Corrective Action Plans

Material Weakness Finding No. 2025-006: Cash Management Views of Responsible Officials and Planned Corrective Action The Organization acknowledges the importance of compliance with 2 CFR §200.305, rules for federal payments; and understood and concurred with the prior year finding (2024-006) and current year renumbered recommendation (2025-006). A. U.S. Department of Health and Human Services (HHS) Substance Abuse and Mental Health Services Federal Assistance Listing Number 93.243. The Organization received this award from the HHS, Substance Abuse and Mental Health Services Administration (SAMHSA), via the State of Hawaii, Department of Health (DOH). In other words, SAMHSA awarded federal dollars to the DOH, who then sub-awarded federal dollars to the Organization. The Organization further sub-awarded to eligible community-based organizations (CBOs), for the purpose of SAMHSA emergency response grants (SERG), as a result of the impacts of the Lahaina wildfires in August 2023. Payments from the DOH, is based on the Organization’s meeting the billing parameters as established by the DOH at the time of contracting. Actual billing by the Organization to the DOH, includes the aggregation of eligible expenditures incurred by sub-recipient CBOs, that are subject to reimbursement from the Organization via the DOH reimbursement. Sub-recipient CBO invoices are reviewed and validated by the Organization’s program staff prior to submission for the Organization’s aggregation and invoicing to DOH. 1. The Organization notes the following process in place as of the June 30, 2025 fiscal year end: Process & Review Controls – Finance Committee & Full Board. The Organization’s monthly Board process and review controls includes the review of the Organization’s: Statement of Financial Position, Statement of Revenues and Expenditures, Statement of Revenues and Expenditures – Net Income/(Loss) by Fund, Fund Details – Additional Information and Statistics, Active Subcontract Summary, Active Subcontract Listing Related to Funds. This monthly process and review controls functioned to mitigate any internal control non-compliance. 2. The Organization also notes the following processes implemented after the June 30, 2025 fiscal year end: Internal Control Environment Policy – July 2025, Updated August 2026. Established and updated the following policies: Internal Control Environment; Implementation of Significant Accounting Policies; Revenue Recognition Policy, Including Federal Draws; and Implementation of Health Resources & Services Administration (HRSA) Related Policies, including cash management processes and procedures. Effective September 2026, the Organization will implement an internal control review of the federal funds to ensure compliance with 2 CFR §200.305 for Federal Assistance Listing Number 93.243. B. U.S. Department of Health and Human Services (HHS) Health Care for Native Hawaiians Federal Assistance Listing Number 93.932. This federal award is referred to as either Public Health Services (PHS) or the Native Hawaiian Healthcare Improvement Act (Act) federal dollars. For context, the Organization’s progressive and corrective actions as of the fiscal year ended (FYE) June 30, 2024 report included the following: 1. System, Process & Review Controls In Practice. a. System Controls. Continued to operate in an environment in which system, process & review controls of the United States Department of Health and Human Services (HHS) are practiced in processing cash (draw) transactions in both the Electronic Handbook (EHB) and Payment Management System (PMS) systems, operated by HHS. Only the director of administrative operations and the CEO have system access to the EHB and PMS systems. b. Process & Review Controls – Finance Committee & Full Board. The Organization’s monthly Board process and review controls includes the review of the Organization’s: Statement of Financial Position, Statement of Revenues and Expenditures, Statement of Revenues and Expenditures – Net Income/(Loss) by Fund, Fund Details – Additional Information and Statistics, Active Subcontract Summary, Active Subcontract Listing Related to Funds, and Native Hawaiian Health Program (Fund 007V), and Native Hawaiian Health Scholarship Program (Fund 017V). This monthly process and review controls functioned to mitigate any internal control non-compliance. c. HHS Drawdown Restriction. The Organization remained on HHS imposed drawdown restriction as of June 30, 2024 and June 30, 2025. The restriction was removed by HHS in July 2026. 2. The Organization also notes the following processes implemented after the June 30, 2025 fiscal year end: a. Internal Control Environment Policy – July 2025, Updated August 2026. Implemented and updated the following policies: Internal Control Environment; Implementation of Significant Accounting Policies; Revenue Recognition Policy, Including Federal Draws; and Implementation of Health Resources & Services Administration (HRSA) Related Policies, including cash management processes and procedures. b. Additional Process & Review Controls – EHB & PMS. Effective March 1, 2026, the Organization implemented, federal draws, process and review of internal controls implemented, via the chief of staff’s review of the director of administrative operations cash management analyses, federal grant receivable composition, reconciliation and related federal grant revenue computations, prior to any director of administrative operations and chief executive officer action in EHB and PMS, respectively. Finding No. 2025-006: Cash Management Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations, and Sylvia Hussey, Ed.D., Chief of Staff.

Finding Reference This corrective action plan relates to audit finding 2025 001 as reported in the schedule of findings and questioned costs. Contact Persons Dwayne Shaw, Executive Director, and Michelle Wright, Office Manager , are responsible for implementing and monitoring the corrective actions, maintaining related policies and procedures, and reporting status to those charged with governance. (207) 483-4336 Management’s Response / Concurrence Management agrees with the finding. The organization acknowledges that it does not currently have written policies and procedures addressing certain required Uniform Guidance compliance areas. Planned Corrective Action Management will develop, approve, and implement written policies and procedures designed to comply with applicable Uniform Guidance requirements, including policies over allowable costs/cost principles, cash management, and procurement, including suspension and debarment. Management will also communicate the new policies to relevant personnel and provide training as needed to support consistent implementation. Anticipated Completion Dates Management will finalize and implement the corrective action plan on or before September 30, 2026.

Effect: The federal awarding agency did not receive interest that could have been earned on the advances. There was no loss from uninsured funds or from lack of segregating funds into separate accounts. Recommendation: The auditor recommends that the Organization implement policies and procedures to ensure that all advance payments are deposited into separate, insured, interest-bearing accounts as required. The grantee should also establish controls to track interest earned on these accounts and remit amounts due to the federal awarding agencies in a timely manner. Training should be provided to staff responsible for cash management to ensure ongoing compliance with federal requirements. 1. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit findings. 2. Action Planned in Response to Finding: The Organization has implemented procedures to deposit the advance funds into separate, insured, interest-bearing accounts as required. The Organization has also established controls to track interest earned on the accounts and credit the interest back to the grant. 3. Official Responsible for Ensuring CAP: Kari Jo Lawrence, Chief Executive Officer and Jernon Kelly, Chief Financial Officer are responsible for ensuring corrective action of this deficiency. 4. Planned Completion Date for CAP: December 31, 2026.

Funds will not be drawn down until an invoice or proper pay request is received, and purchase order or contract are in hand, and payment is made promptly within no more than three business days. The Schedule of Expenditures of Federal Awards will be reviewed by Management that all funding received and reported has be fully expensed by the Authority prior to submission on the Hinkle system for audit.

FA 2025-003 Strengthen Controls over Cash Management Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Description: Cash Management Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education COVID-19 - 84.425U -American Rescue Plan Elementary and Secondary School Emergency Relief Fund S425U210012 (Year: 2024) The School District made cash drawdowns in excess of the immediate cash needs of the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: • The CFO will check all federal grants as a whole by running the general ledger and taking the difference of expenditures to revenue received to ensure that any changes to expenditures in prior months are accurately reflected in the draw down. If it is found that there is an excess of cash, funds will be immediately returned to GaDOE. Estimated Completion Date: December 18, 2026 Contact Person: Torrence H. Freeman 111, CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

Finding 2025-005: Inadequate Controls Over Federal Reimbursement Draw Requests - Significant Deficiency Corrective Action Plan: For each SAMHSA draw request, budget, general ledger and payroll expenditures are reviewed prior to PMS funding requests and approved by CEO. To further document this process, below actions will be implemented. • Implement a detailed Federal Reimbursement Draw Request Procedure. • Require a detailed expenditure schedule showing vendor/payee, invoice or payroll reference, expenditure date, payment date, amount, grant/program, general ledger account, and grant period. • Include only incurred, paid, allowable, and allocable expenditures in reimbursement requests. • Retain invoices, payroll records, proof of payment, general ledger support, and other documentation with each draw package. • Require preparer certification and an independent documented review before submission. • Verify payment status, allowability, grant coding, period of performance, and reconciliation to the accounting system before submission. Responsible Official: Chief Executive Officer, Chief Financial Officer, Financial Coordinator, Grant Program Director and Grant Administrative Support Anticipated Completion Date: 09/25/2026

Views of Responsible Officials: Internal review and approval of the final (close out) funding request submission was provided verbally during an in-person management retreat; both the VPFinance and the Executive Director sat side-byside during review, approval and submission process. Management acknowledges the lack of written documentation and has implemented protocols to ensure all approvals are written approvals, including instances where initial approvals are verbal in nature. Management does not expect to see this finding upon completion of our FY2026 audit. Anticipated Completion Date: December 31, 2025

Finding 2025-004 - Various Federal Programs: Cash Management- Excess Federal Cash, Untimely Reconciliations [Material Weakness}: Condition - At June 30, 2025, the College maintained excess federal cash balances across multiple federal programs, indicating that cash drawdowns and/or payable balances were not aligned with immediate cash needs for allowable program expenditures. These balances represented federal funds drawn or recorded as payable to federal agencies that were not supported by actual and immediate allowable program expenditures at year-end. The following table summarizes excess federal cash balances identified by program as of June 30, 2025: "Federal Program" "Excess Cash" "Minority Science and Engineering Improvement Program" 120,031 "Science Consortium of Minority Schools" 169,907 "NSF - Empowerment of Undergraduate STEM Majors" 94,801 "NSF - Tennessee Louis Stokes TLSAMP" 54,834 "Title III" 455,679 "FUTURE" 188,215 "Total Identified Excess Cash" 1,083,467 The College did not adequately reconcile federal cash activity to underlying grant expenditures on a timely basis and did not ensure that drawdowns were limited to amounts necessary to meet immediate cash needs. In addition, the College lacked effective monitoring controls to identify and resolve excess cash positions across federal programs in a timely manner. Federal bank reconciliations were untimely and error prone. Corrections occurred only after auditor inquiry. Federal accounts also earned excess interest. Corrective Action Plan The College requests drawdowns for Title Ill and FUTURE programs on a reimbursable basis, including review and approval procedures. Of the total amount identified for the Title Ill program, a $181,433 receivable related to FY2025. The balance related to prior year(s) activity. The College will review its Federal program cost allocation procedures to ensure all eligible costs are properly identified and supported going forward. The College has engaged two accounting firms to assist with staff training and bring all reconciliations current. In addition, standard month-end and year-end closing procedures will be implemented to address timely, accurate Federal program reconciliations and audit readiness going forward. The College experienced significant staff turnover within its business office. In addition, the College is undergoing conversion to a new Enterprise Resource Planning (ERP) system which affected its ability to complete some functions within a timely manner. Completion Date - September 30, 2026 Responsible Party - Chief Financial Officer

Finding 2025-003 - U.S. Department of Education [ED) - Federal Work Study - Noncompliance with Cash Management [Material Weakness): Condition -As of June 30, 2025, the College reported excess federal cash of $415,971 related to the Federal Work-Study Program. The excess cash represented cumulative federal funds drawn down through the federal payment system that were not disbursed or allowable Federal Work-Study payroll costs at year-end. The excess cash balance included amounts related to prior award years that had not been fully liquidated through reimbursement of allowable student wage expenditures or returned to the U.S. Department of Education as of June 30, 2025. Corrective Action Plan The College requests drawdowns for the Federal Work Study Program on a reimbursable basis, including review and approval procedures. Of the total amount identified, $26,466 related to FY2025, with the balance relating to prior year(s) activity. The College will review its Federal Work Study Program cost allocation procedures to ensure all eligible costs are properly identified and supported. The College has engaged two accounting firms to assist with staff training and bring all reconciliations current. In addition, standard month-end and year-end closing procedures will be implemented to address timely, accurate Federal Work Study Program reconciliations and audit readiness going forward. Completion Date - September 30, 2026 Responsible Party - Chief Financial Officer

The organization will develop a process of checks and balances to ensure that supporting documentation is provided and attached to justify the draw down requests. A reconciliation of expenditures recorded on the books and submitted request for reimbursement. All excess funds will be returned to the funding source. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date:

CORRECTIVE ACTION PLAN — Finding 2025-002 Compliance Finding – Cash Management | Low-Income Home Energy Assistance Program (LIHEAP) (ALN 93.568) Entity: Southeastern Vermont Community Action, Inc. (SEVCA) | Pass-Through Entity: State of Vermont Department for Children and Families | Cognizant Federal Agency: U.S. Department of Health and Human Services | CAP Contact: Joshua Davis, Executive Director, JDavis@sevca.org 1. Summary of Finding Finding 2025-002 identified that SEVCA drew the maximum allowable 50% advance under the LIHEAP award at the onset of the grant period without a documented cash flow forecast or disbursement schedule demonstrating that the amount drawn was limited to actual, immediate program needs. Approximately 30 days after receipt, a significant portion of the advance remained unexpended. This is not consistent with 2 CFR 200.305(b), which requires advances to be limited to the minimum amounts needed and timed to minimize the elapsed time between receipt and disbursement of funds. 2. Management’s Response SEVCA concurs with the finding. No questioned costs were identified. Management is implementing the corrective actions below. 3. Corrective Actions 1. Develop and implement a written Cash Management Procedure requiring that each advance drawdown request be supported by a documented cash flow forecast / disbursement schedule covering the period through the next expected draw date for that award, in accordance with 2 CFR 200.305(b) — Finance Director; 9/1/26. 2. Limit advance drawdown amounts to anticipated disbursements through the next scheduled draw date, rather than defaulting to the maximum allowable advance percentage — Finance Director; 9/1/26. 3. Formalize Finance Director review and sign-off of draw requests, and require independent review and sign-off by the Executive Director prior to submission, to explicitly document verification of the supporting forecast and the next expected draw date, and the amount requested — Finance Director / Executive Director; 9/1/26. 4. Use a single recurring draw worksheet per award documenting cash on hand, anticipated disbursements through the next draw date, and the amount requested, while reconciling the prior draw’s actual disbursements against projections and flagging any idle balances — Finance Director; 9/1/26. 5. Train relevant staff on the updated procedure and 2 CFR 200.305 requirements, and retain completed draw worksheets to support future audit testing — Finance Director / Accounting Staff; 9/1/26, retention ongoing. 4. Anticipated Completion Date 9/1/26. 5. Monitoring The Finance Director will review completed draw worksheets as part of each draw cycle; the Executive Director will independently review and sign off on each draw worksheet prior to submission, and will assess quarterly whether advances are being appropriately sized and timely utilized across federal awards. Draw worksheets, supporting forecasts, and sign-offs will be retained to support future audit testing.

June29,2026 Cognizant or Oversight Agency for Audit David Raines Community Health Center, lnc. respectfully submits the following corrective action plan for the year ended December 3I,2026. Name and address of independent public accounting firm AAFCPAS, lnc. 50 Washington Street Westborough, MA 01581 Audit period: January L,2025 - December 3L,2025 The findings from June 29,2026, schedule of findings and questioned costs are discussed below The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - FINANCIAL STATEMENT AUDIT FINDINGS NONE FINDINGS-FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY DEPARTMENT OF HEALTH AND HUMAN SERVICES 2025-001 Federal Progrom Identification: Health Center Program Cluster: ALN 93.224/93.527 Health Center Program and Grants for New and Expanded Services under the Health Center Program Recommendation: Management should establish and implement procedures to ensure Federal drawdowns are based on actual, allowable expenditures or immediate cash needs in accordance with 2 CFR 5200'305' Draw requests should be reviewed and approved to verify that amounts requested do not exceed current allowable expenditures or immediate cash requirements. Action Taken: Management concurs with the finding(s). During the period under audit, the organization inadvertently did a duplicative Federal drawdown which was an-administrative oversight. To address this deficiency and prevent future occurrences, management has implemented the following corrective actions: Duplicate Prevention Controls: Management has instituted a centralized drawdown tracking log to cross-reference and reconcile historical requests against immediate cash needs, eliminating the risk of administrative duplication. Management expects to have the above completed by Fully lmplemented (as of April 2026) lf the Department of Health and Human Services has questions regarding this plan, please call Angela Chatman at 318-440-L9L8. Sincerely yours, Angela Chatman Chief Financial Officer

Washington County Ambulance District agrees with the reported finding. The underlying cause was a clerical error that was determined after reimbursement had been requested. Upon identifying the issue, additional acceptable expenses were substituted for this clerical error. Additional review will be completed on each required submission. This will be overseen by Amber Coleman, Chief Administrative Officer, with a target date of completion of December 31, 2026.

Finding 2025-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public Housing Capital Fund Program Federal Assistance Listing Numbers: 14.872 Noncompliance - C. Cash Management Non Compliance Material to the Financial Statements: No Significant deficiency in Internal Control over Compliance for Cash Management Criteria: In accordance with 2 CFR 200.305, payment methods for federal awards must minimize the time elapsing between the transfer of federal funds and the disbursement of those funds by the recipient. Federal funds drawn under the Public Housing Capital Fund Program should be limited to amounts needed to meet the Authority’s immediate cash requirements for allowable program expenditures. Accordingly, the Authority should implement procedures to ensure grant funds are not drawn in advance of actual or imminent eligible expenditures. Condition: The Authority drew down federal funds in advance of immediate cash needs for allowable program expenditures. As of year end, a portion of the funds drawn remained unexpended and was reported as unearned revenue in the financial statements. This indicates that federal funds were received prior to the incurrence of eligible expenditures. Context: During review of the financial statements, the Authority was noted to have unexpended federal funds on hand at year end that had been drawn prior to the disbursement of allowable program costs. Specifically, amounts recorded as unearned revenue represented federal funds received in advance of immediate cash needs. This condition was identified through review of drawdown activity, general ledger balances, and year end financial reporting records. Known Questioned Costs: $134,883. Cause: The Authority did not have adequate internal controls in place to monitor the timing of grant drawdowns in relation to actual program cash needs and allowable expenditures. As a result, federal funds were requested and received prior to the incurrence of eligible costs under the Public Housing Capital Fund Program. Effect: The Authority was not in compliance with federal cash management requirements governing the timing of federal fund drawdowns. As a result, federal funds were held in advance of immediate cash needs, increasing the risk of improper cash management and noncompliance with Uniform Guidance and HUD requirements. Recommendation: We recommend the Authority strengthen its internal controls over cash management to ensure federal funds are drawn only for immediate cash needs related to allowable program expenditures. Management should implement monitoring and review controls over grant drawdown activity, including periodic reconciliation of drawdowns to incurred expenditures, to ensure compliance with 2 CFR 200.305 and HUD requirements. Authority's Response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Ralph Staley, CFO is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring and is expected to be completed by December 31, 2026.

RIDOH agrees with the finding and recommendations. 2025-044a: RIDOH will examine and document internal processes for requesting federal drawdowns and will create and implement revised policies and procedures to align with both federal requirements and Workday requirements for documentation of expenditures. 2025-044b: RIDOH will review and reconcile ELC and Immunization grant awards reporting excess cash drawdowns as of 6/30/2025 and will make adjustments as appropriate to ensure accurate grant award tracking. Anticipated Completion Dates: 2025-044a: June 30, 2027 2025-044b: October 31, 2026 Contact Persons: Alisha Collella, Chief Financial Office, Department of Health alisha.colella@health.ri.gov Sarah Parker, Assistant Director of Health (Budget & Finance), Department of Health sarah.parker@health.ri.gov Carla Lundquist, Deputy CFO / Federal Grants Manager, Department of Health carla.lundquist@health.ri.gov Julie DeMelo, Assistant Director of Health (Budget & Finance), Department of Health julie.demelo@health.ri.gov

Finding Number: Finding 2025-001 Title: Improper Timing of MTW Capital Fund Program (CFP) Drawdowns (ALN 14.881) - Repeat of Finding 2024-002 Program Name: Moving to Work Demonstration Program - Capital Fund Program ALN: 14.881 Description: During testing of the Capital Fund Program (CFP) component of the Moving to Work (MTW) Demonstration Program, we determined that the Authority drew down CFP funds in advance of need. As of September 30, 2025, $1,891,326 of CFP funds drawn during the fiscal year remained unearned (undisbursed) and were carried as restricted/unearned amounts at year end. The drawdowns were not aligned with immediate, allowable obligations or expenditures at the time the funds were requested. This condition is a repeat of prior year finding 2024-002. Planned Corrective Action: The Authority concurs with the finding and acknowledges it is a repeat of finding 2024-002 involving cash management and drawdown procedures. Revise cash management procedures; require documented support and approval for drawdowns; perform monthly reconciliations; monitor interest earned on undisbursed federal cash; provide staff training; and report compliance status to the Board of Commissioners. Timeline for completion: 6 months

Title: Inadequate Tenant File Documentation in MTW Housing Choice Vouchers Program Name: Moving to Work Demonstration Program - Housing Choice Voucher Program ALN: 14.881 Description: During tenant file testing for the Housing Choice Voucher (HCV) component of the Moving to Work (MTW) Demonstration Program, variances were identified between the amounts reported on HUD Form 50058 and the actual Housing Assistance Payment (HAP)/Utility Allowance Payment (UAP) disbursements for six tenants. The Authority did not maintain sufficient documentation to reconcile the differences. Planned Corrective Action: The Authority will implement a process to reconcile all Housing Assistance Payment (HAP) and Utility Allowance Payment (UAP) disbursements to the amounts reported on HUD Form 50058. Identified variances for the affected tenants will be researched and corrected, supporting documentation will be retained in each tenant file, and staff will be trained on documentation and reconciliation requirements under the MTW HCV program. Periodic quality-control reviews of tenant files will be performed to ensure ongoing compliance.

Finding Number: 2025-002 Planned Corrective Action: Management has implemented enhanced cash management and grant monitoring procedures, including strengthened review of draw requests, improved documentation requirements, and closer reconciliation of grant expenditures to amounts drawn. In addition, the Organization is undertaking process improvements to streamline grant accounting and reporting activities, improve the timeliness of expense recognition, and enhance overall oversight of federal awards. Management expects these actions will strengthen compliance with federal cash management requirements and reduce the risk of future occurrences. Anticipated Completion Date: 12/31/2026 Responsible Contact Person: Alison Roca, Chief Financial Officer

KHDA will hire a CPA to oversee this process.

KHDA will hire a CPA to oversee this process.

Finding 2025-004 - Various Federal Programs: Cash Management- Excess Federal Cash, Untimely Reconciliations [Material Weakness}: Condition - At June 30, 2025, the College maintained excess federal cash balances across multiple federal programs, indicating that cash drawdowns and/or payable balances were not aligned with immediate cash needs for allowable program expenditures. These balances represented federal funds drawn or recorded as payable to federal agencies that were not supported by actual and immediate allowable program expenditures at year-end. The following table summarizes excess federal cash balances identified by program as of June 30, 2025: "Federal Program" "Excess Cash" "Minority Science and Engineering Improvement Program" 120,031 "Science Consortium of Minority Schools" 169,907 "NSF - Empowerment of Undergraduate STEM Majors" 94,801 "NSF - Tennessee Louis Stokes TLSAMP" 54,834 "Title III" 455,679 "FUTURE" 188,215 "Total Identified Excess Cash" 1,083,467 The College did not adequately reconcile federal cash activity to underlying grant expenditures on a timely basis and did not ensure that drawdowns were limited to amounts necessary to meet immediate cash needs. In addition, the College lacked effective monitoring controls to identify and resolve excess cash positions across federal programs in a timely manner. Federal bank reconciliations were untimely and error prone. Corrections occurred only after auditor inquiry. Federal accounts also earned excess interest. Corrective Action Plan The College requests drawdowns for Title Ill and FUTURE programs on a reimbursable basis, including review and approval procedures. Of the total amount identified for the Title Ill program, a $181,433 receivable related to FY2025. The balance related to prior year(s) activity. The College will review its Federal program cost allocation procedures to ensure all eligible costs are properly identified and supported going forward. The College has engaged two accounting firms to assist with staff training and bring all reconciliations current. In addition, standard month-end and year-end closing procedures will be implemented to address timely, accurate Federal program reconciliations and audit readiness going forward. The College experienced significant staff turnover within its business office. In addition, the College is undergoing conversion to a new Enterprise Resource Planning (ERP) system which affected its ability to complete some functions within a timely manner. Completion Date - September 30, 2026 Responsible Party - Chief Financial Officer

Finding 2025-003 - U.S. Department of Education [ED) - Federal Work Study - Noncompliance with Cash Management [Material Weakness): Condition -As of June 30, 2025, the College reported excess federal cash of $415,971 related to the Federal Work-Study Program. The excess cash represented cumulative federal funds drawn down through the federal payment system that were not disbursed or allowable Federal Work-Study payroll costs at year-end. The excess cash balance included amounts related to prior award years that had not been fully liquidated through reimbursement of allowable student wage expenditures or returned to the U.S. Department of Education as of June 30, 2025. Corrective Action Plan The College requests drawdowns for the Federal Work Study Program on a reimbursable basis, including review and approval procedures. Of the total amount identified, $26,466 related to FY2025, with the balance relating to prior year(s) activity. The College will review its Federal Work Study Program cost allocation procedures to ensure all eligible costs are properly identified and supported. The College has engaged two accounting firms to assist with staff training and bring all reconciliations current. In addition, standard month-end and year-end closing procedures will be implemented to address timely, accurate Federal Work Study Program reconciliations and audit readiness going forward. Completion Date - September 30, 2026 Responsible Party - Chief Financial Officer

Management acknowledge the improper treatment of the expenditure for the specific period. The expenditure in question was for a one-year marketing services agreement supporting activities under the FDA 503B award. The vendor required payment in advance as a condition of service delivery, and the cost was incurred for legitimate grant-related purposes within the approved scope of work and period of performance. The expenditure was fully documented, allocable to the award, reasonable in nature, and directly connected to approved programmatic objectives. Management acknowledges that the transaction involved payment for services extending across a future service period. Specifically, 2 CFR 200 does not prohibit recipients from entering into prepaid contractual arrangements for allowable services necessary to support award implementation, particularly where such arrangements reflect standard vendor business practices and operational necessity. Further, the organization’s actions must be evaluated in the context of significant federal payment administration changes that began in February 2025. Historically, the organization received advance funding under the award consistent with the cash management principles contemplated under 2 CFR 200.305. Beginning in 2025, however, the organization was required to operate under a reimbursement-based process requiring submission of supporting documentation prior to payment release. This materially altered the organization’s working capital position and limited its ability to independently finance operational expenditures for extended periods pending reimbursement. As a result, management was required to make operational decisions necessary to ensure continuity of approved grant activities while balancing vendor requirements, cash flow limitations, and evolving federal reimbursement practices. The organization did not receive excess federal cash, improperly retain federal funds, incur unallowable costs, or use award funds outside the approved project scope. The questioned transaction reflects a timing and payment structure issue rather than a violation of fundamental federal compliance requirements. Management also notes that 2 CFR 200.305 expressly contemplates advance payment methodologies and recognizes that reimbursement-only environments may create operational hardships for recipients lacking sufficient working capital. The organization’s actions were undertaken in good faith to maintain uninterrupted program operations under materially changed federal payment conditions. Importantly, the expenditure was allowable, the services supported approved award objectives, the costs were incurred during the award period, supporting documentation exists, no misuse or diversion of federal funds occurred, and no financial harm to the federal government resulted. Note also that going forward, PDA will record future services and subscriptions to prepaid and amortize based on the periods stipulated on the vendor invoices.

The Puerto Rico Ports Authority (PRPA) acknowledges the audit finding regarding the unused capital advances as of June 30, 2025. It is important to clarify that these funds were received under the Working Capital Advance (WCA) Program, an initiative led by COR3 to expedite the implementation of FEMA-funded recovery projects. The WCA Program provides subrecipients, such as PRPA, with a 25% upfront advance of the total project cost to address initial project expenses and mitigate delays due to cash flow constraints. The WCA advance is disbursed by PRPA upon completion of contracted deliverables by vendors or suppliers, particularly during the design and early implementation phases of projects. As of the audit date, most of PRPA’s FEMA projects under the WCA were still in the design phase, and the disbursements made thus far correspond to completed design services. The remaining balance of WCA funds will be disbursed as vendors fulfill the contractual milestones tied to architectural and engineering (A&E) and construction services. The apparent delay between fund receipt and disbursement reflects the timing of deliverable completion rather than a lack of project activity. PRPA continues to monitor the progress of A&E and construction services to ensure timely disbursement aligned with actual project progress. To strengthen the oversight of WCA funds and ensure timely utilization, PRPA management is implementing enhanced administrative controls. These include the development and formal adoption of internal procedures aimed at improving the handling, identification, and classification of FEMArelated funds. These measures will support be􀄴er alignment between fund disbursement and project execution timelines and demonstrate PRPA’s commitment to the prudent and compliant management of federal funds.

Finding No. 2025-006 – Internal control deficiencies over accounting for federal funds received from the United States Department of Homeland Security (DHS) Corrective Action Plan Single Audit 2025 Page 6 April 30, 2026 Condition During our procedures over the Authority’s funds received from FEMA we noticed the following: 1. Return of interest earned on FEMA-related funds totaling approximately $211,853 was not timely recorded in the general ledger and was subsequently recorded through a post-closing entry dated January 26, 2026. 2. Management initially misclassified approximately $6 million received under the Coronavirus State and Local Fiscal Recovery Funds as state funds rather than federal awards. As a result, the amount was originally excluded from the Schedule of Expenditures of Federal Awards (the Schedule). Views of Responsible Officials and Corrective Actions It should be noted that, although certain funds received were not properly identified as working capital advances, those funds were properly considered as received from FEMA through the COR-3 office of the Government of Puerto Rico. This situation basically arises because the federal funds coming from FEMA are being handled by outside consultants, without any coordination with the Federal Funds Management Office (FFMO). The Authority’s management will ensure that, in the future, the FFMO will coordinate with the assigned outside consultants all the efforts necessary for the proper handling, identification and classification of funds received from FEMA. Name(s) of the Contact Person(s) Responsible for Corrective Action Romel Pedraza Claudio. P.E. – Assistant Executive Director for Planning & Engineering Elena González – DEA Finance Miguel La Torre – Interim Finance Director Anticipated Completion Date During FY-2026-2027