Corrective Action Plans

Management will implement standardized cash drawdown procedures to ensure federal funds are requested only for immediate cash needs in accordance with Uniform Guidance. A consistent drawdown calculation template will be used, supported by incurred and allowable expenditures. Monthly reconciliations of drawdowns to actual expenses will be performed, and staff involved in federal fund management will receive training on federal cash management requirements.

Recommendation We recommend the College establish the required written procedures for federal monies and have them available to all personnel who work with federal programs Management Response Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on August 8, 2025 - over two years after the end of the June 30, 2023 fiscal year audit), the College did not have the opportunity to review and begin a timely process of addressing a majority of the audit findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the June 30, 2023 audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Corrective Action Taken / Planned: Policy Development • The institution will develop comprehensive written policies and procedures to address compliance requirements related to 2 CFR 200, Subparts D and E of the Uniform Guidance and approved by institutional leadership by July 31, 2025. Policy Review and Approval • Draft policies will be reviewed by VP of Business and Finance and approved by institutional leadership by August 31, 2025. Training • Relevant personnel will be trained on the new policies and procedures to ensure consistent understanding and compliance. Implementation • The institution will fully implement the new procedures by August 31, 2025, and will ensure all departments involved with federal awards are following them. Ongoing Review: • Policies and procedures will be reviewed annually, and updates will be made as necessary to ensure continued compliance with federal regulations. Date of Completion: August 31, 2025 Responsible Parties Vice President for Business and Finance (or appropriate official), Dean of Business and Finance, Director of Finance, Restricted Funds Manager

The Organization hired a new grant and partnership specialist. This specialist reviews all draws to ensure that the draw is for reimbursement for actual expenditure and not estimated expenditure. Reports and draws are also reviewed by the vice president of finance.

View of Responsible Officials: ICMEC discovered an error during FY2024 that resulted in overdraws for their Federal awards as well as drawing expenses from one award that should have been drawn under a different award. After meeting with the funder, ICMEC began to reduce its draws to reduce the overdraw balance. Additionally, ICMEC has received a modification and extension to one of its grants that allows for retroactive indirect and salary costs. As of 8/31/25, the net balance of all JTIP grants combined is close to zero. We are working to correct the individual balances.

The department will adopt written policies with the Uniform Guidance for federally funded grant programs accepted by the department.

Uniform Guidance Corrective Action Plan Management acknowledges that improvements were necessary in assuring that drawdowns of grant funds are in compliance with regulations. Accordingly, drawdowns of grant funds will be more aligned with bi-weekly and/or monthly expenditures as supported by an analysis of payroll and accounts payable system activity by the Chief Financial Officer prior to authorizing any drawdowns. Additionally, requests for drawdowns will be reviewed by a member of the Finance Team to assure that it is within acceptable parameters related to grant spending. This process revision will be implemented no later than March 31, 2026.

FINDING 2024-007 Finding Subject: Special Education Cluster (IDEA) - Cash Management Contact Person Responsible for Corrective Action: Susie Swango, Director of Special Education Contact Phone Number and Email Address: swangos@nlcs.k12.in.us (812) 277-3220 ext. 16243 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business office has worked with the Director of Special Education to create a system of internal control and review where after each month is reconciled and closed the Director of Special Education reviews the program expenditures ensuring they are correctly posted prior to filing for reimbursements. The Business Office will then notify the Director of Special Education when reimbursements for their funds are received and the Director can check that the deposit has been posted correctly. Proper expenditure and receipt documentation will be kept on hand for each reimbursement submitted. Anticipated Completion Date: June 30, 2026

Federal Agency: Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing No.: 84.425 Recommendation: The University should revise its cash management procedures to ensure that HEERF drawdowns are based on actual, immediate cash needs rather than anticipated expenditures. Draw requests should be timed as closely as administratively feasible to the disbursement of funds for allowable program costs. Additionally, management should implement monitoring controls to prevent excess cash accumulation and ensure compliance with 2 CFR 200.305 and HEERF guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University finished issuing student disbursements on 7/8/24. This expended all remaining HEERF monies. This account has ended and has been closed out. Name(s) of the contact person(s) responsible for corrective action: Dorothy Daley, Director of Sponsored Projects Planned completion date for corrective action plan: Complete

Corrective Action Plan – Section III: Cash Management Condition: Two instances were identified where advance funds were not disbursed within a reasonable period after receipt, and reimbursement requests lacked secondary approval and supporting documentation. Cause: This particular award was an exception because the funder requested that The Ocean Foundation draw the remaining balance of funds as the project was closing. Additionally, disbursement of large grant amounts was delayed due to a temporary reduction in staff. Effect: Delays in disbursement and lack of documentation increased the risk of noncompliance with Federal cash-management requirements. Corrective Action: • Implement a strict process for drawing funds beginning in FY26, including: o Written cash-management procedures compliant with 2 CFR §200.305. o Maintaining detailed reporting to support amounts drawn. o Timely program and project notifications for all drawdowns. • Establish a formal review and approval process for reimbursement requests. • Ensure advance funds are maintained in interest-bearing accounts when applicable. Timeline: • Written procedures and process implementation: FY26 • Staff training and monitoring: Ongoing Person Responsible: Jennifer Stahl, Finance Lead

AHC has fully implemented enhanced reconciliation procedures to ensure that all grant drawdowns are reconciled to the general ledger prior to submission, with supporting documentation retained electronically. Quarterly internal audits of drawdown packets are conducted to ensure compliance with federal requirements. These improvements eliminate timing discrepancies and strengthen federal cash management controls. All federal expenditures year-to-date have been verified. It is important to note that AHC did not maintain a single consolidated record of drawdown support but instead retained multiple supporting documents. Despite this documentation issue, all drawdowns were found to be in compliance with HRSA guidelines and were determined to represent allowable costs.

Finding 2024-001: Grant Program: Department of Health and Human Services – National Institutes for Health Research and Development Cluster – Cancer Control – Assistance Listing #93.399 – Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. Montana Cancer Consortium (MCC) has updated the Financial Process Procedure to include language related to receipt management, allowable and disallowed grant expenses, and timing of payment requests. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators

Finding: Significant deficiency in internal control over federal cash drawdowns Corrective action: Pacific Forum has adopted new financial controls policies to ensure federal cash drawdowns are completed in a timely manner and reviewed by management. The Director of Development prepares a financial report that shows the amount that can be invoiced/drawn down from federal funds based on actual expenditures. The Executive Director approves the request for funds prior to submission to the funding organization. These procedures will be incorporated into PFI cash management policy guidelines. Completion Date: February 1, 2026. Responsible Individual: Executive Director

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-010: Cash Management - Inadequate Policies for Drawdowns, Program Income, and Reconciliations (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Management will draft and approve comprehensive written procedures, and will ensure that staff are trained on the standardized drawdown and reconciliation processes. Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2025. Plan to Monitor Completion of CAP: Management will conduct annual reviews of drawdown and reconciliation policies with documented compliance checks.

Processes and controls have been implemented so that the accounting staff prepares the justification and expense support of the grant reimbursement requests which are reviewed and approved by the CEO for submission.

The Department of Health and Human Services/Centers for Disease Control and Prevention – Assistance Listing No. 93.495 Recommendation: We recommend that the Organization implement policies and procedures to ensure subrecipients are paid within 30 days of when the billing is received. If the request is believed to be improper, support for the delay in payment should be maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have established a process to review and track accounts payable, including monthly reviews of outstanding bills, partner invoices, and partner compliance. Furthermore, we have added additional accounting staff focused on disbursements for subrecipients involved in federal grant programs. Finally, we have a process in place to document the receipt of partner invoices submitted to GHN for payment as well as a record of payment approval and/or revisions necessary. Names of the contact persons responsible for corrective action: Jan Warren, Director of Finance & Amber Henderson, Chief Organization Excellence & Strategy Officer Planned completion date for corrective action plan: December 31, 2025

Material Weakness in Internal Control over Compliance and Compliance - Cash Management Federal Program: Major Program- 93.939- HIV Prevention Activities: Non-Governmental Organization Based. Other Program- 16.889- Grants for Outreach and Services to Underserved Populations Federal Agency: Major Program- U.S. Department of Health and Human Services. Other Program- U.S. Department of Justice Award Number: Major Program- NU65PS923746. Other Program- 15JOVW-22-GG-00404-UNDE Fiscal Year: July 1, 2023 – June 30, 2024 Recommendation: We recommend that management ensure drawdowns are strictly aligned with incurred and allowable expenses. This should include: • Pre-drawdown verification of expense documentation. • Monthly reconciliations of drawdown activity to actual expenditures. • Training for staff involved in federal fund management on Uniform Guidance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Procedures related to federal drawdowns were not followed in this case. The finance department will review all procedures and ensure that staff are trained on proper drawdown procedures going forward. Name of the contact person responsible for corrective action: Simon Trowell, Chief Executive Officer. Planned completion date for corrective action plan: December 31, 2025

Condition and Context: The County does not have a complete set of written cash management policies and procedures required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.

Condition: During our audit of the financial management system and cash management practices for the Ryan White Federal Program, we identified the following deficiencies: Transposed Drawdown Amount: A drawdown request submitted to the PMS system for the Ryan White Program had the requested amount transposed with the amount of another federal program. This resulted in an over-request of a material amount on the Ryan White Program. Duplicate Invoice Reimbursement: An invoice was requested and received for reimbursement on a prior drawdown and was subsequently included again in a draw after year-end, resulting in a duplicate reimbursement. Incomplete Expenditure Tracking: The entity did not have a complete system for tracking all expenditures eligible for reimbursement. The drawdown process was limited to cash disbursement and payroll transactions and excluded expenditures incurred and recorded by journal entries. This resulted in the entity having unreimbursed expenditures that could have offset the over-requests noted above. Corrective Action Plan: To correct the deficiency, we are implementing a plan focused on establishing a review and approval process for all drawdown requests and revising our policies to ensure that all eligible incurred expenditures are properly captured and reconciled, thereby assuring strict compliance with federal cash management regulations and preventing federal funds from exceeding our immediate needs. Responsible Party: Austin Maddox, CFO Anticipated Completion Date: December 31, 2025

Management believes that in order to ensure that the amount being drawn down are timely and more accurate to the amounts being drawn upon, management is in the process of developing a more formal policy whereby the general ledger will be formally closed on a monthly basis and all amount will be reconciled to the ledger. Once all amounts are proven, then the drawdown amounts will be initiated with the proper documentation attached.

The County does not have a complete set of written cash management policies and procedures as required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.

Finding 2024-004 - Material Weakness in Internal Control over Compliance and Material Noncompliance (Qualified Opinion) - Inadequate Tracking of Expenditures and Retention of Documentation: Activities Allowed or Unallowed: Allowable Costs/Cost Principles and Reporting (A/B/L) for Assistance Listing Number 19.510 and 93.567 Criteria: The Code of Federal Regulations (CFR) Section 200.510(b) states in part, “The auditee must also prepare a schedule of federal expenditures for the period covered by the auditee’s consolidated financial statements which must include the total Federal awards expended as determined in accordance with 200.502.” Also, in accordance with CFR Section 200.302(b) - Financial Management, the auditees financial management system must provide 1) identification of all federal awards received and expended; 2) accurate, current, and complete disclosure of the financial results of each federal award or program; 3) records that identify adequately the source and application of funds for federally‐funded activities; 4) effective control over, and accountability for, all funds, property, and other assets; 5) comparison of expenditures with budget amounts for each Federal award; 6) written procedures to implement the requirements of section 200.305 and; 7) written procedures for determining the allowability of costs in accordance with Subpart E and the terms and conditions of the Federal award. Recipients of federal awards must submit accurate, complete and timely financial and performance reports. The Organization should have internal controls designed to ensure compliance with those provisions. The Organization should retain sufficient documentation such as invoice and allocation support for expenditures to retain documentation for audit purposes. Condition: During detail testing of expenditures, it was noted that the Organization did not maintain adequate documentation to support how certain costs were allocated to the federal program. Several transactions lacked sufficient detail, such as invoice or expense reimbursement form. Several expenditures selected for testing did not obtain sufficient approval by an individual at the Organization. There was one instance of employee compensation being processed at an approved pay rate and the Center could not provide any supporting documentation such as an offer letter, to substantiate the rate paid. It was noted that quarterly reports provided to the federal program were not reviewed by an individual at the Organization prior to submission to ensure accurate report of expenditures. 2 of the 8 monthly reports sampled were not submitted timely to the grantor. Cause: The Organization does not have an adequate system in place to ensure quarterly reports have sufficient supporting documentation, proper approval/review, and accurate reporting prior to submission. Responsibilities for expenditure tracking were not clearly assigned, and there was no formal review process in place. The Organization is not following their Document Retention Policy. Effect: The effect of this condition increases the possibility that quarterly financial reports are misstated or inaccurate and increase the risk of noncompliance with federal requirements. The effect of this condition also increases the risk that expenditures are unallowable per the grant, federal regulations, or cost principles due to the insufficient support of proper approval retained. Questioned costs: None Repeat Finding: Yes - 2023-003 Recommendation: Policies and procedures should be in place to ensure quarterly financial reports are properly supported, accurately reported, and adequately approved and reviewed. A formal review process should be established to ensure compliance. The Organization should follow the Document Retention Policy that was put in place and required by law and submit the required reporting documentation timely to the grantor to ensure compliance. Management Response: There is no disagreement with the audit finding. Management has taken steps to address these deficiencies in fiscal year 2025 including but not limited to: the implementation of a new accounting system that includes document retention and review/sign off logs, the engagement of a third-party CPA firm to provide client advisory and accounting services and the review and updating of accounting policies and procedures for best practices. Responsible Person for Corrective Action Plan: Marc Hall, Director of Operations Implementation Date for Corrective Action Plan: Fiscal year 2025

Management concurs with the audit recommendation and is taking the following corrective actions to improve cash management efficiency and ensure accurate and timely financial reporting: The District will implement a policy requiring that reimbursement requests are submitted at least quarterly to the grant administrator and reconciled to the SF-425 reporting. • This policy will ensure that federal drawdowns are performed timely and aligned with actual expenditures, improving cash flow management and reducing the risk of reporting discrepancies. • Procedures will reconcile all reimbursement requests with SF-425 financial reports to confirm that expenditures are accurately and consistently reflected in the corresponding SF-425 report, in compliance with 2 CFR 200.305 and 2 CFR 200.328. • Management will ensure staff is adequately trained in grant administration and financial reporting. These sessions will cover federal cash management standards, SF-425 reporting procedures, and internal controls to ensure consistency and compliance. These actions reflect the District’s commitment to improving financial management practices, enhancing grant compliance, and ensuring the timely and accurate reporting of federally funded expenditures.

Recommendation: We recommend that management timely submit annual audit report to the Federal Audit Clearinghouse. To do this, management should develop and implement a clear timeline with internal milestones for completing audit preparation and review. Management should also establish internal control procedures that assign specific responsibilities to staff to ensure that all federal reporting deadlines are met. Views of Responsible Official: Management of the Organization concurs with the audit finding and will immediately implement the auditors’ recommendations. Internal control procedures will be put into place to establish milestones and overseen by the Executive director

For all grant reimbursement requests we will now have an addtional person to review and sign off on the reimbursement request.

U.S. Department of Justice 2024-005 Congressionally Mandated Awards – Assistance Listing No. 16.753 Recommendation: We recommend that the County develop internal controls and procedures to ensure drawdowns are performed in a manner to minimize the time between drawing and disbursing federal funds Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Fiscal Clerk has been trained on proper drawdown of grant funds and accurate recording of expenditures. Name of the contact person(s) responsible for corrective action: District Attorney Fiscal Clerk Planned completion date for corrective action plan: 12/31/25