Corrective Action Plans

Finding number 2025-003: Material weakness in cash management of advance payment. The council drew down a portion of the federal award amount in advance of immediate cash needs. The draw occurred in March 2025 after management determined that a potential federal funding freeze could significantly delay the project if funds were not immediately accessible. The council typically limits drawdowns to requests for reimbursements; however, management elected to deviate from this practice due to the perceived risk. In addition, the council does not currently have a written cash management policy compliant with 2 CFR 200, which contributed to the inconsistency. The funds were fully expended on allowable program costs over a nine-month period. The funds were not kept in an interest-bearing account in accordance with 2 CFR 200.305(b). Questioned costs: none. Contact Person(s): Brian Barr, Executive Director Explanation and specific reasons for disagreement with audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: The Rogue River Watershed Council will develop a cash management policy in compliance with 2 CFR 200 (or amend our Fiscal Management Policy to include required cash management policies and procedures). The policy/ amendment will focus on short-term cash flow needs and the need to minimize time between the transfer and disbursement of federal funds, which will guide the organization’s use of federal funding. Anticipated completion date: Rogue River Watershed Council will have a cash management policy/ updated Fiscal Management Policy in place no later than 7/31/2026.

Finding 2025-002 – Cash Management (Reimbursement Request Error) Significant Deficiency in Internal Control Over Compliance and Noncompliance Corrective Action Plan: The Town will strengthen internal controls over reimbursement requests by implementing a reconciliation process between requested amounts and supporting documentation prior to submission. A secondary review and approval will be required for all reimbursement requests. Responsible Official: Clerk/Treasurer Mayor Planned Completion Date: May 2026

FINDING 2025-018 Name of Responsible Individual: Director of Post Award Compliance and Training Budget Analyst Corrective Action: The University receives advance payments from the sponsor, with the amount determined by the sponsor and adjusted as financial reports are submitted by the University. In response to the auditor’s recommendation to strengthen internal controls, Howard University will implement procedures to document and reconcile all cash payments received from sponsors on a quarterly basis to actual expenses incurred. This reconciliation process will help ensure that sponsor payments are fully accounted for and appropriately matched to related expenditures, thereby enabling the University to clearly demonstrate which expenses have been reconciled to payments received. Anticipated Completion Date: June 30, 2026

FINDING 2025-015 Name of Responsible Individual: Assistant Vice President of Procurement Director of Post Award Compliance and Training Corrective Action: In response to the auditor’s recommendation to enhance internal controls and ensure timely review of invoice protocols and subrecipient monitoring, Howard University is implementing the following: • The University is currently piloting a new Supplier Invoice Portal, launched jointly by the Sponsored Programs Office and the Office of Procurement, to improve invoicing efficiency and compliance. Under this new process, subrecipients will be required to submit invoices electronically in accordance with the terms and conditions of their subawards. The portal will support a streamlined review and approval process, with invoices routed through an automated workflow to ensure timely review and disbursement. • To support completion of the University’s annual audit verification requirements for subrecipients, oversight will occur at multiple stages throughout the subaward lifecycle. This includes reviewing audit reports at the proposal development stage, during which subrecipients are required to complete a Subrecipient Commitment Form (implemented September 2025) prior to proposal submission. • At the award stage, refreshed due diligence will be conducted, including a re-review of the subrecipient’s Single Audit and/or financial statements. Finally, the Post Award Compliance team will perform an annual review of subrecipients’ audit reports and complete audit follow up procedures as necessary. Anticipated Completion Date: August 30, 2026

2025-003-Significant Advance Drawdown on Federal Fund for Six Months, United States Department of Health and Human Services, Native Hawaiian Health Care Systems 93.932, On January 20, 2025, we received the first Executive Order from President Trump, placing a hold on federal funding. We were advised that the PMS (Payment Management System) would be down and drawdowns would not be available until further notice. From January 20th, 2025, we tried to complete a drawdown, and the PMS system was not available. On January 28, 2025, finally accessing the PMS system, we estimated our January expenses and completed a drawdown for $200,000. At the time, we needed the HRSA funding to cover January costs already spent. Due to the uncertainty of the HRSA funding availability, and when the PMS system would be available, we estimated another drawdown the following day, to cover at least 2 more months of HRSA expenses. The other Native Hawaiian Health Systems could not access the PMS system, which prompted us to complete another drawdown to cover HRSA expenses for the remainder of the fiscal year. We were able to expend all HRSA funding that was drawn down by fiscal year ending July 31, 2025.

Name of Contract Person: Renee Dunn, Interim Chief Financial Officer Corrective Action: The Board will implement appropriately designated internal controls to ensure that sales tax refunds are accurately identified and remitted to the respective program that incurred the original expenditure. Proposed Completion Date: The Board will implement the above procedure immediately.

Person responsible for the corrective action: Jim Larson-Shidler, Interim Superintendent/CFO and Cindy Szuminski, Finance Manager Corrective action planned: Actions taken to avoid future late claims include: • The district has added another authorized Level 3 person who can approve meal reimbursement requests in July 2025. This provides the district a backup approver if one is not available. • A recurring monthly task reminding authorized Level 3 approvers to certify the SNP claim has been set up in our Outlook calendars. Anticipated completion date: July 16, 2025

Finding: 2025-079 - The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned Costs: None Assistance Listing Number: 10.237, 15.423, 47.050, 47.074, 47.078 Assistance Listing Title: From Learning to Leading: Cultivating the Next Generation of Diverse Food and Agriculture Professionals Research and Development Cluster (RDC) Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding. Corrective Action (corrective action planned): UAF Office of Finance & Accounting has established procedures to communicate with the departments to ensure outstanding invoices are resolved promptly. Additionally, guidance has been developed and distributed to Principal Investigator to ensure proper delegation of authority when they are unable to sign off on invoices. Completion Date (list anticipated completion date~: Completed Agency Contact (name of person responsible for corrective action): Amanda Wall, Associate Vice Chancellor (AVC), UAF Financial Services, 907-474-7552

The University will strengthen its cash management procedures to ensure that federal funds requests (drawdowns) are limited to immediate cash needs and that funds are disbursed within required timeframes. Enhancements will be made to the existing reconciliation process to ensure it provides sufficient detail to accurately link drawdowns to the corresponding disbursements and payroll charges, supported by adequate documentation. Additionally, Pre‑ and post‑disbursement reviews will be implemented to verify timing, accuracy, allowability, and prevent duplicate requests. Policies and procedures will be reinforced, and internal controls strengthened through segregation of duties, supervisory review, and documented approval processes. All records will be centrally maintained, and staff will receive targeted training to ensure consistent compliance. Furthermore, the University will also implement ongoing monitoring and periodic internal reviews to promote sustained compliance and address repeat findings. All corrective actions will be implemented within 30–60 days.

The District has implemented an internal control process that requires the review and approval of detailed expenditure reports and G5 drawdown amounts prior to submission. The review process includes the Director of the Magnet Program, Finance Coordinator, Executive Director of School Leadership, and the Business Manager to ensure accuracy, compliance, and proper authorization before completion.

2025-005 – Noncompliance and Deficiency in Internal Control over Cash Management Corrective Action: The District will implement a documented review and approval process for each Federal reimbursement request prior to submission, including verification of calculations, agreement to supporting documentation, and allowability within the reimbursement period. The reimbursement package, review documentation, and approval will be retained in accordance with the District’s records retention policy for each applicable grant award. Management will not submit reimbursement requests until the documented review is complete and any identified discrepancies are resolved. Responsible Officials: Fire Chief Gerard Tarleton Anticipated Completion Date: September 2026

Management acknowledges the finding related to cash management requirements and the timing of federal fund draws and disbursements. While the University maintains a robust, multi-layered review process, enhancements are necessary to ensure full alignment with federal requirements regarding the minimization of time between the receipt and disbursement of funds. The University currently utilizes several internal controls, including: • A two-person pre-draw validation process to ensure draws align with liquidated expenses • Programmatic oversight through detailed fiscal year draw reports and reconciliation to G5 activity • Periodic fiscal year and program year reviews to identify and correct discrepancies These controls enabled the University to identify and correct the instances noted in the audit. However, management recognizes that refinements are needed to further align the timing of draws with actual cash disbursement activity. To address this, the University will implement the following corrective actions: 1. Refinement of Draw Timing – Draw requests will be more closely aligned with immediate cash needs and anticipated disbursement activity. 2. Enhanced Pre-Draw Reconciliation – In addition to existing controls, a real-time reconciliation of outstanding obligations and pending disbursements will be required prior to each draw to ensure alignment with cash needs. 3. Standardized Draw Calendar Adjustments – The University will evaluate and adjust its draw schedule, where necessary, to better align with actual disbursement cycles, including payroll and purchase card activity. 4. Formalized Monitoring and Documentation – Documentation will be maintained to support the relationship between drawdowns and disbursements, and periodic internal reviews will be conducted to ensure ongoing compliance. 5. Training and Communication – Additional guidance will be provided to program and fiscal staff regarding federal cash management requirements and expectations for timing of draws. Management believes these enhancements, in combination with existing internal controls, will ensure compliance with federal cash management requirements and prevent recurrence of this issue. Implementation Date: July 1, 2025 Responsible Party: James Altman (Director of Finance) in coordination with Darla Ellett (Trio Director) and Teriki Barnes (Trio Director)

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.