Corrective Action Plans

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to transitioning from manual, offline tracking to a fully integrated, system-based approach within our Enterprise Resource Planning (ERP) system. Action Step: 1. ERP System Configuration: Configure the ERP system to automatically flag and categorize transactions eligible for indirect cost calculation by class object, replacing manual Excel-based methods. 2. Indirect Cost SOP-Develop and implement written formal procedures detailing the extraction of data from the ERP, ensuring traceability back to the source transaction IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget

VIEWS OF RESPONSIBLE OFFICIALS ADSEF acknowledges the findings regarding weaknesses in the Random Moment Sampling (RMS) methodology used for allocating administrative costs. We conclude that the absence of formal written procedures, combined with insufficient communication between the Human Resources Appointments Office and the Finance Division, has contributed to inaccuracies in the distribution of administrative expenses across federal programs. ADSEF reaffirms its commitment to strengthening its cost allocation plan to ensure that only allowable costs, directly associated with the administration of federal awards, are charged to the TANF program, in strict compliance with 2 CFR §200.302. Action Steps: 1. Policy Formalization Develop, approve, and implement a comprehensive Standard Operating Procedure (SOP) that formalizes the RMS methodology, including clear and standardized definitions for all survey response categories. 2. HR–Finance Liaison Establish a structured monthly reporting protocol between the Human Resources Appointments Office and the Finance Division to ensure the RMS participant list remains accurate, complete, and current. 3. RMS Questionnaire Update Revise the RMS questionnaire to remove non-federal program selections and ensure that all response options align directly with federally allowable functions. 4. Quarterly Oversight Institute a mandatory quarterly review of RMS results by senior management to validate alignment between RMS survey data and accounting system allocations IMPLEMENTATION DATE March 31, 2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Coral M. Caceres Alvarez Auxiliary Administrator Human Resources Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Gerhil Medina Baez Auxiliary Administrator Operational Services Rafael Acosta Sepulveda Program Director

Incorrect Grant Drawdown - Allowable Costs/Reporting - Assistance Listing Numbers: 93.224 and 93.527 Consolidated Health Center Cluster Type of Finding: Material Weakness in Internal Control Over Compliance Cause: Controls designed to ensure grant expenditures were properly aligned with the correct federal award prior to drawdown were not operating effectively, and procedures for identifying, reporting, and correcting drawdown errors were not consistently applied. Corrective Actions: 1. Strengthen internal controls over grant drawdowns by implementing procedures to ensure expenditures are reviewed and reconciled to the appropriate federal award prior to requesting funds. Management should also establish formal procedures for timely identification, documentation, and communication of drawdown errors to the awarding agency when identified.

FINDING 2024-003 Criteria: Recipients of federal awards must minimize the time elapsing between the receipt of funds from the U.S. Treasury and disbursement by the Organization set out at 2 CFR section 200.305(b). Audit Recommendation: We recommend that the Organization 1) maintains timely and accurate recording of disbursements in its job-costing system and 2) regularly request grant funds based on amounts expended as report in the Organization’s job-costing system. Auditee Response: UICSL revised its job costing system to better comply with these requirements and had overlap from previous programs/grants within its old QuickBooks Accounting system. UICSL now has a credit card tracking system by class code, ensures an invoice is allocated, and has focused on reimbursement method invoicing. Corrective Action Plan: Invoices and transactions will not be processed without approval and proper coding. Prior grant personnel and leadership are no longer within the organization. Monthly and quarterly invoices are sent according to each grant / contract agreement will be enforced by the GDCM and DFO in compliance with 2 CFR section 200.305(b). UICL is in active good status with all its current grantors, specifically Indian Health Servies (IHS). Person Responsible: Som Chivukula, Finance Director; Matt Poss, Executive Director Timeline: UICSL removing QuickBooks and switching to Oracle NetSuite in 2025/2026. Scheduling monthly check-ins and expenditure reports reviewed with department leads upon hiring of new Finance Director. All invoices reviewed with grant/project leads and logged appropriately. Staff accountant hired in late 2024 to help provide additional checks but also ensure UICSL focuses on reimbursement (post-expense).

Type: Material Weakness in Internal Control Over Compliance Corrective Actions: - Implement reconciliation of each drawdown to actual expenditures. - Require detailed supporting documentation. - Establish supervisory approval process. Responsible Parties: Chief Executive Officer and Chief Financial Officer

Views of Responsible Officials and Planned Corrective Action While the Organization understood the prior year finding (2023-006) and current year renumbered recommendation (2024-006), the Organization notes the corrective actions that have been implemented, The Organization notes the following existing internal control practices, as it relates to cash management subsequent policy and process development and implementation, and the additional controls to be implemented: A. System, Process & Review Controls In Practice. 1. System Controls. The Organization operates in an environment in which system, process & review controls of the United States Department of Health and Human Services (HHS) are practiced in processing cash (draw) transactions in both the Electronic Handbook (EHB) and Payment Management System (PMS) systems, operated by HHS. Only the director of administrative operations and the CEO have system access to the EHB and PMS systems. 2. Process & Review Controls – EHB & PMS. Cash management requests (aka federal draws) are computed by, and entered into the EHB, including the Organization’s justification of the expenditure, by the director of administrative operations, including the CEO on the approval request. The propriety of the cash draw is reviewed by the HHS assigned grants management specialist; and inquiry action, if needed, documented by e-mail from the grants management specialist; and approval documented in the EHB. Once the draw is approved, the director of administrative operations enters information into the PMS, noting that the CEO, is the authorized organization representative (AOR). The grants management specialist must then approve the draw request once more in the PMS system before a PMS representative approves the draw request. 3. Process & Review Controls – Finance Committee & Full Board. The Organization’s monthly Board process and review controls include review of the Organization’s: Statement of Financial Position, Statement of Revenues and Expenditures, Statement of Revenues and Expenditures – Net Income/(Loss) by Fund, Fund Details – Additional Information and Statistics, Active Subcontract Summary, Active Subcontract Listing Related to Funds – Additional Information and Statistics, Native Hawaiian Health Program (Fund 007V), and Native Hawaiian Health Scholarship Program (Fund 017V). B. Internal Control Environment Policy Establishment – July 2025. In July 2025, the Organization developed the following cash management related policies and related procedures: Internal Control Environment; Implementation of Significant Accounting Policies; Revenue Recognition Policy, Including Federal Draws; Implementation of Health Resources & Services Administration (HRSA) Related Policies, including cash management processes and procedures. C. Additional Process & Review Controls – March 2026. Beginning March 2026, for federal draws, process and review internal controls will be implemented, via the chief of staff’s review of the director of administrative operations cash management analyses, federal grant receivable composition, reconciliation and related federal grant revenue computations, prior to any director of administrative operations and chief executive officer action in EHB and PMS, respectively. The current practices of the Organization, to the present period of the report dated June 17, 2026, is consistent with such developed policies.

The City will review the requirements for written policies and will adopt policies, as needed, or will revise its current policies as needed to comply with Uniform Guidance.

Finding 2023-005 ● Condition: There are no written policies and procedures for allowable costs/cost principles, cash management, procurement and suspension and debarment requirements. ● Cause: The Organization does not have a process for reviewing their accounting policies and procedures manual on a regular basis to ensure written procedures conform to Uniform Guidance requirements. ● Corrective Action Plan: Management agrees with the finding and they will evaluate our findings to determine an appropriate corrective action. Financial policies and procedures will be created and implemented. Annual schedule of expenditures will be created by Executive Director or Bookkeeper and reviewed by Board of Directors. Contact Person: Kirsten Jurcek Anticipated Date of Completion: September 1, 2026

The City will develop written procedures to implement the requirements of 2 CFR § 200.305 Payment.

Finding No.: 2024-053 Special Test and Provisions – Project Accounting Responding Agency: Guam Homeland Security (GHS) Responsible Personnel: Esther Aguigui, Director GHS will create a Standard Operating Procedure (SOP) to establish internal policies and procedures in compliance with applicable special tests and provision requirements. GHS will also identify department personnel responsible.

Finding No.: 2024-036 Cash Management Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Federal and Compliance section will establish a Standard Operating Procedure for drawdowns. As well as, conducting drawdowns daily to minimize the time between the drawdowns of federal funds and the disbursement for federal program purposes.

Finding No.: 2024-033 Cash Management Responding Agency: Guam Environmental Protection Agency (GEPA) Responsible Personnel: Michelle Lastimoza, Director Request to DOA will require immediate collaboration between Guam EPA and DOA, as all Guam EPA reimbursement requests are accompanied by the FGIA balance report and, currently, the GFMIS expenditure reports.

Finding No.: 2024-010 Cash Management Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Federal and Compliance section will establish a Standard Operating Procedure for draw downs. As well as, conducting drawdowns daily to minimize the time between the drawdowns of federal funds and the disbursement for federal program purposes.

Assistance listing numbers and program names 97.024 Emergency Management Performance Grants Agency: Department of Emergency and Military Affairs (DEMA) Name of contact person and title: Keith Tagaban, Audit Supervisor Anticipated completion date: September 18, 2026 Agency’s Response: Concur The Department of Emergency and Military Affairs (DEMA) will maintain complete, accurate, and auditable documentation to support all federal award expenditures, matching contributions, and financial reporting in accordance with 2 CFR Part 200 and applicable award terms and conditions, with records retained for a minimum of three years following submission of the final Federal Financial Report (FFR). DEMA will ensure all FFRs are reviewed for accuracy, completeness, and compliance prior to submission and will promptly correct any identified discrepancies in coordination with the federal awarding agency. The Department will implement and enforce written policies and procedures governing reimbursement requests, financial reporting, matching requirements, and record retention, including management review to ensure costs reported are allowable, allocable, reasonable, and adequately supported, and will maintain sufficient staffing and oversight to sustain ongoing compliance.

Action taken: CRMHS management concurs with the finding. During the fiscal year ended June 30, 2024, CRMHS did not consistently operate internal controls over federal cash management as designed. Specifically, a federal draw was processed in excess of immediate cash needs and was not fully reconciled to supporting allowable expenditures prior to submission. This resulted in federal funds being drawn in advance of program disbursement requirements. Management acknowledges that this practice does not comply with 2 CFR §200.305, which requires non-federal entities to minimize the time between drawdown of federal funds and their disbursement for program purposes. While the funds were ultimately expended on allowable program costs, the timing of the draw created a compliance exception and reflects a material weakness in internal control over compliance. Management takes this matter seriously and has implemented corrective measures to strengthen cash management oversight and reconciliation procedures. Such actions include: • CRMHS has completed a full reconciliation of all drawdowns under Assistance Listing 93.696 to supporting allowable expenditures through June 30, 2024. • Any excess cash balances identified were evaluated and adjusted to ensure compliance with federal cash management requirements. • Pre-Draw Reconciliation Requirement—No draw request may be submitted without documented reconciliation to recorded allowable expenditures. • Segregation of Duties and Review—the draw request and documented reconciliation will be reviewed and signed off on by a second qualified member of the accounting team. • Monthly Grant Cash Monitoring—CRMHS will compare cumulative drawdowns to cumulative allowable expenditures to identify and resolve any excess cash position.

MANAGEMENT WILL ENSURE THAT ALL FUTURE GRANT DRAWDOWNS ARE RETAINED IN THE BANK UNTIL SPENT ON ALLOWABLE GRANT EXPENSES.

Finding Number: 2024-006 Finding Title: Financial Policies and Procedures Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Financial Management and Standards of Financial Management Systems (2 CFR §200.302(b)); Allowable Costs (2 CFR §200.403-405); Procurement (2 CFR §200.317-327); Cash Management (2 CFR §200.305); Travel Costs (2 CFR §200.475) Note: Organization has existing Conflict of Interest policy in compliance with 2 CFR §200.318(c)(1). Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization will establish formalized accounting policies and procedures that adhere to the requirements of the Uniform Guidance. Corrective Action Plan: Corrective Action #1: Comprehensive Policy Manual Development • Action: Engage consultant or work with Contract Accountant to develop comprehensive written financial policies and procedures manual addressing all Uniform Guidance requirements, including: (a) Allowable costs (2 CFR §200.403-405); (b) Procurement (2 CFR §200.317-327); (c) Cash management (2 CFR §200.305); (d) Travel costs (2 CFR §200.475); (e) Time and effort documentation; (f) Equipment management; (g) Subrecipient monitoring; (h) Financial reporting; and (i) Record retention. Ensure policies address financial management system requirements under 2 CFR §200.302. Tailor policies to Organization's all-volunteer structure. [Note: Organization already has Conflict of Interest policy complying with 2 CFR §200.318(c)(1).] • Responsible Person/Title: Board Treasurer with Contract Accountant • Anticipated Completion Date: April 30, 2026 Corrective Action #2: Board Approval and Adoption • Action: Present draft policies to full Board of Directors for review and input. Board will formally adopt policies by resolution. Document approval in Board meeting minutes. • Responsible Person/Title: Board President • Anticipated Completion Date: May 31, 2026 Corrective Action #3: Dissemination and Training • Action: Distribute approved policies to all Board members and Contract Accountant. Conduct training session for Board members and Contract Accountant on new policies and procedures. Board members and Contract Accountant will sign acknowledgment of receipt and understanding. Make policies readily accessible (e.g., shared drive, Board portal). • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026 Corrective Action #4: Implementation Tools and Support • Action: Develop templates, forms, and tools to support policy implementation. Create workflow diagrams and checklists for common transactions. Establish Board Treasurer as primary resource for policy implementation questions. • Responsible Person/Title: Board Treasurer and Contract Accountant • Anticipated Completion Date: July 31, 2026 Corrective Action #5: Annual Policy Review Process • Action: Schedule annual review of policies to ensure continued Uniform Guidance compliance. Update policies as needed for regulatory or organizational changes. Submit material policy changes to full Board for approval. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: Annually, beginning June 2027 Corrective Action #6: Governance Structure Assessment • Action: Board will evaluate establishing Audit Committee or combined Finance/Audit Committee to provide enhanced oversight of financial management, internal controls, and federal compliance. If Board size prohibits separate committee, designate at least two Board members with specific oversight responsibilities. • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026

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