Corrective Action Plans

Management will draw down Capital Funds on the date the check is written to avoid drawing down too early.

Finding 2026-002 Federal Grant Cash Management and Federal Financial Reporting Auditor reference: Schedule of Findings and Questioned Costs, page 38 Finding addressed: One federal grant cash draw was partially disbursed before related disbursements, resulting in $180,641 in questioned costs. The audit also identified an inaccurate Annual Federal Financial Report for the H8N award ending August 31, 2025. Planned corrective action 1. Reconstruct and reconcile the transactions. By November 2026, the CFO will complete a transaction-level reconciliation of the $180,641 identified by the auditor and review the relevant draws for the H80 and H8N awards cited. The review will tie draw requests to the general ledger, bank activity, payment dates, grant budgets, supporting invoices or payroll, periods of performance, and submitted Federal Financial Reports. 2. Resolve questioned costs and reporting discrepancies. By December 2026, management will determine, based on source documentation and applicable award requirements, the amount, if any, that requires correction; communicate the results to the appropriate HRSA grants management and payment-system contacts; and obtain direction on any required return of funds, adjustment, or corrected reporting. NHHC will implement required remedies and retain correspondence, approvals, and transaction evidence. The $180,641 will remain an open questioned-cost matter until resolved through the applicable agency process. 3. Establish pre-draw controls. By December 2026, the CFO will revise and implement written cash-management procedures that require a grant-specific drawdown worksheet for each request. The worksheet will document eligible expenditures already disbursed or actual immediate cash requirements, planned payment dates, budget and award-period eligibility, available cash, and the requested amount. A designated Finance preparer will document the calculation, and the CFO will approve each draw before submission; exceptions will be escalated to the CEO. 4. Strengthen Federal Financial Report controls. By January 2027, Finance will implement an FFR preparation and review checklist that requires reconciling award-specific financial records with reported expenditures, disbursements, unliquidated obligations (where applicable), and reporting-period dates. The CFO will independently review and approve each FFR before submission. In coordination with HRSA and the payment-system administrator, Finance will address the identified H8N reporting error through the permitted correction process. 5. Test and monitor compliance. By March 2027, the CFO will document a review of all grant draw requests submitted during the first three months of the revised process and of any FFRs submitted during that period. The review will verify completed pre-draw support, approvals, cash timing, and report reconciliation. Exceptions will be investigated, corrected, and tracked to closure, with a summary provided to the CEO. Responsible contacts: Jason Wallace, Chief Executive Officer; Monica Lerma, Chief Financial Officer Anticipated completion: March 2027 Evidence of correction: Transaction-level draw reconciliation and questioned-cost analysis; HRSA and payment-system correspondence; written cash-management and FFR procedures; approved draw worksheets; FFR support and approval checklists; bank and expenditure records; and post-implementation testing reports. Agency-dependent resolution: NHHC’s completion target excludes agency-controlled determinations of questioned costs and acceptance of corrected federal reporting.

The center corredcted the advance draw by expending the draws during the year ended Janaury 31, 2026 and did not complete an advance draw again in 2026. The center will review its cash management polcies to consider modification to account for certain circumnstances to allow for flexibility advance draws. The center will remit the excess interest earned to the Department of Health and Human Services.

Name: CABUN Rural Health Services, Inc. Contact Name: Judy Southall, CFO Contact Phone Number: 870-798-4064 Auditor/Audit Firm: Forvis Mazars, LLP Audit Period: March 31, 2026 Federal Program: Health Center Cluster Anticipated Completion Date: October 2026 Response: The Organization concurs with the finding, and management will implement formal written procedures and internal controls governing Federal cash drawdowns. The procedures will require Federal funds to be drawn only for actual, immediate cash needs and as close as administratively feasible to the related disbursements. Supporting documentation will be maintained to identify expenditures supporting the draw. The expenditures will be reviewed to verify that they are allowable, properly documented, incurred within the applicable Federal award period, and recorded in the appropriate accounting records. Federal draw requests will be reconciled to the underlying expenditures before submission. The individual responsible for preparing the draw will provide the supporting documentation and reconciliation for review and approval before the draw is submitted.

After being informed of the finding, the Center instituted strategies to align drawdowns with near-term disbursement needs. However, these adjustments commenced during the subject fiscal year and will remain in place moving forward.

The Authority will utilize the reimbursement method and process payment to the vendor before requisitioning funds from ELOCCs.

Mt. Olive Community Outreach Center, Inc. Corrective Action Plan Grant Budget Monitoring and Expenditure Control Finding Mt. Olive Community Outreach Center, Inc. (MOCOC) recognizes the need to strengthen its internal fiscal controls to ensure expenditures remain within approved grant budgets. As a small nonprofit administering multiple grant awards, the organization is implementing additional monitoring procedures to prevent overspending and ensure compliance with all grant requirements. Root Cause The organization did not have a formal written procedure outlining how grant expenditures would be monitored throughout the grant period. Although expenditures were reviewed on an ongoing basis, the review process was not consistently documented or supported by a standardized budget monitoring procedure. Corrective Action Effective immediately, MOCOC will implement the following procedures for all grant-funded programs: 1. Monthly Budget Monitoring The Program Director and (Accountant?) will review each active grant budget on a monthly basis. A Budget-to-Actual report will be reviewed to compare approved budgets with actual expenditures and remaining balances. 2. Pre-Expenditure Budget Verification Before any grant-funded purchase or financial commitment is made, the Program Director will verify that sufficient funds remain within the appropriate budget category. No expenditure will be approved if adequate funds are not available. 3. Grant Budget Tracking The Program Director/(Accountant) will maintain a budget tracking spreadsheet for each active grant showing: • Approved budget • Expenditures to date • Remaining balance • Percentage of budget utilized This tracking document will be updated regularly and reviewed during the monthly budget meetings. 4. Spending Threshold Monitoring When expenditures reach approximately 85% of the approved budget or any major budget category, the Program Director and (Accountant?) will review the remaining budget and determine whether spending adjustments or a budget revision request, if permitted by the funding agency, is necessary. 5. Financial Oversight The Program Director will review and approve all grant-related expenditures before payment. The Program will process payments, maintain accounting records, and reconcile expenditures to the accounting system, after they have been properly approved and signed off on to process. Monthly financial reports will be provided to management for review. Responsible Staff • Executive Director • Program Director • Program Assistants • Accountant (When Applicable) Implementation Date These procedures become effective immediately upon approval and will be incorporated into the organization's Fiscal Policies and Procedures Manual. Monitoring Compliance with these procedures will be monitored through: • Monthly budget review meetings between the Executive Director, Program Director and (Accountant?) • Documentation of budget reviews and any corrective actions taken. • Periodic review of financial reports by the Board of Directors if applicable. • Annual review of these procedures to determine whether revisions or additional controls are needed. Expected Outcome Implementation of these procedures will strengthen MOCOC's internal controls, improve budget oversight, reduce the risk of overspending, and ensure continued compliance with grant requirements and sound fiscal management practices. These measures will promote accountability while providing reasonable internal controls appropriate for the size and structure of the organization.

CRMHS management concurs with the finding. During the fiscal year ended June 30, 2025, CRMHS did not consistently operate internal controls over federal cash management as designed. Specifically, a federal draw was processed in excess of immediate cash needs and was not fully reconciled to supporting allowable expenditures prior to submission. This resulted in federal funds being drawn in advance of program disbursement requirements. Management acknowledges that this practice does not comply with 2 CFR §200.305, which requires non-federal entities to minimize the time between drawdown of federal funds and their disbursement for program purposes. While the funds were ultimately expended on allowable program costs, the timing of the draw created a compliance exception and reflects a material weakness in internal control over compliance. Management takes this matter seriously and has implemented corrective measures to strengthen cash management oversight and reconciliation procedures. Such actions include: CRMHS has completed a full reconciliation of all drawdowns under Assistance Listing 93.696 to supporting allowable expenditures through June 30, 2025. • Any excess cash balances identified were evaluated and adjusted to ensure compliance with federal cash management requirements. • Pre-Draw Reconciliation Requirement—No draw request may be submitted without documented reconciliation to recorded allowable expenditures. • Segregation of Duties and Review—the draw request and documented reconciliation will be reviewed and signed off on by a second qualified member of the accounting team. • Monthly Grant Cash Monitoring—CRMHS will compare cumulative drawdowns to cumulative allowable expenditures to identify and resolve any excess cash position.

Cash Management Type: Material Weakness in Internal Control Over Compliance Corrective Actions: - Implement reconciliation of each drawdown to actual expenditures. - Require detailed supporting documentation. - Establish supervisory approval process. Responsible Parties: Chief Executive Officer and Chief Financial Officer

2025-004 Habitat Conservation – Assistance Lising #11.463 - Material Weakness in Internal Control over Compliance – Cash Management Recommendation: We recommend the Organization implement formal internal controls over the cash management process, including documented supervisory review and approval of all cash draw requests prior to submission. Cash draw requests should be prepared and supported using information maintained within the accounting system and reconciled to the general ledger to ensure that only allowable, properly recorded Federal expenditures are included in reimbursement requests. Additionally, management should develop and implement a written cash management policy that establishes procedures for preparing, reviewing, approving, reconciling, documenting, and retaining cash draw records in accordance with the Uniform Guidance. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action taken in response to finding: JCWC is in the process of implementing updated financial policies and procedures to strengthen internal controls over cash management and Federal reimbursement requests. The new Fiscal Policy Manual establishes a specific process for preparing, verifying, reconciling, reviewing, approving, submitting, and retaining Federal reimbursement and cash draw requests. For example, Section 7.2.1, Reimbursement Request Process, requires: 1. Prepare and Verify The Finance & Grants Manager works with Program Staff and Jitasa to identify eligible expenditures and prepares the reimbursement request, ensuring costs are allowable, appropriately allocated, within the approved budget, and supported by documentation. The request shall be prepared using financial information maintained in QuickBooks. 2. Review and Reconcile The appropriate Director reviews the request and supporting documentation for accuracy, allowability, and budget compliance. Jitasa reconciles the requested amount to the applicable QuickBooks general ledger accounts and supporting documentation. Any discrepancy shall be resolved and documented before submission. 3. Approve and Submit The appropriate Director provides documented approval through an approved electronic signature platform. By approving the request, the Director confirms that the request has been reviewed for accuracy, allowable costs, appropriate grant allocation, and compliance with the applicable grant budget and funding requirements. Once approved, the Finance & Grants Manager submits the request to the funder or partner with all required supporting documentation. 4. Retain Records The reimbursement request, supporting documentation, electronic approval, and submitted request are retained in the designated grant records in accordance with Section 10 and applicable funder requirements. The policy therefore establishes a documented supervisory approval and reconciliation process before Federal reimbursement or cash draw requests are submitted. Action Plan: JCWC will finalize and present the Fiscal Policy Manual to the Board for formal adoption and will continue implementing the procedures in the interim. The Finance & Grants Manager will work with program staff and Jitasa to prepare and verify Federal reimbursement and cash draw requests. Requests will be reconciled to the QuickBooks general ledger and supporting documentation, with any discrepancies resolved and documented before submission. The appropriate Director will review and approve each Federal reimbursement or cash draw request prior to submission. JCWC will retain the request, supporting documentation, reconciliation, and approval in accordance with its records retention requirements and applicable Federal requirements. Following Board The appropriate Director will review and approve each Federal reimbursement or cash draw request prior to submission. JCWC will retain the request, supporting documentation, reconciliation, and approval in accordance with its records retention requirements and applicable Federal requirements. Following Board

Asante Health System Corrective Action Plan for FY25 Single Audit Fiscal year end: 09/30/2025 Audit period: 10/01/2024-09/30/2025 Finding 2025-002 Federal Program: FEMA funding is federal financial aid from the Federal Emergency Management Agency’s Disaster Relief Fund (DRF), providing money for communities to recover from disasters, rebuilding infrastructure, mitigating future risks, and covering essential needs. Duplicate expenditures submitted for FEMA reimbursement resulting in unallowable costs being claimed under the program. Statement of Condition: In six of 40 sample items selected for testwork over activities allowed or unallowed and allowable costs/cost principles related to the program, $469,054 in expenditures out of a total of $1,368,522 expenditures (or 34%) were submitted for reimbursement to the Federal Emergency Management Agency (FEMA) but were related to the same invoices and therefore were duplicate expenditures. Upon further investigation, management identified that a total of $2,636,044 expenditures out of a total of $14,470,349 expenditures related to the program were duplicate expenditures. Further, management’s review that was performed over the underlying program details was not designed at a sufficient level of precision that enabled the identification of the duplication errors. Further, in management’s review for the completed project certification for one of two projects for the program these duplication errors were not identified. Actions Taken and Status: To address this deficiency, the organization has implemented the following corrective actions: 1. Recovery and Adjustment of Duplicate Claims o A complete review of all FEMA reimbursement submissions was performed to identify duplicate expenditures. o Management will work with FEMA to adjust previous reimbursement requests and return any funds received for duplicate expenditures, as required. 2. Enhanced Reconciliation Controls o A detailed reimbursement tracking log has been implemented to identify each invoice: payment date, reimbursement request number, and reimbursement status. o All expenditures submitted for reimbursement will be reconciled against prior submissions before inclusion in a reimbursement request. 3. Training o Finance personnel responsible for federal grant administration and reimbursement submissions have received training on Uniform Guidance requirements, allowable costs, and reimbursement documentation controls. Corrective action training has been completed as of 9/30/2026. Responsible Contact Person: Name: Heather Rowenhorst Title: Chief Financial Officer Department: Administration Phone/Email: 541-789-5098 / Heather.Rowenhorst@asante.org

We modified the current policy to include that future advance drawdowns be limited to immediate cash needs. Any alternative payment arrangement must comply with applicable federal requirements and award terms and receive written awarding-agency approval where required. Board approval alone does not authorize an exception to those requirements. Each drawdown will be supported before it is requested to be in line with the updated policy, tying the request to expenditures paid or due shortly. Each drawdown will be approved in advance by the Executive Director. The Executive Director will be responsible for obtaining written approval from the awarding agency before any request outside of the normal reimbursement cycle. The approval will be kept on file. In this instance, Experimental Station placed drawn federal funds in a segregated interestbearing account. Earned interest on the account, in the amount of $54,333.50, was remitted to the federal government on August 1 3, 2026, prior to the 2025 audit completion, and all funds on the federal awards were expended on the awarded program prior to the award end dates on July 31 and September 14, 2026.

Authority's Response and Planned Corrective Action Plan: 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. Kinteh Darboe, Chief of Financial Operations & Management, is responsible for ensuring the deficiencies have been rectified by March 31, 2026.

Federal Program / Assistance Listing Number (ALN) 84.031 Finding Reference Number 2025-004 1. Finding Summary The auditor noted one (1) of eight (8) drawdowns tested for the Title III program were requested in advance of expenditures incurred. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that during the year, we were notified that the Federal 05 system was scheduled for shutdown, which would block all access to Federal drawdowns. At that time, the University had already incurred, or was expected to incur, expenditures under the Title III program. To ensure timely payment to our Title III staff we expedited our procurement process and identified the necessary amount to cover payroll before the 05 shutdown. After subsequently learning that the Title III program would remain unaffected by the 05 shutdown, we decelerated our procurement process, refunded the drawn funds and resumed normal operations to avoid any cash management non-compliance issues. 3. Root Cause Analysis The root cause was an isolated incidence during an anticipated government shutdown. 4. Corrective Action(s) The early drawdown of federal funds was made in anticipation of a potential federal government shutdown to ensure sufficient funding would be available to support ongoing program operations and avoid disruptions in funding during the anticipated shutdown period. The funds were immediately reconciled upon receipt, and the University confirmed that the drawdown was appropriately accounted for. Description of Corrective Actions The University will draw down Federal funds based on documented cash needs, anticipated eligible expenditures, and applicable federal requirements, while documenting extraordinary circumstances. 5. Risk Mitigation (Required - Even if Disagreeing) The University institution recognizes the importance of drawing down Title III funds in accordance with Federal guidelines. 6. Responsible Party • Office/Department: Title III Office • Title of Responsible Official: Interim Title III Director • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: IZI Yes D No • If not fully implemented, expected completion date: 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation 9. Monitoring and Sustainability The University will continue is monitoring procedures to ensure Title III funds are drawn down in accordance with Federal guidelines.

Finding #SA2025-001: Reimbursement Requested In Advance of Payment Assistance Listing Number: 97.047 Assistance Listing Title: BRIC: Building Resilient Infrastructure and Communities Name of Federal Agency: Department of Homeland Security Pass Through Entity: California Governor's Office of Emergency Services (CalOES) Pass Through Identifying Number: LPM-PJ-09-CA-2023-005 Federal Award Identification Numbers: EMF-2023-PD-0004 • Fiscal Year of Initial Finding: 2025 • Name(s) of the contact person: Katy Hornbeck • Corrective Action Plan: The reporting of project expenses in the amount of $10,858 was due to a misinterpretation of the grantor reimbursement form and was not intended to be an advanced payment. The grantor’s drawdown form indicates the grantee should report “project expenditures.” When Accounts Payable (AP) receives the vendor invoice to process, AP applies the full amount of the invoice to the associated Purchase Order (and its budgeted project/fund source) and withheld retention is tracked in a “retentions payable” liability account. When the Grants Department Accounting Technician prepares a drawdown (reimbursement) request, a Project Summary Report and the Project Cost Summary report are pulled from Finance Enterprise. Both reports reflect the full invoice amount as expenditures incurred. The Account Technician reconciles the summary reports with the cleared checks/electronic payments to confirm the actual amount paid to the vendor and if retention was taken out. The amount of any retention will be noted on the Project Summary Report, and the copy of the retention report will be attached as backup documentation when preparing the SEFA. In accordance with the Park District’s Federal Compliance Procedure, the Park District generally does not accept federal funds on an advancement basis. If an advance were to be required by the granting agency, the advancement of funds would be handled in accordance with any requirements of the grant contract and the C.F.R. part 200, 200.305(b). For future federal grant reimbursements, the Park District will only report project expenditures once they have been reconciled with the corresponding cleared checks/electronic payments. This will ensure retention withheld from contractor invoices is excluded from reported project expenses. • Anticipated Completion Date: July 1, 2027

Finding Number: 2025-001 Condition: The Organization submitted a Request for Reimbursement (SF-270) that included $91,453 for the remaining balance of certain vehicle lease agreements that had not been paid at the time of the request, resulting in Federal funds held in excess of immediate cash needs. As of December 31, 2025, $51,642.70 remained unexpended. In addition, the semiannual financial reports submitted to the Forest Service reported the funds received as cash disbursed, overstating reported disbursements. Management response: Management concurs with this finding. The Organization acknowledges that Federal funds were requested in excess of its immediate cash needs and that the semiannual financial reports did not reflect actual disbursements during the year ended December 31, 2025, and is committed to implementing the corrective action described below. Corrective action plan: In response to the condition in reference, management will establish the following corrective action: • Notify the Forest Service in writing of the unexpended advanced funds and obtain a determination on whether the balance must be returned or may be applied to future lease payments. No additional funds will be requested for the vehicle leases until the determination is received. • Determine whether the advanced funds earned interest and, if applicable, remit it in accordance with 2 CFR 200.305(b). • Adopt a written procedure requiring that each SF-270 be supported by a worksheet showing that costs included in reimbursement requests have been paid, that advances do not exceed 30-day cash needs, and that prior advances have been fully expended. The worksheet will be reviewed and approved before each request is submitted. • Submit revised semiannual financial reports reflecting actual cash disbursements recorded in the accounting records. • Prepare future financial reports from actual disbursements recorded in the general ledger, reconciled to the general ledger and reviewed by a person independent of the preparer before submission. • Provide training to personnel responsible for payment requests and financial reports on the award's terms and conditions and the cash management and reporting requirements of 2 CFR Part 200.

Finding No. 2025-002 — Cash Management — Significant Deficiency Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Name and Assistance Listing Number: Low-Income Home Energy Assistance 93.568 Federal Award Identification Number and Years: 23DSS4301 EW 9/25 and 9/26 Name of Passthrough Entity: Connecticut Department of Social Services Planned Corrective Action: Management will continue to identify opportunities to streamline invoice processing along with conducting periodic reviews of processed invoices to ensure payment was made within the 10 day payment period. Management will also maximize recruitment efforts to fill vacant staffing positions. Name of Contact Person: Tiffany Bell, Director of Energy Services, anticipated completion date — December 31, 2026.

Views of Responsible Officials: During 2025, the Foundation experienced an extraordinary period of uncertainty surrounding the continued availability and accessibility of Federal funding. In response to concerns regarding access to previously awarded Federal funds, the Foundation accelerated certain cash draws associated with approved Federal awards and established work plans. Shortly thereafter, access to certain award accounts within the Federal payment system changed, with access subsequently restored. As circumstances stabilized, the Foundation returned a substantial portion of the advance funding in March 2025. As of December 31, 2025, approximately $7 million remained recorded as refundable Federal advances associated with existing Federal awards. Management anticipated that these funds would be applied to eligible program expenditures and existing award obligations as activities under the approved work plans progressed. The Foundation maintains cash within pooled operating accounts and did not maintain Federal advances in separately segregated bank accounts. While Federal award activity and expenditures were tracked within the Foundation's accounting system, the Foundation's existing cashmanagement and liquidity-monitoring processes did not provide sufficient visibility to demonstrate that cash and investments equal to outstanding refundable Federal advance obligations remained available as of December 31, 2025. The Foundation also maintained access to a $1 million line of credit that was available to provide additional liquidity for short-term organizational working-capital requirements. The line of credit had not been drawn as of December 31, 2025, and therefore was not included in the cash and investments used to measure available liquidity at year-end. Nevertheless, the facility represented an available non-Federal source of liquidity that could have been utilized to address short-term organizational cash-flow requirements. Importantly, as reflected in the auditors' findings, no questioned costs were identified because expenditures unrelated to the applicable Federal awards were not charged to those Federal programs. The Foundation recognizes the need to strengthen its cash-management controls and liquidity-monitoring processes to ensure that Federal cash draws are aligned with immediate program cash requirements and that sufficient liquidity is maintained to satisfy outstanding Federal advance obligations. To address the finding, management has implemented or will implement the following corrective actions: 1. Federal Cash Draw Review and Approval – CFO/Finance Finance will maintain a formal review and approval process for federal cash drawdowns. Draws will be supported by eligible expenditures and actual and immediate cash requirements consistent with applicable federal award requirements. Federal cash draws outside the Foundation's normal reimbursement or cash-management practices will require documented review and approval by the CFO. 2. Extraordinary Federal Cash Draw Protocol – President & CEO/CFO If extraordinary circumstances arise that could affect the Foundation's access to federal awards or federal payment systems, any decision to materially accelerate a federal cash draw will be documented and subject to enhanced executive review.The documentation will include the circumstances supporting the proposed action, affected federal awards, amount of the proposed draw, anticipated eligible expenditures, expected timing of those expenditures, applicable federal cash-management requirements, and identified compliance and liquidity risks. Material extraordinary draw decisions will require approval by the President & CEO and CFO and, when appropriate, consultation with legal counsel, the federal awarding agency, and/or the appropriate Board leadership. 3. Program Certification of Anticipated Eligible Expenditures – Program Leadership When a federal cash-management decision relies on anticipated program activity, the responsible Program Executive will provide Finance with documented projections of the eligible expenditures expected to be incurred under the applicable awards. The documentation will identify the anticipated expenditures, estimated amounts, expected timing, and applicable federal awards. Program Leadership will be responsible for the accuracy and completeness of the programmatic projections provided to Finance. Finance will remain responsible for evaluating the information against applicable federal cash-management requirements. 4. Federal Advance Retention Review – CFO/Finance When a material federal advance remains outstanding, Finance will perform and document an assessment of whether continued retention of the advance is appropriate. The assessment will consider the amount of the outstanding advance, cumulative eligible expenditures, anticipated eligible expenditures, expected timing of those expenditures, applicable award requirements, and the amount, if any, that should be returned. Material advance balances will be periodically reassessed until the funds have been applied to eligible federal program expenditures or returned, as appropriate. 5. Federal Advance Reconciliation – CFO/Finance Finance will maintain an award-level reconciliation of federal cash draws, cumulative eligible expenditures, and outstanding refundable advances. The reconciliation will provide management with visibility into the amount of federal cash advanced in excess of cumulative eligible expenditures and facilitate timely identification of amounts that may require repayment. The remaining refundable advances associated with the December 31, 2025, balance will continue to be monitored through final disposition. 6. Enhanced Cash-Flow and Liquidity Forecasting – CFO/Finance Management will maintain a rolling 90 day cash-flow forecast incorporating anticipated receipts, operating expenditures, federal award activity, refundable advances, unrestricted resources, and other significant obligations. The forecast will be regularly updated and used to identify projected liquidity shortfalls and required management actions. Status: Started September 20267. Federal Advance Liquidity Monitoring – CFO/Finance As part of the Foundation's liquidity reporting, Finance will specifically compare outstanding federal refundable advances with available financial resources. If available resources approach or fall below established thresholds necessary to satisfy federal advances and other restricted or committed obligations, the matter will be immediately escalated to the President & CEO and appropriate Board leadership. This control is intended to prevent a situation in which a significant federal advance remains outstanding without management having timely visibility into the Foundation's ability to satisfy the associated obligation. Status: Started July 2026 8. Executive Accountability Responsibility for remediation will be shared across executive leadership with clearly defined accountability: Finance/CFO will be accountable for federal cash-management compliance, federal draw review, refundable advance reconciliations, cash-flow forecasting, liquidity monitoring, and escalation of identified risks. Program Leadership will be accountable for providing Finance with timely and supportable projections of anticipated eligible program expenditures when those projections are necessary to support federal cash-management decisions. President & CEO will be accountable for ensuring that organizational expenditures and operating decisions are appropriately aligned with available and reasonably forecasted financial resources and for directing organizational corrective action when established liquidity or revenue thresholds are reached. Management believes these measures strengthen the control environment surrounding an extraordinary and unusual event while establishing sustainable controls for federal cash management going forward. Management is committed to ensuring that future federal drawdowns are appropriately aligned with the Foundation's actual and immediate cash requirements and that significant federal advances are subject to documented, ongoing monitoring through their final disposition.

Corporation's Response: 1. The amount undisbursed, $15,000, was notified to the Project of awareness that we intend to return it as soon as possible. We will be contacting the Awarding Agency Officer to allow us the specific instructions for returning funds through the Payment Management System (PMS) following the agency's refund rules. Also, we have procedures to determine whether any interest earned in the advance must be remitted under 2 CFR§ 200.305(b)(9). 2. We have developed and implemented written cash management procedures to ensure that advance requests are limited to immediate cash needs and each of them is backed by paid invoices. 3. A monthly reconciliation is done for each of the funds, comparing federal disbursements with actual disbursements to avoid excessive requests for unused funds. 4. Constant monitoring has been established. Analyses are carried out of the approved and used budget. This analysis is done by someone who doesn’t handle payments, for the segregation of duties and supervision and the senior management does reviews to make sure everything gets done on time. 5. A formal training program on federal award requirements has been developed and implemented for all staff involved in administration, financial management, procurement, and reporting of federal awards. PR CONCRA management traces all CFR 200-related training and federal fund management training for the staff who can attend or participate in these seminars virtually.

The funds in question either already have been, or will be prior to year-end, fully spent down in 2026. No further draws are/will be taken in 2026 unless the need is critical, and if that is the case we will only take that which will (based on budget) be spent over a three-month span. Additionally, we have returned to billing for the awards in question on a cost reimbursement basis in 2026. Anticipated Completion Date is December 31, 2026. Responsible Official - Mike Marchesano, CFO

Management will implement written procedures for federal grant administration applicable to all federal awards. Reimbursement requests will be limited to costs incurred and supported by documentation at the time of the request. The reimbursement request, expenditure listing, supporting documentation, and documented allowability review will be maintained together in a referenced file and will include preparer and reviewer sign-off. For advance payments, management will document the program's immediate cash requirements supporting the amount and timing of each advance and monitor the period between receipt and disbursement of federal funds. The reimbursement log reconciliation and Schedule of Expenditures of Federal Awards will be subject to documented review by an individual who was not involved in their preparation. Management will also coordinate with the USDA Forest Service regarding the $64,969 in questioned costs and follow the awarding agency's direction.

FINDING 2025-014 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Condition of Records Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Centralized Reporting: The Finance Department now mandates that all approved grant documentation (Grant Award Notifications, reimbursement forms, budget breakdowns) be submitted to Finance immediately. This grant is no longer in use. Anticipated Completion Date: September 30, 2024 (grant ended). January 1, 2025 is when grant award documentation sharing was required.

CORRECTIVE ACTION PLAN FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) - Condition of Records Contact Person Responsible for Corrective Action: Kwalfle Scott-Bradley, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, kscottbradley@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reimbursement & Approval Process: Standardized reimbursement requests to require full supporting documentation (transaction details and summary reports). The Director of Federal Grants filters expenditures since the prior request, reconciles totals against disbursements, and obtains CFO approval before submitting. Resolution of Over-Expenditures: Over-expenditures identified during the audit cycle were resolved in January 2026 via School Board approval by transferring unallowable and excess expenditures to the general fund. Category Monitoring: The Special Education Department will monitor budget limits continuously to ensure individual grant categories are not over-expended. Anticipated Completion Date: Completed January 2026

Golden West Humanitarian Foundation agrees with the finding and will implement written cash management procedures designed to ensure compliance with the requirements applicable to interest earned on Federal advance payments. The Foundation will establish procedures to identify Federal advance balances by Federal award and applicable bank or investment account and to calculate the amount of interest earned on those balances. The calculation will be performed at least annually and more frequently when Federal advance balances are significant. As part of this process, the Foundation will determine the amount of interest earned on Federal funds that is subject to remittance after consideration of the annual amount permitted to be retained for administrative expenses. Any amount required to be remitted will be recorded as a payable at year-end and remitted to the Federal government through the applicable Federal payment system in accordance with Federal requirements. The Foundation has evaluated the interest earned on Federal advance balances during the year ended December 31, 2025 and determined the amount, required to be remitted to the Federal government. Any required liability will be recorded and amounts due will be remitted in accordance with applicable Federal requirements. Responsibility for preparing the interest calculation and related reconciliation will be assigned to Asia Johnson, Chief Compliance Officer. The calculation, related accounting entries, and evidence of any required remittance will be reviewed by and approved by an individual (or individuals) independent of the preparer.

2025-002 - Excess Drawdown of Federal Funds (Significant Deficiency and Other Matters) Federal Program Information: Type of Finding: Compliance Areas: Funding Agency: Title: FAL Number: Passthrough: Award Period: Significant Deficiency, Other Non-compliance Cash Management, Allowable Costs and Cost Reporting U.S. Department of Education Teacher Quality Partnership Grants 84.336S NIA 10/01/2024- 09/30/2025 Principles, and Criteria: Cash Management Although 2 CFR 200.305(b)(l ) permits the Foundation to draw down funds in advance, the entity utilizes a cost reimbursement approach for Federal funding. This practice ensures that funds are drawn only for immediate cash needs . 2 CFR 200.305(8)(1) Federal payment. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or projects costs and the proportionate share of any allowable indirect costs. Cost Principals and Reporting: The application of cost principles is governed by 2 CFR 200.400; specifically (b) the non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underly ing agreements, program objectives, and the terms and conditions of the Federal award. Condition: During our review of cash management procedures, we identified the following issue: • The Foundation drew down funds for the Teacher Quality Partnership Grants {TQP) prior to expenditures or when expenditures were not yet anticipated to be actu ally disbursed. o TQP Effective Educators grant - $771,222 o TQP Southwest grant - $572,672 Questioned Costs: None. The Foundation used all the funds drawn down according to the grant directives as it closed out the grant funds. All expenditures were in compliance with the stated objectives. Cause: During the beginning of the second Donald Trump administration, President Trump issued an executive order on January 20, 2025 that established the Department of Government Efficiency (DOGE). Individuals within the Employment and Training Administration (Budget and Management) of the DOL that administered our YouthBuild program and other similar programs encouraged the Foundation to draw down the funds on all grants as they believed the grants were going to be shut down soon by DOGE, but they wanted those entities that were already committed to staffing and programs to be able to complete the year. The Foundation did draw down funds in order to complete the commitments. Effect: The Foundation was not in compliance with 2 CFR200.305(b)(l) and 2 CFR200.400(b) by drawing down funds prior to actual expenditures. Auditor's Recommendation: We recommend that the Foundation not draw down funds prior to incurring actual expenditures or until expenditures are expected in the very near future. Grant program personnel do not have the authority to waive 2 CFR requirements or grant requirements, even in unusual situations like the DOGE occurrence. Responsible official's view: • Specific corrective action plan for the finding: Three Rivers Education Foundation's CEO, Dr. Linda J Coy will ensure that all drawdowns follow appropriate timeframes as required. TREF has already implemented this longstanding practice. The action described in this "Significant Deficiency" came about because of extenuating circumstances and advice provided from the federal government. We were assisted with disbursements by the Federal Program Officer for the TQP programs. • Timeline for completion of corrective action plan: The corrective plan has been implemented as per Dr. Linda J. Coy, CEO for Three Rivers Education Foundation as of September 29, 2026. • Employee positions(s) responsible for meeting the timeline: Dr. Linda J Coy, Executive Director and James L. Coy, Chief Financial Officer