Corrective Action Plans

Finding 2025-001 - Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Equipment and Real Property Context: During testing, we noted the Unit spent $160,847 on flooring upgrades which exceeded the $5,000 federal equipment and real property threshold. However, the Unit did not perform any of the required federal compliance steps related to the flooring purchase (getting approval before making the purchase, adding the flooring purchase to the capital asset listing, and performing an inventory of the flooring). The Unit believed the flooring purchase did not require approval because it does not meet the criteria of a major renovation under Head Start guidelines. However, as noted in the criteria above, the flooring still qualifies as an equipment and real property purchase. Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: The Consortium management disagrees with the finding. Description of Corrective Action Plan: The Consortium plans to discuss this matter with ACF/HHS to determine if the finding is out of compliance. Anticipated Completion Date: June 30, 2026

FINDING 2025-004 Finding Subject: Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address): (765) 795-4664 / mshrout@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We have contacted our Capital Assets vendor to add columns to the report to identify federal purchases. Anticipated Completion Date: July 1, 2027

FINDING 2025-004 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Education Stabilization Fund grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

Auditor Description of Condition and Effect. The College does not have a formal process or system in place to track fixed assets acquired with federal award funds. As a result, there is no centralized or consistent documentation of asset details, location, or usage for assets purchased with federal funds. Without proper tracking, the entity is at risk of noncompliance with federal regulations, potential loss or misuse of federally funded assets, and challenges in conducting accurate inventories or audits. This could lead to questioned costs or disallowed expenditures during federal reviews. Auditor Recommendation. That the College implement a formal fixed asset tracking system that complies with 2 CFR §200.313. This system should include procedures for recording asset details, conducting periodic inventories, and reconciling records. Staff responsible for asset management should be trained on federal requirements to ensure ongoing compliance. Corrective Action. In its Jenzabar accounting system software, the College will code fixed assets that were, and will be, acquired with federal award funds. The College will also set reminders in May 2026, and at least once every two years thereafter, to conduct an inventory and reconcile this with the accounting records. Responsible Persons. Tom Zeidel, Vice President of Finance and Facilities and Troy Slater, Director of Business Office. Anticipated Completion Date. October 31, 2025.

Finding 2025-003 - Internal Control over Major Federal Program Compliance Program : Education Stabilization Fund (CFDA 84.425) Condition: Lack of policies and procedures for asset inventory management. Repeat Finding and Material Weakness Corrective Action Plan: The District will implement procedures to ensure asset physical inventories are completed and inventory records are completed and updated in accordance with the requirements of 2 CFR 200.318 of the Uniform Guidance. The district will provide training to responsible personnel. Planned Completion Date: March 31, 2026 Responsible Contact Person: Dr Marty Spence, Superintendent (417) 469-3260

Condition: The University did not complete a physical inventory of the property within the last two years. Planned Corrective Action: Management will establish a formal inventory schedule that mandates physical inventory and reconciliation at least once every two years. Designated personnel will be assigned responsibility for executing and documenting the inventory process. Additionally, internal controls will be enhanced through periodic monitoring and reminders to ensure timely completion and proper recordkeeping. Contact person responsible for corrective action: David Dettloff, Staff Accountant Anticipated Completion Date: February 26, 2026

2025-003 – Significant Deficiency and Noncompliance – Federal Equipment Corrective Action Plan: The City will implement a centralized Federal Equipment Register capturing all required data elements under 2 CFR §200.313(d) and assign responsibility to the Logistics Officers of the Fire Department, Police Department, and Department of Public Works, with oversight by Finance. A full physical inventory of federally funded equipment will be completed and reconciled by March 31, 2026, and biennial inventory procedures will be established. Staff will be trained on equipment management requirements, and documentation will be retained to ensure compliance. Anticipated Completion Date: March 31, 2026

The School has hired a consultant for training.

Management Response/Corrective Action Plan: A formal procedure will be drafted between the city and school to ensure the city is made aware of any assets that are federally funded so they can be designated as such in Munis. The school department will continue to provide the annual asset list to the city and will now include funding source notations for each asset.

The Finance Director updated property records for one asset to include the FAIN number as required. The Superintendent and Finance Director will coordinate with Principals and Directors to ensure that all equipment is accounted for by conducting and certifying a complete physical inventory at least once every two years. A written explanation and report to the central office will be required for missing items. Prior to moving items, a transfer form must be signed by both the sending and receiving parties, and the inventory system will be updated to reflect the transfer. Any items being disposed of or surplused must also be marked as such in the system. If items are sold, a record of sale and deposit of funds should be maintained. Training for Principals, directors, and others will be provided as needed.

Every Woman's Place has fully implemented corrective action to address the induirect cost calculation and reporting issues identified in this exception. The Agency has formally adopted a signle direct allocation methodlogy, consistent with it FY2021 cost allocation plan, and has discontinued the use of de minimis or alternative indirect cost methodlogies. The cost allocation policy has been updated to clearly define the approved allocation medthod, allocation bases (included square footage, FTE, and usage where applicable), and the treatment of administrative and shred costs. This methodology is applied conssitently across allo programs and funding sources to ensure equitable distribution and compliance with 2 CFR 200 requirements. In addition, the Agency now requires annual board-approved certification of the cost allocation methodlogy. Allocation calculation are documented using standardized worksheets and reviewed as part of the monthly and quarterly financial review process to ensure accuracy and consistency prior to financial reporting and FSR submission. The procedures are documented in the Agency's Fiscal and Cost Allocation procedures manual and are fully operational

Claims are submitted to fiscal court for approval for payment. Checks are processed the following day. With the CSEPP program some payments are dependent on advance payments being received. Master inventory is maintained at state level. Local inventory is being updated and will be completed by 12/31/2025.

The District has a physical inventory of all assets scheduled for 2025. The purchase order has been generated. Anticipated Date of Completion: Immediately. Contact Person: Alicia Evans, Ed.D., Assistant Superintendent of Business Affairs.

Federal Agency: US Department of Agriculture Federal Program Name: Extension Services at 1890 Colleges Assistance Listing No.: 10.512 Recommendation: We recommend management implement procedures for physical inventory to be taken within a two-year timeframe as well as maintain evidence of assets possession such as photos of the property and equipment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In October 2025, the University purchased software to facilitate managing inventory within the Facilities Department. Staff have been trained on the software in preparation for implementation. Beginning in January 2026, all purchases will be inventoried on a daily basis and input into the software. Inventory will be maintained and updated daily. Monthly reports will be submitted to the CFO. Name(s) of the contact person(s) responsible for corrective action: Dr. Heather Bigard, Chief Financial Officer and Director of Facilities. Planned completion date for corrective action plan: June 30, 2026

Views of Auditee and Corrective Actions: GDOE agrees with the finding. The audit identified one asset for which the acquisition cost recorded in the property records did not match the vendor invoice amount. The discrepancy was attributed to a data entry error during the initial recording of the asset. Plan of action and completion date: The asset record has been corrected in Munis, the asset system of record, to accurately reflect the correct acquisition cost based on the vendor invoice and supporting documentation. Plan to monitor and responsible officials: The GDOE Property Management Office will continue to conduct periodic internal reviews of newly recorded assets to ensure that acquisition costs entered into Munis align with vendor invoices and receiving documentation prior to final posting. Any discrepancies identified will be promptly corrected and documented as part of routine compliance monitoring. The Inventory Management Officer, Maribeth Benavente, and Property Control Officers will be responsible for ensuring accurate asset records are maintained. Corrective action for this finding was completed as of December 28, 2025.

Views of Auditee and Corrective Actions: GDOE disagrees with the finding. During the audit fieldwork, the cited assets were in various stages of formal loss reporting, with police reports pending at that time. As of this response, all certificates of loss and corresponding police reports have been completed and finalized in accordance with GDOE SOP 200-015. The condition noted during audit testing was due to the timing of the audit coinciding with ongoing administrative processing and does not indicate a breakdown in internal controls or safeguarding responsibilities. Of the assets cited, one was recovered, and certificates of loss were completed for the remaining four assets, ensuring proper documentation and compliance with established procedures.

Planned corrective actions: Currently an informal yearly review of fixed assets between the operations and business offices is being done. Heritage has an asset inventory that is manually maintained, which indicates the items that are purchased with federal funds. Heritage’s operations department is taking ownership of documenting university fixed assets and deploying an asset management software. This will be helpful in conducting physical inventories in the future. Name of Responsible Party: 1. Aaron Krantz, AVP for Technology & Operations 2. Joanne Fernandez, Controller 3. Sagrario Armenta Jimenez, CFO 4. Dr. Christopher Gilmer, President Anticipated completion date: 6/30/2026

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

Finding Number: 2024-036 Audit Type: Single Audit Finding Title: Deficiencies in Equipment and Real Property Management Related Finding: 2024-021 (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 centralized inventory tracking system and conduct annual reconciliations to ensure compliance with federal property management standards. 3. Anticipated Completion Date June 30, 2026 - plan already in place 4. Management1s Response Management concurs with the finding and will ensure staff are trained on property management procedures. 5. Status of Prior Year Finding This is a new finding.

Views of Responsible Officials and Planned Corrective Action: The Designees of the Grants Monitoring and Compliance team will oversee the completion of a physical inventory of all equipment that exceed $5,000 by October 31, 2026. The Grants team will also house documentation.

Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding. Corrective Action: Fair Haven has internal records with tracking assets but will ensure that all qualifying capital asset purchases are properly capitalized and recorded on the balance sheet in accordance with GAAP and added to the fixed asset register. Management will review significant purchases at acquisitions to confirm proper treatment going forward.

CONDITION: The Regional Office of Education No. 39 manually maintains and stores its inventory of property and equipment. Asset details in the property records include only the description of the property, manufacturer’s serial number or other identification number, source of funds, who holds title, acquisition date, and cost of the property. The other minimum requirements specified by the Code including FAIN, location, use and condition of the property are not included in the property records. PLAN: The Regional Office of Education No. 39 created a combined inventory documents to provide a complete detailed accounting of all property and equipment which provided majority of the required information for federal funds as well as a reconciliation to the capital outlay disclosures within the financial statements. The missing data requirements for the compliance with record keeping of Equipment from Federal funds will be added for Fiscal Year 2025. ANTICIPATED DATE OF COMPLETION: Implemented August 2025

Finding 2024-003 Information on the federal program: Subject: Water and Waste Disposal Systems for Rural Communities – Equipment and Real Property Management Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.760 Federal Award Number: N/A Pass-Through Entity: N/A Compliance Requirements: Equipment and Real Property Management Audit Finding: Material Weakness, Noncompliance Condition: An effective internal control system was not in place at the District to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management compliance requirement. Context: The District did not maintain an updated asset listing that reflects the construction in process balance related to the project funded with federal funds. There was approximately $25.0 million of disbursements from federal funds related to the project as of December 31, 2024. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The third-party accounting firm will compile a capital asset listing that lists out the District’s capital assets and notes the required information, which will include the federal funding source (if applicable). The capital asset listing will be updated on an annual basis. The Board of Directors will review the capital asset listing. Responsible Party and Timeline for Completion: The third-party accounting firm and the Board of Directors will implement the corrective action plan, which will go into effect immediately.

VIEWS OF RESPONSIBLE OFFICIALS Management agrees with the finding and has initiated corrective actions to address each of the issues identified by the auditors. The Department of Education of Puerto Rico (PRDE) recognizes the importance of maintaining an accurate and up-to-date property inventory in accordance with federal regulations under 2 CFR §200.313(d), and is implementing measures to strengthen controls, ensure proper tagging, and monitor the location, use, and condition of all federally funded equipment. The Property Office has initiated a complete physical inventory to reconcile the existing property records with actual assets. All equipment custodians will be required to verify and certify their assigned inventory to ensure records are accurate and reflect current locations and responsible personnel. For deficiencies identified for the IDEA Cluster: Condition 1: For the item describing a three-person sectional sofa, which upon inspection corresponded to a five-burner stove, the Property Office corrected the equipment tag to ensure identification of both items. The correction was made directly on the physical assets to properly reflected the correct property numbers and descriptions. Condition 2: The item identified as not observed corresponds to software licenses that were distributed to teachers for instructional use. The Property Office maintains a detailed record identifying the licenses purchased, the specific equipment on which each license was installed, and the corresponding custodian. For deficiencies identified for the Education Stabilization Fund Programs: Condition 1: For the items that could not be observed during the auditors’ site visits, the Property Office will perform a follow-up investigation with the corresponding school to locate the equipment. Condition 2: The school where the air-conditioning unit is located has experienced electrical voltage issues, which have delayed its installation to prevent potential damage to the equipment. The situation is being addressed in coordination with the school’s maintenance team to correct the electrical problem. Once resolved, the PRDE will proceed with the installation. In parallel, the property office will consult with the corresponding federal program to evaluate the possibility of relocating the unit to another school where the equipment is needed and can be safely installed and used. Condition 3: This type of equipment is kept in the warehouse until a specific need is identified in a school facility. Once a school requests or is identified as requiring the equipment, the Property Office initiates the corresponding transfer, and the movement is duly documented and updated in the property management system.. this process ensures that equipment is allocated efficiently based on program needs and that all transfers are properly supported with documentation. Condition 4: The hydroponic nursery will be relocated to a school where it can be properly utilized for educational purposes. The Property Office, in coordination with the corresponding program, will verify the current condition of the equipment and perform the necessary repairs or adjustments to ensure it is fully functional and in use as intended. Condition 5: The Property Office has already identified a new school to which the Apple computer will be transferred to ensure it is properly utilized for educational purposes. The transfer will be completed om coordination with the corresponding program, and the property records will be updated accordingly to reflect the new location and custodian of the equipment. The PRDE is committed to correcting all deficiencies noted in the finding. All actions described above will be documented and reported as part of the corrective action plan, with an expected completion timeline within fiscal year 2025. These measures will ensure compliance with the Uniform Guidance and strengthen the overall management and safeguarding of federally funded property and equipment. IMPLEMENTATION DATE In process. RESPONSIBLE PERSON Nilda Z. Morales Vazquez Property Office Director

2024-002 Program/Department: Conservation, Research, and Development Federal Agency: Department of Energy AL #: 81.086 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: Various – See SEFA Type of Finding: Internal Control over Compliance - F) Equipment and Real Property Management Internal Control Impact: Material Weakness Finding: Management did not conduct a physical inventory, as required. Status: Management has met with the program team to review the actions and time necessary to conduct a physical inventory and is executing the following Corrective Action Plan. Corrective Action Plan: 1. Preparation Task: Assign team, prepare inventory checklists Assigned to: Program Manager Completion: October 27, 2025 2. Schedule and Execute Physical Inventory Task: Conduct on-site subrecipient equipment inventory, delegating checklist to subrecipients as necessary. Assigned to: Program Team Completion: November 3 to December 5, 2025 3. Reconciliation Task: Compare physical inventory to system records, update records, investigate discrepancies Assigned to: Contract Administrator Completion: December 12, 2025 4. Review and Update Procedures for Equipment and Real Property Management Task: Review procedures to identify failure points and opportunities to create redundancies, update procedures, train all program staff on new procedures, to include a review of compliance responsibilities and their impact on MEC’s standing and ability to do our mission work. Assigned to: Contract Administrator Completion: December 15, 2025 5. Reporting Task: Report completion of Corrective Action Plan as needed for audit record Assigned to: Executive Director Completion: December 19, 2025 Person(s) Responsible for Implementation: KT Engle, Sr. Program Manager, KT.Engle@metroenergy.org, (816) 531-7283 Greg Betzwieser, Contract Administrator, greg.betzwieser@metroenergy.org, 816-531-7283