Corrective Action Plans

FINDING 2025-005 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure allowable costs are documented and that receive board approval for all pay rates moving forward. However, we disagree with the finding on the allowable costs pertaining to the Financial Consulting Claims. We wrote them into the grant, and the grant was approved. There was also no Business Manager or Chief Financial Officer in place during the pandemic, resulting in the need for the consulting firm. Anticipated Completion Date: We anticipate that this correction will be in place by July 2026.

Recommendation: The Judicial Branch should strengthen internal controls to ensure it complies with federal subrecipient monitoring requirements for the Crime Victim Assistance program. Corrective Action Plan as Reported by the Judicial Branch: The Judicial Branch Office of Victim Services (OVS) agrees to strengthen its internal controls as described below to comply with federal subrecipient monitoring requirements for the Victims of Crime Act Assistance (VOCA) Program. In 2025, OVS performed site visits for four VOCA-funded programs and completed financial-desk reviews of monthly or quarterly financial reports for all programs. That year, OVS experienced personnel turnover in its three-employee Fiscal Services Unit, notably the separation from state service of a Program Manager and a Court Planner, who together performed OVS’ programmatic site visits of VOCA-funded programs. Also, there was a significant increase in workload resulting from OVS’ contributions to the 2024-2025 VOCA request-for-proposal process. In response, staff outside the unit contributed while managing other assigned duties, a Program Manager and Grants and Contract Specialist were hired to restore the unit to its three-employee configuration, the new employees received training on subrecipient monitoring policies and procedures, and a revised subrecipient site visit plan was developed and has begun being implemented. To strengthen internal controls, OVS has developed a revised site visit plan for the remaining VOCA-funded programs scheduled to receive site visits in 2025. April 15, 2026, is the anticipated date for OVS to complete the site visits. OVS has completed sending letters to the subrecipients operating the VOCA-funded programs. The letters request supporting documentation, which is programmatic and financial in nature, in accordance with OVS administrative policy and procedure. Also, the letters inform subrecipients that site visits will commence in accordance with a revised site visit plan. Anticipated Completion Date: April 15, 2026 Judicial Branch Contact Person: Marc Pelka, Office of Victim Services Director marc.pelka@jud.ct.gov (860) 263-2760

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency will strengthen controls by enhancing annual trainings to ensure matching requirements are properly tracked, documented, and applied to Federal expenditures as required by the Federal award. Additional notes will be added on the Federal Final Modification forms to address any differences required by the Cooperative Agreement. Anticipated Completion Date: 10/01/2026 Name of the contact person responsible for corrective action: Anita Ballington at 803-299-2031

Finding 2025-003 Significant deficiency in internal controls over compliance and instance of noncompliance related to matching requirements. Contact Person(s): Nicholas Lee, Chief Financial Officer Corrective action planned: Management identified that the required matching report was not submitted to the funder in accordance with the grant deliverable requirements. The organization has since reviewed the grant agreement to ensure full understanding of all reporting and matching obligations. Corrective actions have been implemented. A centralized grant compliance checklist has been developed to outline all required deliverables, including matching report deadlines. Matching requirements have been incorporated into the organization’s grant reporting calendar with reminder controls in place. Responsibility for tracking and submitting match documentation has been formally assigned to designated Finance personnel, with supervisory review prior to submission. These measures strengthen internal controls over grant compliance and are designed to ensure timely submission of all required matching documentation going forward. Anticipated completion date: Implemented as of December 31, 2025

Matching, Level of Effort, and Earmarking Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN Office of Grants and Contracts Post-Award Management received approval from the award sponsor to perform a budget revision to remove office space usage from the cost share. The Office of Grants and Contracts Post-Award Management also advised the Office of Sponsored Projects to avoid using unallowable cost share expenses in award applications. ● How compliance and performance will be measured and documented for future audit, management and performance review. CSN Office of Grants and Contracts Post-Award Management will continue to monitor award budgets to avoid using unallowable cost share expenses. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Office of Grants and Contracts Post-Award manager is accountable for exercising oversight and responsibility. GBC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o GBC will standardize a cost share calculation workflow between the Grants and Business Operations departments to ensure proper calculation and review against payroll records. o GBC also will formalize written internal procedures for cost share calculation and documentation and distribute to relevant staff. o All corrective actions were implemented immediately upon identification of the finding and will be fully in place within 30 days of notification. The revised procedures are now standard practice for all grants requiring cost share. ● How compliance and performance will be measured and documented for future audit, management and performance review. o A cost share verification checklist will accompany each cost share transaction and will be retained in each year’s grant file. This internal review will confirm: (1) use of current salary data; (2) mathematical accuracy; and, (3) proper documentation support. o Grant financial reports will include documented evidence of secondary review prior to submission. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and the Director of Business Operations are responsible for oversight of grant compliance. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP has enforced a required cost share form to be completed, and will require that documentation be attached and verified before submission to the sponsor. For effort identified as cost share, a new process is currently being tested to capture it in the financial system. The cost share policy will be updated before the end of spring semester and disseminated to the campus community for immediate implementation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Verifiable documentation will be required upon review/submission to be uploaded with the financial report in Workday. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with the Principal Investigator’s documentation. UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management will implement quarterly review of all gift accounts used for cost share to ensure that they are properly established and correctly linked to the award through a GR cost share line, which will generate the required effort certification process. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through a review and confirmation that all cost share transactions are accurately recorded, supported, and associated with the appropriate worktags.  ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; WNC will continue its FY26 adopted internal control processes by implementing a two-step review process for all invoicing, including match verification and reporting. The assistant controller creates the invoice packet and submits it to the grant administrator for review and approval. The packet then has a secondary and final review and approval by the vice president of finance and administration. The sampled transaction occurred before internal controls were in place. Internal controls were implemented in October 2025. ● How compliance and performance will be measured and documented for future audit, management and performance review. The grant administrator maintains records of monthly invoicing reviews, including time-stamped email receipts, internal tracking spreadsheets, and Workday transactions. Workday transactions provide actuals for each invoice period, which are compared to the internal tracking spreadsheet to determine the totals to be invoiced/reported. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Final responsibility and accountability fall on the grants administrator. SA – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The spreadsheet that System Administration uses to track in-kind cost share was not correctly updated when the fringe rate changed at the beginning of the fiscal year. The Post-Award Manager will update the spreadsheet each July when the fringe rate is confirmed and run effort reports using the current salary and fringe rates. ● How compliance and performance will be measured and documented for future audit, management and performance review. The Office of Sponsored Programs will document that the fringe rate for the new fiscal year has been reviewed, and that the in-kind cost share spreadsheet was updated each July. Documentation will be included in the cost share file. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The System Administration Office of Sponsored Programs Director is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Matching, Level of Effort, and Earmarking Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP has mandated a required cost share form to be completed and will require that the documentation be attached and verified before submission to the sponsor. For effort identified as cost share, a new process is currently being tested to capture it in the financial system. The cost share policy will be updated before the end of spring semester and disseminated to the campus community for immediate implementation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Verifiable documentation will be required upon review/submission to be uploaded with the financial report in Workday. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with Principal Investigator’s documentation. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

The City concurs with the finding. The City will update Continuum of Care procedures related to subrecipient monitoring, in-kind contribution documentation, match tracking and reporting, and grant closeout review to strengthen compliance and oversight. Additionally, the City will provide additional grants training and a list of subject matter experts within each department that can work with auditors during the single audit.

Views from Responsible Officials and Corrective Action Plan BCFS Health and Human Services For the Year Ended August 31, 2025 Finding Number: 2025‑001 and 2025-002Federal Program: Crime Victim Assistance – AL 16.575 (Common Thread – Texas) Pass‑Through Entity: Texas Office of the Governor Award Number: 3853406 Questioned Costs: $853,982 Responsible Person: Rosa Baez, President BCFS Health and Human Services Views of Responsible Officials: Management concurs with the finding. BCFS Health and Human Services’ (BCFS HHS) in-kind match plan includes the use of exempt personnel performing after-hours "on-call" volunteer duties, such as answering phones or undertaking responsibilities outside their standard work roles. BCFS HHS did not meet the in-kind match requirements, as the former Program Executive Director deviated from the in-kind match plan, as approved by the funder. The former Program Executive Director did so by hiring full-time personnel to perform the same duties as the on-call volunteers and including them as part of the in-kind match. In 2022, during the COVID pandemic, the funder waived match requirements; during this period, the prior Program Executive Director hired full-time overnight on-call personnel, in response to increased call volume driven by restrictions on face-to-face services due to concerns of exposure. The match waiver was discontinued with the grant awarded for October 2024 through September 2025, and BCFS HHS was required to meet their match obligations. The former Program Executive Director failed to reassign the On-Call workers resulting in a significant deviation from the approved match plan and contributed to the noncompliance of in-kind match requirements. Immediately upon the issuance of the monitoring report regarding match requirements, BCFS HHS’ President has been actively working with Office of the Governor (OOG) to rectify the match requirements per the grant. Management has recorded an accrual for the estimated adjustment and has implemented the corrective action plan outlined below. Page 2 of 3 Corrective Action Plan Upon receiving the preliminary monitoring report from the OOG, management promptly initiated an internal review with the OOG and began collaborating with OOG to address and resolve the findings identified. Effective immediately, BCFS HHS has established new protocols to ensure compliance with match requirements for the Common Thread Texas program. BCFS HHS will undertake the following corrective actions: 1. Revised In-Kind Volunteer Hotline Process A protocol has been implemented to manage the volunteer hotline for the Common Thread Program during after-hour operations. The hotline provides callers with program information, resources, referrals, and transfers calls as appropriate, including crisis response or intake services. The volunteer hotline is managed by volunteers that include exempt employees (working outside their regular duties), interns, and other approved community volunteers. Volunteers must complete training prior to being scheduled. The protocol guidelines include: •A designated volunteer timesheet. •A signed attestation certifying that hours listed are an accurate record ofvolunteer service. •Confirmation that the volunteer work is not required by their employment andis different and separate from their regular job duties. These measures provide robust supporting documentation and ensure that match activities are voluntary, allowable, and compliant. The Volunteer Hotline Protocol was reviewed and approved by the Office of the Governor (Public Safety Office and Office of Compliance and Monitoring). Target completion: Completed January 2026 2. Strengthen Match Documentation Processes Volunteer Attestation and Timesheet- Volunteers are required to sign a timesheet and an attestation affirming that the recorded hours accurately reflect their service with the Common Thread Volunteer Hotline. Additionally, if applicable, volunteers must confirm that this service is not mandated by their employment and is distinct from their regular job responsibilities. Monthly Match Meetings: These meetings will review the reported match activities against the approved match plan. Additionally, the meetings provide an opportunity to evaluate current needs and trends, and to ensure match obligations are met. Page 3 of 3 Target completion: Completed January 2026. 3. Correct and Reclassify Previously Reported Match BCFS HHS excluded the disallowed match activities and included permissible methods such as unrecovered indirect costs, reductions in billed expenditures, including personnel and training—and additional adjustments approved by OOG. All necessary changes are incorporated in the final Financial Status Report (FSR) submitted on January 29, 2026. Target completion: Completed. 4. Staff Training and Ongoing Compliance Monitoring BCFS HHS will provide Common Thread leadership training on uniform guidance match requirements, OOG-specific guidance, and the Volunteer Hotline Protocols. Weekly Audits- The BCFS HHS Director of Support Services, or designee, will conduct weekly audits to ensure protocol adherence. This will encompass a review of the hotline volunteers’ timesheets, and schedules. Results will be discussed in the monthly match meetings. Use of U.S. Bureau of Labor Statistics wage data- All volunteer and intern hours are valued using OOG‑approved labor categories. Target completion: Training will be completed by February 28, 2026; monitoring process will be implemented February 1, 2026. Sincerely, Rosa Baez, President BCFS Health and Human Services

Special Programs for the Aging-Title III, Part C-Nutrition Services – Assistance Listing No. 93.599 Recommendation: We recommend the Organization put procedures in place to retain documentation of supervisory approval of time and effort reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Program leadership will review and retrain staff of the volunteer hour log requirements, including signatures, matching of hours to digital logs, properly documentation of updates made, and retention of documentation. Program leadership will conduct reviews of documentation for all their locations on a frequent basis to address any deficiencies and address as needed. Finally, administrative staff will conduct rotating reviews of site documentation as a secondary verification. Name(s) of the contact person(s) responsible for corrective action: Drew Erickson Planned completion date for corrective action plan: 02/28/2026

Matching – Assistance Listing No. 93.671 Recommendation: We recommend the Organization enhance its internal controls over the review of the payroll allocation to ensure matching contributions are accurately calculated and supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Senior Accountant or Director of Grants and Compliance will conduct the initial review to ensure that match costs are allowable, properly supported, and accurately calculated. The Chief Financial Officer will perform a secondary review and approval to validate completion of the initial review and confirm that reported match amounts reconcile to supporting documentation. Evidence of review will be documented through dated signatures or electronic approval within the grant billing file. Name of the contact person responsible for corrective action: Ashley Freivogel Planned completion date for corrective action plan: September 30, 2026

The purpose of the Goods Receipt (GR) is to record receipt of goods or services as soon as they are delivered and verified to be in acceptable condition. A Goods receipt must be posted in SAP for all items actually received. Vendors submit invoice(s) referencing the purchase order (PO) directly to Accounts Payable after delivery, indicating that the goods or services have been provided and requesting payment. Accounts Payable then reviews the vendor invoice, purchase order, and goods receipt in SAP to perform the required three-way match (PO, GR, and vendor invoice) before processing payment. 1. The Accounts Payable team will collaborate with the Procurement Services Division to establish and implement a process that ensures the timely review and reconciliation of Goods Receipt (GR) entries. This will include the development of clear guidance / training materials for schools and offices to periodically review their GR balances. Training will be conducted via Virtual Office Hours on a quarterly basis for sites to make necessary adjustments when the goods or services received differ from the original Purchase Order (PO) or the corresponding invoice. 2. The Accounts Payable team will collaborate with the Procurement Services Division to develop supplemental documentation and guidance regarding proof of delivery for goods and services received. 3. Accounts Payable staff will receive ongoing training throughout the year on documentation and reconciliation requirements, particularly when new internal controls, procedures, and processes are created. Training will be incorporated into regular team meetings, procedural updates, and onboarding for new team members to maintain alignment and accuracy across the department. The implementation target date for the above corrective action plan is June 30, 2026. Name: Rocio Saucedo Title: Director of Accounts Payable Contact Information: Rocio.Saucedo@lausd.net

Higher Education Institutional Aid – Assistance Listing No. 84.031 Condition: The Institution did not adjust the employee’s payroll costs to reflect the reported effort. We noted that the actual time and effort charged to the grant did not agree to the time and effort report. Recommendation: We recommend that the Institution strengthen its internal controls to ensure expenditures are reviewed and adjusted for, if necessary, in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As a corrective action, Coppin State will complete the implementation of the following: 1. Award PI will provide training regarding proper submission of Time and Effort Reports. 2. Award PI will review distribution of time and percentage. 3. Award PI will review compensation and fringe benefits. 4. Award PI will approve Time and Effort Reports and route to the Payroll Office. 5. Award PI with the support of the Controller will obtain the appropriate role in Workday that allows for the review and confirmation of approved payroll allocations and adjustments.

Higher Education Institutional Aid – Assistance Listing No. 84.031 Condition: Time and Effort documentation were not being documented and reviewed timely. Recommendation: We recommend that the Institution strengthen its internal controls to ensure that Time and Effort are documented, expenditures are reviewed and adjusted for, if necessary, in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In June 2024, we successfully implemented a new ERP system designed to automate the documentation of Time and Effort. This system streamlines the process by capturing and organizing data more efficiently, reducing manual effort and enhancing accuracy. As part of the implementation, we have established a process for regular reviews and adjustments of expenditures, ensuring ongoing compliance with regulatory requirements and maintaining the integrity of financial records. We are providing comprehensive training for relevant staff members, focusing on how to utilize the new system effectively. This training will ensure that documentation is completed in a timely, accurate, and consistent manner, minimizing the risk of errors and improving overall operational efficiency. Moving forward, we will continue to monitor the system's performance and provide ongoing support to ensure its success. Name(s) of the contact person(s) responsible for corrective action: Miliani Sinclair Planned completion date for corrective action plan: April 2025

Finding Number: 2024-043 Audit Type: Single Audit Finding Title: Use of Unapproved Federal Funds to Satisfy Required Local Match Related Finding: 2024-022 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department2. 2. Planned Corrective Action The City will revise its grant accounting procedures to ensure only eligible local funds are used for matching requirements. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will coordinate with granting agencies to confirm match eligibility. 5. Status of Prior Year Finding This is a new finding.

Finding Number: 2024-035 Audit Type: Single Audit Finding Title: Internal Control Deficiency Over Federal Matching Requirements Related Finding: 2024-024 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will implement a formal review process to verify matching fund eligibility prior to grant submission and reimbursement. 3. Anticipated Completion Date September 30, 2025 4. Management's Response Management concurs and will ensure compliance with federal matching requirements going forward. 5. Status of Prior Year Finding This is a new finding.

Thank you for your review and the findings shared in the recent audit. We appreciate the thorough assessment and the opportunity to strengthen our processes. We acknowledge the findings; however we respectfully disagree with [Finding Reference 2024-003, Insufficient Non-Federal Share]. Based on the support and documentation we provided we captured $191,000 (25% non-federal match) of in-kind to meet our obligation of $189,250 for grant award Year 1, 2023. And although we met our in-kind obligation, we experienced several delays which were recognized by our grantee, MBDA. The delay in funding the grant award took place from July 2023 to September 2023 and subsequently after funding was released an additional black-out period from September 2023 to October 2023 was experienced due to a system transition from BAS to GEMS/era Commons. Acknowledgement of these delays was addressed by an official during an MBDA All Equities call on October 18, 2023. During that call awardees were advised to continue focusing on our program activities and clients as the situation was being addressed. To account for the delays, we later submitted a budget revision request through the new system, eRA Commons on 12.09.2024 asking for a budget carryover of $337,825.00 which also outlines how the funds will be expended. Additionally, it is noted in your finding that the allowable in-kind contribution is being reduced given that budget categories were not met by line item. However, our interpretation of MBDA Capital Readiness NOFO (pg.14), we are directed to Section CFR200.306 [https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/section-200.306] which does not cap in-kind by line-item. Lastly, the MBDA organization has changed dramatically since the inception of the Capital Readiness grant in 2023, yet we have been in communication with an MBDA government official who acknowledges the delays during the time outlined above and ask that flexibility for this non-federal share requirement be re-considered. Supporting documentation has been sent to support the statements. Name of the contact person responsible for corrective action: Sharon R. Pinder, President, 301.593.5861 Planned completion date for corrective action plan: We plan to continue to seek validation of our position from our grantor and grant management entity – 4th Quarter 2025.

In January and February of 2024, TRAC was transitioning from being a program of CitySquare to becoming an independent 501(c)(3). Following the transition, two staff members previously allocated to the match departed in September 2024, and their associated match was not reassigned. To address this, TRAC has implemented monthly accounting reports (effective August 1, 2025) to compare budgeted vs. actual match requirements. The Finance Director reviews these reports each month, and variances greater than 10% are reported to the CEO for corrective action. This process ensures that match requirements are budgeted, tracked, and reconciled in accordance with federal regulations. Completion Date: October 1, 2025.Responsible Parties: Nicole Binkley, Chief Executive Officer Josh Runnels, Director of Finance and Operations

With regard to Federal Award Finding 2024-002, Procedures for Match Requirements, in the audit report for Mountain Home Montana, Inc. for the year ended December 31, 2024, we offer the following response: Mountain Home will immediately implement written policy and procedures to ensure compliance with federal grant matching requirements. The new policy and procedures are attached.

DAWI acknowledges the finding and will implement the following: 1. Cash Management Policy: We will update this policy to require signed documentation of reimbursement requests. a. We will then follow this policy and retain signed documentation of reimbursement requests. 2. Matching Policy: We will develop a match policy to include documented review and signed document retention for matching contributions, ensuring compliance with CFR §200.306. a. We will then follow this policy and retain signed documentation of matching contributions. Proposed Completion Date – October 31, 2025

Finding Number 2024-008: Matching – Significant Deficiency in Internal Control Over Compliance Corrective Action: The inclusion of certain costs in the matching pool was due to a misinterpretation of the requirement; the federal agency has accepted this approach for multiple years, and there was no impact as the Village exceeded the required match due to its commitment to serving the homeless. Management will further enhance its policies and procedures and implement a documented review process to ensure only allowable costs are included in the matching pool. Name of Responsible Individual(s): Jason Brenier, Judy Bokhari and Luz Gonzales-Toscano Anticipated Completion Date: June 2025

Corrective Action: 4-C will implement procedures for tracking and documenting matching contributions. Responsible for Corrective Action: Executive Director, Business Manager Anticipated Completion Date: 12/31/2025

Management recognizes its responsibility for understanding and adhering to the Cost Sharing rules outlined under 2 CFR 200.306. Management is working with the New Hampshire Dept. of Environmental Services to correct any funding requests for the Webster Ave. Pump Station project in which ARPA funds were used as a match against the project’s federal CDS grant. Prior to submitting its first CDS funding request to EPA, engineers for the project requested guidance from an EPA representative on matching local funding for the project with CDS funding. The feedback they received led us to believe that using ARPA against CDS funding was not an issue since in total the project’s local funding source (CWSRF) far exceeded the 20% CDS match requirement. Considering the actual Cost Sharing rules under 2 CFR 200.306, the feedback was misinterpreted.

Audit Finding The audit found that during the reimbursement request process, WITA included total expenditures on the A-19 form without excluding the 10% required match, as outlined in the grant agreement and under 2 CFR § 200.306. The error was identified by the Washington State Department of Commerce and corrected before the reimbursement was issued. This was the sole instance of noncompliance identified within the 28 sampled requests. Cause of the Finding This error occurred early in WITA’s management of federal funds, during a period when the Association was still building internal knowledge and procedures for federal grant compliance. At the time, WITA unknowingly lacked fully developed internal controls specific to federal match reporting, and the staff involved had limited experience with federal grant administration. Corrective Actions and New Controls Implemented To address this issue and strengthen internal compliance, WITA has implemented the following controls: • Grant Management Procedures: A formalized checklist has been created for preparing reimbursement requests, which includes a step to verify exclusion of the 10% match. Manual calculations are performed on each Match Submittal Form to verify the requested amount excludes the 10% match. • Dual Review Process: All reimbursement requests are now subject to a dual review and approval process before submission to the granting agency. Responsible Party for Monitoring Compliance The Grant Management Assistant, Maranda Davis, is responsible for overseeing compliance with federal grant requirements and ensuring all reimbursement requests meet applicable match exclusion rules. Ongoing oversight is provided by the Executive Director. Timeline of Implementation • February 2024: Error identified and corrected in partnership with the Department of Commerce • March 2024: Grant reimbursement checklist developed and implemented • Ongoing: Dual reviews of requests initiated WITA is committed to ensuring strict compliance with federal grant requirements and continuously improving our internal controls. We appreciate your attention to this matter and the opportunity to strengthen our grant management practices. Sincerely, Betty Buckley Executive Director, Washington Independent Telecommunications Association

Corrective action planned: Housing Connector will develop and implement a written policy to address company match contributions used to meet federal cost share requirements, in alignment with 2 CFR 200.306. The policy will provide general guidance on the allowability, tracking, and reporting of match to ensure compliance with federal grant regulations. Relevant staff will be informed once the policy is finalized.

Corrective Action Plan: The Organization will ensure to track minimum level of effort requirement in regard to any key staff to stay in compliance. All invoices will be reviewed by accounting management staff to ensure level of effort requirements are in compliance. Estimated completion date: June 30, 2025 Contact person: Chue Vang, Chief Financial Officer