Corrective Action Plans

As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third-party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford’s compliance department to ensure that there are no findings that would be of concern to Sanford’s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. Prior to this year’s review, in November 2024, Sanford enhanced their operating procedures and began documenting a monthly validation of the suspension and debarment search results performed by the third-party vendor. These preventative and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to the vendors that are suspended or debarred. Sanford believes the risk of any material disbursement to suspended and debarred vendors is effectively mitigated through existing preventative and detective internal controls. During the review, there were 5 instances out of 25 samples where suspension and debarment was not performed prior to vendor set up. None of those vendors were associated with the programs funded with federal funds. In addition, there were no instances where the suspension and debarment search was not performed after the enhanced operating procedures were implemented in November. As it relates to the procurement of goods and services, Sanford’s preventative and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being utilized for procurement. Sanford believes the risk of any material disbursement subject to procurement is effectively mitigated through existing preventative and detective internal controls. To provide context on the scale of Sole Source procurement, the two transactions for which the requester and the approver of the sole source justification form was the same individual totaled $56,551. The total federal expenditures for the RHC program for the fiscal year ended December 31, 2024, were $1,422,158. Total procurement tested under RHC program was $77,209. Total population subject to procurement was $77,209 which represents 5.42% of the total federal expenditures under the RHC program. Sanford has revised internal procedure to strengthen controls for sole source justification and documentation. Responsible official: Tracy Sattler, Director of Compliance and Melanie Paape, Vice President, Supply Chain Operations; Anticipated completion date: already completed; Responsible Party: Kristi Crawford, Director of Office of Grants; Anticipated completion date: May 1, 2025

As it relates to the Federal Funding Accountability and Transparency Act (FFATA) reporting, Sanford has revised procedures to provide further clarity on FFATA reporting. There is an additional requirement to include the FFATA report as an attachment to the subrecipient monitoring form and this will be monitored through the monthly internal review conducted on subrecipient risk assessment and monitoring status. Responsible Party: Kristi Crawford, Director of Office of Grants. Anticipated completion date: May 1, 2025

FA 2024-001 Improve Control over Employee Compensation Compliance Requirement: Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: $102,234 Prior Year Finding: 2023-004 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Corrective Action Plans: The District is developing correction action to strengthen controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: June 30, 2026 Contact Person: Connie Walker, School Nutrition Executive Director Telephone: 678-676-1780 Email: Connie_R_Walker@dekalbschoolsga.org

The Project Engineer and Assistant County Engineer will track and manage all federal grant deadlines in their Outlook calendars to avoid risk of non-compliance. Additional reimbursement requests for this grant will be reviewed and approved by the Assistant County Engineer and Finance prior to submitting through the system for reimbursement. For future federal grants, cost reimbursement system access will only be granted to Finance. The Accountant will review the general ledger for active federal projects monthly and submit the general ledger detail to Engineering for review and approval per contract terms. Once Engineering approves, the Finance Director will review and approve prior to the Accountant submitting the request to avoid risk of non-compliance. Finally, the SAM.gov website will be utilized to confirm vendors are active and not suspended or debarred from federal work prior to entering into contracts to avoid risk of non-compliance.

2024-001 – Preparation of the Schedule of Expenditures of Federal Awards (SEFA) (Significant Deficiency) Criteria: According to 2 CFR 200.210(b), a recipient of Federal awards is required to prepare a SEFA for the period covered by the entity’s financial statement which must include the total Federal awards expended. In addition, 2 CFR 200.303 requires non-Federal entities to, among other things, establish, document, and maintain effective internal control over Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Effective internal controls should include procedures to ensure expenditures are properly reported on the SEFA. In addition to providing an accurate SEFA, an organization must also be able to demonstrate that it has a system of internal control that supports the preparation of the SEFA. Condition: The University did not have an adequate process in place to prepare and review its SEFA. Cause: The University’s internal control process for preparing the SEFA did not include review and approval of the SEFA prior to providing it to the auditor. Effect: Failure to accurately report federal expenditures on the SEFA could result in noncompliance with federal regulations. Recommendation: We recommend the University establish, document, and maintain effective internal controls over the preparation of the SEFA. At a minimum, an organization should be able to show documentation that the SEFA was reviewed and approved by an individual who was not directly involved with the initial preparation of the SEFA. The review process should include checking both the reported expenditures of federal awards and the assistance listing numbers reported for each grant program. Action Taken: Management has put in place the following procedures: We will establish, document and maintain effective internal control over Federal awards by performing reconciliation of federal funds at the end of each trimester. The account reconciled will be listed on the SEFA. The Director of Financial Aid will be responsible for preparing the SEFA. It will be reviewed and re-reconciled by the Business Systems Analyst and the FA Asst. Director. Reports used to reconcile come from our Sonis system and are the Award Summary Detail and the Charges and Credits reports. Responsible Party and contact information: Valerie Souza, FA Business Systems Analyst and Lynda Swanson, Asst. Director of Financial Aid. Expected Date of Correction: At the end of each trimester. Full completion of processes will be at the end of our fiscal year/calendar year when audit preparation begins.

Contact Person(s): Kristen Bacon, Director of Finance Corrective action planned: The corrective actions to enhance Geneva’s lease management process are being implemented in Q1 and Q2 of 2025. A retroactive review of all Lease agreements was conducted in Q1 2025. An outcome of this review is the rollout of a requirement for real estate development firms to submit monthly invoices per the contractual terms with Geneva. In addition, a monthly reconciliation process is being performed by the Accounting Manager with an extra layer of review by the Director, Finance and Accounting, along with a quarterly reconciliation of leases (by location) performed by the Accounting Manager to ensure that payments match the data in recent Lease modifications by location. Lastly, the Accounting Manager is re-training Finance staff on file management and the utilization of a lease management tracker. If process deficiencies are identified or Standard Operating Procedures are not current, updates will be made, and end user compliance training will be rolled out to ensure a clear understanding. Recovery of the excessive lease payments will occur prior to 30 June 2025. Anticipated completion date: 30 June 2025

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Cliff Wadhams, Business Manager Anticipated Completion Date: August 31, 2025 Planned Corrective Action: The District will be requiring all District LEAs to take the necessary training through  the  Arizona  Department  of  Education  web  portal  and  related  classes  as  necessary  to  be  better informed on Capital Expenditures and required approval and form submission.

Condition: The County’s controls over meal participants did not ensure a review was in place to check the intake forms for Halal Home Delivered meal participants or that updated assessments were obtained for home delivered meals. Lastly there was not a control in place to ensure liquid meal participants maintained a physician order, renewed every six months, stating the need for the continued supplement service. Planned Corrective Action: Wayne County’s Department of Senior Services will implement processes to ensure only eligible individuals receive meals. A quarterly report will be run to verify all home delivered meal clients have updated assessments and reassessments and will be reviewed by the Department Director and or Division Director quarterly. Halal home delivered meal clients assessments will be reviewed by a second staff member to ensure eligibility and verified by the Department Director and or Division Director monthly. Contact person responsible for corrective action: Joan Siavrakas, Division Director Anticipated Completion Date: 04/25/2025

Finding 2024-002: Review of Compliance Matrices and Narratives The single audit report included the following recommendation: We recommend that Amtrak establishes a more defined timeline for the events that would trigger the update and review of the compliance matrices and compliance narrative, which could include execution of any new federal awards or amendments to existing federal awards. Additionally, Amtrak should establish a process where the modifications to the provisions are assessed for materiality/applicability and include documentation of the respective conclusions as part of the review process. Management Response/Status of Action Plans: Amtrak acknowledges the need to augment process documentation around the controls over the preparation and updates to the compliance matrices. The company is in the process of updating these controls now and will incorporate the identified findings in developing more robust controls. The company specifically notes the need to add more documentation on considerations for what provisions are updated in the compliance matrices and the evidence of review. The review procedures and controls are being enhanced to include a checklist to improve the review. This checklist will be completed by both the compliance matrix creator (upon creation) and the compliance matrix reviewer/approver (upon review and final approval). The contact for this item is Lucia Butts, AVP Funding and Grants and Meghan Histand, Director of Discretionary Grants. Amtrak anticipates fully remediating this finding by September 2025.

Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) The single audit report included the following recommendation: We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner Management Response/Status of Action Plans: Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The contact for this item is Lucia Butts, AVP Funding and Grants. Amtrak anticipates fully remediating this finding by September 2025.

Corrective Action Plan: Finding 2024-001 – Reporting – Federal Funding Accountability and Transparency Act (FFATA) Federal Program Information: Federal Agency: United States Agency for International Development United States Department of State Assistance Listing: 98.001 - USAID Foreign Assistance for Programs Overseas 19.421 – Department of Statue Bureau of Educational and Cultural Affairs: Academic Exchange Programs – English Language Program Federal Award Identification Number: 98.001 - 7200AA22CA00016; 72048619CA00001; 7200AA18CA00011; 7200AA19CA00002; 7200AA19CA00002 19.421 - SECAGD19CA0156 Award Year: FY 2024 Corrective Action Plan: FHI 360 will implement a corrective action plan comprised of the following actions: 1) continue global communications and meetings with key management teams 2) targeted and detailed training on FFATA requirements and completion of the FSRS template via an e-module 3) continue additional review through centralized team both to identify prospective transactions and perform a final review of data quality prior to data entry in FSRS, and 4) implement system-based enhancement to capture signature data to allow for centralized monitoring of execution date ensuring timely reporting based on execution dates Person(s) Responsible: Director, Contract Management Services Chief Operating Officer Completion Date: September 30, 2025

FINDING 2024-002 Finding Subject: Drinking Water State Revolving Fund - Procurement and Suspension and Debarment Summary of Finding: Controls were not in place to ensure the Town followed its procedures for suspension and debarment. Contact Person Responsible for Corrective Action: Aaron Kaytar Contact Phone Number and Email Address: 317-852-1120 akaytar@brownsburg.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: In 2023 a Purchasing Policy was implemented for all departments to follow. It states: To provide services to the Town of Brownsburg, you must not be debarred, suspended, or otherwise be excluded from or ineligible for participation in federally assisted programs under Executive Order 12549. Upon entering contracts, the Capital Projects and Procurement manager will ensure a vendor is not suspended or debarred by following one of the three acceptable means as required by the federal government. All contracts are reviewed and approved by the Town Council. Anticipated Completion Date: January 1, 2025

FINDING 2024-001 Finding Subject: SLFRF - Procurement, Suspension and Debarment Summary of Finding: Controls were not in place to ensure the Town followed its procedures for suspension and debarment. Contact Person Responsible for Corrective Action: Aaron Kaytar Contact Phone Number and Email Address: 317-852-1120 akaytar@brownsburg.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: In 2023 a Purchasing Policy was implemented for all departments to follow. It states: To provide services to the Town of Brownsburg, you must not be debarred, suspended, or otherwise be excluded from or ineligible for participation in federally assisted programs under Executive Order 12549. Upon entering contracts, the Capital Projects and Procurement manager will ensure a vendor is not suspended or debarred by following one of the three acceptable means as required by the federal government. All contracts are reviewed and approved by the Town Council. Anticipated Completion Date: January 1, 2025

Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Recommendation: We recommend the County to conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the expenditures were incurred). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: BHRS will make the necessary corrections to their cost allocation program and involve finance staff to manually redirect system data to ensure costs are not misclassified. The Auditor’s office will monitor progress of BHRS throughout the fiscal year. Names of the contact persons responsible for corrective action: Aimee Espinoza, Auditor-Controller and Alonzo Solis, AC Senior Accountant. Planned completion date for corrective action plan: June 30, 2025, is not feasible due to the issuance date so expected completion date to June 30, 2026.

Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Recommendation: We recommend the County to conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the expenditures were incurred). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Auditor’s Controllers office provides training on accrual basis of accounting at year-end training. All personnel related to recording the expenditures related to this program will be required to attend the meeting. In addition, the Auditor’s office will require all department heads and chief fiscal officers to sign off on the accuracy and completeness of their revenue and expenditures prior to closing each fiscal year going forward. Names of the contact persons responsible for corrective action: Aimee Espinoza, Auditor-Controller and Alonzo Solis, AC Senior Accountant. Planned completion date for corrective action plan: June 30, 2025, is not feasible due to the issuance date so expected completion date to June 30, 2026.

Block Grants for Community Mental Health Services - Assistance Listing No. 93.958 Recommendation: We recommend the County to conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the expenditures were incurred). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Auditor’s Controllers office provides training on accrual basis of accounting at year-end training. All personnel related to recording the expenditures related to this program will be required to attend the meeting. In addition, the Auditor’s office will require all department heads and chief fiscal officers to sign off on the accuracy and completeness of their revenue and expenditures prior to closing each fiscal year going forward. Names of the contact persons responsible for corrective action: Aimee Espinoza, Auditor-Controller and Alonzo Solis, AC Senior Accountant. Planned completion date for corrective action plan: June 30, 2025, is not feasible due to the issuance date so expected completion date to June 30, 2026.

: Borough Finance staff have redesigned the methodology for the fiscal year end reconciliation between the amounts reported to grantors, the amounts recorded in the General Ledger and the amounts reported in the Schedule of Expenditures of Federal Awards (SEFA). Going forward the amounts recorded in the General Ledger will tie to the amounts reported in the SEFA and any reconciling items will be noted on the reconciliation between the General Ledger and the amounts reported to the grantors. Completion Date: June 30, 2025

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $72,595 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund programs revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were properly recorded. Corrective Action Plans: Our office was unaware our financial program could automatically generate employee's supplemental checks in addition to standard monthly checks. Now that we are aware, Ivey McLendon and I will monitor our financial program's automatically generated claims closely to adapt our manual accrual entries. Estimated Completion Date: June 30, 2025 Contact Person: Sherry Gray, Financial Director Telephone: (229) 524-2433 Email: sgray@seminole.k12.ga.us

Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2024 – 12/31/2024 Comments on Findings and Recommendations: Finding 2024-002 – Eligibility - Pell Finding: Herzing University did not properly award Pell funding to an eligible student in the Spring 2024 semester. Condition: A student was eligible to receive Pell funding but did not receive Pell funds due to an employee error. For one out of 40 students tested for eligibility, we noted 1 student (2.5%) who was eligible to receive Pell funding but did not receive Pell funds due to an employee error. Action Taken: The identified student withdrew from the University on May 8, 2023. The student’s 2023-24 Pell award was cancelled during the required R2T4 process that was completed on May 23, 2023. The 2023-24 Pell award for the Spring 2024 semester was not manually reinstated upon the student’s return to an Active status on June 28, 2023. The employee who was responsible for updating the student’s financial aid package upon the student’s return to an Active status erroneously neglected to reinstate the 2023-24 Pell award for the Spring 2024 semester. This finding is attributed to human error. In April 2025, Herzing University created an internal compliance checkpoint for Pell awarding. This checkpoint will identify any students with a Pell eligible SAI for the Federal Award year that do not have Pell packaged for the semester. This checkpoint was completed for the Spring 2025 semester on April 7, 2025, and will be completed each semester going forward. Any affected students identified during the completion of this semester-based checkpoint will have their financial aid package revised to include Pell funding for the applicable semester, prior to the end of the semester. Herzing University’s Policy Manual was updated in April 2025 to reflect the addition of the Pell Awarding compliance checkpoint. For the identified student, Herzing University has provided a tuition waiver for the amount of the Pell funds that the student was eligible for and should have received for the Spring 2024 semester. The required corrective action for Finding 2024-002 listed in the SFA audit for the period 1/1/2024 – 12/31/2024 was completed on 5/7/2025. The person responsible for completion of the corrective action was Kevin McShane, Vice President of Financial Aid & Compliance. ____________________________________ _______________________ Kevin McShane Date Vice President of Financial Aid & Compliance Herzing University 275 W. Wisconsin Ave., Ste. 210, Milwaukee, WI 53203 Email Address: kmcshane@herzing.edu

Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2024 – 12/31/2024 Comments on Findings and Recommendations: Finding 2024-001 – Eligibility - SEOG Finding: Herzing University did not properly award SEOG funding to an eligible student in the Fall 2024 semester. Condition: A student was eligible to receive SEOG funding but did not receive SEOG funds due to an employee error. For one out of 40 students tested for eligibility, we noted 1 student (2.5%) who was eligible to receive SEOG funding but did not receive SEOG funds due to an employee error. Action Taken: On May 1, 2024, a Financial Aid Advisor manually cancelled the identified student’s 2024-25 SEOG award in Regent (Herzing University’s Financial Aid Management Software), with a notation that the student had an ineligible Student Aid Index (SAI). The student had an SAI of -117 on their 2024-25 ISIR, and in accordance with Herzing University’s FSEOG policy were eligible for 2024-25 SEOG in the Fall 2024 semester. The award was incorrectly manually canceled by the advisor because of human error. In April 2025, Herzing University created an internal compliance checkpoint for FSEOG awarding. This checkpoint will serve as a safety net to identify any students who have a Pell award for the Federal Award year, have an SAI that is FSEOG eligible according to Herzing University’s FSEOG policy, and do not correctly have FSEOG packaged for the semester. Any affected students identified during the completion of this semester-based checkpoint will have their financial aid package reviewed and if necessary revised to include FSEOG funding for the applicable semester, prior to the end of the semester. This checkpoint was completed for the Spring 2025 semester on April 4, 2025, and will be completed each semester going forward. Herzing University’s Policy Manual was updated in April 2025 to reflect the addition of the FSEOG Awarding compliance checkpoint. For the identified student, Herzing University has provided a tuition waiver for the amount of the FSEOG funds that the student was eligible for and should have received for the Fall 2024 semester. The required corrective action for Finding 2024-001 listed in the SFA audit for the period 1/1/2024 – 12/31/2024 was completed on 5/7/2025. The person responsible for completion of the corrective action was Kevin McShane, Vice President of Financial Aid & Compliance. ____________________________________ _______________________ Kevin McShane Date Vice President of Financial Aid & Compliance Herzing University 275 W. Wisconsin Ave., Ste. 210, Milwaukee, WI 53203 Email Address: kmcshane@herzing.edu

Finding 2024-015 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Comments on Finding Prior to executing subgrant agreements, in accordance with 2 CFR 200, the Mayor’s Office of Recovery Programs (Recovery Office) confirms that subrecipients have a Unique Entity Identifier (UEI) through SAM.gov. The Recovery Office is responsible for ensuring that UEI information is correctly entered into subgrant agreements that are between the Recovery Office and a subrecipient. Additionally, the Recovery Office shared the UEI requirement with City agencies and developed template ARPA subgrant agreements that City agencies must use with their subrecipients. These templates include a specific field in which to enter the UEI. City agencies are responsible for ensuring that this information is correctly entered into the subgrant agreement. Whether the subgrant agreement is executed by the Recovery Office or another City agency, the Recovery Office collects and retains the SAM.gov record for each subrecipient on the City’s secure network and records the UEI number in a spreadsheet. UEIs are also included in all statutorily required quarterly and annual reporting to the U.S. Department of Treasury. This information has consistently and accurately been reported to the Treasury. However, though required reports to Treasury are accurate, the Recovery Office acknowledges that the UEI was missing or incorrect for some subgrant agreements. This is due to the following: • Clerical errors in the preparation of draft agreements; and • An early version of a funding exhibit in ARPA template subgrant agreements that did not include a specific field in which to enter the UEI (this funding exhibit has since been corrected). CAP for Agreements Executed by the Mayor’s Office of Recovery Programs Subgrant Agreement Review • The Recovery Office will complete a review of all executed subgrant agreements to confirm that the correct Unique Entity Identifier (UEI) appears in the agreement. o This review will exclude Interagency Agreements with City agencies since they are not considered subrecipients, but as the prime recipient, the City of Baltimore. o This review will also exclude any agreements related to projects classified under Expenditure Category 6.1 in ARPA SLFRF guidance. According to Frequently Asked Questions (FAQs) issued by the Treasury, this EC does not give rise to subrecipient relationships, therefore UEI information is not required1. Resolution of Identified UEI Errors in Subgrant Agreements • For any subgrant agreements with an incorrect or missing UEI, the Recovery Office will submit a single memorandum that presents correct UEIs to the Board of Estimates (BOE) to ensure that the official record has correct UEI information. New Subgrant Agreements • The Recovery Office will implement a revised business process for the review of subgrant agreements. All ARPA funding was obligated as of December 31, 2024. According to Treasury guidance, there are very limited circumstances in which a jurisdiction may enter new subgrant agreements after the statutory obligation deadline. If the Recovery Office does execute a new subgrant agreement, the Recovery Office Project Manager must include the following two items in their request for the Chief Recovery Officer’s signature on the document: o a copy of the subrecipient’s SAM.gov record; and o written confirmation that the UEI number presented in the agreement matches the subrecipient’s SAM.gov record. CAP for Agreements Signed by Other City of Baltimore Agencies Subgrant Agreement Review • The Recovery Office will distribute a list to City agencies with all subgrants funded by ARPA. The list will include the subgrant agreement amount, subgrantee name, Workday identifiers (e.g., Purchase Order or Supplier Contract numbers), and the UEI number on file. o This review will also exclude any agreements related to projects classified under Expenditure Category 6.1 in ARPA SLFRF guidance. According to Treasury FAQs, this EC does not give rise to subrecipient relationships2. o City agencies must complete a review of all ARPA-funded subgrant agreements included on the list and confirm that the UEIs are accurate. Resolution of Identified UEI Errors in Subgrant Agreements • For any subgrant agreements with an incorrect or missing UEI, the Recovery Office will require each City agency to submit a single memorandum that presents correct UEIs to the Board of Estimates (BOE) to ensure that the official record has correct UEI information. • Using the list distributed by the Recovery Office, City agencies will confirm that the correction memo has been submitted and approved by the BOE. New Subgrant Agreements • The Recovery Office will implement a revised business process for the review of subgrant agreements in Workday. Though the Recovery Office does not execute ARPA-funded agreements initiated by other City agencies, executed agreements are routed in Workday for Recovery Office approval. The Recovery Office Project Manager will review the UEI presented in the agreement and confirm its accuracy. If it is missing or inaccurate, the Project Manager will notify the agency and instruct them to submit a memorandum to the BOE with the correct UEI information. 1 According to FAQ 13.14 Treasury is not collecting subaward data for projects categorized under Expenditure Category Group 6 “Revenue Replacement.” Treasury has determined that there are no subawards under this eligible use category. U.S. Department of the Treasury. (2021). Final Rule Frequently Asked Questions (FAQ). Retrieved from https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-FAQ.pdf. 2 According to FAQ 13.14 Treasury is not collecting subaward data for projects categorized under Expenditure Category Group 6 “Revenue Replacement.” Treasury has determined that there are no subawards under this eligible use category. U.S. Department of the Treasury. (2021). Final Rule Frequently Asked Questions (FAQ). Retrieved from https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-FAQ.pdf. Contact Person: Elizabeth Tatum, Deputy Director, Mayor’s Office of Recovery Programs Completion Date: June 30, 2025

Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Auditee’s Corrective Action Plan: BCHD has developed a subrecipient monitoring policy currently routing internally for approval that addresses the assessment, monitoring and documentation portions of subrecipient monitoring as well as other key elements to ensure adherence to 2CFR 200. The following tools have been created and implemented or in progress to use during monitoring: A. Subrecipient vs. Contractor Determination Checklist that must be completed by staff when submitting contract request to the contract unit to ensure subrecipients are properly identified and to develop a comprehensive monitoring schedule for the agency. B. Comprehensive risk assessment tool to determine monitoring plan for subrecipient. C. Both programmatic and fiscal baseline monitoring tools. Programmatic tools are at the beginning stages of implementation and continue to be customized for specific grant award requirements when necessary. D. Updated expense tracker for the accountants to utilize for review of subrecipient invoices. E. Updated monitoring and risk assessment tools to include requesting and documenting both single audit reports and SAMS.gov status. F. Subrecipient contract agreement templates are being updated to ensure subaward is clearly identified and includes the Federal Award Identification Number, subrecipient’s UEI, along with clear monitoring expectations. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: June 30, 2025

Finding 2024-027 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-023 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. D. Established a Contract and Compliance Unit responsible for overseeing the filing of the FFATA report. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

Finding 2024-026 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: Yes; 2023-022 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Auditee’s Corrective Action Plan: BCHD has developed a subrecipient monitoring policy currently routing internally for approval that addresses the assessment, monitoring and documentation portions of subrecipient monitoring as well as other key elements to ensure adherence to 2CFR 200. The following tools have been created and implemented or in progress to use during monitoring: A. Subrecipient vs. Contractor Determination Checklist that must be completed by staff when submitting contract request to the contract unit to ensure subrecipients are properly identified and to develop a comprehensive monitoring schedule for the agency. B. Comprehensive risk assessment tool to determine monitoring plan for subrecipient. C. Both programmatic and fiscal baseline monitoring tools. Programmatic tools are at the beginning stages of implementation and continue to be customized for specific grant award requirements when necessary. D. Updated expense tracker for the accountants to utilize for review of subrecipient invoices. Updated monitoring and risk assessment tools to include requesting and documenting both single audit reports and SAMS.gov status. E. Update subrecipient contract agreement templates ensure subawards are clearly identified and include the Federal Award Identification Number, subrecipient’s UEI, along with clear monitoring expectations. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: June 30, 2025