Corrective Action Plans

Corrective action plan: Dallas County HCVP will expand inspection capacity by hiring additional full-time and contractual inspectors, including an Inspector Supervisor, to ensure timely completion of all inspections within HUD-required timeframes. Increasing staffing levels will enable the program to meet HUD-required timeframes consistently and reduce the likelihood of delays. Additionally, the Housing Supervisor will review inspection status regularly to ensure compliance with HUD-related inspection schedules. Implementation dates: September 30, 2026 Responsible persons: Kesete Yohannes, Assistant Director of Housing

Corrective Action Plan: Dallas County HCVP leadership addressed EIV compliance during the April 2026 and May 2026 monthly staff meetings and will continue to emphasize the requirement. Review of meetings agendas dated April 22, 2026, and May 20, 2026, confirm that EIV compliance was discussed. Additionally, the HCVP Housing Supervisor issued an email to all staff reiterating the requirement to retain EIV reports for all transactions, including but limited to recertifications, interims, and relocations. Implementation Date: June 11, 2026 Responsible Party: Kesete Yohannes, Assistant Director of Housing

Corrective action plan: The Ryan White Grants Management Division will ensure the addition of enhanced controls to the existing subaward agreement template. Implementation dates: August 30, 2026 Responsible persons: Sonya Hughes, Assistant Director, Ryan White Grants Compliance

Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: We recommend the District implement a formal process requiring documented evidence of review and approval of all reimbursement requests prior to submission, such as dated sign-offs or electronic approval records, to strengthen internal controls and ensure compliance with Federal requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will provide formal documentation by reviewing and signing the claims for approval of reimbursement requests before submission to the state. Name(s) of the contact person(s) responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025

Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: We recommend the District obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on SAM.gov. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will ensure the process of suspension and debarment checks are performed prior to entering into contracts. Name(s) of the contact person(s) responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025

Comment #2025-001 COMPENSATION METHODOLOGY SHOULD BE REVIEWED FOR INCENTIVE PAYMENTS COMMUNITY SERVICES BLOCK GRANT AND LOW-INCOME HOME ENERGY ASSISTANCE PROGRAM FAL #93.569 and 93.568 Views of Responsible Officials and Planned Corrective Actions: Management concurs with the recommendation. FACAA updated its Incentive Compensation Policy, which was approved by the Board of Directors, in accordance with 2 CFR 200.430 and 2 CFR 200.303. The policy establishes the methodology for incentive payments, and all incentive payments have been documented and supported by appropriate records to ensure compliance with applicable federal requirements. Implementation Date: Effective immediately, our policies have been enhanced to clarify and support our methodology used during the periods noted under review, and for all subsequent periods. Responsible Person(s): Dr. Howard Grant, President/CEO

Program: Section 8 Housing Choice Vouchers (HCV) Finding: 2025-004 Finding Title: Internal Controls Over Participants Reexaminations Identification as a repeat finding if applicable: 2024-007 Contact Person: Michelle Mel-Duch, Housing Administrative and Financial Services Officer, Health & Human Services Department, (562) 570-5344, Michelle.Mel-Duch@longbeach.gov Planned Actions: HACLB has updated its SEMAP Quality Control sample size worksheet to ensure the minimum required sample size is calculated using the total number of assisted families, in accordance with HUD SEMAP Indicator 3 requirements. The revised worksheet will be used for future quality control reviews to ensure compliance with federal requirements. In addition, HACLB has transitioned to the MRI housing management software platform, which provides enhanced reporting capabilities to generate accurate listings of assisted families, support the selection and tracking of quality control samples. To strengthen internal controls, HACLB will implement and document completion of reviews of reexamination files selected for SEMAP quality control. Expected Completion Date: December 31, 2026

Program: Section 8 Housing Choice Vouchers (HCV) Finding: 2025-003 Finding Title: Internal Controls over Compliance of Reinspection’s to Enforce Housing Quality Standards Identification as a repeat finding if applicable: 2024-005 Contact Person: Michelle Mel-Duch, Housing Administrative and Financial Services Officer, Health & Human Services Department, (562) 570-5344, Michelle.Mel-Duch@longbeach.gov Planned Actions: Process Improvement for Reinspection Scheduling HACLB implemented an enhanced reinspection scheduling process designed to ensure that all reinspections are completed prior to the expiration of the required 30-day correction period. As part of this effort, HACLB configured its housing management software system (MRI) to generate and schedule reinspections upon identification of deficiencies. Compliance Monitoring HACLB utilizes MRI to identify and track cases where extensions have been requested or approved. The MRI functionality provides staff with visibility into extension requests while maintaining oversight of compliance requirements. Inspections staff reviews scheduling reports to monitor upcoming and overdue reinspections, verify completion of required inspections, and ensure timely follow-up on outstanding cases. Ongoing Monitoring and Quality Assurance To further strengthen compliance, inspections staff will conduct periodic reviews of payment hold reports to track approved extensions and to verify that all required reinspections have been scheduled. Any identified discrepancies will be promptly addressed through corrective action, staff coaching, and process improvements as necessary. Expected Completion Date: December 31, 2026

Program: Section 8 Housing Choice Vouchers (HCV) Finding: 2025-002 Finding Title: Internal Controls and Compliance over the Timeliness of Housing Choice Voucher Participant Re-examination and Recertification Identification as a repeat finding if applicable: 2024-003 Contact Person: Michelle Mel-Duch, Housing Administrative and Financial Services Officer, Health & Human Services Department, (562) 570-5344, Michelle.Mel-Duch@longbeach.gov Planned Actions: Staffing Augmentation and Organizational Support HACLB has recruited additional Housing Specialists to support management of the high-volume Housing Choice Voucher (HCV) Program, improve processing efficiency, and ensure compliance with HUD requirements and program deadlines. HACLB has hired a Housing Administrative and Financial Services Officer and a Housing Operations Program Officer. These positions provide strategic oversight of program operations, staff productivity, workload management, resource allocation, and performance monitoring. As of June 23, 2026, eight Housing Specialists have been hired and have undergone training. HACLB has requested renewal of the supervisory eligibility list to fill several vacant supervisory positions critical to operational oversight and staff development. To further reduce the backlog, HACLB has reassigned duties and created a dedicated team responsible for tracking overdue recertifications, monitoring progress, and implementing measures to ensure ongoing compliance. Contracted Support Services To accelerate backlog reduction efforts, HACLB renewed its contract with an external agency to provide dedicated assistance with processing overdue reexaminations. Additionally, HACLB has initiated a competitive procurement process to secure supplemental third-party support services to assist with backlog clearance and provide additional operational capacity while newly hired staff complete training and onboarding. Technology Improvements HACLB has transitioned to a new housing management software platform (MRI PHA Pro) designed to improve annual recertification tracking, workflow management, reporting capabilities, and productivity monitoring. The software system provides: • Enhanced monitoring of annual recertification deadlines. • Improved workflow tracking and assignment management. • Dashboard reporting and exception monitoring. • Increased visibility into staff productivity and workload distribution. • Improved compliance monitoring Additional Actions Taken to Date HACLB has implemented several operational improvements to strengthen internal controls and maintain compliance: Process Improvements • Revised recertification workflows and assignment procedures. • Established productivity targets and performance expectations for Housing Specialists. • Utilized MRI dashboards and exception reports to identify overdue cases and trigger management escalation procedures. • Increased supervisory oversight of workload distribution and case processing. Data Monitoring and Oversight Program management and data analytics staff actively monitor program performance and backlog reduction efforts through: • Regular forecasting and workload analysis. • Prioritization of high-risk and overdue cases. • Exception reporting and trend monitoring. • Ongoing evaluation of staffing needs and productivity levels. Staff Training HACLB continues to provide training for both new and existing staff on: • HUD recertification requirements. • Timeliness standards. • Case processing procedures. • Workflow management and quality assurance practices. Expected Completion Date: December 31, 2026

Program:HOME Investment Partnerships Program (HOME) Finding:2025-001 Contact Person:April Apodaca Administrative & Financial Services Bureau Manager Community Development Department Phone: (562) 570-6611 Email: April.Apodaca@longbeach.gov Planned Actions: The City has exercised its rights to enforce compliance with the terms of its contractual arrangement for this standalone developer/owner, which has resulted in the highest levels of legal action. Through its established monitoring and review procedures, City staff identified documents submitted by the developer that appeared to be inaccurate or falsified. This discovery prompted a multi-year investigation and subsequent litigation, undertaken in direct collaboration and response to instructions as directed by HUD. Throughout this period, the City’s investigative and litigation activities have not been historically viewed as compliance concerns, particularly given their necessity in preserving the integrity of the legal process. At every stage, the City has acted consistently with HUD’s directives and the requirements of the applicable contractual framework. During the multi‑year investigation, HUD expressly instructed the City to continue normal program operations to avoid alerting the developer and to maintain the integrity of the ongoing inquiry. The City respectfully asserts that the audit finding is inconsistent with HUD’s guidance and the historical practices necessary to ensure effective enforcement. Since the initial identification of the finding, the City has taken all reasonable corrective actions within its authority to address the issue and mitigate associated risks. These actions include following established monitoring procedures to ensure compliance with HOME program requirements, making repeated documented requests for tenant eligibility records from the developer/owner, and escalating efforts through the City Attorney. This issue is isolated to one developer/owner and sampling for other developers/owners has not identified similar concerns. The City has been transparent about the ongoing litigation involving the standalone developer/owner responsible for maintaining the records and remains committed in resolving this matter and in pursuing additional actions available once the legal proceedings have been concluded.

Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Financial Assistance Listing Number: 10.766 Finding Summary: As a part of the audit process, a reclassification entry was made to move an additional 12 months of reserve funds from the cash sweep general fund to a separate bookkeeping account. The Hospital had excess cash available to cover the required reserve amount for the fiscal year. Responsible Individuals: Renae Karst, Chief Financial Officer Corrective Action Plan: Management will fund the reserve account from the cash sweep general fund and will monitor the separate bookkeeping account throughout the year to ensure the reserve is properly funded throughout the year as required by the loan documents. Anticipated Completion Date: June 30, 2026

Finding 2025-001- Material Weakness related to Procurement and Suspension and Debarment Information on the federal program: Federal Agency: Department of Health and Human Services, Department of Homeland Security, Department of Defense, Department of Justice, National Science Foundation, Department of Agriculture, US Agency for International Development Program Name: Research and Development Cluster Assistance Listing Number: Various Planned corrective action: The Medical Center has updated the reporting logic of the vendor report submitted to the third-party service provider for suspension and debarment evaluation. The Medical Center has also implemented an internal control where a member of Research Finance management will review the vendor report for accuracy and completeness and sign-off prior to submitting to the third-party service provider for suspension and debarment evaluation. Name of responsible official: Michael Brennan Director, Research Finance Michael.Brennan@childrens.harvard.edu Anticipated completion date: May 11, 2026

Management Response and Corrective Action Plan Finding 2025-001 – Allowability Federal Agency: United States Department of Health and Human Services Program Name: Research and Development (R&D) Assistance Listing Number: 93.859 Responsible Individual: BIDMC – Jarod Kohr, Director, Research Finance or The Center - Roy Bourne, Director, Research Finance and Operations Contact Information: BIDMC - jkohr@bidmc.harvard.edu; 617-216-7479 The Center - rbourne2@joslin.harvard.edu; 617-309-5741 A review of Beth Israel Deaconess Medical Center’s (BIDMC) salary allocation process revealed 53 instances out of approximately 11,000 records of allocation in excess of NIH Salary Cap limits (0.04%). BIDMC acknowledges discovery of system limitations that will correct future instances. Accordingly, management has concluded that controls are operating as intended, but will be enhanced to limit human errors. Corrective Action Plan: - Management will implement a calculation control that will prevent the ability to save changes to salary allocation that exceeds the salary cap for the respective period. (Completed) - Management will implement a calculation control that will prevent the ability to reflect a percent salary higher than the percent effort for any salary cap controlled grant. (Completed) - Management will monitor monthly changes to effort/salary allocations in the Time and Effort system for calculated variances. (Ongoing) Expected Completion Date: October 1, 2026 Status of Completion: In process The Center’s management acknowledges that an invoice was incorrectly matched to a purchase order; however, this was not reflective of the overall control environment. The Center maintains established controls over purchase order invoice processing, including system-generated duplicate invoice detection, cost matching tolerances, and restrictions preventing matching to closed purchase orders. Transactions outside established parameters are automatically flagged for manual review. Management performed a targeted review of these transactions, noting expenditures were properly allocated with the exception of the item noted in this finding. Accordingly, management has concluded that controls are operating effectively overall, Accordingly, management has concluded that controls are operating effectively overall, while continuing to evaluate and enhance processes to further mitigate the risk of recurrence. Corrective Action Plan: - Management will reinforce matching requirements through targeted training and communication with Accounts Payable and Purchasing (Completed) - Periodic reconciliation reviews will be performed to identify and correct any misallocated costs as necessary (Completed) - The Center’s planned implementation of a new ERP system on October 1, 2026 will introduce enhanced automated matching controls, further reducing the likelihood of recurrence Expected Completion Date: October 1, 2026 Status of Completion: In process

Special Tests and Provisions Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance Department of Agriculture Federal Financial Assistance Listing #10.766 Community Facilities Loans and Grants Finding Summary: The Hospital did not maintain the required debt service coverage ratio for the year ended December 31, 2025. Additionally, the Hospital does not have a control process in place to ensure that the monitored debt service coverage ratio is accurate and non-compliance is reported timely. Responsible Individuals: Eric J. Price, CFO Corrective Action Plan: Management has enhanced internal control policies and processes to monitor compliance with debt covenants, including the periodic calculation of debt service coverage ratio, documentation of management review and approval, and timely communication with the lender if noncompliance is identified. Anticipated Completion Date: September 30, 2026

Finding Number: 2025-001 Finding Title: Procurement Controls (Significant Deficiency) Name of Contact Person: Janice Clark, Chief Finance & Operations Officer Corrective actions implemented or in process include the following: 1. Enhanced Procurement Oversight and Centralized Review The Organization, building on its established procurement policies, implemented stricter headquarters oversight and approval requirements for higher-risk and higher-dollar procurements, including defined approval thresholds for procurement solicitations, evaluation activities, and contract execution. Specialized and international procurements now require additional senior-level review and involvement, regardless of value. 2. Strengthened Vendor Due Diligence and Market Research Procedures The Organization updated procurement procedures to require expanded documentation of vendor due diligence and market research activities, including enhanced validation of vendor qualifications, procurement support documentation, and vendor representations associated with federal procurements. 3. Enhanced Monitoring of Procurement Documentation and Compliance Requirements Management implemented strengthened review procedures over procurement advertisements, vendor certifications, geographic code compliance documentation, and other supporting procurement records. The revised procedures also require additional review and escalation for identified procurement irregularities or inconsistencies. 4. Advance Payment and Approval Controls The Organization implemented revised controls governing advance payments, including enhanced approval requirements for significant prepayments and additional supporting documentation requirements for high-risk payment arrangements. 5. Procurement Evaluation and Technical Assistance The Organization enhanced procurement evaluation oversight by requiring additional Headquarters participation in evaluation activities for procurements exceeding defined thresholds. In addition, the Organization engaged specialized procurement and logistics resources to provide technical assistance and support for international procurement activities. 6. Personnel Actions and Training The Organization took personnel actions in response to the investigation findings and implemented enhanced procurement and compliance training for relevant personnel involved in procurement and grants management activities. Management believes these corrective actions appropriately address the control deficiencies identified in the finding and strengthen the Organization’s internal control over compliance related to procurement activities under federally funded programs. Anticipated Completion Date: Substantially completed as of April 6, 2026, with ongoing monitoring and training activities continuing through fiscal year 2026.

At the time of the audit, we did not have a policy to require managers sign off on credit card payments in the way that they sign off on check payments. We did not require management approval because receipts were required to be submitted with every credit card purchase and reviewed by the finance team monthly. The policy to require management approval for credit card payments has since been adopted, however, after the fiscal year under audit.

Almost Home, Inc. has formalized this through our required client file checklist and related policy. The policy was in place and was applied improperly. Staff members who failed to apply the policy were given corrective action at the time. Our quality/compliance control processes did not catch this mistake in time, and our management corrective action plan will include improvements on the quality/compliance control to ensure that all necessary documentation is maintained. Also necessary to note is the fact that Almost Home, Inc. will no longer receive TANF funding as of December 31, 2025.

There is no direct guidance detailing steps to update the FMAP rate in STAARS. Changes are made in the STAARS cost allocation test environment and then implemented in the production environment via STAARS Support. Cost allocation runs quarterly. While we initiate the entering of statistics from work sampling and other sources, we are at the mercy of STAARS Support to actually run cost allocation for DHR.

DHR has added additional steps related to Adult Day Care services entered in FACTS. This will ensure entered services reconcile to the approved invoice prior to approval in FACTS.

The Alabama Emergency Management Agency (AEMA) will strengthen its subrecipient monitoring procedures to ensure compliance with the audit requirements outlined in 2 CFR 200.501. AEMA will implement formal written procedures requiring the identification of subrecipients subject to Single Audit requirements and the timely collection, review, and retention of applicable audit reports. AEMA will establish a centralized tracking system to monitor the receipt of required audit reports and identify subrecipients that have not submitted audits by the required due date. Designated personnel will be responsible for conducting and documenting reviews of all received audit reports to determine whether any findings, questioned costs, or deficiencies impact federally funded programs administered by AEMA. In instances where audit findings are identified, AEMA will follow up with subrecipients to obtain corrective action plans and monitor the implementation of corrective actions to ensure identified deficiencies are adequately addressed. Management will also implement periodic supervisory reviews to verify that audit reports are obtained, reviewed, and documented in accordance with federal requirements.

Finding Number: 2025-003 Finding Title: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting Program: 93.658 Foster Care Title IV-E, 93.778 Grants to States for Medicaid Name of Contact Person Responsible for Corrective Action: Ryan DuMond, Supervisor, Accounting Corrective Action Planned: Staff will conduct thorough reviews of all Quarterly Fiscal Memos and attachments issued by DHS to ensure that reporting requirements are fully understood and applied consistently. The County will also develop and document a comprehensive procedure for preparing the DHS‑2550 and DHS‑2556 reports, including detailed instructions for entering adjustments, processing reversing entries, reporting amortization, properly coding capital purchases, and handling MAXIS‑related costs. A mandatory review process will be implemented before submission of each report to verify accuracy and compliance with DHS guidance. As part of this review, staff will closely examine expense classifications to ensure that capital outlay expenditures are accurately coded and reported, and that all required amortization expenses are correctly included. These actions will help prevent misclassification and report errors in future submissions. Anticipated Completion Date: July 2026

Management Response: Management acknowledges Finding 2025-004 and agrees that weaknesses in the review and approval of expenses represent a material weakness in internal control over compliance. The reimbursement of personal credit card expenses and the charging of those transactions to federal awards resulted in unallowable costs and demonstrated a breakdown in the review process for employee reimbursements and supporting documentation. Although the known questioned costs total only $46, the broader risk is that additional unallowable, unsupported, or improperly coded expenses could be charged to federal awards if review controls are not strengthened. Management determined that the root causes included insufficiently detailed procedures for reviewing employee reimbursement requests, inconsistent verification of business purpose and allowability before reimbursement, and inadequate supervisory review of expense documentation before costs were posted to federal awards. Existing controls were not precise enough to identify personal or otherwise unallowable charges embedded within reimbursement activity, particularly when descriptions were incomplete or reviewers did not independently confirm that the expense was necessary, reasonable, properly documented, and allowable under Uniform Guidance. To address this material weakness, management is implementing a corrective action plan focused on strengthening pre-payment and pre-posting review of employee reimbursements and other expense transactions charged to federal awards. The plan includes four key actions: revising reimbursement and accounts payable procedures to require detailed support for every request; requiring documented secondary review by supervisory or finance personnel independent of the submitter; implementing exception-based review procedures for higher-risk transactions; and performing periodic post-payment monitoring to confirm that review procedures are operating effectively and that unallowable costs are promptly identified and corrected. Under the revised process, no employee reimbursement or expense charged to a federal award will be approved unless the request includes sufficient supporting documentation to allow the reviewer to determine that the cost is necessary, reasonable, allocable as applicable, consistently treated, and adequately documented in accordance with Uniform Guidance cost principles. Reviewers will be required to confirm the business purpose of the transaction, assess whether the type of cost is allowable under the terms of the award and applicable federal regulations, and verify that no personal items, duplicate charges, sales tax errors, or unsupported amounts are included. If documentation is incomplete or a charge appears questionable, the transaction will be held pending clarification, recoded to a non-federal source, or denied reimbursement as appropriate. Any unallowable expense identified after reimbursement will be promptly removed from the applicable federal award and reported through management’s corrective follow-up procedures. Management will also reinforce accountability through targeted training and oversight. Employees who prepare, review, approve, or process reimbursements and expense reports affecting federal awards will receive training on allowable cost principles, documentation expectations, and the importance of careful review under 2 CFR Part 200, including the requirement that costs be adequately documented and necessary and reasonable for the performance of the federal award. In addition, Finance will generate periodic exception reports highlighting reimbursement activity charged to federal awards, personal credit card reimbursements, and other transactions meeting defined risk criteria. These reports will be reviewed by management to identify trends, address control failures, and implement additional corrective measures when needed. Management believes these corrective actions directly address the auditors’ recommendations and strengthen controls over the review and approval of expenses charged to federal awards without repeating the corrective actions already established for pre-award costs, allocation methodology, or broader financial close procedures. Responsibility for implementation will rest primarily with the Finance Director, in coordination with accounts payable, grants, and program leadership. Management expects enhanced documentation standards, independent review requirements, exception-based oversight, and monitoring activities to reduce the risk of personal or otherwise unallowable expenses being reimbursed and charged to federal awards in future periods. Corrective Action Plan Summary Corrective Action Responsible Staff/Role Target Completion Date Evidence of Completion Revise and adopt written expense reimbursement and accounts payable review procedures requiring itemized receipts, documented business purpose, funding source identification, and explicit confirmation that requested costs are not personal in nature. Finance Director; Accounts Payable Supervisor June 30, 2026 Approved procedures; updated reimbursement forms; staff distribution records. Implement a standardized reimbursement review checklist requiring reviewer validation of allowability, Accounts Payable Supervisor; July 15, 2026 Completed checklist template; sample reviewed reimbursement business purpose, receipt support, coding accuracy, and identification of any personal or unsupported charges before reimbursement or posting to a federal award. Finance Director packages; approval signoff documentation. Require independent supervisory review and approval for all employee reimbursements and any expense transaction charged in whole or in part to a federal award, including personal credit card reimbursement requests. Finance Director Effective immediately Supervisor approval records; signed reimbursement packages; workflow evidence showing independent review. Provide targeted training for employees, supervisors, accounts payable, and grants personnel on allowable cost principles, documentation standards, and reviewer responsibilities for expenses affecting federal awards. Compliance Officer; Finance Director August 31, 2026 Training materials; attendance logs; completed acknowledgements or knowledge checks. Create periodic exception reports for reimbursement activity charged to federal awards, missing receipt transactions, unusual merchants, and other higher-risk expense patterns, and require documented management review of the results. Accounting Manager; Finance Director September 30, 2026 Exception report format; monthly or quarterly review logs; documented follow-up on exceptions. Perform quarterly post-payment monitoring of a sample of reimbursed expenses charged to federal awards to verify compliance with documentation, Compliance Officer; Finance Director Quarterly, beginning September 30, 2026 Quarterly monitoring reports; exception logs; evidence of recoding, recovery, or corrective follow-up. approval, and allowability requirements and to ensure prompt correction of any identified exceptions.

Item 2025.003 - Cash Management Recommendation The Organization should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding Not a repeat finding. Action Taken The Health Center has engaged Cambire Consulting, a grant and contracts consulting firm. A drawdown policy will be established for the July 2026 Board Meeting for approval.

Persons responsible for corrective action: Patience Teboe, Grants Administrator Corrective action planned: A) During the initial kickoff meeting for all new grants, the Grants Department will identify and document all reporting requirements, deadlines, and compliance obligations associated with the grant award. B) The Grants Department will enter all reporting deadlines into the grant management calendar system. Automated email notifications will be generated to provide timely reminders to the responsible operational manager and their direct supervisor prior to reporting due dates. C) Operational managers will be required to submit all grant reports electronically to their direct supervisor, or designated approver, for review prior to submission to the funding agency. D) The reviewing supervisor or designated approver will provide documented electronic approval (email approval will serve as evidence) to both the operational manager and the Grants Department. The Grants Department will maintain the approval documentation and update the grant management calendar to reflect completion of the reporting requirement. E) Any required report that has not received documented approval and been returned to the Grants Department at least five (5) business days prior to the reporting deadline will be escalated to the appropriate Executive-level leader and the Chief Financial Officer (CFO) for immediate follow-up. Implementation date: July 1, 2026 If you have any questions regarding the Tribe's Corrective Action Plan, please contact Chief Financial Officer, Greg Gunderson at 402-315-2760 ext. 4116 or ggunderson@poncatribe-ne.gov.

Persons responsible for corrective action: Keith Morrow, Health Services Chief Executive Officer Corrective action planned: Developed and implemented process by which Business Services staff in Health Services review documents provided by non-Ponca Native Americans upon initial request for services and on an annual basis to follow to confirm and verify their capacity to receive health services from the Ponca Tribe. Steps have been taken to see the staff verifying are independent from those who initially collect such documents. Additionally, confirmed such process is consistent with existing verification review of Ponca members requesting services. Implementation date: December 1, 2025.