Corrective Action Plans

Finding 2025-003 Cash Management – Timeliness of Subrecipient Payments Plan: UIC - The Office of Sponsored Programs (OSP) reviewed existing systems, reporting and procedures available to enhance invoice monitoring capabilities. UIC will develop a subaward invoice routing system to centralize and track the subrecipient’s invoice from submission through approvals and timely payment. UIUC – Sponsored Programs Administration is implementing an automated subaward invoicing solution to improve processing efficiency and enhance transparency. By the end of February 2026, all subaward invoices will be routed through the SPA Subaward Tracker, a new online workflow system that enables multiple users to submit, review, and approve invoices at any time. This platform streamlines routing,provides real-time visibility into invoice status, and reduces manual processing bottlenecks. These improvements are designed to support timely review and payment of subaward invoices and to help ensure compliance with the 30-day federal payment requirement. Expected Implementation Date: UIC –June 2026 UIUC – February 2026 Contact: Katrina Lopez, Associate Director Office of Sponsored Programs (OSP) University of Illinois Chicago klopez3@uic.edu 312-996-3782 Karen Thomas, Director Post-award Sponsored Program Administration University of Illinois Urbana-Champaign Kthomas2@illinois.edu 217-265-4096

Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: Management acknowledges the finding. Delays in approvals may occur due to multiple internal and external parties involved. To prevent recurrence, management will monitor all parties, issue email reminders with clear deadlines, and enforce timely processing to ensure compliance with the 30-day requirement. Contact person responsible for corrective action: Teresa Martinez, Lorena Soto, Alvaro Espino and Mariela Romo Anticipated Completion Date: 8/31/2026

Malama Honua Public Charter School Foundation (“MHPCS Foundation”) acknowledges the observation noted by the auditors regarding the timing of the advance drawdown received on February 7, 2025 and the subsequent disbursement on April 29, 2025. As described in the audit finding, the funds remained on hand for approximately 81 days prior to disbursement, which exceeds the expectation under 2 CFR §200.305(b) that non-Federal entities minimize the time between the transfer of federal funds and their disbursement. Management notes that the timing of the disbursement occurred during a period of heightened uncertainty related to federal appropriations and funding continuity. During 2024 and early 2025, the federal government operated under a series of short-term Continuing Resolutions due to delays in the passage of full-year appropriations legislation. In early 2025, the federal government faced a potential shutdown while operating under temporary funding authority that extended through March 14, 2025. The uncertainty associated with these circumstances contributed to adjustments in project timelines, vendor invoicing schedules, and payment coordination. While these conditions affected the timing of project-related expenditures, MHPCS Foundation recognizes the importance of ensuring that federal drawdowns are aligned as closely as possible with immediate disbursement needs. MHPCS Foundation maintains internal financial management practices designed to support compliance with federal cash management requirements and has taken steps to strengthen documentation and oversight related to drawdown requests. As part of its corrective action plan, the Foundation has implemented procedures to ensure that advance payment requests are generally limited to anticipated expenditures expected to occur within approximately five to seven days, consistent with the objective of minimizing the time between the receipt and disbursement of federal funds. Prior to requesting a drawdown, the Project or Program Director prepares an itemized expenditure schedule identifying the anticipated immediate cash needs associated with the project or program budget. The itemized expenditure schedule is submitted to the Foundation’s Accountant for review. The Accountant verifies that the projected expenditures are consistent with the approved program budget and prepares a Drawdown Authorization Form documenting the requested advance payment. The Drawdown Authorization Form is then reviewed and approved by the Foundation’s Board President prior to submission of the draw request through the applicable federal payment system (e.g., G5). Following submission, confirmation of the draw request is attached to the authorization documentation and retained for accounting and audit purposes. This process provides documented support for draw requests, establishes multiple levels of review, and ensures that advance payments are supported by near-term disbursement forecasts. Advance payments outside of regular payroll cycles may occur only when supported by documented project or program expenditures and must follow the same authorization and documentation procedures described above. These strengthened procedures are intended to ensure that future drawdowns are aligned with immediate program needs and supported by documented payment schedules, thereby reinforcing compliance with 2 CFR §200.305(b) and related Uniform Guidance requirements. Management believes the procedures outlined above address the circumstances described in the finding and enhance the Foundation’s internal controls over federal cash management. The Foundation remains committed to maintaining strong financial stewardship and ensuring continued compliance with applicable federal regulations governing advance payments and cash management.

Finding Number: 2025-001, Subrecipient Payments Condition: The University did not have adequate controls in place to ensure invoices to subrecipients were paid timely within the 30-calendar-day requirement. Planned Corrective Action: Penn State created a new Subaward Administration and Compliance Office (SACO), which is part of the new Post Award Contractual Compliance Office. The SACO is led by its own director and provides central oversight over key subaward compliance processes, such as subrecipient payments, and provide training to campus on subrecipient processes. This function has already implemented new changes and workflows in the financial system to allow for better tracking and reporting of subaward compliance activities, and continues to refine subaward processes. The creation of this office demonstrates Penn State’s commitment to compliance for subaward activities. Contact person responsible for corrective action: Jason Guilbeault, Assistant Vice President for Research – Post Award Contractual Compliance Anticipated Completion Date: February 27, 2026

2025-003-Cash Management MVRTD recognizes this material weakness. Several factors lead to the inaccurate billing noted in the audit. Firstly, it must be noted the during FY25 the MVRTD did not have a financial director on staff and the billing work was being performed by a staff accountant with no previous training in the billing of MVRTD specific grants and no written manuals or instructions were left behind to reference. Due to the fact allocations were set up to be calculated as an automatic entry inside of Passport ( our previous accounting system) and completed outside the system, there were no oversite measures that would have provided a way to prevent or identify duplicate transactions such as the overbilling that occurred. Since July 1, 2025, we have hired a full-time Finance Director and established a new accounting system. We have started using Quick Books Online (QBO), which is a much more detailed and comprehensive accounting system that allows us to be able to identify errors in the billing process and we established an entirely new cost allocation system that is outside of QBO. This ensures an internal and external check and balance system. All invoices and back-up are now being reviewed and approved by the Executive Director. Both the Finance Director and Executive Director will sign off on the invoices before submitting them to the state.

The Bureau of Financial Operations (BFO) will continue conducting during-the-award subrecipient monitoring for the SSBG based on the results of the documented risk assessment. As it relates to the cash management portion of the finding, given the relatively small amount of funds involved and the number of counties affected, DHS has determined that it is not economically feasible to change the payment methodology at this time. Anticipated Completion Date: 06/30/2026 Contact Name: Kelly Graham, Director, Division of Financial Reporting

Finding 2025-001: Timely Remittance of Earned Interest Federal Programs ALN: 93.575, 93.596, 93.558, and 93.667 Responsible Party: Alison Fraga, Chief Executive Officer Anticipated Completion Date: Management response: Concur. Corrective Action Plan: Coalition management will make sure that measures are in place to ensure all DEL funding is always held in interest bearing bank accounts and returned timely in accordance with rules and regulations

The City will review the requirements for written policies and will adopt policies, as needed, or will revise its current policies as needed to comply with Uniform Guidance.

Lack of Review over Financial Status Reports Auditor Description of Condition and Effect. The University did not have documented review procedures in place for federal grant drawdowns nor review over monthly Financial Status Reports. Drawdowns were processed and Financial Status Reports were submitted without a formal review or approval process to verify that amounts reported and requested were based on allowable expenditures. This deficiency increases the risk of drawing and reporting federal funds in excess of actual expenditures or for unallowable costs, potentially resulting in noncompliance with federal regulations. Auditor Recommendation. We recommend that the University should implement formal review procedures for all federal grant drawdowns including monthly FSRs, including enhancing policies around reviewing drawdowns, designated reviewers, and system controls to ensure drawdowns are accurate, allowable, and properly supported. Corrective Action. The University will implement a review process to ensure that all drawdowns are reviewed by a second individual prior to submission. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026

Program: AL 12.401 – National Guard Military Operations and Maintenance (O&M) Projects – Cash Management & Reporting Corrective Action Plan: Continue to monitor program expenditures to aid in optimizing forecasting and advance request accuracy. Contact: Lauren Hargreaves Anticipated Completion Date: Ongoing

Responsible Person(s): Darin Moore, Deputy Director of Administration and Outreach; Sarah Boggs, Accounting Manager for Planning and Finance; Suzanne Robinson; Tim Springer, Budget Manager for Planning and Finance Corrective Action Planned: Review the current DWR process and determine whether DWR should petition the Comptroller for an exception to CAPP Topic 20605 or modify the DWR process to the “split coding” method instead. This will include: 1.) Evaluation of grant program guidance to ensure no obstacles exist from the Federal Awarding Agency to changing DWR's current methodology; 2.) Meeting and discussing with other (like) state agencies for policy, procedure, and training examples for split coding grant eligible expenditures; 3.) Scheduling meetings with Department of Accounts and the previous APA Audit Team to discuss DWR's evaluation, decision, and next steps; 4.) Developing and implementing new DWR policies and training to ensure compliance with the approved methodology. (Estimated completion date: July 1, 2026) Update current policies and procedures to conform with CAPP Manual Topic 20405 and to enhance the agency's current supporting documentation for all journal entries. At a minimum, these new policies and procedures will require that Voucher ID/Expense Report IDs that are moved within a journal entry are documented in the journal reference line in the system to improve transparency, will add more detailed explanations to justify coding changes, will upload applicable documents into the system to assist in manager approval, and will maintain all documentation centrally in one location for easier access and review. (Estimated completion date: July 1, 2026) Publish and maintain a sustainable federal drawdown schedule, by: 1.) Evaluating DWR's current federal drawdown schedule in accordance with current policies, procedures, employee workload, cashflow, and Federal Awarding Agency's guidance; 2.) Developing specific controls, and revised job descriptions as needed to ensure the drawdown schedule can be consistently maintained; and 3.) Incorporating both the new schedule and controls into appropriate policies and procedures to ensure accountability. (Estimated completion date: June 1, 2026) Evaluate current policies, procedures, and practices pertaining to how DWR manages and records Program Income. Develop and update policies and procedures to ensure compliance with CAPP 20205. Provide training on new policies and procedures to employees within the Planning and Finance Division. (Estimated completion date: June 1, 2026) Review current internal procedures for reporting federal expenses on the SEFA and Attachment 15 and identify training gaps. Enlist training support from Department of Accounts and/or other state agencies to address training gaps. Develop new written policies and procedures, along with new supporting documentation requirements, to conform to SEFA and Attachment 15 guidelines and expectations. Provide training on new policies and procedures to employees within the Planning and Finance Division. (Estimated completion date: July 1, 2026) Review all other written policies and procedures for administering federal grants and contracts, and develop and update as necessary to address insufficient guidance and noncompliance. (Estimated completion date: August 31, 2025) Estimated Completion Date: 7/1/2026

FINDING 2025-004 Subject: COVID -19 - Education Stabilization Fund - Cash Management Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation will implement and consistently apply a standardized two-level review and approval process for all grant reimbursements to ensure proper accounting, documentation, and compliance. The grants administrator (or designee) will prepare and conduct the initial review of each grant reimbursement to verify that all expenses and receipts contain the correct accounting information, are properly documented, and are recorded in the appropriate accounts within the Financial Management System (FMS). The Corporation Treasurer (or designee) will perform an independent secondary review of all grant reimbursements, including a review of supporting documentation and account coding, and will provide final approval and signature as evidence of authorization. On a monthly basis, grant accounts will be reviewed by the grants administrator for accuracy and completeness, with the Corporation Treasurer (or designee) conducting a secondary monthly review to confirm accuracy and compliance. This two-level review process ensures adequate segregation of duties, strengthens internal controls, and provides documented oversight of all grant reimbursement activity. Anticipated Completion Date: The ESSER grant is finished. If we were to receive this grant in the future, Silver Creek School Corporation would apply the procedures in the corrective action plan.

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring remittance of federal funds directly to subrecipients, rather than paying vendors on the subrecipient's behalf. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective October 1, 2025, all subrecipients were notified that payments would be made only to them, requiring them to directly pay their contractors and vendors. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: October 1, 2025

Corrective Actions Taken or Planned: MARTA has grown substantially in the last several years. This progress includes identifying areas that need to be updated or developing new processes and documentation. MARTA has an Asset Inventory Policy and Procedures in which the purpose is to ensure that fixed assets are properly accounted for, identified, and tracked. MARTA also has Cash Handling Policy and Procedures which addresses safeguarding public funds and maximizing the available resources. This is designed to reduce the risks associated with the collection, receipts storage and reporting of cash transactions and to safeguard and maintain the security and integrity of MARTA's fiscal assets. MARTA will review and update these policies and/or create new policies to make sure that they are compliant with the Uniform Guidance. Personnel responsible: Sandy Benson, General Manager Anticipated completion date: October 2026

Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. Montana Cancer Consortium (MCC) has updated the Financial Process Procedure to include language related to receipt management, allowable and disallowed grant expenses, and timing of payment requests. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators

Finding Number: 2025-001 Responsible Person: Michele Brand, Director Finance/HR/IT Management Views: Management agrees with the finding and immediately implemented the recommendation. Corrective Action: This was a one-time error due to end-of-year accrual adjustments and spending allocation modifications that reduced the amount of spending in certain grants. This is the first time estimates were used, and we deviated from our normal procedures. Estimates will not be used in the future. Anticipated Completion Date: Already complete.

Noncompliance/Material Weakness in Internal Control over Compliance: • Provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. • Develop and implement policies and procedures that ensure grant funds are drawn at the time of, or following, expenditures for allowable costs. These policies and procedures will include that, for each draw from a Federal award, 1) detailed documentation of the expenditures for which the grant funds are being drawn is prepared prior requesting the draw, including transactional details such as vendor, invoice number, invoice amount, check number, check date, payee, and check amount; 2) that the documentation supporting the draw is reviewed and approved by a member of management (other than the person who prepares the documentation) prior to requesting the draw, and 3) that the documentation supported each draw is maintained as part of the Organization's accounting records. • Return H8F funds, including interest, to the Federal grantor agency.

Finding 2025-003: Cash Management Assistance Listing Number 84.126A Rehabilitation Services - Vocational Rehabilitation Grants to States Award Period: July 1, 2024 – June 30, 2025 Responsible Person: Karen Miller, Controller, 609-771-2203, Jeanette Vega, Director of Grant Financial Administration, 609-771-2847 Amy Cuhel-Shuckers, Director, Grants and Sponsored Research, 609-771-3120 Corrective Action Plan: For the fiscal year ending June 30, 2025, the College had certain reimbursement requests under ALN 84.126A that were not submitted within the required timeframes and were missing certain documentation elements specified within the underlying grant agreements. While all reimbursement requests were made for allowable expenditures incurred prior to the date of request, the timing and documentation issues resulted from staff turnover and gaps in detailed review procedures within both Finance & Business Services and the Office of Grants and Sponsored Research (OGSR). The College recognizes the importance of ensuring that reimbursement requests are fully compliant with the timing and supporting documentation requirements outlined in 2 CFR 200.305 and the corresponding award documents. During FY25 and FY26, the College strengthened internal controls over reimbursement processing by implementing enhanced month-end monitoring procedures, hiring a Research Business Assistant responsible for additional oversight, improving documentation standards, strengthening cross-functional communication and coordination, and establishing a grant-specific reimbursement deadline tracker. These improvements were incorporated into updated training for principal investigators and grant support staff, with mandatory annual training implemented beginning FY26.The College implemented portions of the corrective actions during the fiscal year, with remaining items implemented at the start of FY26. These actions collectively support full and ongoing compliance with reimbursement requirements for federal and pass-through grant programs. Anticipated Completion Date: June 30, 2026

Audit Finding Number: 2025-001 – Cash Management Agency: Public Housing Capital Fund Responsible Person, Title: Stephanie Schmutzer, Accountant Completion date: 7/1/2025 Agency Response: Concur Corrective Action Plan: Management concurs with the recommendation to implement timely LOCCS fundings that coincides with our normal accounting cycle when receiving Capital Funds in the future.

Corrective Action Plan: Upon assuming the role of Executive Director in July 2024, it became clear that rent reasonableness studies were not being conducted under the previous administration, as required. Recognizing the importance of compliance with HUD regulations, I initiated the implementation of a rent reasonableness policy and process. To support this effort, we entered into a contract with MRI to provide us with the rent reasonableness software. Last year we supplied MRI with the necessary property addresses and zip codes to begin the analysis. Due to the complexity of the implementation and the volume of data required, the setup process took time. We are now actively incorporating rent reasonableness determinations into all tenant files during annual recertifications and interims. With nearly 700 families in our program, this is an ongoing process, but significant progress has been made. Our team is fully committed to ensuring full compliance with HUD regulations, and we continue to work diligently toward that goal. In addition, to ensure continued compliance and to maintain the integrity of our files, the HCV Supervisor will be conducting weekly audits. This internal quality control measure helps us identify and address any inconsistencies or issues in a timely manner.

Condition: The Village did not have written policies for cash management or procurement that adhered to the requirements of the Code of Federal Regulations. Planned Corrective Action: The Village is currently reviewing existing policies to determine the best course of action and updating them for compliance. Some updates may require voter approval as certain provisions are in the Village Charter. Contact person responsible for corrective action: Penny Ray Anticipated Completion Date: 12/31/2026

Finding Number: 2025-001 Completion Date: 03/31/2025 Responsible Contact Person: Kami Greene, Director of Accounting and Controller Kristen Cope, Assistant Controller Corrective Action: The University enhanced its written procedures for requesting cash draws and further trained new staff on policies and procedures to ensure compliance. In addition, a review process has been established before each cash draw takes place to ensure that all cash draws are for expenses that were incurred to prevent funds from being overdrawn.

Criteria or Specific Requirement: Subparts D and E of 2 CFR Part 200 require a nonfederal entity to establish written policies, procedures, and standards of conduct, including procedures to implement the cash management requirements of 2 CFR section 200.305, procedures that comply with the procurement standards of 2 CFR sections 200.318 through 200.326, and procedures for determining the allowability of costs in accordance with Subpart E of 2 CFR Part 200. Specifically, 2 CFR sections 200.430, 200.431, and 200.475 require written policies concerning compensation for personal services, fringe benefits, and travel costs, respectively. Views from Responsible Officials: Management agrees with the finding. Management has established written policies and procedures after yearend that were the policies and procedures followed during the year under audit and meets the requirements of Subparts D and E of 2 CFR Part 200. Contact Person: John Jacques Date of Completion: November 14, 2025

Recommendation The Organization should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding No Action Taken A new federal cash draw down form has been created that will ensure all cash draw downs are reviewed and approved by the CEO. If there are any question regarding this plan, please e-mail Diane Manning at dvdlmanning@usmhs.org.

DEPARTMENT OF THE TREASURY CDFI Equitable Recovery Program (CDFI ERP) – Assistance Listing No. 21.033 Recommendation: The Credit Union did not maintain supporting records to demonstrate that interest earned on unused funds held in interest-bearing accounts was remitted to the federal government, as required by 2 C.F.R. § 200.305(b)(7). This deficiency appears to stem from a lack of formal procedures and oversight related to the handling of advance payments and interest earned on federal funds. To address this issue, we recommend that the Credit Union implement internal controls designed to ensure compliance with grant requirements, including procedures for tracking interest earned, verifying remittance to the federal government, and maintaining appropriate documentation to support these activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement grant compliance controls and maintain proper documentation. Name(s) of the contact person(s) responsible for corrective action: Cindy Lindsey, CEO Planned completion date for corrective action plan: December 2025