Corrective Action Plans

Corrective action plan - management response: The organization to update policies and procedures, over completing tenant certification and re-certification, to include review by a management agent or acting management agent. Name(s) of the contact person(s) responsible for corrective action: Marsha Larkin Marani, Project Manager Planned completion date for corrective action plan: March 2025

Corrective action plan - management response: Management to update income limits in Onesite to reflect HUD income limits applicable as of the tenant’s application date. Name(s) of the contact person(s) responsible for corrective action: Marsha Larkin Marani, Project Manager Planned completion date for corrective action plan: March 2025 (as Income Thresholds become available annually by HUD)

2024-039 Oregon Department of Emergency Management Continue FFATA reporting improvements and make inquiries on FSRS functionality Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM has undertaken and continues the following corrective actions to address the recommendations made by the Secretary of State’s Audits Division: • OEM has developed procedures for capturing necessary information and ensuring FFATA reports are filed in compliance with federal criteria. • OEM has identified all awards since July 1st 2023 and is working to ensure 100% compliance from that date forward. • OEM will conduct timely follow up on all submissions that fail to successfully load into the system, and clearly document that follow up for inclusion in our files. • OEM will continue to review older awards to determine what actions should be taken. Anticipated completion date: June 30, 2025. Contact person: Amy Mettler, Chief Financial Officer.

2024-019 Oregon Department of Human Services Improve controls and compliance over long-term care facility auditsManagement Response: We agree with this recommendation and will make these changes on the July 1, 2025 cost report template. We will be adding a line item to distinguish between Total Administration overtime and Administrator only overtime. .Anticipated Completion Date: July 1, 2025 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director

2024-017 Oregon Department of Human Services/Oregon Health Authority Strengthen internal controls over the ONE system Management Response: We agree with this recommendation. ODHS will continue to work with our vendor to secure a SOC 2 Type II audit of our processes and oversight of the ONE system in 2025. Additionally, ODHS will work on amending the ONE M&O agreement with Deloitte for them to obtain a scoped SOC 2 Type II audit related to their work within the ONE system. ODHS would expect to negotiate this additional audit requirement in 2025 with the first audit then happening in 2026. In addition, the agency will request reports that will allow reconciliation of transactions between ONE and the mainframe system. Anticipated Completion Date: December 31, 2026 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director

2024-011 Oregon Health Authority Strengthen existing controls to ensure only those costs incurred during the period of performance are charged to the grant Management Response: The agency agrees with the finding. While the appropriate internal controls are in place to review the period of performance, a mistake was made while following the procedures. Secondary reviews will be performed going forward to ensure all expenditures are appropriately captured. The expenditures in question were moved to the correct phase 22 on Jan. 23, 2025 with document BTCG3186. Anticipated Completion Date: January 23, 2025 Contact Person: Travis Labrum, Accounting Manager

2024-010 Oregon Health Authority Submit required Federal Funding Accountability and Transparency Act reports Management Response: The agency agrees with the finding. The FFATA Reporting Coordinator position within the Office of Contracts & Procurement (OC&P) has been vacant for eight months but should be filled by April 15, 2025. On March 8, 2025, FSRS.gov was retired, and all subaward reporting data and functionality are now on SAM.gov. The new SAM.gov reporting system will allow for multiple Data Entry roles, allowing each program or division of ODHS/OHA to submit their own reporting, and allowing OC&P to conduct Quality Assurance/Quality Control. Once the FFATA Reporting Coordinator is onboard and trained, we anticipate the FFATA reporting will resume and any missing reports will be submitted by April 15, 2026. Anticipated Completion Date: April 15, 2026 Contact person: Noemi Schlegel, Compliance & Audits Program Manager

2024-033 Oregon Housing and Community Services Department Federal reports should contain accurate information Management Response: The agency agrees with this finding. A dedicated staff resource has been trained and has brought grant reconciliations and reporting current. Additional training has been provided for awareness of the obligation requirements as well. Anticipated Completion Date: June 30, 2025 Contact person: Beth Brown, Controller

2024-023 Oregon Department of Human Services Strengthen controls over program expenditures Management Response: We agree with this recommendation. Department management acknowledges the finding and has already initiated actions to address the concerns. Quarterly collaboration meetings including TANF and TADVS policy, business security unit, business operations, and office of financial services began in July 2024. Issues and resolutions are discussed during these quarterly meetings; as a result, guidance for staff has been developed, and regular internal audits take place throughout the year. Business operations team in partnership with TANF policy will send out communication reminding staff of the process when a check is reported as lost, and the steps that must happen prior to a replacement check being issued. In addition, policy and business operations will attend meetings with those who have a leadership role in the system to approve payments and share the transmittal along with a discussion on ways to mitigate duplicate payments in the future. Child Welfare reviewed and corrected the transaction identified in this audit. Although the SPOTS card was reimbursed on July 21, 2023, the request in OR-Kids was not canceled on that day causing the transaction to hit the SFMA. During the audit, the error was discovered and Federal Policy and Resources worked with Office of Financial Services (OFS) to correct the reimbursement on February 26, 2025. The transaction was canceled in the OR-Kids system through financial cycle on February 26, 2025. OFS entered the correction in SFMA to reflect the reduction to TANF funding, which processed through OR-Kids on February 27, 2025, and interfaced to SFMA on the evening of February 27, 2025. Anticipated Completion Date: 12/31/2025 Contact Person: Eva Ruiz, TANF program manager

2024-022 Oregon Department of Human Services Improve controls to ensure eligibility criteria are met Management Response: We agree with this recommendation. Beginning in April 2025 the Quality Control (QC) manager will have oversight of the process and be included in the emails between the QC lead and administration concerning the error packets being sent to the branch for corrective action by the 15th of each month. The QC manager will check on the 16th of each month to ensure the task was completed. Department management acknowledges the finding and has already initiated actions to address the concerns. The State of Oregon has implemented a structured approach to address this concern. Since January 2025, the Oregon Eligibility Partnership (OEP) has updated and developed six eligibility guides aimed at improving, understanding, and execution of processes related to TANF enrollment, including asset pursuit and IEVS checks. These guides are now available as part of the training curriculum for eligibility workers. Additionally, the "Verification Take Time for Training" (TT4T) module, which was last presented in October 2022, will be reviewed by the OEP to assess potential gaps or outdated information. Any necessary updates will be incorporated by July 2025 to ensure comprehensive training is available to all eligibility workers. Finally, OEP will continue to monitor the effectiveness of the updated training materials and guides through ongoing reviews, feedback collection from eligibility workers, and periodic review and refreshing of the materials. Anticipated Completion Date: December 31, 2025 Contact Person: Eva Ruiz, TANF program manager

2024-043 Department of Veterans' Affairs Encourage accuracy of per diem recalculations Management Response: ODVA agrees with this recommendation Reconciliation/recalculation procedures have been updated to fully align with regulations as established by 38 CFR 51.40. These procedures will include calculation of days when a veteran may be absent for purposes other than receiving hospital care. In addition to strengthening procedures, the controller will review the reconciliation each month. Anticipated Completion Date: June 30, 2025 Contact person: Nicole Dolan, Budget and Fiscal Manager

2024-038 Oregon Business Development Department Implement controls over reporting Management Response: We agree with this recommendation. The submission of the quarterly financial reports by Business Oregon to DAS CFRT is on-going and within the submission deadline of DAS CFRT staff. When preparing for the quarterly financial report, the accounting/financial data has been prepared by our accountant and reviewed by Business Oregon’s accounting manager. The data is then submitted to program staff to complete the programmatic narrative and other performance-related information to further explain or describe the transactions for the reporting period, and then program staff submits the quarterly report to DAS CFRT. Going forward, to ensure reports submitted to DAS CFRT match with accounting records, management will make procedure changes by routing the report back to the accounting team for final review of financial data after program has entered their part of the report before sending to DAS CFRT. We will implement this process change effective immediately for the quarterly report ending March 2025. For the cumulative variance of $1.6 million, Business Oregon will conduct research to determine the cause of the variance. The under-reporting of expenses on the quarterly report ending June 2024 could be the result of data provided to DAS in mid-July 2024, to meet DAS CFRT reporting deadline, when the fiscal month of June 2024 was not officially closed until early August 2024. While the fiscal year-end process was still on-going through August 2024, the month of June is still open for accrual entries or adjustments, resulting to more expenditures in accounting records than what was reported to DAS in July. Business Oregon will perform reconciliation of data from 2020 to March 2025 to true up the expenditures reported in the accounting records and the reports submitted to DAS CFRT. Anticipated Completion Date: March 31, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager

2024-031 Department of Education Implement controls to ensure FFATA reporting is completed for all required subawards Management Response: ODE agrees with this finding. To strengthen controls and ensure FFATA reporting is completed for all required subawards, ODE plans to implement the following process improvements: • Collaborate with the Child Nutrition program management and Fiscal Grants team to provide full documentation of grant awards including terms, conditions and attachments. • Update ODE’s grant profile request Smartsheet tool to: o Identify FFATA eligibility prior to setting up a new grant award in the accounting system. o Automatically notify the FFATA team of new grant awards that require reporting. Anticipated Completion Date: June 30, 2025 Contact person: Kristie Miller, Accounting Director

Recommendation: Our auditors recommended the Organization update their method of allocating expenditures to federal awards based on invoice date to ensure the incurred date is within the proper period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will review grant requirements and make sure that allowable costs are incurred and allocated to the grant within the grant period.

ndation: Our auditors recommended the Organization create effective internal controls and procedures over the cash management process and drawdowns of federal funds that allows for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will review grant requirements and make sure that drawdown terms are followed and that a review will take place over any drawdowns prior to requesting the funds.

Head Start - AL #93.6000 Recommendation: The Organization should perform an inventory count with proper reconciliations to asset listing along with having a different individual review and document such review of count/reconciliation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findings: We are currently in the process of finalizing the physical inventory count reconciliations to the asset listing along with having a different individual review and document that review. Name(s) of the contact person(s) responsible for corrective action: Rita Zilka, Fiscal Director Planned completion date for corrective action plan: September 30, 2025

Head Start - AL #93.6000 Recommendation: The Organization should establish a backup signatory process to ensure that there is always an available individual to provide necessary signatures, even during periods of unavailability. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the findings: We implement a policy to ensure there is someone available to provide signatures. Name(s) of the contact person(s) responsible for corrective action: Penny Paul Planned completion date for corrective action plan: September 30, 2025

Condition: Northeastern Illinois University (University) did not have adequate procedures in place to ensure the Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF) reports were accurate and timely submitted to the U.S. Department of Education and posted to NEIU’s website. Planned Corrective Action: The grants and Contracts Office will frequently review funding agency websites to ensure reports are up to date with changes in reporting requirements. The published reports will be revised to meet the requirements of the funding agency. The Grants and Contracts Office will also ensure that reports will be submitted and published as required by the funding agency in a timely manner. Contact person responsible for corrective action: Jannica Rae Quintana, Director of Controller’s office and Ruthann Griffith, Grants and Contracts Manager Anticipated Completion Date: 1/30/2025

Finding 2024-001: Rural Rental Housing Loans Assistance Listing Number: 10.415 U.S. Department of Agriculture Compliance Requirement: Eligibility 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 and Alamosa Site Manager to provide for a review process of tenant eligibility determinations. Action Taken: I have hired office personnel in the Monte Vista office. The procedures will be established to adequately segregate the duties. In the Alamosa office, either I or Priscilla Schimpf will be assisting Laura with adequately segregating the duties in that office. The process will become effective March 1, 2025. 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.

Finding 2024-002 Program: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Financial Assistance Listing Number: 14.251 Federal Agency: U.S. Department of Housing and Urban Development Grant Award Number: B-23-CP-CA-0240 Finding Summary: We identified one (1) project, “Courtplace”, in which Section 3 requirements are applicable to the City. The City was unable to provide supporting documentation to demonstrate that Section 3 requirements were communicated and followed by the applicable project contractor. Corrective Action Plan: The city continuously assesses internal controls and policy to ensure compliance with applicable regulations and standards. During an assessment, the city discovered the issue and corrected In October 2024 Since then, monitoring has been performed. As an additional safeguard, the city has implemented a bid portal where all applicable documents (grant letters, funding sources, project details, etc.) are submitted for review to ensure all grant requirements are included in bid specifications prior to posting. Responsible Individuals: Sid Lambert – Purchasing Manager; Eric Amaya – Assistant Engineer Anticipated Completion Date: April 2025

Recommendation: Review of vendors suspension and debarment should be done prior to entering into a contract or obtaining goods or services. Management Response: The City has worked and will continue to work diligently on this issue. The City is working to ensure that all vendors are properly reviewed for suspension and debarment on an ongoing basis. Responsible Parties: Brittany Retherford, City Manager, Nick Walsh, Comptroller, and Mindy Brown, Assistant Comptroller Anticipated Completion Date: September 30, 2025

Recommendation: Review of reports should be documented prior to submission to the grantor. Management Response: The City has worked and will continue to work diligently on this issue. The City is working to ensure that all reports are properly reviewed prior to submission and that evidence of the review process is properly documented. Responsible Parties: Brittany Retherford, City Manager, Nick Walsh, Comptroller, and Mindy Brown, Assistant Comptroller Anticipated Completion Date: September 30, 2025

Recommendation: The City should create a process to alert/remind management and City officials to meet the reporting requirements and deadlines. Corrective Action: The City recognizes the need for timely grant reporting and has recently added a Grants Administrator position to the Finance Department who has created a grant report tracking process. Responsible Parties: Candice Blake, Finance Director Anticipated Completion Date: September 30, 2025

The Utilites Board of the City of Oneonta will not request advance receipt of payment. The Organization will be following Procedure CFR section 200.305 (b)(1). Payments will be processed and issued within 10 business days of received date from engineer. If payments cannot be made within 30 days, received funds will be required deposited into a designated insured interest-bearing account until payments have been issued. Anticipated Completion Date: 2/4/2025 Responsible Person: Mark Gargus, General Manager

March 26, 2025 Eide Bailly, LLP Supervisor, Local Government & Finance Reno, NV 89706 Dear Mr. Kurt Schlicker, We have received and reviewed the audit report issued by your firm regarding our financial statements for the fiscal year ended June 30, 2024. We appreciate the thoroughness and professionalism demonstrated by your audit team throughout the process. We acknowledge the critical importance of establishing and maintaining an effective system of internal control over compliance, particularly in relation to accurate reporting of financial data reporting per Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303. As such, we are committed to taking immediate corrective actions to address accurate reporting of the SF-425 reports to the federal agency. We have outlined below the specific steps we have already undertaken and will undertake: 1. Revise & Standardize Reporting Procedures: a. Review the current SF-425 reporting procedures to identify gaps and inconsistencies. b. Revise and standardize the SF-425 reporting workflow to ensure consistency and accuracy in data entry. c. Implement a checklist for all required data fields on the SF-425 form to ensure no information is omitted or inaccurately reported. d. Develop clear guidelines for preparing and submitting the SF-425, detailing the roles and responsibilities of all staff involved. e. Establish a timeline for regular preparation and submission, ensuring reports are submitted on time. 2. Staff Training: a. Develop a targeted training program for staff responsible for preparing and submitting SF-425 reports, covering the details of the form, reporting standards, and compliance requirements outlined in 2 CFR Part 200. b. Conduct training sessions on accurate financial reporting, how to fill out the SF-425 form, and the importance of timely submission. Offer refresher training annually or whenever there are significant changes to the reporting process or the Uniform Guidance. c. Create written documentation, such as a manual or guide, to assist staff in preparing future reports. 3. Strengthen Internal Monitoring and Oversight Mechanisms: a. Create a two-tier review process: first, a departmental review by the grant administrator or compliance officer, followed by an executive-level review by a department head. b. Develop a checklist of specific financial items (e.g., total grant expenditures, unliquidated obligations, remaining balances) to ensure that all necessary data is accurately reflected. c. Ensure that any discrepancies identified during the review process are corrected prior to submission. d. Document all approvals and review steps for transparency and accountability. 4. Establish a Reporting Calendar and System for Timely Submission: a. Create a comprehensive reporting calendar that includes the submission deadlines for all SF-425 reports, as well as internal deadlines for review and approval. b. Implement a reminder system to notify relevant staff members in advance of upcoming deadlines for SF-425 submissions. c. Ensure that all parties involved in the reporting process are aware of their specific deadlines and responsibilities, with ample time allocated for review and approval. d. Monitor submission timelines to ensure that reports are submitted without delay. 5. Responsible Parties and Accountability to be designated: a. Department Head: Responsible for reviewing the SF-425 and provide ongoing oversight of the reporting process. b. Finance Department: Responsible for preparing the SF-425 reports, ensuring that financial data is accurate and complies with federal guidelines. c. Grant Administrator/Compliance Officer: Oversee the development and implementation of the corrective action plan, ensure compliance with federal regulations, and review SF-425 reports for accuracy and completeness. d. Procurement Staff: Ensure all financial activities related to the AFG are properly documented and reported in the SF-425. By implementing these corrective actions, we are committed to addressing the material weakness in compliance, including accurate reporting of SF-425 financial data. These steps will enhance the accuracy, reliability, and transparency of our financial reporting and improve our internal controls over our financial and federal reporting. The District is committed to ensuring the accurate and timely submission of SF-425 reports in accordance with federal regulations and the Uniform Guidance. By implementing this corrective action plan, we will strengthen our internal controls over compliance and reporting, ensuring that all federal financial reports are submitted correctly and within the required timelines. Through the establishment of robust procedures, training, and continuous monitoring, we aim to maintain the integrity and compliance of our financial reporting process for the Assistance to Firefighters Grant Program. We appreciate your insights and recommendations provided during the audit process and welcome any additional guidance or support your firm can offer as we work to address the identified weaknesses. Should you have any questions or require further information, please do not hesitate to contact me. Thank you for your continued partnership and support. Sincerely, Jackie Signorelli CFO