Corrective Action Plans

Corrective Action: What we've already been doing to correct the issue LifeWire has strengthened oversight within Services by consolidating the Services and Rapid Rehousing programs under a single Director, creating clearer accountability for expenditure documentation. The expanded multi-tier approval workflow (Advocate → Manager → Director → Finance) now includes a documentation completeness check at each stage, requiring that underlying support for all charges be attached and verified before a transaction advances toward payment. LifeWire has updated its policies and procedures to explicitly require that underlying documentation supporting the nature and amount of each expenditure be retained at the time the charge is generated from the program services department, consistent with 2 CFR §200.403(g). This will include clear guidance on what constitutes sufficient documentation (e.g., invoices, receipts, lease agreements, or other source documents) and the requirement that payment confirmation alone is not sufficient. What else we are putting in place LifeWire has implemented training for all Services staff on federal documentation standards, reinforcing that charges to federal programs must be supported by documentation that evidences both the nature and the amount of the expense. The Services Director is responsible for delivering and maintaining this training on an ongoing basis. All staff will be required to formally acknowledge completion of the training and their understanding of the updated requirements. Responsible Staff: Olivia Montgomery •Advocates and program staff (generating and attaching underlying documentation at pointof charge) •Services Managers (first level review for documentation completeness) •Services Director (program oversight and secondary review) •Executive Director (internal audit oversight; reviews Director of Services approvals andmonitors compliance) •Finance Director / Finance Department (final documentation review, approval, and paymentoversight) Anticipated Completion Date: Policy and procedure updates and staff training will be completed, with full implementation and demonstrated compliance expected by Q3 2026.

Provide funder-led training sessions for management and staff, maintain current budget tracking incorporated federal program compliance into relevant staff performance evaluations, implement a dual-storage documentation methodology combining a shared drive and a document management system (DMS) and update the Finance Manual.

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

Due to inadequate monitoring of grant deadlines and project implementation timelines, the Organization did not obligate certain federal funds before the expiration of the award period. As a result, a portion of the awarded funds remained unused and was no longer available for program activities. The Organization will implement enhanced grant management procedures to ensure that federal funds are obligated and utilized within the approved period of availability. Corrective actions include: 1. Maintaining a centralized grant tracking system that identifies award periods, obligation deadlines, expenditure deadlines, and closeout requirements. 2. Requiring quarterly reviews of grant balances and project progress by program and finance personnel. 3. Establishing written procedures for monitoring unobligated balances and addressing delays in project implementation. Providing training to program managers and fiscal staff regarding federal grant requirements, including obligation and period-of-performance requirements. Requiring management review of all federal awards at least 90 days prior to expiration to identify and address any risk of unexpended or unobligated funds. Anticipated Completion Date: Immediately

FINDING – Federal Award Finding 2025-001: Agency: U.S. Department of Health and Human Services (CSBG) Program: Community Service Block Grant (AL No. 93.569) Significant Deficiency and Noncompliance over Allowable Costs / Period of Performance Repeat Finding: No Condition: During our testing over allowable costs, we identified 2 transactions in the amount of $38,225 that were incurred in fiscal years 2022 and 2023; however, those costs were recorded as federal expenditure and revenue in fiscal year 2025. The current CSBG grant covering fiscal year 2025 covers the period October 1, 2024 – September 30, 2025, as such, those costs were recorded outside of the period of performance and as such are unallowable. Recommendation: We recommend that management strengthen controls over the timing of federal expenditure recognition to ensure costs are recorded in the proper period of performance. Additionally, the entity should implement procedures to review and reconcile expected expenses to actual invoices received on a periodic basis to ensure all vendor invoices have been timely received. Auditee Response and Corrective Action Plan: UPO has recently implemented two methods for procuring goods and services to address the noted condition. Use of the P-Card for micropurchases and the Purchase Request for larger purchases. P-Card purchases will allow recurring vendor invoices and payments to be captured in real time and recorded in the appropriate billing and funding period. Mandatory use of Purchase Request/PO for all other purchases, to allow the program and finance team to monitor invoices and obligations, and record them within the funding period.

Audit Finding Reference: 2025-003 Improve Controls over Period of Performance Planned Corrective Action: The District has strengthened its grant management and closeout procedures to ensure that all expenditures charged to federal awards are incurred, processed, and paid within the applicable period of performance. Specifically, the District will: 1. Implement a formal grant closeout checklist that includes a review of all open purchase orders, encumbrances, unpaid invoices, and outstanding obligations prior to submission of final expenditure reports. 2. Require reconciliation of grant expenditures between the Grants Office, Special Education Department, and Business Office before final grant reports are submitted. 3. Establish periodic reviews of open encumbrances throughout the year to identify outstanding obligations and ensure timely processing of invoices. 4. Designate backup personnel and document grant management procedures to ensure continuity during staffing transitions or vacancies. 5. Require supervisory review and approval of all grant closeout documentation to verify that all allowable expenditures have been recorded and reported appropriately. 6. Provide training to personnel responsible for grant administration and financial reporting regarding federal period-of-performance requirements and grant closeout procedures. Planned Implementation Date of Corrective Action: The revised grant monitoring and closeout procedures have been implemented for all active federal grants and will be fully incoiporated into the District's grant management process beginning with the current fiscal year. Person Responsible for Corrective Action: Grants Manager Signature Derek Pinto, Assistant Superintendent of Finance

Period of Performance Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: We recommend that the Organization design, implement, monitor and maintain evidence over internal controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will assign responsibility for maintaining source documentation to a specific individual or team and develop a system for organizing and storing source documentation, such as a centralized electronic database. Monitoring and testing procedures will be implemented to ensure that source documentation is being maintained and is readily accessible. Lastly, there will be regular reviews and updates to the system for organizing and storing source documentation as needed to ensure ongoing effectiveness. Name of the contact person responsible for corrective action: Lyn Elliot, CEO Planned completion date for corrective action plan: 7/1/2026

Agency personnel will ensure costs that are charged to federal awards were incurred during the applicable period of performance and recorded in the correct period.

Condition: The Town’s files for a project totaling $90,550 that was obligated at December 31, 2024 only contained quotes and not documentation that showed that an obligation to pay was incurred at December 31, 2024. Corrective Action Planned: The Town will implement enhanced controls and documentation standards to ensure that all reported obligations are based on correct and legal documentation. The Town will require that all obligations be supported by executed contracts, purchase orders, or other legally binding agreements clearly dated prior to the reporting cutoff. Anticipated Completion Date: Fiscal year 2026 Contact: Fred Aponte, Town Accountant

2025-00I Condition: The center did not maintain adequate documentation to support compliance with Federal requirements related to allowable costs, period of performance, and procurement standards. Auditor's Recommendation: We recommend The Center review and revise its documentation policies and procedures to ensure that compliance is met with regards to federal awards. Management response: Management agrees with the finding and has collaborated with grant personnel to implement standardized personnel activity reporting and cost allocation documentation for all federal grants. The Center will strengthen controls to ensure that only allowable costs incurred within the approved grant period are charged to federal awards. In addition, procurement procedures have been revised to ensure compliance with 2 CFR §§ 200.317-200.327. Corrective actions have been implemented or are in progress and apply to all federal awards moving forward beginning in FY2026.

Period of Performance – Assistance Listing No. 93.958 Recommendation: Management should review and revise its process for allocating costs to federal grants to include additional layers of review and so that costs for which some or all are from outside of the period of performance, may be appropriately excluded from the federal grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will revise cost allocation procedures to add program and finance review steps to ensure that only costs incurred within the applicable period of performance are charged to federal grants. Costs identified as outside the allowable period will be excluded or reclassified. Updated procedures will be communicated to relevant staff and monitored for compliance. Name(s) of the contact person(s) responsible for corrective action: George Pepe Planned completion date for corrective action plan: 6/30/2026

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.

Federal Program Title: R&D Cluster and TRIO Cluster Assistance Listing Number: R&D and 84.TRIO Type of Finding: • Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that UEC strengthen its controls over expenditure recognition to ensure costs are recorded in the appropriate fiscal period and enhance payroll review procedures to ensure timesheets are submitted and reviewed in a timely manner to support accurate payroll reporting. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: University Enterprises Corporation (UEC), as the entity responsible for fiscal oversight, compliance, and financial reporting for sponsored programs, has initiated and continues to implement enhancements to strengthen internal controls and ensure expenditures are recorded in the appropriate fiscal period. These actions include strengthening period-end review and accrual practices to improve fiscal accuracy, reinforcing expectations for timely payroll documentation and supervisory review through formal communication and standardized procedures, clarifying roles and responsibilities across UEC and campus partners to support consistent compliance, enhancing documentation standards and internal review processes, and establishing ongoing monitoring to ensure sustained adherence to federal requirements. These efforts build upon recent communications and procedural updates issued to Deans, Principal Investigators, and campus leadership to reinforce compliance expectations and accountability. Contact(s) Responsible for Corrective Action: UEC Executive Director Planned Completion Date for Corrective Action: In action as of February 2026.

Condition: During the fiscal year ended June 30, 2025, NeoMed Center, Inc. used the advance payment method through the HHS Payment Management System (PMS) to obtain federal funds. In certain instances, drawdowns were requested based on aggregated projections and liquidity needs before specific eligible expenses were fully identified and ready for immediate disbursement. Although the funds were later applied to eligible expenses incurred within the authorized award periods, the absence of a documented, expense-level linkage at the time of each drawdown created a temporary timing difference between cash receipt and expense recognition. Accordingly, funds that did not meet revenue recognition criteria at the end were recorded as Unearned Revenue. Consistent with U.S. GAAP and federal grant revenue recognition policies, the Unearned Revenue balance of approximately $1.8 million as of June 30, 2025, represents federal funds received in advance, for which revenue recognition was contingent on incurring future eligible expenses. This balance was analyzed, reconciled, and recognized as eligible expenses were incurred, as supported by reconciliations provided to the external auditors, and was appropriately disclosed in the notes to the financial statements for the years ended June 30, 2025, and 2024. Planned Corrective Action: To prevent recurrence, NeoMed Center, Inc. adopted and implemented “Federal Fund Drawdown via HHS Payment Management System (PMS)” (Policy No. NMCIP 46), approved by the Board of Directors and effective March 2026. The policy requires drawdowns to be based solely on immediate cash needs, supported by a documented short-term cash forecast, and prohibits requesting funds for expenses not yet incurred or not ready for immediate disbursement. Key internal controls include: • Mandatory preparation of a cash forecast by award prior to each drawdown. • Independent review and approval by the Finance Department prior to submission of drawdown requests in PMS. • Monthly reconciliations between PMS, bank accounts, and the general ledger. • Monitoring of the time elapsed between the receipt of funds and their disbursement, with a maximum internal standard of three (3) business days. • Documentation and formal approval of any exceptions. • Adoption of an internal benchmark of 8.33% per month (1/12 of the annual award) as a control parameter. • Clear definition of segregation of duties; and • Periodic reporting to Senior Management and the CEO. Management concludes that this matter resulted from cash-management timing and not from misuse of federal funds. Monitoring: Management will perform monthly monitoring of federal fund drawdowns beginning April 1st ,2026 to ensure they are limited to immediate cash needs and supported by documented short‑term cash forecasts. Drawdowns will be reconciled monthly to the general ledger, bank statements, and allowable expenditures incurred within the approved period of performance. Any timing variances or exceptions will be reviewed and documented. Monitoring results will be reviewed by senior management to ensure continued compliance with Uniform Guidance requirements. Responsible Official: Jose A. Guzman Machuca Time frame: This condition was identified on February 20, 2026, and is expected to be resolved by May 2026, upon the implementation of formal monitoring procedures and enhanced remittance controls.

Period of Performance Health Centers Cluster – Assistance Listing No. 93.224 and 93.527 Recommendation: We recommend the Organization implement a comprehensive and thorough process to review and monitor expenditures charged near the beginning and end of grant periods to ensure the expenditures incurred are within the authorized federal award grant period. Action taken in response to finding: A procedure was implemented March 2026 to perform an internal audit of the expenditures charged within the pre-and-post 30 days of a grant year transition to ensure expenses are occurring within the appropriate grant year prior to draw submission and will continue moving forward. A remedy of $87,554.96 was implemented over two grant draws within the grant year to address the population of period of performance crossing expenses. Name(s) of the contact person(s) responsible for corrective action: John Robinson, CFO Planned completion date for corrective action plan: New policy and procedure implemented in March 2026 and will be carried forward.

Planned Corrective Action: The City acknowledges the finding. Based on the recommendation, the City plans to do the following: • Establish separate program/project accounts within the financial system for each WIC grant award to ensure expenditures are recorded and tracked individually by grant period. • Develop and implement written procedures requiring that all expenditures be reviewed and recorded based on the date incurred relative to the grant’s period of performance. • Perform monthly reconciliations of WIC expenditures by grant to verify that costs are accurately recorded and aligned with the appropriate funding period. • Implement period-end cutoff procedures to ensure expenditures near grant end dates are reviewed and properly assigned to the correct grant period. CHD Fiscal will begin implementing the plan by creating the program codes and will meet with WIC to establish roles for the written procedures. Anticipated Completion Date: 06/30/2026 Responsible Contact Person: Mark Menkhaus, Division Manager

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND OTHER MATTERS U.S. Department of Justice 2025-002 Department of Justice Second Chance Act Community-based Reentry Program – Assistance Listing No. 16.812 Recommendation: We recommend that TASC follow its established procedures for charging allowable expenses to the grant during the period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will follow established procedure to make sure costs are recorded in the proper period. Management will review the procedure with all accounting staff. Name(s) of the contact person(s) responsible for corrective action: Roy Fesmire, CFO Planned completion date for corrective action plan: June 30, 2026

Reference Number: 2025-021 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Health and Social Services State Division: Division of Medicaid and Medical Assistance Federal Program: Children’s Health Insurance Program Assistance Listing Number: 93.767 Award Number and Period: SAI000005399 (10/1/2023 – 9/30/2024) Compliance Requirement: Period of Performance Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Recommendation: The Division should review and enhance its procedures and internal controls to ensure that it maintains documentation that expenditures charged to the program 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: To prevent recurrence, we are implementing the following actions: 1. Enhanced Monitoring Controls o Establish a centralized tracking system for all awards, including start and end dates. 2. Staff Training and Accountability o Conduct mandatory training for program and finance staff on compliance with period of performance requirements. o Assign clear responsibility for monitoring award timelines to designated personnel. 3. Pre-Closeout Review Process o Introduce a formal pre-closeout review 60 days before the award end date to identify and resolve outstanding obligations. o Require certification from both program and finance leads confirming that all expenditures fall within the allowable period. 4. Post-Expenditure Review o Perform monthly reconciliation of expenditures against the period of performance. o Immediately flag and correct any discrepancies identified. Name(s) of the contact person(s) responsible for corrective action: Joel Riley – Program Integrity Chief Anthony Yeager – Fiscal Manager Planned completion date for corrective action plan: July 31, 2026

March 25, 2026 Finding Number: 2025-002 Finding: (Significant Deficiency) AL#84.048: Career and Technical Education Basis Grants to States, U.S. Department of Education, Award No. V048A240016, Passed through the Kansas State Board of Education Contact Person: Taben Azad, Director, Budgeting Planned Corrective Action: The District acknowledges the finding. The Budget Department will implement a training process for all internal budget analysts as well as Career and Technical Education (CTE) program managers and business office staff on the requirements of 2 CFR 200.308 and 200.309, focusing on the “Period of Performance” and allowable cost principles. Additionally, the Budget Department will establish both a quarterly and year-end reconciliation process where the CTE assigned budget analyst will compare all expenditures against the authorized period of performance dates listed in the Perkins V Local Grant Handbook and specific grant award terms. Anticipated Completion Date: These processes will be implemented immediately.

Reference Number: 2025-007 Prior Year Finding: 2024-010; 2023-008: and 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) Compliance Requirement: Period of Performance Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that, prior to charging costs to the program, they are incurred within an award’s allowable period of performance and that payments are reviewed and approved by a supervisor who has knowledge of costs that are allowable under the program. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: The Department will review its procedures and internal controls and update as necessary to ensure that all expenditures incurred on an award fall within the allowable period of performance. Scheduled Completion Date of Corrective Action Plan: June 30, 2026 Contacts for Corrective Action Plan: Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

Audit Finding Reference: 2025-001 Improve Oversight Over Period of Performance of Federal Awards Planned Corrective Action: To address the material weakness regarding the period of performance, the Longmeadow Public Schools will implement the following actions: Procedure Revision: The Longmeadow Public Schools will update internal control procedures to require that all invoices charged to federal grants explicitly state the dates of service. Staff pro-cessing invoices against Federal grant funds will be instructed to verify these dates against the au-thorized period of performance listed on the Grant Award Notification before processing payment. Staff Training: The Town will conduct mandatory training for the Special Education Department and central office administrative support staff. This training will focus on 2 CFR §200.309, specif-ically emphasizing that costs are only allowable if incurred during the approved budget period, re-gardless of when the invoice is received or paid. Name of Contact Person: Thomas Mazza, Assistant Superintendent for Finance and Operations, Longmeadow Public Schools, tmazza@longmeadow.k12.ma.us Completion Date: Prior to July 1, 2026

Special Education Cluster – Assistance Listing No. 84.173 Recommendation: We recommend that the Board strengthen internal controls over federal grant expenditure by implementing procedures to ensure costs are incurred within the approved period of performance prior to being charged to federal awards. This should include enhanced supervisory review, system controls where feasible, and training for staff responsible for grant accounting and compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To address this issue, the Board will implement the following corrective actions: 1. Enhanced Review Procedures: All payroll journal entries to reclassify expenditures charged to federal grants will be reviewed by Lead Staff Accountant and/or Budget Manager to verify that the time worked along with the transaction accounting date falls within the approved grant period of performance prior to posting. 2. System and Process Improvements: The Board will explore report customizations regarding payroll transactions to provide more visibility of the actual days worked regardless of the transaction accounting date. This system improvement will help prevent payroll journal entry reclassifications from being charged to grants outside of the approved period of performance. These procedures will strengthen internal controls over federal grant expenditures and help ensure compliance with federal regulations. Name(s) of the contact person(s) responsible for corrective action: Sherri Fisher-Davis Planned completion date for corrective action plan: March 2026

Finding 2025-002: Noncompliance with OMB Compliance Supplement; Period of Performance (H) for Assistance Listing Number (ALN) 93.958 Block Grants for Community Mental Health Services Criteria: The Code of Federal Regulations (CFR) Sections 200.308, 200.309, and 200.403(h) states “a non-Federal entity may charge only allowable costs incurred during the approved budget period of a federal award's period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entities.” Costs incurred before or after the period of performance are unallowable unless explicitly approved. Condition: During our testing of expenditures charged to ALN 93.958, we identified 2 transactions out of a total sample of 15 totaling $192 that were incurred outside of the award’s period of performance. Corrective Action Plan: To ensure compliance and accurate reporting, we established internal control protocols for the formal review of service dates, verifying that all expenditures correspond to the appropriate period of performance. The Controller's signature on formal, documented month end checklists will serve as confirmation that all year-end invoices have been checked for appropriate period distribution. Responsible Person for Corrective Action Plan: Addy Hiles (Controller) Implementation Date for Corrective Action Plan: September 2025

2025-003 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing Number 21.027 Recommendation: We recommend procedures be strengthened to ensure that charges to the grant program are obligated and/or incurred within the period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City acknowledges the finding related to documentation supporting the period of performance for expenditures reported under the SLFRF revenue loss category. Because the City applied the standard allowance for revenue loss and did not track specific expenditures to the grant at the transaction level, some expenditures initially provided for testing were outside the period of performance, although sufficient eligible expenditures existed within the allowable period. To address this issue, the Finance Department will implement procedures to maintain supporting schedules identifying government service expenditures incurred within the applicable period of performance that support amounts reported under the revenue loss category. Finance will also implement a review process to verify that expenditures identified for compliance or audit testing meet applicable period of performance and obligation requirements. These procedures will strengthen documentation and ensure expenditures supporting SLFRF revenue loss are clearly identified and supported for compliance purposes. Name(s) of the contact person(s) responsible for corrective action: Michael Tucker, Deputy Finance Director Planned completion date for corrective action plan: Implemented immediately and effective for all current and future federal awards.

2025-002 Special Education Cluster - Assistance Listing Number 84.027, 84.173 Recommendation: We recommend procedures be strengthened to ensure that charges to the grant program are incurred within the period of performance included in the grant award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will implement procedures to ensure that expenditures charged to federal awards are incurred within the approved period of performance in accordance with 2 CFR §§ 200.308, 200.309, and 200.403. The School Department will enhance its grant monitoring procedures by maintaining a tracking schedule of grant periods of performance and reviewing invoices and payment requests for compliance with grant award dates prior to processing. School Department Finance staff will also provide guidance to departments administering grants to ensure expenditures are incurred and submitted within the allowable grant period. These procedures will strengthen internal controls and reduce the risk of expenditures being charged outside the approved period of performance. Name(s) of the contact person(s) responsible for corrective action: Brian Cisneros, Business Administrator Planned completion date for corrective action plan: Implemented immediately and effective for all current and future federal awards.