided supporting documentation within this particular audit. Internal controls have been in place for many decades. The external auditors have been reviewing, studying and auditing our internal controls for three decades. Over the years, LPSB internal controls have been adjusted, strengthened or heighten to prevent operational deficiencies, fraud and/or non-compliance of which the auditors have contributed to its advancement. Substantially, there has been no change to internal controls as they are in place for a reason. Systematically, internal controls are planted and executed in various areas and departments for various functions and/or lawful requirements. The biggest threats to any organization are misappropriation or improper disbursement of funds. Neither have occurred, because internal controls such as the utilization of electronic requisitions and check request processes were in place to ensure goods and services were precured properly and vendor payments were substantiated. LPSB stands by its management representations that have been provided to the auditors. We acknowledge our responsibility for the design, implementation, and maintenance of internal controls relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. In addition to supporting documentation, the external auditors had complete access to our financial software to ascertain the completeness and accuracy of our financial records.

A. OBJECTION On December 29, 2025, following LPSB’s submission of its Response to the Draft Findings of Kolder, Slaven, and Company, LLC (“KS&C”) relating to its 2024-2025 Annual Audit, LPSB received two additional findings characterized as Disclaimers of Opinion. The issuance of these post-response Disclaimers of Opinion regarding the findings highlights KS&C’s apparent lack of objectivity and its failure to adhere to generally accepted government auditing standards in conducting the 24-25 audit. A Disclaimer of Opinion “is expressed when the auditor is unable to obtain sufficient appropriate audit evidence on which to base the opinion, and the auditor concludes that the possible effects on the financial statements of undetected misstatements, if any, could be both material and pervasive.”1 According to LLA, “a local auditee that provides for an audit report with a disclaimer of opinion” is regarded as being in noncompliance with its reporting requirements to LLA under the audit law (Louisiana Revised Statute 24:513). LLA further expects the CPA to include in such a report a finding that provides a full explanation for the disclaimer of opinion.2 The two supplemental responses provided are, however, substantially lacking the “full explanation” mandated by the Legislative Auditors for the serious allegations being presented by KS&C. As with its other findings, these recent findings fail to cite any specific conditions present during the audit period that would have precluded KS&C from forming a conclusion. Therefore, as with the original findings, LPSB, on January 6, 2026, again requested that KS&C provide supporting evidence for its claim that it was unable to obtain “evidence regarding significant financial statement balances, transactions, and disclosures.” KS&C responded by stating that these new findings were based on Finding 16 - Invoices Paid Without Sufficient Supporting Detail (IC & C), Finding 26 - Management Override of Established Internal Controls (IC), Finding 31 - Unsupported Experience-Based Pay Increases (IC), and other undisclosed matters. Notably, none of these specific findings are instances where KS&C was prevented from forming a conclusion. To the contrary, the original findings identified by KS&C reflect otherwise. For instance, in Finding 16, KS&C notes it “tested 539 and identified 213 in which invoices were paid without sufficient documentation.” Despite KS&C’s assertions, LPSB has at no point failed to provide information to KS&C upon request (see Corrective Action sections below). In fact, KS&C issued 33 Findings, each purportedly substantiated by documentation. As stated in LPSB’s Response, a request was made by LPSB for KS&C to produce the referenced specific supporting documentation. However, KS&C declined to provide the documentation. Auditing standards stipulate: “Auditors should document supervisory review, before the report release date, of the evidence that supports the findings and conclusions contained in the audit report.”3 They further require: “Auditors should document any departures from the GAGAS requirements and the effect on the audit and on the auditors’ conclusions when the audit is not in compliance with applicable GAGAS requirements because of law, regulation, scope limitations, restrictions on access to records, or other issues affecting the audit.”4 Despite LPSB, in its Response and communications prior thereto pointing out erroneous references to the law and facts, KS&C refused to modify its findings. Instead, it introduced these two ambiguous Disclaimers of Opinion, alleging that LPSB failed to provide necessary information for KS&C to reach a conclusion. However, a cursory review of its original findings clearly reflect that KS&C did reach conclusions, which they assert were based upon conditions found during their investigation. Which is it? Are KS&C’s findings supported or not? KS&C’s ex post Disclaimers of Opinion not only misrepresent LPSB’s cooperation and full disclosure of information, but they are also predicated upon the unfounded assertion that LPSB’s “representations, including written representations required under auditing standards, could not be relied upon due to concerns regarding the reliability of management representations.” After 33 years of engagement with LPSB audits, KS&C has now made the unwarranted claim that LPSB’s representations are unreliable, without pointing to a specific instance of unreliability. Ironically, it is the auditor’s own representations that are demonstrated to be unreliable, as evidenced by the submission of these two vague and contradictory Disclaimers of Opinion. “[A] CPA cannot enter into the engagement with a pre-conceived notion that the local auditee is doing everything wrong. Going into an engagement with [this] attitude impairs the independence of the CPA firm.” The two findings, submitted after LPSB responded to its original findings, do not meet the standards set forth in the Louisiana Governmental Audit Guide. They contradict the original findings, misrepresent LPSB’s cooperation throughout the audit, insert slanderous statements as to the reliability of LPSB’s representations, and fail to provide a full explanation for the disclaimer of opinion. KS&C should remove these findings from its report. 1 LGAG 400-1160, Types of Auditor’s Opinions 2 LGAG 400-1160, Types of Auditor’s Opinions 3 GAO-24, Sections 6.31 (emphasis added) 4 GAO-24, Sections 6.32 B. CORRECTIVE ACTION Prior to the financial audit, Lafayette Parish School Board (LPSB) staff prepared reports and documentation for at least 185 requests that were made by the external auditors. These requests consisted of, but were not limited to, all General Ledger data and information on all Major and Non Major Funds (i.e. General Fund, Construction Funds, Debt Service Funds, and Special Revenue funds), worksheets, personnel records, copies of checks, copies of invoices, grant reimbursement requests, expenditure detail reports, capital asset data and reports, accounts payable data and reports, the type of computer equipment used (including the software and operating systems), construction related documents, copies of contracts, insurance invoices, schedules of judgments and agreements, check registers, calendars, securities pledged, accounts payable details, financial statements, schedule of construction contracts, retirement reports, listing of new hires, purchase orders, check requests, financial reconciliations, sales tax reports and documents, other insurance related documents, insurance policies, monitoring reports, AFR report, arbitrage documentation, copies of deposits receipts, copies of budgets, outstanding checks, revenue reports, expenditure reports, and balance sheet reports. Under the Department of Education agreed upon procedures audit, LPSB staff provided Class size data, PEP data and a user guide. Under the Statewide Agreed Upon procedure, LPSB staff provided proof of required trainings such as ethics, bond insurance policies, list of all bank accounts, a listing of employees, officials employed during the year, and a list of deposit and collection sites. Other requests from our external auditors may come via email throughout the audit process and responses are provided likewise. All of the items listed above, and other items that were not listed above, are routinely provided each year. For several decades this has been the standard and nothing has changed in terms of provided supporting documentation within this particular audit. Internal controls have been in place for many decades. The external auditors have been reviewing, studying and auditing our internal controls for three decades. Over the years, LPSB internal controls have been adjusted, strengthened or heighten to prevent operational deficiencies, fraud and/or non-compliance of which the auditors have contributed to its advancement. Substantially, there has been no change to internal controls as they are in place for a reason. Systematically, internal controls are planted and executed in various areas and departments for various functions and/or lawful requirements. The biggest threats to any organization are misappropriation or improper disbursement of funds. Neither have occurred, because internal controls such as the utilization of electronic requisitions and check request processes were in place to ensure goods and services were precured properly and vendor payments were substantiated. LPSB stands by its management representations that have been provided to the auditors. We acknowledge our responsibility for the design, implementation, and maintenance of internal controls relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. In addition to supporting documentation, the external auditors had complete access to our financial software to ascertain the completeness and accuracy of our financial records.

Finding Number: 2025-001 Condition: While the System had controls over accumulating the data for inputs into the portal, it did not have an adequate control in place to ensure transactions subject to FFATA reporting were reviewed for completeness and accuracy upon submission. Planned Corrective Action: Management concurs with this recommendation. MetroHealth will establish and maintain a log documenting FFATA report submission, with internal reviews of disclosures prior to submission Contact person responsible for corrective action: Michele Benos, Manager, Grants Accounting and Brynna Baird, Manager, Sponsored Programs Anticipated Completion Date: 05/31/2026

2025-003 Allowability of Rental Assistance Payments - Landlord Verifications Federal Agency- US Department of Housing and Urban Development Continuum of Care Program -Assistance Listing# 14.267 Hennepin County Contract HS00001366 Year ended June 30, 2025 Material Weakness in Internal Control over Compliance Recommendation - Agate Housing and Services, Inc. strengthen internal controls to ensure landlord verifications are completed and required documentation, including W9 forms, is obtained and retained for all vendors prior to the disbursement of rental assistance funds. Management should implement a procedure to verify required documentation is present before payment approval. Corrective action - Agate Housing and Services, Inc. agrees with the finding and is in the process of strengthening its controls over the verification of landlords. All vendors without TINs have been archived from the accounting system. A new portal has been created on Agate's website for landlords to submit required documentation electronically and paperwork (W9 and Property Tax Records) are attached to vendor profiles in the accounting system prior to issuing payments. Name of contact person(s) responsible for corrective action - Elizabeth Macha rt, Director of Housing Programs and Sara Wenzel, Associate Director Time Limited Housing Completion date - Vendor purge began January 2025 and rollout of new LL portal March 2026

2025-001: Insufficient Controls Over Monitoring Federal Expenditures and SEFA Preparation (Significant Deficiency) The City concurs with the finding and will strengthen controls over monitoring federal expenditures and preparation of the Schedule of Expenditures of Federal Awards (SEFA). The Finance Department will implement centralized oversight of federal grant activity and maintain a grant tracking schedule to monitor cumulative federal expenditures by program, including reimbursements and receivables. Departments administering federal programs will be required to report grant expenditures to Finance, and periodic reconciliations will be performed between departmental records, reimbursement requests submitted to the pass-through agency, and amounts recorded in the general ledger. At year-end, the Finance Department will prepare the SEFA and perform a formal management review to ensure all federal expenditures are complete and accurately reported and evaluated against the Single Audit threshold in accordance with Uniform Guidance. Personnel involved in grant administration will receive training on applicable Uniform Guidance requirements to support compliance with federal reporting and monitoring requirements. Anticipated Completion Date: June 2026

Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The loan resolution security agreement states the Hospital must set aside a capital asset replacement account which may be established as a bookkeeping account or as a separate bank account. Funds may be deposited in institutions insured by state and federal government orinvested in marketable securities backed by the full faith and credit of the United States. Condition: The funds that represented the capital asset replacement fund were commingled with an existing board-designated CD account. Views of Responsible Officials and Planned Corrective Action: Management agrees with the funding and will deposit the required capital asset replacement funds in either a separate bank account or general ledger account. Planned Completion Date: December 31, 2026 Person Responsible: Nik Brimeyer, CFO

Finding 2025-001: Rural Rental Housing Loans Assistance Listing Number: 10.415 U.S. Department of Agriculture (Repeat of Finding 2024-001) Compliance Requirement: Eligibility, Program Income Type of finding: Internal Control Over Compliance (significant deficiency) Recommendation: The Organization should strengthen its internal controls with adopted policies and procedures to ensure a review process is established through adequate segregation of duties. The Organization should consider assessing and realigning the duties and responsibilities of the Executive Director, Administrative Assistant, and Alamosa Property Manager to provide for a review process of tenant eligibility determinations and the monthly housing assistance payment requests for the Sierra Vista Alamosa Housing Complex. Action Taken: This finding was from the actions of the pervious on-site manager, concerning the Alamosa Complex only. Sierra Vista/Alamosa Complex has already implemented the internal control concerning compliance in house. Priscilla and Alonzo will make sure that all internal compliance issues are segregated and check by at least 2 persons in the office, and if needed, the Executive Director can request viewing of internal control procedures as well. Alonzo and Priscilla prepare and review along with signatures of the review and approval dates of internal affairs. "This institution is an equal opportunity provider." If there are questions regarding this plan, please call the responsible party at (719)852-5505. Sincerely yours, Corinna Garcia Executive Director Monte Vista Community Center Housing Authority, Inc.

2025-004 LACK OF INTERNAL CONTROL OVER REPORTING U.S. Department of Housing and Urban Development ALN 14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Contract No. B-22-CP-KY-0347 (2022) and B-23-CP-KY-0612 (2023) Criteria and Condition: During our audit procedures, we noted there was no process in place to ensure periodic reporting was submitted timely and accurately. Cause: Certain internal controls were not in place to prevent or detect lack of periodic reporting, or inaccurate reporting. Effect: Federal funds could be withheld if periodic reports are not submitted, or are inaccurate. Questioned Costs: None Recommendation: We recommend management obtain a greater understanding of the Compliance Supplement requirements over HUD grants, and implement a review process whereby there is a review control over the submission of period reports. Action Taken: The Authority will gain a greater understanding of HUD grants, and will implement a review process over required periodic reporting. Individual(s) responsible for implementing: Maureen Carpenter, CEO Anticipated Completion Date: September 30, 2026

2025-003 PREVAILING WAGE U.S. Department of Housing and Urban Development ALN 14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Contract No. B-22-CP-KY-0347 (2022) and B-23-CP-KY-0612 (2023) Criteria and Condition: During our audit procedures, we noted the Authority did not notify contractors that Federal funds would be in payments. As such, contractors did not include federal prevailing wage language in their bids/contracts, and did not provide weekly certified payroll reports to the Authority. Cause: Management was unaware of the requirements of prevailing wage for federal construction grants, and as such, did not communicate to contractors that federal funds would be utilized. Effect: The Authority was not in compliance with the grant requirements in the OMB Compliance Supplement over prevailing wage requirements for laborers and mechanics. Questioned Costs: Unable to determine. Recommendation: We recommend management obtain a greater understanding of the Compliance Supplement requirements over HUD grants, and implement a review process whereby contracts and invoices are not approved without appropriate prevailing wage consideration and certified payrolls. Action Taken: The Authority will gain a greater understanding of HUD grants, and will implement a review process to ensure prevailing wage requirements are considered prior to approving contracts and invoices. Individual(s) responsible for implementing: Maureen Carpenter, CEO Anticipated Completion Date: September 30, 2026

2025-002 SUSPENSION AND DEBARMENT U.S. Department of Housing and Urban Development ALN 14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Contract No. B-22-CP-KY-0347 (2022) and B-23-CP-KY-0612 (2023) Criteria and Condition: During our audit procedures, we noted there was no process in place to ensure vendors were not on a suspension or debarment list, and were eligible to be reimbursed with federal grant funds. Cause: Certain internal controls were not in place to prevent or detect and correct payments made to suspended or debarred vendors. Effect: Federal funds could be used to reimburse payments made to vendors that are suspended or debarred. Questioned Costs: None. Recommendation: We recommend management obtain a greater understanding of the Compliance Supplement requirements over HUD grants, and implement a review process whereby vendors are periodically checked for suspension and debarment. Action Taken: The Authority will implement procedures to include verifying new and existing vendors are not on suspension and debarment listings. Individual(s) responsible for implementing: Maureen Carpenter, CEO Anticipated Completion Date: June 30, 2026

We recommend Christian Care management strengthen internal controls and oversight over the rental assistance calculations and tenant eligibility documentation to ensure accuracy of all assistance payments.

2025-005 Lack of Reporting Review Recommendation: The City should have controls in place to ensure all reports are reviewed prior to submittal. Management Response: Management agrees that reports should be reviewed prior to submission and notes that the City does have controls in place to ensure appropriate review procedures are performed. In this instance, the report was prepared and submitted by the City Manager, and due to limitations within the Federal Government’s online reporting system, there was not a built-in approval workflow available to document the review process. To strengthen our controls, the City will print and retain a copy of the report prior to electronic submission to allow for documented review and approval. This will ensure appropriate oversight is evidenced and that sufficient supporting documentation is maintained to demonstrate the review process was completed. Responsible Parties: Brittany Retherford, City Manager, Mindy Brown, Comptroller, and Bethany Messersmith, Assistant Comptroller Anticipated Completion Date: September 30, 2026

2025-004 Suspension and Debarment Recommendation: The City should require all vendors to provide certification of their status before a contract or purchase order is completed with the vendor and the City should obtain new certificates annually to ensure the vendor status has not changed. Management Response: Management agrees with the recommendation. The City has implemented procedures requiring all departments to obtain vendor certification of status prior to executing a contract or issuing a purchase order. Over the past year, we have worked diligently to educate departments on the importance of obtaining and maintaining proper vendor certifications to ensure compliance with applicable requirements. We will continue to reinforce this expectation and monitor compliance, including obtaining updated certifications annually to ensure vendor status has not changed. Responsible Parties: Brittany Retherford, City Manager, Mindy Brown, Comptroller, and Bethany Messersmith, Assistant Comptroller Anticipated Completion Date: September 30, 2026

Finding Reference Number: 2025-001 – Significant Deficiency in Internal Control Over Compliance and Non-Material Non-Compliance Finding: One instance where a unit failed its inspection and re-inspection was not performed or scheduled within the required timeframe. The Organization also failed to abate the housing assist payments (HAP) or terminate the HAP contract for this unit in a timely manner. Additionally, for this unit the inspection was not performed on the required biennial basis. Planned Corrective Action: The housing team utilizes Yardi to manage the housing program. The team has been using the software to schedule inspections. Through their internal review, the team confirmed Yardi's reporting capabilities within the system were not being fully utilized to monitor overdue reinspections or trigger abatement actions. This gap contributed to the oversight cited in the audit finding. A retraining on Yardi is being scheduled for April 2026 to ensure the full reporting capabilities within the system will be utilized to ensure proper monitoring of overdue inspections. In addition, there are adequate policies and procedures in place to ensure inspection and reinspection of units, but we will revise current policy to strengthen this area. Anticipated Completion Date: Ongoing with a completion date of April 30, 2026. Name(s) of the Contact Person(s) Responsible for Corrective Action: Ronald Walker, CPA, Vice President, Finance, 202-893-9907, ronald.walker@ccdc1.org Sanique Lyn, MPH, AVP-Clinical Housing, 202-870-5090, slyn@ccdc1.org

The district Business Manager has implemented a system whereby copies of all invoices will be emailed to the Treasurer for approval before invoices are paid from any State, Local or Federal Funds. This will help prevent the district from using Federal funds for unallowable costs or activities. This process will help ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.

FINDING 2025-004: Impact Aid Application Controls Response: The District has implemented that the documentation for the Impact Aid application will be kept in the Business Manager office rather than the Superintendent office to ensure that this documentation is maintained for future years. The District has implemented the use of an updated spreadsheet that includes all the required information for the Impact Aid application rather than multiple documents.

Processes have been developed and implemented to ensure both receipt of funds and return of interest to the grantor is done on a timely and consistent basis.