Corrective Action Plans

Management has agreed to closely monitor the receipt of federal funds and disburse those funds timely in order to ensure compliance with this regulation. The Cash Balance Report that is updated daily of all incoming receipts will be used as a tool to ensure expenses incurred are paid timely in the weekly disbursements.

The District will implement procedures to ensure drawdowns are timed with the District's immediate cash requirements.

The Town will design and implement policies and procedures required by the Uniform Guidance.

Cash Management The University acknowledges the finding related to missing documentation supporting cash drawdowns for the Higher Education Institutional Aid program. We recognize that federal regulations require all drawdown requests to be supported by underlying expenditures and appropriate supporting records. Corrective Actions 1. Implementation of Required Documentation Procedures: The University has established a formal process requiring that all drawdown requests be supported by detailed expenditure reports before funds are drawn. Supporting documentation must be uploaded and retained in a shared electronic repository. 2. Enhanced Review and Approval Controls: Drawdown requests must now undergo a two step review process by Grants Management and the Controller’s Office to ensure compliance with cash management requirements prior to submission. 3. Staff Training: Relevant staff is updating training on Uniform Guidance §200.305 requirements and on maintaining complete documentation to support each drawdown. 4. Ongoing Monitoring: Periodic internal reviews will be conducted to confirm that all future drawdowns are documented, properly supported, and compliant with federal cash management standards. The University believes these actions will strengthen internal controls over cash drawdowns and ensure compliance with federal regulations moving forward.

Processes have been developed and implemented to ensure both receipt of funds and return of interest to the grantor is done on a timely and consistent basis.

iLearn Schools, Inc. notes that the excess reimbursement of $85,425 was identified, properly recorded as a grant advance liability, and not recognized as revenue or expense in the current year. Going forward, all reimbursement requests will be based on actual allowable direct costs incurred. Management will establish written procedures for indirect cost recovery, implement a formal review and reconciliation process prior to submission, and provide staff training on Uniform Guidance requirements. These corrective actions will be in place for the fiscal year ending June 30, 2026. Responsible Official: Mr. Coban, Chief Financial Officer

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. The third (2025-03) and fourth (2025-004) findings relate to federal cash management practices for Title Ill and TRIO grant programs. The audit determined that federal funds had been drawn down prior to immediate program expenditures, resulting in excess cash balances. To correct this issue, the College implements formal grant cash management procedures to ensure that internal controls over federal funds management are strong. Please review the details below: Corrective action 2025-004: Implement monthly grant reconciliation procedures, strengthen monitoring of federal drawdowns, and align disbursements with program spending patterns Target resolution: FY 2026

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. The third (2025-03) and fourth (2025-004) findings relate to federal cash management practices for Title Ill and TRIO grant programs. The audit determined that federal funds had been drawn down prior to immediate program expenditures, resulting in excess cash balances. To correct this issue, the College implements formal grant cash management procedures to ensure that internal controls over federal funds management are strong. Please review the details below: Corrective action 2025-003: Establish formal grant cash management procedures, implement monthly reconciliation of drawdowns vs. expenditures, and increase oversight of grant balances. Target resolution: FY 2026

Finding 2025-003 - U.S. Department of Education (USO), TRIO Programs (Significant Deficiencies): Information on the federal program - Student Support SeNices, FAL No. 84.042A, June 30, 2025; Ronald McNair Program, FAL No. 84.217A, June 30, 2025. Under 2 CFR 200.305, non-Federal entities must request Federal funds only for allowable program costs that have been incurred, and must maintain contemporaneous supporting documentation demonstrating: a. Actual, allowable expenditures existed at the time Federal funds were drawn; and b. Records supporting the nature and timing of those expenditures were on file and readily available. These requirements ensure 1. Corrective Action Description a. The College now mandates that GS drawdown requests include approved documentation stored on the accounting drive, effective July 31, 2025. b. Time and Effort reports must be submitted monthly with supervisor sign-off before reaching the Office of Sponsor Programs, showing 100% time allocation. Any changes will require a Personnel Action Form and administrative approval signatures. c. showing 100% time allocation. Any changes will require a Personnel Action Form and administrative signatures of approval. 1. Person Responsible and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu 2. Implementation Timeline This procedure took effect as of July 31, 2025. 3. Planned Preventive Measures Following the policy and procedures to support all drawdowns with proper documentation. 4. Disagreement with the Finding None

Finding 2025-002 - U.S. Department of Education (USO}, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program - Federal Pell Grant Program, FAL No. 84.063, June 30,2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Teachers Education Assistance for College(TEACH),FAL No. 84.379, June 30, 2025. Under 2 CFR 200.305 and the U.S. Department of Education's cash management requirements at 34 CFR 668.162, institutions must draw down Title IV funds only for expenditures 1. Corrective Action Description The College now requires all drawdowns to include supporting documentation of the funds requested from GS, along with sign-offs on preparation and approval. Supporting documents are stored securely on the College's accounting drive for easy access. 2. Person Responsible and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu a. Implementation Timeline This procedure took effect as of July 31, 2025. b. Planned Preventive Measures Following the policy and procedures to support all drawdowns with proper documentation. c. Disagreement with the Finding None

Finding Number: 2025-013 ALN Number(s) and Program Title(s): 21.029 – Coronavirus Capital Project Funds Views of Responsible Officials and Planned Corrective Action: ASBO acknowledges the auditor’s observation regarding the timing of disbursements following drawdowns from the U.S. Department of the Treasury. ASBO procedures include a 15-day internal processing target intended to promote efficient payment processing. While 19 of 34 drawdowns exceeded this internal benchmark, the applicable federal standard under 31 CFR § 205.33 requires recipients to minimize the time between drawdown and disbursement. Additionally, under 2 CFR § 200.305(b)(3), when the reimbursement method is used, payment must be made within 30 calendar days after receipt of a proper payment request. ASBO recognizes the importance of maintaining strong cash management controls and ensuring timely payment to subrecipients. The State of Arkansas is enhancing tracking, reconciliation, and workflow controls within its financial management processes to better monitor drawdown-to-disbursement timing. These measures are intended to strengthen timeliness and prevent recurrence. Anticipated Completion Date: June 30, 2026 Contact Person: Name: Glen Howie Title: State Broadband Director Agency: Arkansas State Broadband Office Address: 1 Commerce Way City, State, Zip: Little Rock, AR 72202 Phone Number: 501-683-6000 Email Address: broadband@arkansas.gov

PRMP partially concurs with this finding. CMS requires timely payment to ensure that expenditures are valid and that federal funds are drawn only for allowable and properly incurred costs. PRMP will strengthen internal controls to ensure that all valid requests for payment are processed and paid within the 30-calendar-day timeframe required by **2 CFR §200.305(b)(1)**. However, the delayed application of credits results from administrative practices established by PRMP in response to limitations within the accounting system. Because the system cannot process negative balances, PRMP must wait until sufficient positive fund balances are available before issuing the return of outstanding credits. Additionally, to strengthen internal controls and ensure all required approvals were obtained, PRMP follows administrative practices that include awaiting receipt of CMS’s approval prior to reimbursing funds to the subrecipient.

PRMP respectfully disagrees with this finding. The responsibility for reporting quarterly drug utilization to manufacturers within 60 days after the end of each quarter, as well as the requirement for manufacturers to remit rebate payments within 30 days of receiving utilization data, is delegated to the Puerto Rico Health Insurance Administration (ASES) through the Memorandum of Understanding (MOU). PRMP is confident in this delegated process, particularly given that it was subject to audit and resulted in no findings for the year ended June 30, 2025. PRMP obtained the Puerto Rico Health Insurance Administration (A Component Unit of the Commonwealth of Puerto Rico) Financial Statements and Compliance Audit of Federal Financial Assistance for the Fiscal Year Ended June 30, 2025, and noted the following opinion: Opinion on Each Major Program (Page 46) We have audited the Puerto Rico Health Insurance Administration’s (the Administration) compliance with the types of compliance requirements identified as subject to audit in the OMB Compliance Supplement that could have a direct and material effect on each of the Administration's major federal programs for the year ended June 30, 2025. The Administration's major federal programs are identified in the summary of auditor's results section of the accompanying schedule of findings and questioned costs. In our opinion, the Administration complied, in all material respects, with the types of compliance requirements referred to above. Furthermore, the Medicaid Program initiates reimbursement of drug rebates to CMS once the following conditions are met: - The actuarial team completes its analysis and validation of the allocation of funds to be returned to CMS for each grant and population subject to the applicable FMAP rates. - PRMP receives the corresponding invoice to process refunds to ASES, reflecting the deduction of drug rebate collections. - The Puerto Rico Medicaid Program remits drug rebate funds to the Payment Management System Accordingly, the Puerto Rico Medicaid Program does not concur with the finding asserting that rebate collections were not properly identified, recorded, or credited to the Medicaid Program in a timely manner. Refunds are processed within the same quarter—or at the beginning of the subsequent quarter—following receipt of the final actuarial data, which provides the required distribution and identifies the associated grants. This sequencing ensures that remittances are based on complete, validated information and are aligned with the applicable federal funding allocations.

Conduct a full review of all FEMA funds received in FY 2024-2025 to properly reclassify them as Federal Revenue/Income in the General Ledger. Implement a mandatory review of FEMA Project Worksheets (PWs) and Obligation Notifications to distinguish between "Reimbursements" and "Capital Advances" upon receipt. Create separate General Ledger (GL) accounts for FEMA disaster/project and Federal Funds to track expenditures vs. drawdowns in real-time. Establish a semi-annual meeting between the FEMA Coordinator and Finance departments to verify that all FEMA-funded work performed matches the reported expenditures. Update the SEFA preparation process to ensure FEMA expenditures are reported in the period they were incurred, regardless of when the reimbursement was received. Provide specialized training for the finance team on Federal Funds accounting.

Corrective Action Plan In the event that the System receives federal cash advances prior to the cash expenditures, the System will perform an additional financial review of any advanced payments compared to the related expenditures. Should accounting identify advances not yet spent, they will inquire with the grant administrator responsible for the grant to review their advance fundings, any potential resulting interest calculations. Anticipated Completion Date June 30, 2026 Name of Contact Person for Corrective Action Amanda Hymel, Corporate Controller

Federal Program Title: R&D Cluster, Child Care Access Means Parents in School, and TRIO Cluster Assistance Listing Number: R&D, 84.335, and 84.TRIO Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Recommendation: We recommend that the UEC strengthen its cash management and financial reporting procedures to ensure reimbursement requests include only costs incurred in the appropriate fiscal period, are supported by adequate documentation, and are submitted in a timely manner. The UEC should also enhance review controls to verify proper period recognition of costs before submitting reimbursement requests. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: University Enterprises Corporation (UEC) has implemented and is continuing to strengthen internal controls over cash management, reimbursement timing, and supporting documentation. Corrective actions include the implementation of a revised subaward management process to improve documentation, period alignment, and pre-submission review, strengthening controls to ensure reimbursement requests include only costs incurred within the appropriate fiscal period, reinforcing documentation and validation requirements prior to submission, establishing clearer expectations and monitoring for timely reimbursement processing, and clarifying roles and responsibilities to support consistent compliance. Contact(s) Responsible for Corrective Action: Director of Sponsored Programs Administration Planned Completion Date for Corrective Action: June 30, 2026.

Condition: For the fiscal year ended June 30, 2025, NeoMed Center, Inc. earned interest on federal funds more than the $500 annual amount permitted under 2 CFR §200.305(b)(12). The excess interest was not remitted timely to the U.S. Department of Health and Human Services (HHS) through the Payment Management System (PMS). This condition resulted from the lack of a formalized control process to periodically monitor interest earned on federal cash balances and to identify when the allowable annual retention threshold had been exceeded. Planned Corrective Action: Management implemented formal written policies and procedures governing the monitoring of interest earned on federal funds in accordance with Uniform Guidance requirements. These procedures require periodic calculation, documentation, and supervisory review of interest earned on federal cash balances to ensure compliance with the $500 annual allowable retention limit. Any interest earned more than the allowable threshold is identified promptly and remitted timely to HHS through the Payment Management System (PMS). Targeted training was provided to finance personnel responsible for cash management activities to ensure proper understanding and consistent application of federal interest requirements. Key internal controls include: • Implemented formal written policies and procedures for monitoring interest earned on federal funds. • Established monthly review of interest balances. • Implemented timely remittance procedures for excess interest through PMS. • Provided targeted training to finance staff on federal cash management and interest requirements. Monitoring: Management will monitor interest earned on federal funds monthly beginning April 1st, 2026, to ensure compliance with the $500 annual allowable retention threshold. Interest calculations will be reviewed and documented, and any excess interest identified will be remitted timely to the Payment Management System (PMS). Monitoring activities will be evidenced through reconciliations and management review documentation, which will be maintained for audit purposes. Responsible Official: Jose A. Guzman Machuca Time frame: This condition was resolved in March 17th ,2026 upon the implementation of formal monitoring procedures and remittance controls.

Condition: During the fiscal year ended June 30, 2025, NeoMed Center, Inc. used the advance payment method through the HHS Payment Management System (PMS) to obtain federal funds. In certain instances, drawdowns were requested based on aggregated projections and liquidity needs before specific eligible expenses were fully identified and ready for immediate disbursement. Although the funds were later applied to eligible expenses incurred within the authorized award periods, the absence of a documented, expense-level linkage at the time of each drawdown created a temporary timing difference between cash receipt and expense recognition. Accordingly, funds that did not meet revenue recognition criteria at the end were recorded as Unearned Revenue. Consistent with U.S. GAAP and federal grant revenue recognition policies, the Unearned Revenue balance of approximately $1.8 million as of June 30, 2025, represents federal funds received in advance, for which revenue recognition was contingent on incurring future eligible expenses. This balance was analyzed, reconciled, and recognized as eligible expenses were incurred, as supported by reconciliations provided to the external auditors, and was appropriately disclosed in the notes to the financial statements for the years ended June 30, 2025, and 2024. Planned Corrective Action: To prevent recurrence, NeoMed Center, Inc. adopted and implemented “Federal Fund Drawdown via HHS Payment Management System (PMS)” (Policy No. NMCIP 46), approved by the Board of Directors and effective March 2026. The policy requires drawdowns to be based solely on immediate cash needs, supported by a documented short-term cash forecast, and prohibits requesting funds for expenses not yet incurred or not ready for immediate disbursement. Key internal controls include: • Mandatory preparation of a cash forecast by award prior to each drawdown. • Independent review and approval by the Finance Department prior to submission of drawdown requests in PMS. • Monthly reconciliations between PMS, bank accounts, and the general ledger. • Monitoring of the time elapsed between the receipt of funds and their disbursement, with a maximum internal standard of three (3) business days. • Documentation and formal approval of any exceptions. • Adoption of an internal benchmark of 8.33% per month (1/12 of the annual award) as a control parameter. • Clear definition of segregation of duties; and • Periodic reporting to Senior Management and the CEO. Management concludes that this matter resulted from cash-management timing and not from misuse of federal funds. Monitoring: Management will perform monthly monitoring of federal fund drawdowns beginning April 1st ,2026 to ensure they are limited to immediate cash needs and supported by documented short‑term cash forecasts. Drawdowns will be reconciled monthly to the general ledger, bank statements, and allowable expenditures incurred within the approved period of performance. Any timing variances or exceptions will be reviewed and documented. Monitoring results will be reviewed by senior management to ensure continued compliance with Uniform Guidance requirements. Responsible Official: Jose A. Guzman Machuca Time frame: This condition was identified on February 20, 2026, and is expected to be resolved by May 2026, upon the implementation of formal monitoring procedures and enhanced remittance controls.

Research and Development – Assistance Listing No. 11.469 Research and Development – Assistance Listing No. 20.000 Research and Development – Assistance Listing No. 47.083 Research and Development – Assistance Listing No. 81.089 Recommendation: We recommend the OSU STW review and update policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The delays resulted from staffing shortages and turnover, as well as a misunderstanding of the Uniform Guidance requirements. To address this issue, information will be shared with departments regarding the importance of timely invoice processing. This communication will emphasize that invoices must be processed promptly, any discrepancies that could delay payment should be clearly noted on the invoice, and explanations for such discrepancies will be documented. To prevent recurrence, staff will receive additional guidance to ensure they fully understand the Uniform Guidance requirements related to subrecipient payments. Name(s) of the contact person(s) responsible for corrective action: Andrea Sherwood, Assistant Director of Grants and Contracts Financial Administration Planned completion date for corrective action plan: May 31, 2026

Inclusive Ventures Small Business Program – Assistance Listing No. 59-059 Recommendation: We recommend that management develop and implement written procedures to track, record, and report program income, including interest earned on Federal advances. 2660 Riva Road, Suite 200, Annapolis, MD 21401 􀆔 t (410) 222-7410 􀆔 f (410) 222-7415 􀆔 www.aaedc.org Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We recognize the importance of maintaining clear, consistent procedures to ensure that all program income, including interest earned on Federal advances, is properly tracked, recorded, and reported in compliance with applicable requirements. To address this recommendation, management will develop and implement formal written procedures that outline the processes and responsibilities for identifying, documenting, and reporting program income. These procedures will include guidance on calculating and recording interest earned on Federal funds, as well as periodic reconciliation and review controls to ensure accuracy and completeness. In addition, relevant staff will be trained in the new requirements to promote consistent application and ongoing compliance. Name(s) of the contact person(s) responsible for corrective action: Lisa Grunder, Vice President of Administration Planned completion date for corrective action plan: March 23, 2026.

Condition: Northeastern Illinois University (University) did not pay reimbursements within 30 days for certain subrecipients in the Research and Development Cluster. Planned Corrective Action: The University will explore procedures to address this issue. Contact person responsible for corrective action: Jannica Henry, Controller’s Office Anticipated Completion Date: 6/30/2026

Finding Number: 2025-003 - Inadequate Internal Control over Subrecipient Payments Condition: Western Illinois University (University) did not have adequate procedures in place to complete a timely disbursement of requested pass-through funds to subrecipients within the required time period. Planned Corrective Action: The University is committed to developing a comprehensive plan to ensure compliance with payment of pass-through funds policies and procedures. Contact person responsible for corrective action: Mary Pat Wolhford Anticipated Completion Date: 06/30/2026

Research and Development – Assistance Listing No. 10.215 Research and Development – Assistance Listing No. 93.433 Recommendation: We recommend that the University review and update policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2023 audit report in May 2024. The 2023 audit was completed after substantially all of Fiscal Year 2024 had elapsed, so there was not adequate time for the University to fully implement corrective action. While these corrective measures were implemented during Fiscal Year 2025, they did not fully resolve the issue. The University continues to strengthen its accounts payable processes and sign-off approvals to help ensure reimbursements to subrecipients are paid timely. Additional updates to procedures for payment processing are also being developed. Methods for more accurate tracking of invoice receipt dates are being developed to ensure the 30-day period begins on the correct day. Principal investigators and designated administrative personnel within academic departments will be reminded of the need to initiate payments to subrecipients timely. Accounts payable training has been held for such personnel and will persist. Name(s) of the contact person(s) responsible for corrective action: Ms. Andrea Sherwood, Assistant Director, Grants and Contracts Financial Administration at Oklahoma State University and Ms. Nykkia Harris, Controller for Fiscal and Administrative Affairs Planned completion date for corrective action plan: May 2026

2025-001 Cash Management ALN: Research and Development Cluster (R&D) - Various ALNs Finding: The College did not provide evidence of effectively designed internal controls to ensure subrecipients are paid by the College within 30 days of requests for reimbursements received by the College. Corrective Action Plan: Management acknowledges that some of the payments to subrecipients selected for audit were not made within 30 days of receipt. We value the relationships with our subrecipient partners and endeavor to pay all of them timely. Substantially all subrecipient payments are made by the College within the prescribed timeline subject to the underlying transactions being properly approved. This includes the approval by principal investigators and approval of supply chain personnel after the performance of standard controls surrounding disbursements. Management will continue to identify root causes around identified delayed payments and evaluate go-forward process improvements with supply chain services, treasury and academic department personnel. Person(s) Responsible: Rob Falivene, Vice President, Supply Chain Services, and Oswaldo Ramirez, Vice President, Treasurer Expected Completion: December 2026

FINDING 2025-011 Name of Responsible Individual: Lisa Simon, CPA, CFO Corrective Action: The University acknowledges that the internal controls surrounding the cash draws during fiscal year 2025 were lacking and needed to be reinforced for future fiscal years. With the hire of the new CFO and Senior Accountant post June 30, 2025 – these enhanced controls and processes have been put in place. Anticipated Completion Date: Completed Fall 2025 and Ongoing