Corrective Action Plans

COVID-19-Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)– Assistance Listing No. 21.027 Recommendation: We recommend the Department implement procedures and internal controls to ensure that it complies with program requirements, that it maintains documentation, and that documentation is readily available for audit. Explanation of disagreement with audit finding: The items in question are internal journal entries used to reclassify prior year expenditures to the correct accounts. The expenditures tested during the audit period were reviewed and found to be in compliance with program requirements. Journal entries are prepared by one person then reviewed and signed by the chief of accounting for accuracy. The journal entries are then keyed into the accounting system. In the future, MDL will ensure that all journal entries are provided in a timely manner. Action taken in response to finding: Internal controls exist to provide documentation. To ensure compliance, DOL agrees to provide documentation on time for testing. Name(s) of the contact person(s) responsible for corrective action: Sherry Baynes Planned completion date for corrective action plan: Documentation was provided after the deadline for testing,

U.S Department of Education (USDE)Recommendation: We recommend that the Department continue to implement the sub recipient monitoring procedures and develop internal controls to ensure that the monitoring requirements are performed in a consistent and timely manner. Furthermore, the procedures should ensure that the documentation supporting compliance is maintained and readily available for review. We also recommend that the subawards contain all required federal award information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: [Describe action planned or taken]. The Department has engaged a vendor to perform subrecipient monitoring of federally funded COVID relief grants (Assistance Listing No. 84.425 C, D, R, U, V, W and CSLFRF). MSDE worked with the Department of Budget and Management (DBM) to receive approval to enter into a contract with Hagerty Consulting since October of 2024. The target date of completion is October 31, 2025. In addition, the Contract Manager will monitor and ensure that all deliverables have been satisfactorily completed and documented. Further, the Program Manager will create or review existing Standard Operating Procedures (SOPs) regularly and update as necessary to ensure monitoring requirements are performed in a consistent and timely manner and that subawards contain all the required federal award information. Maryland State Department of Education respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023-June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. Findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Maryland State Department of Education

U.S. Department of the Treasury Department of Housing and Community Development respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023-June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Housing and Community Development 2024-014 COVID-19 – Emergency Rental Assistance Program – Assistance Listing No. 21.023 Recommendation: We recommend that the Department review and enhance supervisor review and approval to ensure that program requirements are consistently performed. Documentation to support compliance with the requirements should be maintained and readily available for review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The subrecipient who administered the assistance for three (3) of the four (4) affected records has fully expended ERA 2 funds. DHCD will review the subrecipient’s internal approvals process and tenant notification process to determine where improvements can be made and issue recommended recordkeeping changes for the subrecipient to implement for future federal subawards. DHCD will review and make necessary changes to program policy guides as necessary to strengthen case file recordkeeping requirements and ensure that case file reviews for direct financial assistance programs include a review of notifications to clients. In prior desk monitoring and file audits, the relevant subrecipient files always included a notification of assistance to the tenant. Name(s) of the contact person(s) responsible for corrective action: Danielle Meister Planned completion date for corrective action plan: April 30, 2025 2024-015 COVID-19 – Homeowner Assistance Fund – Assistance Listing No. 21.026 Recommendation: The Department should reevaluate current process, implement proper controls, and perform additional training over time and effort reporting. The Department should not seek federal reimbursement unless they can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Monthly reporting to Senior Management of any exceptions to the federal timesheet process will be required to ensure that all federal timesheets are completed and received in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Wade Simmons Planned completion date for corrective action plan: April 30, 2025 If the U.S. Department of the Treasury has questions regarding this plan, please call Crystal Quinzani at (301) 429-7840.

U.S. Department of the Treasury Department of Housing and Community Development respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023-June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Housing and Community Development 2024-014 COVID-19 – Emergency Rental Assistance Program – Assistance Listing No. 21.023 Recommendation: We recommend that the Department review and enhance supervisor review and approval to ensure that program requirements are consistently performed. Documentation to support compliance with the requirements should be maintained and readily available for review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The subrecipient who administered the assistance for three (3) of the four (4) affected records has fully expended ERA 2 funds. DHCD will review the subrecipient’s internal approvals process and tenant notification process to determine where improvements can be made and issue recommended recordkeeping changes for the subrecipient to implement for future federal subawards. DHCD will review and make necessary changes to program policy guides as necessary to strengthen case file recordkeeping requirements and ensure that case file reviews for direct financial assistance programs include a review of notifications to clients. In prior desk monitoring and file audits, the relevant subrecipient files always included a notification of assistance to the tenant. Name(s) of the contact person(s) responsible for corrective action: Danielle Meister Planned completion date for corrective action plan: April 30, 2025 2024-015 COVID-19 – Homeowner Assistance Fund – Assistance Listing No. 21.026 Recommendation: The Department should reevaluate current process, implement proper controls, and perform additional training over time and effort reporting. The Department should not seek federal reimbursement unless they can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Monthly reporting to Senior Management of any exceptions to the federal timesheet process will be required to ensure that all federal timesheets are completed and received in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Wade Simmons Planned completion date for corrective action plan: April 30, 2025 If the U.S. Department of the Treasury has questions regarding this plan, please call Crystal Quinzani at (301) 429-7840.

Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance. To Whom It May Concern: On behalf of our Team, let me thank you for the support CLA team has provided in the just ended single audit. Please see our response below. Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance DWDAL Response: The Maryland Department of Labor’s Division of Workforce Development and Adult Learning (DWDAL) accepts the FFATA finding. DWDAL was not aware of the aspect of the FFATA requirement that stipulated internal control of a non-Federal entity as per 2 CFR section 200.303(a), and therefore, had not established a protocol. Action taken in response to finding: Develop a policy relating to the FFATA requirements and implement within DWDAL’s Financial Management Handbook and circulated to all Local Workforce Development Areas (LWDAs). Name(s) of the contact person(s) responsible for corrective action: Dorothee Schlotterbeck Planned completion date for corrective action plan: June 28, 2025

Department of Labor (DOL)Financial Statement Preparationinancial Statement Preparation. Unemployment Insurance – Assistance Listing No. 17.225 Recommendation: We recommend the Department implement procedures and internal controls to ensure that it complies with program requirements, that it maintains documentation, and that documentation is readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Recommendation: We recommend the Fund establish procedures to ensure that financial reporting is performed in a timely manner and provide accurate and relevant information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The team that was assembled to work through the audit has also been enlisted to redesign the process and build new tools to create UI Trust Fund financial statements every month. While this is still in development, we plan to have it functioning accurately by May of 2025. Name(s) of the contact person(s) responsible for corrective action: John Fahnbutu. Planned completion date for corrective action plan: 5/30/2025 Recommendation: We recommend the Fund establish procedures to ensure that financial reporting is performed in a timely manner and provide accurate and relevant information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The team that was assembled to work through the audit has also been enlisted to redesign the process and build new tools to create UI Trust Fund financial statements every month. While this is still in development, we plan to have it functioning accurately by May of 2025. Name(s) of the contact person(s) responsible for corrective action: John Fahnbutu. Planned completion date for corrective action plan: 5/30/2025 Maryland Department of Labor- Unemployment Insurance Trust Fund (the Fund) respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023-June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS

1. The Maryland Military Department respectfully submits the following corrective action plan for the year ended June 30, 2024.Projects – Assistance Listing No. 12.401 (1) Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award's allowable period of performance. (2) Explanation of disagreement with audit finding: There is no disagreement with the audit finding. (3) Action taken in response to finding: The Department will carefully exam and allocate expenses to the fiscal year in which they are incurred, ensuring proper period assignment when expenses span multiple fiscal years. This will confirm accurate costs charged to the programs. 2. Audit period: July 1, 2023-June 30, 2024 3. The findings from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. 4. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS: a. Finding 2024-011: National Guard Military Operations and Maintenance (O&M

STATE OF MARYLANDCOVID-19 – Pandemic EBT – Assistance Listing No. 10.542 Recommendation: We recommend the Department enhance its procedures and internal controls to ensure that it submits programmatic reports on a timely basis. Explanation of disagreement with audit finding: No disagreement. Action taken in response to finding: Google Calendar (the Department’s internal calendar) reminders will be set up to generate reminders of the due dates for the reports, as well as, an internal tracker will be created to monitor the due dates and the submission of the reports. These tools will be used by Management to ensure the federal reports are submitted timely according to the United States Department of Agriculture Food and Nutrition Service (FNS) program integrity calendar. Name(s) of the contact person(s) responsible for corrective action: Jessica Smith, Acting Chief Financial Officer Planned completion date for corrective action plan: June 2025 CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2024 U.S. Department of Agriculture Department of Human Services respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 - June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Human Service

2024-003 Verification of Suspension and Debarment checks Recommendation: We recommend that the City add a section to its standard contractor and subrecipient contracts for the other party to certify they are not suspended or debarred. In addition, we recommend the City establish controls to ensure that evidence of suspension and debarment compliance procedures is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City agrees with finding and will implement steps to verify if the contractor has been suspended or debarred from federal contracts. Name(s) of the contact person(s) responsible for corrective action: Albert Avila, Finance Director Planned completion date for corrective action plan: 01/22/2026

Finding 2024-004: Significant Deficiency and Noncompliance Over Reporting Responsible Official’s Response and Corrective Action Plan We concur with the finding. We acknowledge the importance of adhering to the Federal guidelines for the submission of the reporting package within the mandated nine-month period. This finding is a result of the transition in the accounting team. To address this, the 1890 Universities Foundation will implement the following actions: 1. Policies and Procedures Development: We will create and enforce comprehensive policies and procedures to ensure that audits are initiated and completed promptly. This will include detailed timelines and checkpoints to monitor progress throughout the audit process. In addition, we will adhere to a year end closing process that reconciles all significant accounts. 2. Training for Grant Administration: We will provide training for individuals responsible for administering federal assistance programs within the 1890 Universities Foundation. This training will cover essential aspects of grant administration, ensuring that our team is well-equipped to manage these programs efficiently and in compliance with federal requirements. Planned Implementation Date of Corrective Action Plan December 2025 Person Responsible for Corrective Action Plan Dr. Felecia Nave, Chief Executive Officer & President Natésha Johnson, Director of Finance and Administration

Finding 2024-004 – Insufficient Skills, Knowledge and Training, and Leadership (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land ManagementCriteria: Under Uniform Guidance 2 CFR §200.303, non-federal entities must establish and maintain effective internal control over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the award terms and conditions. This includes ensuring that:  Personnel administering federal awards possess adequate skills, knowledge, and experience.  Management and leadership provide appropriate oversight of federal award activities.  Financial management systems adequately support accurate reporting, documentation, retention, and reconciliation of federal expenditures in accordance with 2 CFR §200.302. Condition: During the audit of federal awards, the entity did not demonstrate sufficient skills, knowledge, or experience of the staff and leadership responsible for administering and overseeing federal programs. Specifically:  Adequate supporting documentation for federal award expenditures was not maintained or provided.  Leadership oversight of federal award compliance activities was limited, and management review of grant activity were not evidenced. These conditions resulted in weaknesses in financial reporting, compliance monitoring, and documentation related to federal awards. Cause: Partnership for the Umpqua Rivers has not ensured that staffing levels, qualifications, and experience are sufficient to support federal award administration and compliance. In addition, leadership lacks adequate knowledge of federal award requirements to provide effective governance, oversight, and monitoring of compliance activities. Formal training and documented procedures for federal awards management have not been prioritized. Effect or Potential Effect: As a result of these deficiencies:  Partnership for the Umpqua Rivers is at increased risk of non-compliance with Uniform Guidance requirements.  Federal expenditures may be unsupported, inaccurately reported, or unallowable.  Errors or compliance violations may not be detected or corrected in a timely manner.  The entity may be subject to questioned costs, repayment of federal funds, or additional scrutiny from grantor agencies. Questioned Cost: None identified Context: During our audit, it was found that the Partnership for the Umpqua Rivers experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. No financial files for Accounts Payable, invoices, or reporting were available to the current financial staff. Not adequately retaining supporting documents and invoices to support the expenditures of the general ledger and requests for reimbursement for grants, the organization records may be insufficient for testing and review, for internal controls or meeting federal documentation and reporting requirements. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers:  Ensure staff responsible for federal awards receive appropriate training on Uniform Guidance requirements, grant financial management, documentation, and compliance monitoring. Assign federal award oversight to personnel with sufficient experience and qualification or obtain external grant management and accounting support as needed.  Establish written policies and procedures for federal award administration, including expenditure documentation, reconciliation, compliance review, and management approvals.  Require leadership to perform and document periodic oversight and monitoring of federal awards, including review of reconciliations reimbursement requests, and compliance metrics.  Implement ongoing monitoring and internal control assessments to ensure compliance with federal award requirements. District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: _____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: ___________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

Finding 2024-003 – Lack of Internal Controls over Expenditure Documentation (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: Natural Resources Conservation ServiceName of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Title 2 CFR §200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the awards in compliance with federal statutes, regulations, and the terms and conditions of the award. Additionally, 2 CFR §200.302(b)(3) requires entities to maintain records that adequately identify the source and application of funds, including supporting documentation for expenditures, and 2 CFR §200.430 requires documentation for compensation for personal services. Condition: During our review of expenditures charged to the federal programs, the entity was unable to provide invoice copies or other sufficient supporting documentation for certain expenditures tested. As a result, we could not verify the allowability, accuracy, and proper approval of these costs in accordance with federal requirements. In addition, records were unavailable for Personnel expenditures that were charged to grant awards, and no support or evidence of time per grant was available. Cause: Partnership for the Umpqua Rivers does not have effective internal controls in place to ensure that invoice documentation and other supporting records are retained, centrally filed, and readily available for audit and monitoring purposes. In addition, management did not perform ongoing monitoring to verify that required documentation was maintained prior to reimbursement or reporting. Effect or Potential Effect: because supporting documentation was not available, expenditures from detail documentation could not be substantiated. This increases the risk that the unallowable, unsupported, or inaccurate costs may be charged to the federal program and reported in the Schedule of Expenditures of Federal Awards (SEFA). Questioned Cost: Yes, $332,409 related to Personnel costs, equipment and other purchases that were not documented with detailed support. Context: During our audit, it was found that the Partnership for the Umpqua Rivers experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. No financial files for Accounts Payable, invoices, or reporting were available to the current financial staff. Not adequately retaining supporting documents and invoices to support the expenditures of the general ledger and requests for reimbursement for grants, the organization records may be insufficient for testing and review, for internal controls or meeting federal documentation and reporting requirements. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit.Recommendation: Partnership for the Umpqua Rivers should implement policies and procedures requiring invoice copies and supporting documentation to be maintained for all grant expenditures. Management should strengthen record retention practices, provide training to staff on documentation requirements, and implement periodic internal reviews to ensure compliance. District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: _____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

I have been working with CDBG grants for 25 years and have never had a problem with having invoices or anything else. [Grant administrator name redacted] was administering the grant and failed to give me all the needed documents. In the future I will make sure to get the documents.

Recommendation:We recommend that management develop, implement, and maintain written policies and procedures documenting its system of internal control over federal programs to ensure compliance with Uniform Guidance and applicable federal requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and plans to develop and implement written internal control policies and procedures over federal programs. Management anticipates completion by June 30, 2026.

2024-002 Activities Allowed and Allowable Costs To address the finding regarding missing backup documentation for cash disbursements, the Biddeford-Saco-Old Orchard Beach Transit Committee has implemented new workflow controls in our new integrated accounting software. Starting July 1, 2025 all employees are now required to create a purchase order (PO) and obtain approvals before payments can be made. This process controlled by the finance manager creates a complete audit trail for every transaction, ensuring that all disbursements are properly documented.

2024-004 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition As part of our audit procedures, we selected a sample of 40 payroll transactions for review. This process included examination of employee human resource files (such as signed W-4 and I-9 forms), management-approved pay rates, time sheets with supervisory sign-off, and corresponding payroll reports. We recalculated total hours per timesheet using the employees' pay rates and compared these figures to the relevant payroll reports. During our review, we observed that two employees received additional compensation ranging from $25 to $75 for undertaking extra responsibilities related to the administration of the CBS Food Program’s Summer Food Service Program by the former Chief Executive Officer. Management was unable to provide supporting documentation evidencing approval by the former Chief Executive Officer or confirmation from the Commonwealth of Pennsylvania, Department of Education, indicating that such additional compensation complied with the contractual agreement governing the Summer Food Service Program. Additionally, of the 40 payroll transactions sampled, we noted one employee’s required payroll change documentation (e.g., an approved payroll change form) was not present in their personnel file. Recommendation We recommend that management improve internal controls for payroll authorization by making sure every payroll change form and supplemental compensation approval is filled out, approved, and kept on file. Introducing a central electronic document management system will help securely store records, standardize documentation, and create clear audit trails for all payroll and personnel files. Management should also regularly review payroll records to confirm that all necessary paperwork, such as personnel forms, pay rate approvals, and backup for extra pay, is included. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions repeats the actions to be taken in response to finding 2024-003 and adds the following: Community Benefit Solutions will utilize ADP document management capabilities to maintain employee files including, but not limited to, Payroll Change Forms or other documentation related to modifications or supplements to employee pay. Community Benefit Solutions will ensure complete upload of all paper files to the appropriate employee profile within ADP to ensure documentation can be readily accessible by those with necessary authorization. Planned completion date for corrective action plan: June 30, 2025

Chairman of the Board of County Commissioners: The lack of cooperation and oversight during the prior County Clerk's administration left significant gaps that required immediate attention. The current leadership has made addressing these gaps a top priority. Together, we are: • meeting monthly to update procedures and build stronger internal controls, • developing and formalizing policies to ensure full compliance with federal grant requirements, • and improving communication between offices to ensure federal reporting is accurate and timely. Our collective commitment is to put permanent measures in place to prevent these issues from recurring and to uphold the highest level of compliance for all federal programs. County Clerk: I was not the County Clerk in office at this time. The County will comply with all aspects of grant reporting and requirements. The Officials will work together to put policies and procedures in place to ensure more accurate reporting. County Treasurer: The County Officers will work on better communication to more accurately report the SEFA funds.

City of Parker Management’s Corrective Action Plan For the Fiscal Year Ended September 30, 2024 Financial Statement Finding Number: 2024-101: Reimbursement Requests were Not Formally Approved by the City Prior to Submission Planned Corrective Action: The City will update its procedures to require documented City review and approval of all reimbursement requests prior to submission to a grantor. The City will also clarify responsibilities with the consultant to ensure submission and acknowledgment are independently performed and appropriately documented. Anticipated Completion Date: 09/30/2026 Responsible Contact Person: Kimberly Dalton, Bookkeeper

Immediate Control Reinforcement and Staff Training - The Executive Director and the Program Manager have already started identifying specific areas of each contract and grant for federal awards. The Executive Director will call a meeting between all managers to go over each contract and grants together with information that has already been reviewed. It will be important to observe specific instances when controls were created, and documentation was not accurate. Staff will be trained regarding the agency budget, and each role and responsibility of their program to better understand how their service delivery affects organizational funding. Monthly monitoring of grant funding from all managers will be important for transparency and prudent decision making. All managers will receive frequent training to keep up with any changes or new processes that will impact federal funding. Monitoring and Periodic Internal Auditing - The Executive Director, Program Manager, and Finance manager will meet every month before the Finance Committee meeting to go over the progression of spending. The Executive Director and Finance Manager will keep record of all information that will be helpful for the next audit regarding federal grants. Written corrective action plans will be created for each area of noncompliance. Finance Manager will be responsible for maintaining accurate budget updates and will inform Executive Director of any updates and changes as soon as they happen to ensure full transparency and preparation. Failure to do so will result in disciplinary consequences. All information will be presented to the Board of Directors whether at the monthly Board meeting or at the request for a special meeting. Documentation and Formalization - The Executive Director will meet with the Finance Manager to understand what process is used for quality assurance and documentation the finance staff uses. Any improvements necessary will be implemented as soon as possible after evaluating all processes. An evaluation of the software used for tracking all grant funding will be done and any quality assurance improvements will be implemented as soon as possible. Federal grants compliance adherence will be included in performance reviews and documented.

Review individual grants for eligibility and documentation requirements • Create a policy to review the application for eligibility and ensure second approval on each application • Retain all documentation required by the grants

Review and update the Accounting Manual as needed • Re-train employees in the need for proper use of purchase orders, needed documentation to support charges to federal awards, and detailed receipts to show taxes paid (if any) according to the Accounting Manual

Review current policies regarding employee travel and expense reimbursements and adjust, if needed, to be aligned with award requirements • Implement a pre-approval process for all employee travel and expense reimbursements charged to federal programs. • Require detailed documentation (receipts, agendas, purpose statements) to demonstrate direct program benefit. • Provide staff training on allowable costs and documentation standards.

Assistance Listings number and program name: 21.027 COVID-19—Coronavirus State and Local Fiscal Recovery Funds Name of contact person: Heather Patel Completion date: October 31, 2025 Corrective Action Planned: Pinal County acknowledges the recommendations from the Arizona Auditor General and has implemented procedures to ensure that the quarterly and annual reporting to the federal program aligns with the expenditures recorded in the county’s financial system. These procedures include: • Using the county’s general ledger to reconcile and match expenditures for the appropriate reporting period in accordance with GAAP. • Submitting the federal report to a manager or higher level for review and approval prior to sending to the federal agency. • Reviewing all expenditures, including those after year-end, to identify the appropriate reporting period. • Due to the timing of the annual report due date and the accrual period, there may be times when the annual report does not include accrued expenditures, as these expenditures may be recorded after the due date of the federal report. When this is the case, the county will make note of these expenditures and work with the federal agency to amend the annual report if needed.

The County will work diligently to implement internal controls over its federal award program to ensure accurate reporting of any activity.

Finding 2024-002: (Significant Deficiency) AL# 21.027: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury Condition: The City’s control procedures for the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) requires the department personnel to authorize payment and the program manager to certify the expenditures to the CSLFRF program prior to being paid. The program manager did not approve four invoices prior to the expenditure being charged to the grant. Criteria or Specific Requirement: 2 CFR 200.303, the Non-Federal entity must establish and maintain effective internal controls over federal awards to ensure compliance with federal statutes, regulations and the terms and conditions of the awards. Cause: Purchase orders are created that identify projects that are part of the CSLFRF and expenditures coding is assigned at that time prior to the purchase. Once the invoice was approved by department personnel, the expenditures were applied to the assigned purchase order coding. Effect: Failure to follow established internal controls increases the risk of noncompliance with the grant requirements and processing unallowable costs towards the grant. Corrective Plan: To address the underlying issues identified in the audit finding, the City will implement the following steps: 1.Correct Approval Control GapInternal Audit worked with Accounts Payable and department personnel and made recommendations tocorrect the control gap and ensure compliance with approval procedures. It is anticipated theserecommendations will be implemented in the next two months. Additional review steps were added inaccounts payable to ensure required approvals obtained prior to payment processing. 2.Implement Monitoring ReportAccounting services developed a report to verify approvals and provide secondary oversight for CSLFRFexpenditures. These actions will be implemented and monitored to ensure compliance with grant requirements. Alex Fedak, CPA 1/7/26 Date Controller