Corrective Action Plans

Audit Finding: The Authority did not have sufficient internal controls to ensure that payroll expenditures submitted to FEMA were incurred within the applicable period of performance prior to submission of the project worksheet. Recommendation: The Authority’s policy and procedures should be designed to strengthen the internal controls over the review of the submissions to ensure accurate reporting as required by the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 1. Enhanced Review of Period of Performance (POP): The Authority will implement a formal verification step requiring the Finance Department to confirm that all costs included in FEMA project worksheets were incurred within the approved period of performance prior to submission. This verification will specifically address payroll costs that span multiple pay periods. 2. Payroll Cost Allocation Controls: Payroll expenditures that cross fiscal periods or project periods of performance will be allocated based on actual days worked within the applicable period. Payroll reports will be reviewed to ensure that only eligible dates are included in each FEMA project. 3. Secondary Review: The Authority will require a secondary review by a finance staff member not involved in the initial preparation of the FEMA project worksheet to ensure accuracy, completeness, and compliance with FEMA eligibility requirements. 4. Correction of Identified Error: Management has corrected the duplicated payroll costs of $104,434 by removing them from the project ending June 30, 2022 and ensuring they are only reported in the project beginning July 1, 2022. Total FEMA expenditures reported on the Schedule of Expenditures of Federal Awards were adjusted accordingly. In addition, VCUHSA has voluntarily prepared a letter to VDEM to alert them of the identified issue and request assistance on next steps to return the funds that were received in error. The letter will be followed up by an email. The Finance team has also notified the CFO of both the findings of the audit and the related corrective actions. Name(s) of the contact person(s) responsible for corrective action: Min Cummings, VP of Finance and Accounting, 804-827-0545 Planned completion date for corrective action plan: Notification of error to be sent to VDEM within 60 days of audit completion. All other planned actions to be implemented immediately for any future costs and expenditures.

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

Condition: Nine (9) employee payroll expenditures were claimed at an hourly rate greater than that approved by ISBE. Corrective Action Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. In addition, budgets will be monitored and amended accordingly within the period performance of the grant. Responsible Person: Janiesa Owens, Chief School Business Official Anticipated Completion Date: June 30, 2026

Finding 2025 – 002- Allowable Costs & Period of Performance (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. To strengthen policies and procedures surrounding grant disbursements and ensure expenses are properly approved and allowable under the specific grant budget, the Fiscal Service Office along with the Human Resources Department will implement a process to properly document, review, and approve all allowable grant pay rates and salaries.

2025-001 Costs Incurred Beyond the Period of Performance Criteria: According to 2 CFR §§200.1, 200.308, 200.309, 200.344, and 200.403(h), a non-Federal entity may only charge allowable costs incurred during the approved budget period of the Federal award’s period of performance, and any costs incurred before the Federal award was made that were authorized by the Federal awarding agency or pass-through entity. All financial obligations incurred under the Federal award must be liquidated within the required time period. Costs incurred outside the approved period of performance are unallowable and constitute questioned costs. Client’s Response: During the grant cycle, the Organization submitted for an extension but did not receive confirmation of said extension. During the current fiscal year, the Organization has implemented additional controls to ensure that all grant funding is expended within the timeframe allotted. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444

Finding 2025.004 – Period of Performance Federal Program Name: Continuum of Care Federal Assisted Listing Number:: 14.267 Recommendation We recommend that management implement additional controls and policies over period of performance. Staff who purchase items with grant funds should have additional training on period of performance requirements. Planned Corrective Action: TVCCA is strengthening its period of performance controls through the following actions: 1. Training – All employees with purchasing power will be trained on the deadlines of the grants they are responsible for. This training includes what the definition of obligation truly is, as well as allowable spend down period of their grants. Finance staff will also be trained on the timing and definitions of obligations. 2. Revised internal controls and workflow – Cutoff testing will be performed and added to the month close checklist on a quarterly basis to align with grant closing schedules. 3. Monitoring – Cutoff testing will be monitored on a quarterly basis in association with quarter ending checklist. Name of Contact Person: Max Logan, CFO, 860-425-6506, mlogan@tvcca.org Anticipated Completion Date: March 31, 2026

U.S. Department of Health and Human Services Department of Human Services respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 - June 30, 2024 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 PROGRAMS AUDITS Department of Human Services Low-Income Home Energy Assistance Program – Assistance Listing No. 93.568 Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Explanation of disagreement with audit finding: No disagreement. Action taken in response to finding: The Department has made changes in the Office of Budget and Finance Leadership team and continues to do so at every level. The Department will review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Currently, expenditures are recorded in the State’s Financial Management Information System (FMIS) with program cost accounting codes used to identify the funding source(s) for each activity. The system-generated report summarizes the information and includes the effective date of the activity. In turn, this same report is used to run the cost allocation to properly charge the exact costs to the funding source. Currently information is manually inputted into multiple spreadsheets to prepare the federal reports resulting in the possibility for errors. This significantly impedes the accuracy of the data being reported to federal grants and the provision of supporting documentation. As such, the Department will partner with external consultants to develop a better and more seamless recording structure for grant expenditures to the general ledger. This structure will require quarterly review by the Deputy Cost Allocation Revenue Management Director (CARM), the Cost Allocation Revenue Management Director, and the Deputy Chief Financial Officer. The Department will create a database and document repository to track the submission and reconciliation for federal grant reporting. The document repository will include the FMIS generated report and the cost allocation results table. Upon submission to the federal grant

U.S. Department of Education (USDE) Maryland State Department of Education respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023-June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. Finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Maryland State Department of Education 2024-023 Special Education Cluster– Assistance Listing No. 84.027, 84.173 Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MSDE will review and enhance its Standard Operating Procedures (SOPs) and internal controls to ensure that it charges expenditures (including accounts payable and payroll) to Federal programs that are incurred within an award’s allowable period of performance. Name(s) of the contact person(s) responsible for corrective action: Neeta Gandhi Executive Director Office of Program Fiscal Operations and Local Strategic Finance Jenna Meinl Director Office of Procurement and Contract Management Planned completion date for corrective action plan: June 30, 2025 If the USDE has questions regarding this plan, please call Patricia Ramallosa at 410- 767-0103. Page 2 Approval of Response to the CLA Findings and Recommendations: Document Version Approval Date Approved by Signature 1.0 Mar 29, 2025 Neeta Gandhi, Executive Director-Office of Program Fiscal Operations & Local Strategic Finance Mar 29, 2025 Jenna Meinl, Director-Office of Procurement and Contract Management Mar 29, 2025 Donna Gunning, Assistant Superintendent of Financial Policy, Planning, Operations & Strategy Mar 29, 2025 Shawn Rushing, Assistant Superintendent of Administration Mar 29, 2025 Krishnanda Tallur, Deputy Superintendent of Finance and Operations

1. The Maryland Military Department respectfully submits the following corrective action plan for the year ended June 30, 2024.Projects – Assistance Listing No. 12.401 (1) Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award's allowable period of performance. (2) Explanation of disagreement with audit finding: There is no disagreement with the audit finding. (3) Action taken in response to finding: The Department will carefully exam and allocate expenses to the fiscal year in which they are incurred, ensuring proper period assignment when expenses span multiple fiscal years. This will confirm accurate costs charged to the programs. 2. Audit period: July 1, 2023-June 30, 2024 3. The findings from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. 4. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS: a. Finding 2024-011: National Guard Military Operations and Maintenance (O&M

Finding 2024-010 – Period of Performance (Material Weakness) Finding: The Organization did not have good controls to ensure the period of performance requirements was met due to staff turnover. Management Response: Management concurs. Corrective action plan: •Implement a grant compliance checklist and training for staff by the end of 2025 to ensure expenditures are within the grant period. •Require pre-approval for all expenditures near grant end dates. •Quarterly compliance reviews. Responsible Party: CFO Completion Date/Status: Expected to be Implemented by end of 2025; ongoing review.

Corrective Action Plan – Federal Funds Review and Processing Audit Finding Reference: Response to Finding 2024-002: Improvement Control Over Period of Performance for Federal Awards Name of Contact Person and Completion Date: Krystal De Gray, COO of Nashua School District 09-22-2025 Planned Corrective Action: The Nashua School District acknowledges the finding related to the control over the period of performance for federal awards (Finding 2024-002). In response, the district will develop and implement a formal internal procedure to ensure that all purchases funded by federal awards are both placed and received within the established period of performance. This procedure will include appropriate review, documentation, and oversight to maintain compliance with federal grant regulations. To further strengthen internal controls, the Nashua School District will implement a procedure limiting purchases to occur no later than 15 days prior to the grant’s end date. Additionally, all necessary services must be received and completed prior to the expiration of the grant period. Mario Andrade Krystal De Gray Superintendent Chief Operating Officer

2024-003 The City charged costs that were incurred prior to the beginning of the period of performance of the grant. Helen Tomic, Long Range Planning Manager December 31, 2025 The City will implement control procedure to prevent the charging of costs before the period of performance.

Audit Finding Reference: 2024-001 Description of Finding: The audit revealed that grant expenditures were incurred outside the authorized performance period, resulting in non-compliance with grant regulations and potential cost disallowance. Planned Corrective Action • Conduct a comprehensive assessment of existing procedures to identify gaps that led to noncompliance with grant regulations. • Ensure timely submission of grant applications. • Implement enhanced oversight and monitoring processes for all grant-related expenditures to ensure alignment with policy 2 CFR 200.1. • Maintain detailed documentation of all award dates and expenditures to provide a clear compliance record. • Ensure all documentation is easily accessible and systematically organized for audit purposes. • Ensure pre-award costs are allowable only to the extent they would have been allowable if incurred after the effective date and only with written approval from the Federal awarding agency (as per 2 CFR 200.458). • Establish a process for obtaining and documenting written approval for pre-award costs. • Provide comprehensive training on compliance with Uniform Grant Guidance to all relevant staff. • Review and update policies and procedures related to grant expenditures regularly to ensure they are current and compliant with federal regulations. • Assign accountability for monitoring and reporting compliance to specific roles within the organization. The Business Manager, Elizabeth Bouchard, will be responsible for implementing this plan beginning with the Fiscal Year 2026 grant cycle. As of September 2025, non-compliance issues have been identified and addressed, documentation has been maintained to track award dates, and training has been provided to designated roles within the District. In addition, procedures to maintain detailed documentation of all award dates and expenditures to ensure a clear compliance record have been shared with all District Administrators utilizing grant funds.

Finding 2024-004 – Key Personnel Requirements ● Issue: No internal controls to track/approve changes in key personnel (repeat of 2023-007). ● Corrective Actions: 1. Formalize procedures for notifying federal funders of personnel changes. ● Responsible Party: Operations Manager, Executive Director ● Timeline: Finalize procedure by December 2025.

The purchase of the grant management system will interface directly with the organization’s accounting software, allowing for the automated extraction of financial data. This data will be systematically mapped to the corresponding budgetary lines of each grant to ensure accurate tracking and reporting. On a monthly basis, the Financial Grant Coordinator will collaborate with Senior Directors and Program Directors to review financial activity. These reviews aim to verify that expenditure aligns with the allowable costs defined by each grant, ensuring full compliance with funding requirements. Corrective: Budget vs. actual reviews are conducted with senior directors to evaluate financial performance and ensure alignment with programmatic, administrative, and funding guidelines. During these reviews, directors assess which costs are permissible and identify any expenditure that falls outside allowable parameters. Non-compliant costs are reallocated to appropriate programs that permit such expenses or to administrative accounts as necessary.

The Agency agrees with the finding. We will provide training to program managers who are approving program expenditures to ensure proper allocation of costs to the appropriate grant cycles. We will also update our purchasing procedures to ensure that the proper allocation of costs is reviewed prior to supervisor's approval of the cost.

USAID Foreign Assistance for Programs Oversees – Assistance Listing No. 98.001 Recommendation: Management should review its existing control structure and ensure that there are adequate processes and controls to ensure only expenditures incurred during the period of performance are booked to Federal programs and that the correct program codes are charged, based on the underlying supporting documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Training on the Federal awards regulations to be provided to the country office. In addition, adjustments will be made to the review structure of expenditure to ensure full compliance. Follow up of the implementation status will be carried out by HQ finance. Name(s) of the contact person(s) responsible for corrective action: Florence Ruona Planned completion date for corrective action plan: September 30, 2025

County department personnel changes have been implemented, which address this deficiency. Additional training from the Auditor’s Office and state grantors has occurred for newer staff in certain departments with large amounts of federal and state awards.

Action taken in response to finding: Trilogy will conduct a thorough review of our current cost allocation procedures to identify gaps related to the timing and eligibility of expenses. Based on this review, we will revise our process to ensure that only allowable costs incurred within the grant’s period of performance are charged. A multi-tiered review process will be established, to verify expense timing and relevance and to confirm compliance with grant terms. Staff will review descriptions and flag transactions that fall outside the grant’s period of performance. These controls will prevent such costs from being allocated unless properly justified and approved. Staff involved in grant management will receive updated training on federal cost principles, including the importance of period-of-performance compliance. Written guidance will be distributed to reinforce expectations. Name(s) of the contact person(s) responsible for corrective action: Shunita Rhodes & Hagar Buster Planned completion date for corrective action plan: July 2025

Tuerk House, Inc. recognizes the importance of maintaining compliance with federal grant requirements related to allowable costs and documentation standards. The Organization acknowledges the deficiencies identified in the areas of time and effort reporting and supporting documentation for expenditures charged to grant programs. To address this finding, Tuerk House is taking the following corrective actions: ·Implementing a formal time and effort certification process that requires employees to certify actual time worked on federal grant activities on a regular basis, rather than relying on budgeted allocations. ·Developing a standardized cost allocation methodology that aligns with actual grant activity and is supported by verifiable documentation. ·Requiring that all expenditures charged to federal awards be supported by complete and accurate source documentation, including vendor invoices, timesheets, and approvals. ·Establishing a document retention policy consistent with 2 CFR § 200.334 to ensure all supporting records are retained for the required period and readily accessible for audit or review. Training sessions for program and finance staff will be conducted to ensure consistent understanding and application of these updated policies and procedures. Organization Contact Person Responsible for Corrective Action – Joseph Koehler, Director of Finance Anticipated Completion Date – June 30, 2025

Recommendation: We recommend that only costs incurred during the period of performance be charged to the grant. For payroll in which pay periods extend over multiple budget periods, we recommend prorating the amount charged to the grant by the days worked within the grant period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1. Create list of grants with pertinent contract terms for monitoring and reference. Highlight grants with term end dates within the fiscal year. 2. Update Grant Tracking workpapers to alert on grant year end and create allocation tab to separate payroll expenses that crossover grant end terms. Review non-payroll expenses to ensure they belong to proper grant term. 3. Monitor progress and review grants at fiscal year end to ensure process was followed. Name of the contact person responsible for corrective action: Keith Flores, CFO Planned completion date for corrective action plan: 8/31/2025

Finding: 2024-085 - One sample of five grants with level of effort provisions in the grant award notification did not meet the level of effort for key personnel required by the federal agency. Questioned Costs: None. Assistance Listing Number: 84.031 Assistance Listing Title: Higher Education Institutional Aid Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding. Corrective Action (corrective action planned): The findings have been corrected. OGCA developed a policy in place to ensure the proposals are submitted by the department in a timely manner for OGCA to review thoroughly and to go over any questions that may arise. OGCA will upon receiving the federal award, review it with the departmental proposal to ensure the level of effort listed on any Granting Award Notification (GAN) matches what was proposed. Ifthe GAN does not match what was proposed, OGCA will reach out to the department and agency, as necessary. Completion Date (list anticipated completion date): Completed Agency Contact (name of person responsible for corrective action): Anne Doyle, Finance Director, College of Indigenous Studies, 907-474-7106; Michelle Bunch, Office of Grants and Contracts Associate Director, 907-474-6173

Finding: 2024-035 -Six of seven award extensions for the NGMOMP program were untimely. Additionally, one award was not closed timely. Questioned Costs: None Assistance Listing Number: 12.401 Assistance Listing Title: NGMOMP Views of Responsible Officials (state whether your agency agrees or disagrees with the finding if you disagree, briefly explain why): DMVA concurs with the finding. Corrective Action (corrective action planned): Administrative Services has consistently provided notification and set clear deadlines to the Federal and State Program Managers of an expiring award under the Cooperative Agreement (CA). This notification has included a financial report detailing posted expenses and open obligations and when applicable, a copy of the most resent approved extension for reference. Due to inconsistent and untimely responses, the Finance officer in conjunction with the Administrative Services Director will update and strengthen written procedures, elevating responsibility for follow-up when responses are not received to ensure timely submission of extension requests and award closeouts following 2 CFR 200.303(a), 2 CFR 200.308(e), and 2 CFR 200.344. Updated documented procedures and training will be provided to the components under the CA. Completion Date (list anticipated completion date): 06/30/2025 Agency Contact (name of person responsible for corrective action): Bob Ernisse Pamela Wiederspohn

The Company acknowledges the importance of accurately documenting key personnel requirements in support of federal contract compliance. The audit noted one contract with two projects where the individual listed as key personnel did not match the most current contract documentation. However, internal “load sheets” and program communications consistently reflected the correct personnel assignments, and there was no impact on contract performance or deliverables. Given the isolated nature of these discrepancies and their lack of effect on program execution or financial reporting, the Company does not consider this matter to be material. Nonetheless, to strengthen internal controls, the Contracts Department now records and maintains all key personnel data directly in Costpoint. Additionally, the Controller performs a quarterly internal review of these records to verify accuracy and completeness. These measures provide added assurance that the Company remains fully compliant with federal award requirements. Director of Contracts/Elena Einstein now oversees this control which was put into place as of April 2025.Notwithstanding these findings, management is confident that the accompanying financial statements present fairly, in all material respects, the Company’s financial position for the fiscal year ended September 30, 2024.

Finding 2024-021 National Guard Military Operations and Maintenance (O&M) Projects, ALN 12.401 - Extension Procedures Management Views DMVA agrees with the finding. Planned Corrective Action DMVA will set annual recurring calendar appointments to review program activities with the program managers one month before the end of the period of performance to ensure a joint understanding of extension requirements, allowing sufficient time to prepare and submit period of performance extension requests timely, if needed. Anticipated Completion Date September 1, 2025 Responsible Individual(s) Rachelle Breeden, DMVA