Corrective Action Plans

Due to changes in reimbursement and funding availability, the procurement policy and procedures will be revised to requiring at least one week prior to purchases being made unless there are extenuating circumstances, which will require an explanation on the Purchase Order Form. This policy will be reinforced. Expected Completion Date: Effective immediately, May 2026

Management acknowledges the auditors’ review of HUD HOME eligibility testing. We believe our current processes generally comply with HUD requirements; however, we recognize the opportunity to strengthen controls. To address the auditors’ comments, we will enhance our eligibility verification procedures, improve documentation consistency, and provide additional staff training. These corrective actions will help ensure ongoing compliance and accuracy in eligibility determinations. Personnel Responsible for Implementation: Meredith Elguira Position of Responsible Personnel: Community Development Director Expected Date of Implementation: April 30, 2026

Federal Agency Name: United States Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Federal Assistance Listing #10.766 Finding Summary: The Organization did not have an adequate internal control policy in place to ensure the reserve account was separately tracked and a documented review and approval over the reserve fund occurred. Responsible Individuals: Sharlene Knutson, Administrator Corrective Action Plan: We have adopted a policy to enhance internal control to ensure the reserve fund reconciliation has a secondary review and approval that is documented. Anticipated Completion Date: 6/30/2026

Management will update its procurement policies and procedures to require formal evidence that suspension and debarment checks are completed prior to entering into contracts. This will include requiring staff to sign/initial, and date SAM.gov verification screenshots or reports, or alternatively, obtain vendor certifications confirming their status. Training will be provided for relevant personnel to ensure consistent implementation of the revised procedures.

Management will conduct a comprehensive review of existing processes and internal controls related to eligibility determination and documentation to ensure alignment with federal requirements. As part of this effort, management will evaluate the timing and sequencing of required signatures to better reflect operational realities while maintaining compliance.

Allowable Activities and Costs, Cash Management, and Reporting Health Center Cluster – Assistance Listing No. 93.224 Recommendation: We recommend the Clinic develop and implement formal policies and procedures to ensure consistent review and approval over all applicable compliance requirements for federal programs. This should include but not limited to assigning responsibility for each compliance area, implementing documented review and approval controls (e.g., review of financial reports, cash drawdowns, and grant expenditures), and retaining evidence of review (e.g., sign-offs, checklists, or electronic approvals). Action taken in response to finding: The Clinic has implemented policies and procedures to ensure formal review and approval is documented for each compliance area. Name(s) of the contact person(s) responsible for corrective action: Kim Wieloch, Finance Director Planned completion date for corrective action plan: April 1, 2026.

Finding Number: 2025-002 Condition: DWIHN’s internal controls were not sufficiently designed and/or operating effectively to prevent the submission of unallowable costs for reimbursement under the federal award. Planned Corrective Action: Program and finance staff responsible for the approving and processing of FSR’s have been informed of the need to review FSR’s in greater detail before they are submitted, approved, and payment occurs. A more detailed review of the FSR’s and adherence to established policies and procedures will eliminate the risk of errors and omissions. Contact person responsible for corrective action: Vice President of Finance and Director of Grants and Community Engagement Anticipated Completion Date: August 7, 2025

We agree with the finding and will review and implement the recommendations accordingly. We are committed to ensuring proper application of indirect costs, avoiding duplication of costs across reporting periods, and maintaining compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan will be implemented by June 30, 2026.

As of March 2026, management has implemented controls that properly support the distribution of personnel charges. In addition, documentation is being obtained and retained to substantiate these charges and a new procedure of documenting the review process to help ensure these errors are corrected before submission to the grantors has been implemented.

Wesleyan College management has completed all outstanding reconciliations for the affected periods. Reconciling items noted during the delayed reconciliations were reviewed, investigated, and resolved or appropriately aged and documented. Evidence of supervisory review has been added to completed reconciliations where missing. Management is in the process of developing and implementing remediation and preventative actions, including strengthening reconciliation policies, assigning clear ownership and escalation procedures, and implementing monitoring controls to ensure reconciliations are prepared and reviewed timely. These actions are expected to improve the effectiveness of controls over material account balance reconciliations. Auditor’s Evaluation of the Corrected Action Plan: Wesleyan College’s response was appropriate for immediate remediation for the current affected period. Furthermore, the plan for preventative actions appears to be appropriately focused to ensure reconciliations are prepared and reviewed timely.

2025-003 Suspension and Debarment Recommendation: The City should put controls in place to verify SAM checks before authorizing a contract or a purchase order with a vendor for a covered transaction. Corrective Action: Management recognizes the importance of compliance with federal suspension and debarment requirements. Management has implemented procedures to ensure compliance with suspension and debarment requirements for federally funded transactions. As part of the procurement process, vendors responding to solicitations for grant-funded projects will be required to provide evidence of active SAM registration and certify that they are not suspended or debarred. In addition, prior to execution of contracts or issuance of purchase orders for covered transactions, management will perform and document an independent SAM.gov verification as part of standard pre-award procedures to confirm vendor eligibility. Responsible Parties: B. Keith Smith, Finance Director Anticipated Correction Date: September 30, 2026

2025-004 Reporting Recommendation: The City should review the underlying data along with the report to ensure that report agrees with the support and the underlying data is correct. Corrective Action: Management recognizes the importance of accurate and complete reporting to the U.S. Treasury. While procedures were in place, the review of underlying data was not sufficient to ensure accuracy and completeness prior to submission. The issue was limited to a single report and was corrected in the subsequent U.S. Treasury reporting cycle in accordance with program requirements. To prevent recurrence, management has enhanced its review procedures over grant reporting to include reconciliation of underlying data and validation checks for inconsistencies prior to report submission. Additionally, a secondary level of review will be performed to ensure reports are complete and accurate before submission to the U.S. Treasury. Responsible Parties: B. Keith Smith, Finance Director Anticipated Correction Date: September 30, 2026

The Florida School Nutrition Association, Inc. (FSNA) acknowledges the audit finding regarding the misalignment between the pass-through entity’s grant agreement and the OMB Compliance Supplement for ALN 10.185. While the Association operated in accordance with the terms of the executed agreement with the Florida Department of Agriculture and Consumer Services, it was subsequently determined that certain administrative costs permitted under that agreement were not allowable under the Uniform Guidance (2 CFR Part 200). Finding 2025-001: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Upon identification of this discrepancy, FSNA has taken immediate and decisive action: Program Termination & Strategic Shift: FSNA has formally concluded its participation in the Local Food for Schools Cooperative Agreement Program and has ceased all related activities. The Association has made the strategic decision not to pursue or engage in federal grant programs of this nature moving forward. This determination ensures alignment with the organization’s operational capacity and mitigates compliance risk associated with complex federal cost principles. Final Resolution: The identified material weakness has been addressed through the discontinuation of the applicable program, thereby removing the operational conditions under which the noncompliance occurred. Future Funding Consideration (If Applicable): While FSNA does not anticipate pursuing similar federal awards, the organization has established an internal standard that any future funding opportunities, if considered, will undergo a comprehensive compliance review to ensure alignment with the Uniform Guidance (2 CFR Part 200), the OMB Compliance Supplement, and all grantspecific terms and conditions. Record Retention: FSNA will maintain all financial and supporting documentation related to the FY25 audit period in accordance with applicable federal record retention requirements.

Management will be refreshing training and cross-training for staff to ensure accurate calculation of rental assistance and timely completion of interim certifications whenever required. Additionally, we will provide a refresher training to staff on HUD Section 8 documentation standards.

Finding 2025-002 – Significant Deficiency AL Nos: 20.507 and 20.526, 20.205 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Cluster - Direct Award Compliance Requirement: Other Compliance Requirements Award Nos: All awards under Assistance Listing (AL) Numbers 20.507, 20.526, and 20.205 Condition: Several changes were made to the schedule of expenditures of federal awards (SEFA) after the single audit began, including: - The periods of performance had to be updated on several grants. - Missing criteria, such as the award date, had to be added for new grants. - The assistance listing number was corrected for two grants. - A grant amount immaterial to the major program was removed from the SEFA after the single audit began. - Adjustments were made to the SEFA after the audit began to claim current year expenses for disallowed 2024 costs to fully implement the recommendation made in the 2024 single audit. - Qualified expenses were shifted between eligible routes for one grant on the SEFA. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Cause: Grant management procedures are not documented, a complete schedule of all available grants to use when reconciling expenses for inclusion on the SEFA and accruing grant revenue was a work in progress and not all necessary changes were identified by the District’s review procedures. Effect: Expenses were omitted from the SEFA and other expenses were included on the SEFA that were already reported in the prior year. The SEFA had to be revised, which delayed the audit testing and major program determination process. Context: The number of grants has increased since the pandemic due to new pandemic related grants becoming available that delayed the use of the District’s regular federal grants. This caused grants to be combined by grantors with different allowable expenses, areas of service, and periods of performance and caused grants to be extended, causing significant complexity. The dollar amount of auditor changes made to the SEFA were immaterial and the SEFA was not relied upon by the District to ensure compliance with compliance requirements so the changes to the SEFA did not result in noncompliance with other compliance requirements. The District staff made a significant effort to bill all qualifying expenses during the audit, which will help reduce the complexity of remaining grants in future years. Recommendation: We recommend the District develop written procedures to allocate expenses to routes and purposes under federal grants that document the timing of the preparation and review of the allocation schedule. A summary tab should be added to the allocation schedule to reconcile amounts for each route/purpose to total operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the population of expenses in the general ledger. We also recommend the District develop a schedule to summarize all approved and pending grants that includes the amounts available under each grant, each route/purpose within each grant, periods of performance for each amount available, the last date to submit invoices, and amounts claimed and still available for each grant by route/purpose. The District should re-evaluate budgets if changes or delays occur to federal grants and ensure a new federal or local funding source is identified and claimed for the expenses. The SEFA should be prepared after expenses are reconciled to the general ledger at the invoice/paycheck level by route/purpose and the allocation schedule is thoroughly reviewed. The SEFA should be reviewed by a knowledgeable member of management to ensure completeness and accuracy. We also recommend the District claim expenses more quickly to allow the granting agency time to review and approve the claims before the audit begins. We recommend the District reconcile expenses within 30 days of quarter end and prepare claims within 45 days of quarter end. If the District is unsure about the period of performance dates or other restrictions on a grant, staff should contact the granting agency for clarification. Finally, we recommend the District request the grants be made available for general operating expenses rather than for individual routes, times etc. to reduce complexity wherever possible. 2025-002 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and recognizes the importance of maintaining strong procedures for the monitoring, allocation and claiming of federal grant expenses. Over the past year, the District has made significant progress addressing the complexity created by the increase in federal grants following the pandemic, including reviewing prior year grant activity, resolving overclaims, coordinating closely with Federal Transit Administration (FTA), and amending grants where necessary. During this process, the District delayed certain claims while prior year matters were being resolved to ensure that expenses were claimed appropriately and in accordance with grant requirements. Staff also developed improved internal worksheets and summary schedules to track grant activity and allocations across funding sources. As the District moves beyond the review and resolution of older grant issues, management expects continued improvement in the monitoring, management, and reconciliation of federal funding sources. The District will continue strengthening internal procedures, including developing more formal written documentation of allocation methodologies, reconciliation schedules, and review procedures. These efforts are expected to further improve timeliness, accuracy, and oversight of grant reporting and claiming activities. Responsible Party: Director of Finance & Administration Implementation Date: Ongoing; full implementation expected by December 31, 2026 YCTD Contact Person Responsible for the Correction Actions; Chas Ann Fadrigo.

Signing of invoices have been added to our procedures when submitting invoices for payment. The required staff were notified of this addition to the procedures.

Finding Number: 2025-001 Condition: The Township submitted the required reports, but one of the reports submitted did not properly identify the federal expenditures paid during the reporting period. Planned Corrective Action: The Township will implement a reconciliation and review process requiring all reported federal expenditures to be verified against the general ledger and supporting documentation prior to submission. In addition, the Township will correct the identified errors and resubmit the report with accurate federal expenditure information. Contact person responsible for corrective action: Wendy Hillman Anticipated Completion Date: 12/31/2026

Management agrees with the finding and will strengthen procedures over documenta􀆟on and drawdown processes, including 􀆟mely, organized maintenance of suppor􀆟ng documenta􀆟on and improved processes for preparing and suppor􀆟ng reimbursement requests.

Finding No. 2025-001 Internal Controls Over Compliance a. Comments on the Finding and Each Recommendation We agree with the auditors’ findings and recommendations. b. Action(s) Taken or Planned on the Finding The managing agent has hired an accounts receivable personnel to ensure rent collections and deposits are processed in a timely and consistent manner.

Finding Number: 2025-004 It is recommended that that district review the design of its internal control over compliance to ensure the documentation requirements are incorporated into the control design. Response: To enhance internal controls to ensure the segregation of duties, the Assistant Director of Food Services will be responsible for the initial preparation and completion of all the claims. Subsequently, a secondary review and approvable will be preformed by either the Director or the Chief School Business Official (CSBO) prior to submission.

Finding: 2025-084 - The University did not properly maintain documentation to demonstrate a student’s intent to become a permanent resident. Questioned Costs: None Assistance Listing Number: 84.044 Assistance Listing Title: TRIO Cluster Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding. Corrective Action (corrective action planned): Services for the students involved have been terminated. UAA has reviewed the current procedures and implemented system improvements to prevent similar omissions in the future. The existing student eligibility verification checklist has been reviewed thoroughly to ensure all required documentation is in place; and a random sample of students files will be reviewed semi-annually to proactively identify any issues. In addition, all the staff involved have completed the necessary training. Completion Date (list anticipated completion date): Completed Agency Contact (name of person responsible for corrective action): Tamika Dowdy, UAA TRIO Programs Director, 907-786-4520

Finding: 2025-083 - The University did not properly report student enrollment changes for - students who received federal student aid to the National Student Loan Data System. Questioned Costs: None Assistance Listing Number: 84.063, 84 268, 84.007, 84.033 Assistance Listing Title: SFAC Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding. Corrective Action (corrective action planned): The untimely enrollment reporting issue was related to gainful employment reporting and the use of National Student Clearinghouse as part of the reporting process. The process has since been corrected to ensure timely reporting going forward. The inconsistent effective date reported was related to an unofficial withdrawal. The office of Registrar is developing procedures to ensure the reported date of unofficial withdrawals aligns with the institutional records in the future. Completion Date (list anticipated completion date): May 31, 2026 Agency Contact (name of person responsible for corrective action): Holly McDonald, UAF Registrar, 907-474-6300

Finding: 2025-082 - The University did not pay student’s Title IV credit balance within 14 days. Questioned Costs: None Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Assistance Listing Title: SFAC Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding. Corrective Action (corrective action planned): UAF has implemented automated refunds since Spring 2025 to ensure the refunds are returned to the students promptly. Additionally, a weekly monitoring report has been established and is reviewed regularly to identify and resolve any issues in a timely manner. Completion Date (list anticipated completion date): Completed Agency Contact (name of person responsible for corrective action): Jennie Witter, UAF Bursar, 907-474-6196

Finding: 2025-081 - During inquiries with management the University of Alaska identified multiple students during enrollment verification process that they determined were fictious. Questioned Costs: AL 84.007: 4,947, AL 84.063: 27,059, AL 84.268: 158,554 Assistance Listing Number: 84.063 84.268 84.007, 84.033 Assistance Listing Title: Student Financial Assistance Cluster (SFAC) Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding. Corrective Action (corrective action planned): The university has been actively implementing process improvements across all campuses (UAF, UAA and UAS) to strengthen controls and prevent similar occurrences. Enhancements to the existing processes include the deployment of multilayered interim screening measures to mitigate fraudulent accounts and strengthen internal controls. In addition, the University has acquired a long-term software solution which is currently in the final phase of implementation, to further enhance identity verification procedures and strengthen cybersecurity capabilities. Completion Date (list anticipated completion date): May 31, 2026 Agency Contact (name of person responsible for corrective action): Amanda Wall, AVC, UAF Financial Services, 907-474-7552

Finding: 2025-080 - The University did not have documentation of the Federal Funding - Accountability and Transparency Act (FFATA) reports submitted in a timely manner. Questioned Costs: None Assistance Listing Number: 10.237 Assistance Listing Title: From Learning to Leading: Cultivating the Next Generation of Diverse Food and Agriculture Professionals Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding. Corrective Action (corrective action planned): FFATA reporting is currently managed by UAF Office of Grants & Contracts Administration (OGCA). OGCA has developed procedures in place to ensure that all FFATA reports are submitted as soon as the awards are fully executed. In addition, OGCA will create a new report on SAM.gov for subaward amendments to provide clear and complete reporting documentation. Completion Date (list anticipated completion date): Completed Agency Contact (name of person responsible for corrective action): Brent Davis, UAF OGCA Grants and Contracts Officer, 907-474-1851