Corrective Action Plans

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

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

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

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

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

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

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

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

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

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

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

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

Department: Health and Human Services Title: Internal control over CCDF subrecipient cash management needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Department is in compliance with the requirement for minimizing the time between payments to our subrecipients and the disbursement of the funds. Payments are made as close as is administratively feasible. The Compliance Supplement suggested audit procedures for Cash Management for pass-through entities refers to 200.305(b)(1) ... that same paragraph states that the timing and amount of advance payments must be as close as is administratively feasible. Completion Date: N/A Agency Contact: Tara Williams, Associate Director of Early Care & Education, DHHS, 207-557-2342

Department: Health and Human Services Title: Internal control over PDG subrecipient cash management needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Department is in compliance with the requirement for minimizing the time between payments to our subrecipients and the disbursement of the funds. Payments are made as close as is administratively feasible. The Compliance Supplement suggested audit procedures for Cash Management for pass-through entities refers to 200.305(b)(1) ... that same paragraph states that the timing and amount of advance payments must be as close as is administratively feasible. Completion Date: N/A Agency Contact: Tara Williams, Associate Director of Early Care & Education, DHHS, 207-557-2342

Department: Health and Human Services Title: Internal control over Health Disparities program subrecipient cash management needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Department is in compliance with the requirement for minimizing the time between payments to our subrecipients and the disbursement of the funds. Payments are made as close as is administratively feasible. The Compliance Supplement suggested audit procedures for Cash Management for pass-through entities refers to 200.305(b)(1) ... that same paragraph states that the timing and amount of advance payments must be as close as is administratively feasible. Completion Date: N/A Agency Contact: Eden Hale, Associate Director, Division of Population Health Equity, Maine CDC, 207-441-1090

Finding 2025-700: Dairy Business Innovation Initiatives—Cash Management Planned Corrective Action: To comply with federal cash management requirements, Research and Sponsored Programs (RSP) revised all contracts with WCMA to be standard cost-reimbursement only agreements. RSP developed a cash management guidance that specifies the circumstance and requisites in which a cash advance may be suitable with department and RSP Director approval. The guidance has been shared with pre- and post- award RSP staff. Anticipated Completion Date: April 1, 2026 Person responsible for corrective action: Liz Bevins-Smith, Director of Research Financial Services Research and Sponsored Programs bivinssmith@rsp.wisc.edu

Finding Reference: 2025-005 - Cash Management (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director - Student Financial Services & Scholarships (Letherio.h.zeigler@jsums.edu) Corrective Action Planned: During the 2024-2025 award year, there was a change in leadership within the financial aid department near the end of 2024 that disrupted the normal process of reconciliation of funds to be disbursed which caused the delayed drawdowns that were outside the scope of compliance regarding allocation of funds towards student accounts. The Executive has developed a timely process of reconciliation that is in line with federal regulations to ensure that funds will drawdown timely as well as the institution has gone voluntarily to a system with COD in which drawdowns will not occur until COD receives approved response files for Federal Pell grant and Student Loans to ensure there is no delay in drawdowns. Estimated Completion Date: August 1, 2026 Finding Reference: 2025-005 - Cash Management (USM) Responsible Official: Erica Kennedy, Associate Vice President for Research (Erica.kennedy@usm.edu) Corrective Action Planned: USM acknowledges the finding related to cash management timing requirements under 2 CFR §200.305(b). To address the root cause and ensure ongoing compliance, USM will implement the following corrective actions: 1.Maintain standard monthly draw schedule. a.USM has returned to the standard monthly draw schedule, which aligns with the institutional accounting close timeline and supports accurate, reconciled requests. b.This schedule is now designated as the required default for all TRIO drawdowns, and deviations will not be permitted except in documented emergency situations approved at the VP level. 2.Reinforce internal controls linked to monthly draws. a.Existing internal controls, including pre-draw reconciliation, multi-level review, and validation of current/month expenditures, remain in place and are explicitly tied to the monthly schedule. b.Any proposed changes to the draw frequency must undergo formal written approval, including documentation explaining the reason for change and a review of associated compliance risks. 3.Monitoring a.For the next two quarters, the AVPR will conduct spot checks to confirm continued adherence to the monthly schedule and compliance with standard reconciliation procedures. Estimated Completion Date: Corrective actions are completed. The standard monthly draw process was reinstated and fully implemented, effective April 2025.

FINDING 2025-008 Finding Subject: COVID-19 - Education Stabilization Fund – Condition of Records Federal Agency: Department of Education Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls will be put in place to ensure all COVID 19 ESSER Funds are reported accurately to the State and Federal Department of Education. Reimbursements will be attached to State Email for disbursement. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

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