Corrective Action Plans

Provide all management staff with annual training on federal grant requirements, perform periodic internal reviews and a final year-end reconciliation, maintainall grant-related records on a shared organizational drive accessible to all responsible staff, provide formal onboarding and off boarding procedures for federal grant management, and update the Finance Manual .

Finding Number: 2025-002 Finding Title: Cash Collateralization (Repeat Finding 2024-004) Planned Corrective Action: Management acknowledges the finding regarding cash collateralization. As of September 30, 2025, the Coalition's cash deposits were pledged and collateralized. After year-end, management became aware that two affiliated financial institutions participating in the deposit sweep program had inadvertently assigned the same certificate numbers during the nightly sweep process. Consequently, a portion of the Coalition's deposits may have been swept into the same financial institution, resulting in balances that may have temporarily exceeded applicable FDIC insurance limits. Although this condition resulted from the financial institutions' sweep process rather than the Coalition's cash management practices, management recognizes its responsibility to monitor deposit coverage and ensure compliance. To address this finding, the Coalition will implement the following corrective actions: 1. Meet with representatives from both participating banks to discuss the issue and formally notify them of the audit finding. 2. Request written confirmation that the nightly sweep process has been reviewed and modified to prevent deposits from being placed with the same institution through duplicate certificate assignments or other system errors. This may happen from time-to-time but IntraFi corrects those deposits and reallocates them, It will be reviewed weekly to make sure they did reallocate those funds. 3. Communication with certain representatives within the financial institution will be contacted by NUHIC and will need to request that dollars are required to be transferred to IntraFi to remain in compliance of your audit before 2:30pm everyday. 4. Obtain and review periodic reports from the financial institutions identifying the banks holding swept deposits and the amount of funds placed with each institution. 5. Establish a weekly review process to monitor cash balances, FDIC insurance coverage, and collateralization to identify any exceptions on a timely basis. 6. Maintain documentation of all reviews, bank communications, and corrective actions as part of the Coalition's internal control procedures. 7. If the financial institutions cannot provide adequate assurance that deposits will remain fully insured or properly collateralized, the Coalition will evaluate alternative cash management options, including other insured cash sweep providers or collateralized deposit arrangements. Management believes these corrective actions will strengthen oversight of the Coalition's cash management process and reduce the risk of future noncompliance with FDIC insurance requirements. Responsible Official: Carlett Gregory Anticipated Completion Date: December 31, 2026

Condition: The Corporation’s cash management policies were not in conformance with Uniform Guidance requirements. Although cash management transactions tested were performed in accordance with existing practices, the Corporation did not have a written cash management policy that met Uniform Guidance requirements. Planned Corrective Action: The Corporation will implement and formally adopt written cash management policies and procedures that conform to Uniform Guidance requirements and should ensure those procedures are consistently followed and documented. Contact person responsible for corrective action: Michelle Toups and Brian Balutanski Anticipated Completion Date: 1/1/2027

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Ivy Melendez, Executive Director, will be responsible to implement this corrective action by September 30, 2026.

Finding Number: 2025-002 Planned Corrective Action: We concur with the finding. We will continue to monitor our federal grant cash requirements and seek additional cash flow when governmental environment changes. The Finance Administrator will continue to monitor cash flow requirements to mitigate cash advances to ensure timely federal grant cash remittance policies are being followed. Anticipated Completion Date: On-going Responsible Contact Person: Cynthia Diaz, Finance Administrator

DC Government Operations (DCGO) concurs with this finding and acknowledges the deficiencies identified during the audit period. The corrective action plan below assigns responsibility accordingly and includes a designated section for OCFO’s response. Condition 1 — DCGO will establish a formal monthly drawdown coordination meeting between the Grants Management Specialist and the OCFO to align on report readiness and submission timelines. DCGO will also update its grants reporting calendar to include monthly SF-270 submission deadlines with 30-day and 15-day advance triggers. The Grants Management Specialist will track submission status in real time and escalate to the CAO when deadlines are at risk. Condition 2 — DCGO will implement a monthly grant activity checklist requiring the Grants Management Specialist to confirm that all active awards, including the Facility Sustainment Restoration Modernization project, are represented in each drawdown cycle. Any award with no drawdown activity will require documented justification reviewed by the CAO before the cycle closes. Condition 3 — This condition is squarely within the DCGO lane, and we take full accountability. Effective immediately, the following controls will be implemented: The Grants Management Specialist will route every SF-270 through a documented approval workflow requiring CAO review and Director signature before submission. No SF-270 will be submitted to the GOR or USPFO without confirmed Director approval on record. Upon submission, the Grants Management Specialist will retain timestamped confirmation of submission, via DC Gov BOX, as permanent audit evidence in the grants compliance file. The DCGO SOP governing SF-270 preparation and routing will be updated to codify these steps no later than August 31, 2026. Condition 4 — DCGO will implement a pre-submission reconciliation checkpoint requiring the Grants Management Specialist to perform a line-by-line comparison between the billing authorization worksheet and the corresponding SF-270 before routing for Director approval. Any variance must be documented, explained, and resolved prior to submission. This reconciliation step will be captured as a required sign-off in the updated SOP. Condition 5 — DCGO will require that every SF-270 be traceable to an approved billing authorization worksheet before processing. The Grants Management Specialist will maintain a master award register cross-referencing all active grants against billing authorizations each cycle. Any SF-270 that cannot be matched to an authorized billing entry will be flagged and held pending resolution with Cooperative Agreement Program Manager (CAPM) and Director review. Condition 6 — DCGO will establish a cash receipt tracking log maintained by the Grants Management Specialist. Following each SF-270 submission, the GMS will monitor federal payment confirmation and document receipt in the log within 5 business days of funds being received. Unconfirmed receipts beyond 30 days of submission will be escalated to the CAO for follow-up with the GOR and USPFO.

Cash Management Moving to Work Demonstration Program AL No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of the 66 grant drawdowns during the year, 19 drawdowns were tested and it was noted that 1 of the drawdowns was made in advance of the supporting invoices being paid to the vendors and subsequently the invoices were not paid within three business days, as required. Auditor’s Recommendations: The Agency should continue to develop and implement internal controls over grant management to coordinate capital fund draws with the timing of invoice payments. Action Taken: Action Due Date Responsible Person This finding occurred prior to the staff receiving the results of the previous audit. There have been no additional invoice payments outside of the 3-day allowable time. Staff developed and implemented an internal tracking document to ensure payments are made within three days of the draw. Complete – May 2025 Accounting Technician, Kary Smith, Lauren Hodgens and Ryan Bates

Management acknowledges the importance of cash management policies with regards to reimbursable programs. Day Kimball Healthcare is committed to full compliance with federal cash management requirements and takes seriously its obligation to request reimbursement only after program expenditures have been both incurred and paid. During fiscal year 2025, the employee responsible for previous reporting of these expenses retired, and the job function of submission and review of this grant passed on to other individuals. Management recognizes that our existing review process did not include a sufficient control step to verify payment status prior to submission of reimbursement requests, and employees have now been trained on proper procedure, which includes confirmation of payment of expenses before submission is allowed. In addition, the reviewer is now aware of this requirement and confirmation of payment is now a part of this individual’s responsibilities as well. Going forward into fiscal year 2026 Management believes these controls will prevent similar findings from occurring. Sheena Farner, Director of Budget & Financial Reporting, will oversee this corrective action plan to be fully implemented by September 30, 2026.

Item 2025.003 - Cash Management Recommendation The Organization should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding Not a repeat finding. Action Taken The Health Center has engaged Cambire Consulting, a grant and contracts consulting firm. A drawdown policy will be established for the July 2026 Board Meeting for approval.

Non-compliance with Cash Management Requirements of the Capital Fund Program Corrective Action With the exception of Capital Fund Program grant authorizations budged for Public Housing Program operating assistance, the Authority will expend the unexpended Capital Fund Program grant proceeds held prior to drawing down additional funding from Capital Fund Program grants. Jebidiah Jackson, Executive Director, has assumed the responsibility of executing this corrective action as of August 1, 2026.

Agency personnel will ensure they are minimizing the time between the transfer of funds from the federal awarding agency and the disbursement of those funds.

Finding summary – The Organization’s internal controls over the cash drawdown process were not operating effectively to minimize the time elapsing between the transfer of funds to the Organization from the U.S. Treasury and the issuance of payments for program purposes to the Organization. Corrective Action Planned – Designated Crossing Healthcare staff will submit cash draw down requests no more than 5 business days prior to the anticipated pay date for the pay period claimed. Anticipated Completion Date – Completed 5/7/2026 Responsible Contact Person – Julie Brilley, CEO Management Response - Management concurs with the auditor's finding. The Organization acknowledges that the cash drawdown process was not operating effectively to minimize the time lapsing between the transfer of funds to the Organization from the U.S. Treasury and the issuance of payments for program purposes to the Organization. Management has developed a corrective action plan, including a dedicated schedule listing Organization pay periods, pay dates, appropriate fund draw dates, and funding draw amounts.

Finding 2025-002 Condition: During the auditors’ walkthroughs of the cash draw process, the Organization appeared to drawdown on federal funding before incurring related expenses. Corrective action plan: Management agrees with the recommendation and has established a written policy and implemented a documented process for the preparation and review of federal drawdowns, including clear evidence of review such as signoffs or electronic approvals. Responsible Individual: Etleva Bejko, Executive Director Planned Completion date: 05/22/2026

2025-002 Cash Management Corrective action planned: Management will implement controls over all draws from the Payment Management System to minimize the time elapsed between the drawdown of funds from PMS and the payment for expenditures. The controls will incorporate the following: Prepare a detailed listing of expenditures claimed for reimbursement for each drawdown request. The expenditures listing will be reviewed by appropriate personnel to ensure cash payments for the expenditure are made before the date of the draw or within a reasonable time after the draw. Drawdowns are authorized and approved by the appropriate personnel before the drawdown is made and will be tracked and summarized in a ledger. Anticipated completion date: June 2026 Contact person responsible for corrective action: Harjeet Sidhu, Chief Financial Officer

Finding Number: 2025-001 Condition: The City did not have established written cash management procedures for processing of federal payments. Planned Corrective Action: Develop and implement written Cash Managament Procedure for processing federal payments Contact person responsible for corrective action: Benjamin Grier Anticipated Completion Date: 05/22/2026

VILLAGE OF BELLEVUE 201 N. Main St. Bellevue, MI 49021 269-763-9571 • Fax 269-763-9998 manager@bellevuemi.net • www.bellevuemi.net treasurer@bellevuemi.net 69 CORRECTIVE ACTION PLAN Certain matters were brought to our attention as a result of the audit process. These are described more fully in the Schedule of Findings and Questioned Costs. We evaluated the matters as noted below and have described our planned actions as a result. 2025-001 MATERIAL JOURNAL ENTRIES PROPOSED BY AUDITORS Views of Responsible Officials: Management agrees with the finding and will take appropriate steps to remedy noted finding. Corrective action plan response: The Village will take steps to ensure that material journal entries are not necessary at the time future audit analysis is performed. Responsible Party: Nicole Roberts (Village Manager) and Michelle Pennington (Assistant Village Manager). Date of Planned Corrective Action: December 31, 2026 2025-002 SEGREGATION OF DUTIES OVER KEY FINANCIAL PROCESSES Views of Responsible Officials: Management agrees with the finding and has taken appropriate action to remedy the bank reconciliation portion of the finding during fiscal year 2025. Corrective action plan response: The Village will take steps to actively seek ways to strengthen its internal control structure. This may include requiring as much independent review, reconciliation, and approval of journal entries and bank reconciliations by qualified members of management and documenting such review as part of the Village’s control procedures. Responsible Party: Nicole Roberts (Village Manager) and Michelle Pennington (Assistant Village Manager). Date of Planned Corrective Action: December 31, 2026 2025-003 BANK RECONCILIATIONS Views of Responsible Officials: Management agrees with the finding and will take appropriate steps to remedy noted finding. Corrective action plan response: The Village will take steps to ensure that bank reconciliations are documented as reviewed and reconciliating items are properly documented. Responsible Party: Nicole Roberts (Village Manager) and Michelle Pennington (Assistant Village Manager). Date of Planned Corrective Action: December 31, 2026

Personnel Responsible for Corrective Action: Karla Clubine, Chief Executive Officer, David Cichocki, Chief Financial Officer Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Planned Corrective Action: Management accepts the recommendation. The Hospital will strengthen its federal grant cash management procedures and will perform and document cost verification prior to all federal grant drawdowns beginning in fiscal year 2026.

Significant Deficiency, Nonmaterial Non-Compliance Finding 2025-005: Name of Contact Person: Bill Bradley The Town did not have a system of internal controls in place to ensure cash management compliance requirements were met. Auditor’s review indicated that a reimbursement request #4 was drawn and received in August yet the Town did not disburse the funds, until September. Therefore, the monies were not paid to the vendor within the three (3) day required compliance period. Corrective Action: With the new Town Manager and Finance Director the Town fully expects to comply with the three (3) day compliance requirement Proposed Completion Date: Immediately.

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