Corrective Action Plans

4. SCMRC will continue to require documented CEO approval on all federal drawdown submissions to ensure sustained internal control.

Condition: During our testing, we identified one reimbursement request that included a check that was not paid as it was voided and paid with a subsequent check, which was also requested for reimbursement. Planned Corrective Action: Effective 6/1/2025, TARTA implemented a new ERP system that will allow us to electronically control, accumulated, and monitor all transaction related to our grant draws in accordance with 2 CFR 200.305 going forward. Contact person responsible for corrective action: James Karasek Anticipated Completion Date: 6/1/2025

Condition: The Organization did not have the appropriate controls in place over FFATA reporting and did not file the required reports. Further, while the Organization had written procedures over cash management, they were outdated and did not reflect the current staffing model. Planned Corrective Action: Reporting was completed in SAM.gov in May 2025 for subrecipient subaward amount based on the award period running from calendar periods of July to June. Written internal MMTC procedures regarding cash management will be updated and will include the current staff. Contact person responsible for corrective action: Alan Kowalewski Anticipated Completion Date: 10/31/2025

Noncompliance with Cash Management (Public Housing Capital Fund CFDA 14.872) We will implement controls to ensure all future eligible Capital Fund draws are made within 3 business days of expenditures. Date of completion: July 8, 2025

Finding No. 2024-002 - Cash Management – Noncompliance and Internal Control (Significant Deficiency) Corrective Action Plan: We recognize the auditor’s finding regarding our cash management because we were not fully aware of the requirement to use interest-bearing accounts for advanced federal funds. This was unintentional and we acknowledge the gap in the cash management compliance process for federal grants. 1) We will update our grant cash management policy to ensure all advance payments from federal or similar grants are placed in interest-bearing accounts where applicable. 2) We will have separate interest-bearing accounts established for any federal grant advances with this requirement. 3) Staff will be trained on federal grant cash management 4) Remittance of interest earned over $500 per year to the federal government 5) On-going quarterly reviews of all federal grant accounts will be conducted to ensure compliance with interest-bearing requirements. Management is committed to full compliance with federal grant requirements and has taken steps to ensure this issue does not recur. Anticipated Completion Date: 1) Renaissance booked a payable to the federal government of $48,248 on 12/31/24 financials for the interest. The interest was paid to the federal government on 9/12/2025 regarding the Federal CDFI grant contracts. 2) Federal grants to be held in interest bearing accounts will be completed by Sept 30, 2025 3) Staff will be trained on federal grant cash management to be completed by Sept 30, 2025 4) Grant cash management policy update to be completed by Oct 31, 2025 5) On- going quarterly reviews of all federal grant accounts will be conducted to ensure compliance with interest-bearing requirements. The interest earned over $500 will be remitted to federal government each year before the organization’s fiscal year end. Person(s) Responsible for Corrective Action: Jessie Lee, Renaissance Managing Director, 212-964-6022

The Company acknowledges non-compliance with 2 CFR § 200.305 that the entity must minimize the time elapsing between the transfer of funds from the U.S. Treasury or the pass-through entity and the disbursement of funds by the recipient or subrecipient. However, the questioned costs that were transferred in advance were ultimately deemed reasonable because they were disbursed during the grant period for allowable costs as part of the federal contract awarded. The Company will ensure a proper understanding of the compliance requirements for all federal contracts prior to requesting funds and will ensure funds transferred are compliant with the requirement that the Company minimize the time elapsed from the time of transfer and the disbursement of funds in accordance with the grant terms. Contact Person Michael Davis, Chief Financial Officer of Southern Regional Hospital Expected completion date: This will be implemented on new federal contracts awarded subsequent to August 28, 2025.

The Board of Health will adopt updated written policies periodically in accordance with the Uniform Guidance to help improve internal controls over federal compliance for the findings listed in this number.

Changes to the submittal process implemented by OTDA also delayed HSNY’s ability to submit claims for approval. This had a detrimental impact to cash flow as operating costs needed to be paid during this period. With the approval of the contract and efforts being made at OTDA to expedite payment, HSNY’s cash flow position has since improved and reimbursements to subcontractors as of the audit date are being made timely.

Finding 2024-004: Written Policies and Procedures • Planned Corrective Action: We will adopt formal policies and procedures that document our current practices and also meet the requirements of the Code of Federal Regulations (CFR). • Anticipated Completion Date: September 30, 2025. • Responsible Contact Person: Rick Smith, Executive Director

Finding 2024.003 – Cash Management Recommendation The Center should develop written procedures to review all drawdowns that occur to ensure accuracy. Not a repeat finding. Action Taken Since September 2023, the Center has implemented weekly grants management reviews with the grants team and key executives. Action items are tracked through meeting agendas, minutes, and NMH’s project management platform, Monday.com. Meetings include invoice approvals for grant-funded expenditures, and review of allocations, payroll dates, and stipends for drawing down calculations. The meetings going forward will document the amounts for federal grants drawdowns and will be logged within Monday.com and through an external verification spreadsheet. Starting May 2025, an updated verification spreadsheet along with an itemized attestation was implemented.

County department personnel changes have been implemented, which address this deficiency. Additional training from the Auditor’s Office and state grantors has occurred for newer staff in certain departments with large amounts of federal and state awards.

Implementation of plan of action - Management will review its internal controls and policies and procedures to ensure that requests for reimbursement are for appropriate program expenditures. Implementation date - Anticipated completion August 28, 2025. Persons responsible for the implementation - The Board of Directors and Head of School.

In Finding 2024-007, a condition was noted in which the Organization did not maintain proper documentation of qualifying expenditures prior to making drawdowns of federal funds. Management recognizes the importance of complying with federal cash management guidelines. In response to Finding 2024-007, procedures will be implemented to ensure that federal grant expenditures are documented prior to drawdowns of federal funds so that advance draws of federal funds do not occur.

Effect: The federal awarding agency did not receive interest that could have been earned on the advances. All advances received during 2024 were expended by December 31, 2024. There was no loss from uninsured funds or from lack of segregating funds into separate accounts. Recommendation: The auditor recommends that the Organization implement policies and procedures to ensure that all advance payments are deposited into separate, insured, interest-bearing accounts as required. The grantee should also establish controls to track interest earned on these accounts and remit amounts due to the federal awarding agencies in a timely manner. Training should be provided to staff responsible for cash management to ensure ongoing compliance with federal requirements. 1. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit findings. 2. Action Planned in Response to Finding: The Organization has implemented procedures to deposit the advance funds into separate, insured, interest-bearing accounts as required. The Organization has also established controls to track interest earned on the accounts and credit the interest back to the grant. 3. Official Responsible for Ensuring CAP: Kari Jo Lawrence, Chief Executive Officer and Jernon Kelly, Chief Financial Officer are responsible for ensuring corrective action of this deficiency. 4. Planned Completion Date for CAP: December 31, 2025.

Finding 2024-001: Federal Transit Cluster – Cash Management/Financial Management and Capacity (Noncompliance and Significant Deficiency in Internal Control) Condition: TANK staff drew down federal funds in advance of allowable expenditures and did not disburse the federal funds within the required three business days. Corrective Action: TANK has worked with the FTA to address this finding. We have developed procedures for: adherence to federal regulations related to federal grants management, training of all staff involved in the management of federal grants, and identifying back-ups who are trained/educated on doing this work. The procedures include explicit instruction on federal drawdown procedures and timelines, ECHO Reimbursement procedures, cash management of federal funds and training plans/compliance associated with these drawdowns. The procedures have been accepted by the FTA and are now active. Repayment was made to the grant in May 2025 and no penalties were assessed. Responsible Party: Sutton Rowley, FP&A Manager Anticipated Completion Date: Complete and finding was closed on March 24, 2025.

Finding 2024-005 – Lack of Written Policies Required by the Uniform Grant Guidance Contact Person: Nicole Roberts, Village Manager Planned Corrective Action: The Village will develop and adopt written policies and procedures to comply with Uniform Guidance requirements, including internal controls, procurement, cash management, and allowable costs. Anticipated Completion Date: December 31, 2026

Action Taken: Management agrees with the finding noted above. Management will also note that as a repeated finding we do not so much offer a corrective action plan as we do a summarization of steps already taken to close this finding for fiscal 2025. A new and highly qualified Chief Financial Officer with over 30 years of public housing experience was hired by the agency in April of 2024. The CFO has fully staffed the department with competent and qualified individuals including a new and fully qualified Controller and Director of Finance. All individuals hired have received targeted training from both internal and external sources. In June 2024 the new financial management team implemented a policy/procedure for the records requirement and payment timeframes for all capital fund draw downs. This policy requires the hand signing of eLOCCS forms and reconciliation of individual draws at the time of drawdown. During fiscal 2025 the entire Finance staff was trained extensively on all matters related to HUD accounting. Specific training was directed to the Capital Fund program, its eligibility standards, accounting processes, and drawdown procedures. This training was conducted by a nationally recognized HUD-specific trainer. The Authority has hired a qualified, experienced internal auditor. The internal auditor has completed a 100% testing sample on capital fund draws made in fiscal 2025. His observations were rectified, and the policy revised where needed. The sampling assured that supporting documentation was sufficient for audit, that it matched the amounts drawn, and that invoices were paid within HUD dictate s timeframes. Management feels that with this policy and enhanced testing in place the finding will not be repeated in 2025. Management expects closure of this finding, under the direction of the Chief Financial Officer, for the Fiscal 2025 audit.

Correction action • Finance team is in the process of implementing a new financial accounting (Grants Management System, Sage) system to ensure that coding for grants are accurately tracked. Internal reports will be built to provide monthly analysis of individual grants. Finance will work with program staff to ensure timely and accurate budget to actuals review and reconciliations. • Finance will contact Grant Manager responsible for each grant to develop plan of action for returning any overdrawn funds. Responsible Person • Associate Director - Finance Anticipated completion date • September 30, 2025

Correction action • Finance will work HR and Program staff to document written procedures for staffing allocations. • Finance will strengthen monthly project monitoring of project activity and also ensure that budget changes, if necessary, are approved by the Grants Manager. • Drawdown process is being revised to ensure that the general ledger activity, pending draw request, and vendor payables are all in sync. • Finance will contact Grant Manager responsible for each grant to develop plan of action for returning any overdrawn funds. Responsible Person • Associate Director - Finance Anticipated completion date • September 30, 2025

Recommendation: We recommend management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented with supporting documentation retained for the revised internal control. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: TCA will have a Grant/Staff Account or designee prepare documentation for the drawdowns. The CEO or designee will approve drawdown documents. CFO/Controller or designee will process the drawdown and take a screenshot when completed. All approvals will be shown on the excel sheet with the drawdown information. Name(s) of the contact person(s) responsible for corrective action: Jeremy Runde, Controller Planned completion date for corrective action plan: June 2025

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will ensure that all reimbursable costs are submitted for reimbursement in a timely manner. The Group has significant experience in submitting for reimbursement for federal, state, and similar types of grants and contracts.

Finding: 2024-081 - Fifteen of the sampled 40 subrecipient draws, on reimbursement basis, were paid to the subrecipients beyond 30 days of when the University received the payment request. Questioned Costs: None Assistance Listing Number: 81.049, 12.000, 43.001, 11.417 Assistance Listing Title: 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): The Associate Vice Chancellor (AVC) for Financial & Business is working with the Office of Finance & Accounting to establish a procedure for follow up on all invoices sent to the departments to ensure timely payment. Also the departments will develop a procedure to ensure that appropriate delegations are in place in case a PI is unavailable when an invoice is received. Completion Date (list anticipated completion date): June 2025 Agency Contact (name of person responsible for corrective action): Amanda Wall, AVC Financial Services 907-474-7552

Finding 2024-004 – Cash Collateralization (Repeat Finding 2023-003) Condition: During our review of the Coalition’s cash, it was noted that as of September 30, 2024, they have. not collateralized cash balances more than the amounts insured by the Federal Despot Insurance Corporation. Cash balances of $7,596,383 were uninsured at September 30, 2024. Unearned revenue was reported at approximately $4,434,584 which includes advance payments of Federal Funds. Corrective Action Plan – Finding 2024-004 Corrective Action: In response to the finding regarding the lack of collateralization for cash balances exceeding the amounts insured by the Federal Deposit Insurance Corporation (FDIC), the Nebraska Urban Indian Health Coalition (NUIHC) acknowledges that corrective actions were initially delayed due to the illness and eventual retirement of the former CEO. However, under new leadership, these actions have since been fully implemented. As of April 2025, NUIHC is in full compliance with the cash collateralization requirements outlined in 2 CFR §200.305(b)(7). A formal cash collateralization agreement has been executed with our financial institutions, ensuring that all cash balances—including advanced federal funds—are now either insured or properly collateralized. In addition to entering into this agreement, the following measures are in the process to strengthen ongoing compliance: 1. Updated Cash Management Policies: Policies are being reviewed and revised to reflect current federal requirements and internal procedures regarding custodial credit risk and cash handling practices. 2. Monitoring and Compliance Controls: A monitoring system is in place to routinely review cash balances and coordinate with our financial institution to ensure all funds remain protected. 3. Staff Training: Targeted training was provided to financial and accounting staff to ensure continued understanding of cash collateralization requirements and the importance of ongoing compliance. Implementation Summary: • Cash Collateralization Agreement: Completed – April 2025 • Policy Revisions and Monitoring System: In process– July 2025 • Staff Training: Completed by – August 2025 Responsible Party: Chief Financial Officer, Carlett Gregory

Action: Set Fridays as a standard recurring day to pay invoices. Date completed: May 2025 Responsible Person: Accounting Technician, Kary Smith Action: Set Monday as the day to make capital grant drawdowns. HUD deposits the draws via ACH on Wednesdays. The PHA releases the payment on Friday Date completed: May 2025 Responsible Person: Senior Accounting Technician, Stacy Verrinder Action: At the time of the request for capital grant transfers from the Moving to Work account to the operating account, include the Accounts Payable tech in the email distribution and include information about which invoice A/P must pay by Friday Date completed: May 2025 Responsible Person: Senior Accounting Technician, Stacy Verrinder

Mov ing to Work Demonstra tion Program - Capital Fund ProgramALN: 14.881 Description: During testing of the Mov ing to Work Demonstration Program - Capital Fund Progra m, we selected a sample of eight elOCCS drawdown vouchers for rev iew. Of these, the Authority was unable to provide sufficient supporting documentation to substantia te the eligibility, timing, or purpose of the draw d owns for four v ouchers. For another v oucher, the Authority could only partially support the a mount dra wn. These issues reflect a lack of a dequate documentation necessary to substantiate the allowability and propriety of the expenditure charged to the CFP grants. Planned Corrective Action: Fiscal Year 2024 was a year marked by personnel turnover in key administrative, accounting, and human resources positions. The Authority will work to implement a process to ensure that every drawdown request is accompanied by the required supporting documentation. In addition, the supporting documentation will be reviewed to ensure that it meets eligibility and "just-in-time" requirements prior to the Executive Director signing the request.