Corrective Action Plans

Findings – Federal Award 2025-001 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Reporting Context: The Department of Housing and Urban Development (HUD) requires a Performance Report to be submitted, which must include a completed Federal Financial Report as an attachment. The required Progress Report was filed timely and accepted by HUD, however the required Federal Financial Report was omitted from the submission. Recommendation: The entity should implement and document internal controls to ensure all required reports are prepared, reviewed, and submitted in accordance with federal award requirements. Action Taken: To address the root cause and ensure strict adherence to federal reporting standards moving forward, the Finance Department has implemented the following internal controls, effective immediately: 1. Implementation of a Pre-Submission Checklist: A mandatory "Federal Reporting Checklist" has been developed. This document requires the preparer to physically check off that all required attachments—including narrative progress reports and financial reports (SF-425)—are present and accurate prior to upload. 2. Staff Training: Relevant staff members involved in the grant reporting process have been retrained on the specific submission requirements for HUD awards to ensure clarity on all deliverable components. Responsible Official: Rambod Behnam, Director of Finance Planned Completion Date: June 30, 2026.

NACAA has received and reviewed the draft audit report for fiscal year 2025 conducted November 25, 2025. We have provided our auditors DeLeon & Stang with a Management Response to include with the audit. This document will outline NACAA’s course of corrective action for those findings. Finding 1: The Organization charged indirect costs to the major federal program in excess of the amount permitted under its approved NICRA for the fiscal year ended September 20, 2020. In addition, amounts reported on the annual Federal Financial Report (FFR) to the federal funder were incorrect, reporting the wrong base and charged amounts. The amounts reported on the FFR did not match the actual indirect cost base and charges for fiscal year 2025. Background As noted in the audit finding, NACAA’s NICRA has historically been based on a salary and fringe benefits allocation base. During fiscal year 2025, NACAA experienced significant turnover of longtenured employees, resulting in a substantial decrease in salaries and wages and, accordingly, a reduction in the approved indirect cost rate. As a result, indirect costs were overcharged to the federal program by $96,196. The annual Federal Financial Report (FFR) submitted on November 6, 2025, was based on internal year-end reports not NACAA’s audited final numbers. The information reported as the indirect cost rates and amounts were taken from the NICRA applications for the FY24 final and FY25 provisional negotiated rates. Remediation In order to address these findings, NACAA has contacted its EPA Project Officer and Grant Specialist to discuss appropriate corrective action. We explained that NACAA is having trouble paying its overhead expenses using the current negotiated indirect cost rate of 16.84% due to the substantial changes in our staff since the rate was negotiated. NACAA’s 2025 provisional indirect costs rate was calculated based on a SWF amount of $1,306,688. At year end because of staff changes, NACAA’s 2025 SWF amount is only $950,264, which makes our base for calculating indirect costs $356,424 less than when the rate was set. The indirect cost limit based on the old SWF was $220,046, while it’s $160,024 based on the new. NACAA’s indirect costs for 2025 were $256,919. After speaking with EPA, NACAA met with its auditors and accountant to discuss corrective action. It was recommended that some of NACAA’s overhead costs that have traditionally been added to the indirect cost pool (professional fees, rent, office insurance, etc.) be charged as direct costs using NACAA’s grant-related salaries and fringe benefits to allocate expenses between direct and indirect costs. To correct the other issue related to the Federal Financial Report (FFR) errors, NACAA will work with its accountant to complete the required FFRs and other grant reports to ensure that all figures being reported at correct. Reclassifying Indirect Charges to Direct Cost Categories NACAA has contacted the EPA Grants Management team to determine if our anticipated corrective course of action would be acceptable to EPA. We have received concurrence by email that the suggestion made by NACAA’s Auditors that pro-rating costs using salary as a basis for allocating overhead charges as direct costs is reasonable. This method should be used to allocate all expenses that are “traditionally” allocated as indirect costs. NACAA is currently drafting a request to re-budget its 2026 expenses, allocating many of the expenses traditionally part of the indirect cost pool as direct expenses, pro-rating costs using salary as a basis for allocating overhead charges as direct costs. NACAA’s Project Officer needs to approve that request so an amendment can be made for the current year of NACAA’s two-year cooperative agreement. Accountability Once NACAA’s re-budgeting request has been approved, NACAA’s Operations Manager and Accountant will be responsible for ensuring that expenses are correctly allocated every month using salary as a basis for allocating overhead charges as direct costs. Please see a description of NACAA’s Time and Attendance System and Method of Fringe Benefit allocation. These will be used to determine the percentage of expenses that will be allocated as direct costs: Salaries and Wages: Time & Attendance System: NACAA’s staff complete detailed timesheets on the 15th and last day of each month. Personnel Time Allocation Policy: Traditionally, activities of the NACAA headquarters office fall into three categories: federal grant-related activities; non-grant related activities; and indirect functions. Fringe benefits are allocated into these three categories based on the number of hours worked in each. Non-grant related activities are funded by the NACAA treasury. A very modest amount of time is allocated as Indirect Salaries, Wages and Fringes. Indirect salaries are included in NACAA’s indirect cost pool. Fringe Benefits: Fringe Benefits for NACAA’s staff members include employer-paid share of payroll taxes, health, life and disability insurance and a retirement plan. NACAA allocates fringe benefits based on a fringe benefit rate and distributes them based on salaries and wages.

Finding Number: 2025-001 Planned Corrective Action: Towpath Trail High School will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 2/14/2026 Responsible Contact Person: Dave Massa, Treasurer

Completion of Oustanding Reports: All required SF-425 reports for continuing Early Head Start grants have been completed. Policy and Procedure Enhancements: DPFC has updated its financial policies and procedures to formally document federal reporting responsibilities, required timelines, and internal review protocols. Enhanced Monitoring and Oversight: A standardized monthly compliance claendar has been implemented and is actively monitored by the CFO to ensure upcoming reporting deadlines are identified and met.

Hope Network acknowledges receipt of the Schedule of Findings and Questioned Costs included in the Single Audit Report dated January 21, 2026, identifying Finding #2025-001: Major Federal Award Finding- Reporting. Hope Network agrees with this finding and the recommended actions to be taken. Corrective Action Plan: Specific Corrective Action: Completion Date File all overdue semiannual performance reports. Completed Submit overdue required written request due upon final funds draw and project completion. Completed Finance department will review all grant agreements to ensure all required reporting, not just financial reports, are tracked and filed in timely within the terms of the grant agreement. 03/31/2026 Finance in conjunction with Hope Network Foundation will review existing grant procedures to develop a uniform process to be utilized across all Hope Network Affiliates. 06/30/2026 We are committed to resolving this issue.

Finding 2025.002 - Reporting - Material Weakness Recommendation We recommend that management establish and formally document comprehensive policies and procedures for the reporting process. These policies and procedures should clearly outline all required reports, filing timelines, and the method for maintaining supporting documentation. We recommend that CLC develop and implement a standardized checklist outlining all required grant compliance requirements. The checklist should clearly identify the individual responsible for preparation and the individual responsible for review. Additionally, both the preparer and reviewer should document their completion of the review to provide evidence that compliance requirements have been appropriately verified. Planned Corrective Action: Management concurs with the finding and will strengthen controls over federal reporting for the Head Start Cluster. Corrective actions include: • Establish and document a grant reporting calendar and compliance checklist covering all required submissions (including SF-425 and FFATA subaward reporting, as applicable), due dates, and responsible parties. • Require all reports to be supported by underlying accounting records and retained with supporting schedules in a centralized repository. • Implement documented preparer and independent reviewer sign-off prior to submission; the reviewer will verify tie-outs to the general ledger and supporting documentation. • Provide training and cross-training to ensure continuity of compliance responsibilities during personnel changes. Name of Contact Person: Neil Shah, Interim CFO, neilshah@clcstamford.org Anticipated Completion Date: March 31, 2026

Planned Corrective Action: The district will implement controls for monitoring reporting grant requirements and grant expenditures to ensure compliance with reporting and period of performance requirements for federal grants. Anticipated Completion Date: 6/30/26 Responsible Contact Person: Hiwot Abraha

Management of the City concurs with the audit finding. The City program staff responsible for preparing the report was not aware of the requirement to submit the federal financial report. The City program staff has been informed of the reporting requirements, and management will perform a quality control review over future submissions to ensure compliance with grant requirements.

Finding 2025 – 003 - Reporting (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 enhance the effectiveness of internal controls and ensure that all Title III reports are accurate, properly reviewed, and approved prior to submission, the Fiscal Service office will require management to review and sign off as confirmation of approval prior to submission.

2025-001 Reporting US Department of Education – AL #s10.553, 10.555, 10.559 and 10.582 Child Nutrition Cluster Condition: The District submitted monthly child nutrition reimbursement claims that contained inaccurate meal counts for multiple months during the fiscal year. Specifically, the District overstated reimbursable meal counts due to errors in including non-reimbursable meals served. Additionally, the claims were not subject to an independent review prior to submission to ensure accuracy and completeness. Name of Contact Person: Ann Berman, Business Manager Plan of Action: The District will revisit the internal control processes surrounding the grant reporting and reimbursement process to ensure meal count information submitted is within program requirements of Child Nutrition Cluster programs. In the event there are questions surrounding meal count and other information subject to reporting, the District will continue to rely on timely guidance from external governmental accounting consultants, the Oregon Department of Revenue, and the Oregon Department of Education.

Management's Response/Planned Corrective Action: The Controller will ensure a process of dual review/approval on reporting is followed going forward to aid in identifying any reporting inconsistencies or misunderstanding of reporting instructions. This will be undertaken immediately.

HHC recognizes their responsibility to ensure that all required Federal Reports, including FFRs, are filed on a timely basis. HHC recognizes that during the fiscal year ended 3/31/2025, we were deficient in meeting the timely filing requirement for FFR reports. HHC established a new process in August 2025, whereby the Controller will review the Payment Management System on a bi-weekly basis, but not less frequently than monthly, to identify the deadline for all required Federal Grant reports, including but not limited to FFR reports. The Controller will notify all appropriate individuals of any reports that require attention to meet the reporting deadlines and will be responsible for the timely completion of all such required reporting.

Views of Responsible Officials: In instances where Federal financial and programmatic reports were submitted after the due dates, delays were primarily driven by the time required to obtain and reconcile financial and programmatic data from subrecipients and to complete BRAC USA’s internal reviews and sampling procedures. While this resulted in late submissions, our priority was to ensure the completeness, accuracy, and integrity of reported information rather than compromising quality for timeliness. To strengthen compliance going forward, in any instance where BRAC USA anticipates a delay in submitting required Federal financial or programmatic reports, we will proactively communicate with donor or the pass-through entity in advance of the due date, explain the reasons for the delay (including any timing issues related to subrecipient data), and request written approval of a revised reporting deadline. This approach will help ensure transparency, maintain the donor’s ability to effectively monitor grant performance, and document mutual agreement on adjusted submission dates, while still allowing BRAC USA to complete the necessary review and reconciliation procedures to ensure accurate and reliable reporting. Planned Completion Date: December 31, 2025

Finding 2025-003 Lack of Internal Controls over Reporting Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: The District will save copies and related supporting documentation of required reports submitted to granting agencies in a file accessible to appropriate individuals to ensure information is available to more than one District employee. This will mitigate issues in obtaining compliance documents when requested. Proposed Completion Date: December 2025.

Strengthening Institutions Program – Department of Education Federal Financial Assistance Listing #84.031 P031A080196 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: Section 3 of the Title III Endowment Report for the year ending June 30, 2024, was completed materially incorrect for Type of Savings Account Security line items and Total Invested line item. Responsible Individuals: Michael Van Surksum, Vice President for Business and Finance Corrective Action Plan: Management will review their current process to ensure reporting requirements are met and amounts are materially correct. Anticipated Completion Date: Already complete – annual report for the year-ending June 30, 2025 has now been submitted with the correct amounts.

Management concurs with the finding. The Authority has developed a Compliance Reporting Schedule listing all required HUD submissions, their due dates, and the responsible staff. Calendar reminders and verification checkpoints have been implemented to ensure timely submissions. In addition, the Authority will conduct quarterly internal audits to confirm adherence to HUD reporting requirements. Management anticipates full corrective action by December 2025.

Finding 2024-006 – Compliance; Internal Control over Compliance, Reporting (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of AgricultureFederal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Under 2 CFR 200, recipients must submit performance and financial reports as required by the terms and conditions of the award and must retain records sufficient to demonstrate compliance (see (§200.301Monitoring and reporting program performance, and §200.328 Financial reporting, §200.329 Monitoring and reporting program performance, and §200.334 Retention requirements for records). The grant agreements for awards above require timely submission of performance / progress reports by specified due dates, with documentation maintained to support the submitted information. Condition: For the fiscal year ended June 30, 2024, the auditee could not provide sufficient evidence that required reports for the programs listed were prepared, reviewed, and submitted in accordance with grant terms. Specifically:  No provided required financial reports, and Partnership for the Umpqua Rivers lacked copies or evidence of submission, and support for reported amounts requested.  Auditors were not provided with performance/progress reports and were instructed that Partnership for the Umpqua Rivers had no retained copies, review sign-offs, or submission confirmation.  Where payments were received, support for the required reports or metrics were not retained and could not be supplied to auditors for reconciling to underlying records. Cause: Management has not implemented formal reporting controls, including:  A documented reporting calendar with due dates and responsible staff,  Reconciliation of report amounts to the accounting records,  Retention procedures for report copies, underlying support, and submission confirmations, and  Supervisory review evidenced by signatures or workflow approvals. Effect or Potential Effect: Absent evidence of timely, accurate reporting and adequate record retention:  The organization is at risk of noncompliance with federal award conditions,  Inaccurate financial or performance information may be reported to the funding agency, and  The entity may be subject to remedial actions, including heightened monitoring, repayment of questioned amounts, or potential suspension of funding. Questioned Cost: None directly noted, but potential risk if reports were incomplete or inaccurate.Context: During our audit, it was found that the Partnership for the Umpqua Rivers experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. Award files provided to auditors did not contain information related to reporting of activity, expenditures, or progress of the awards. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers:  Establish a formal reporting and retention policy aligned with 2 CFR 200 and grant terms.  Implement a centralized reporting calendar that tracks due dates, preparers, reviewers, and submission methods.  Require reconciliations of financial reports to the general ledger and supporting schedules, retain the reconciliation with the reporting package.  Create standard workpapers for performance metrics for each award.  Configure the grant portal or document management system to retain submission confirmations, reports, receipts, and version -controlled copies of all reports for awards.  Document supervisory review through sign-offs prior to submission and with evidence retained.  Provide training to staff on Uniform Guidance requirements and record retention (§200.334). District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: ____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _____________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

2024-008 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: As part of the reporting requirements for the CBS Food Program under the National School Lunch Program (NSLP) and Summer Food Service Program (SFSP), management is responsible for submitting the FNS 10 (NSLP) and FNS 418 (SFSP) reports within 30 days after month-end. However, management was unable to provide five (5) monthly NSLP reports and one (1) monthly SFSP report requested for audit testing. Recommendation: The Organization should establish and enforce strengthened internal controls over federal reporting to ensure that all required monthly reports (FNS 10 and FNS 418) are: (a) completed accurately, (b) submitted on time, and (c) retained in accordance with federal record retention requirements (2 CFR 200.334). Management should designate responsible personnel and implement a monitoring process to ensure compliance. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Effective, July 1, 2024, Community Benefit Solutions no longer administers the National School Lunch Program. In the event Community Benefit Solutions should begin administering the NSLP, Community Benefit Solutions will develop and implement requisite policies and procedures to ensure proper reporting requirements including, but not limited to, completion and submission of the FNS10. Planned completion date for corrective action plan: June 30, 2025

The City will assign responsibillity for the filing of the Federal Financial Reports and will verify that the reports have been submitted.

2024-007 Untimely Submission of Project and Expenditure Report: Management acknowledges the finding related to the untimely submission of the American Rescue Plan Act (ARPA) Project and Expenditure Report. To address this issue and prevent future occurrences, the City is implementing an ARPA reporting process that clearly defines reporting requirements, deadlines, and responsible personnel, along with a centralized compliance calendar to track all federal grant reporting deadlines and provide reminders to ensure timely submission. Primary responsibility for ARPA reporting has been assigned to designated Finance Department staff, with supervisory review by senior management to ensure reports are complete, accurate, and submitted on time. In addition, Finance staff have received training on federal and ARPA specific reporting requirements, and cross-training will be implemented to ensure continuity in the event of staff absences or turnover. Management will continue to monitor compliance with federal reporting requirements and update internal controls as necessary.

FINDING 2024-014 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation in the form of dated expenditure reports for all federal grant reimbursements and for the final expenditure reports. The Business Office will implement a system of internal control and review where after each month is reconciled and closed, the Federal Grants Administrator will review the program expenditures, ensuring they are correctly posted prior to filing the reimbursements. All reimbursements will be reviewed and signed off on by the Federal Grants Administrator and an additional reviewer prior to submission for reimbursement. In addition, the final expenditure reports will be reviewed and signed off on by Grants Administrator and an additional reviewer prior to submission. Anticipated Completion Date: The school district began the practice above on January 1, 2024, and anticipate it will be completed by June 30, 2026.

Significant Deficiency in Internal Controls over Compliance Condition: As of the March 31, 2024 reporting date, the Town’s Project and Expenditure report had reported cumulative expenditures that were approximately $29,900 less than what was recorded in the grant fund on the general ledger Corrective Action Planned: FY2026 Grant activity is being reconciled to the General Leger with the help of the outside consultant. This process will be completed by the end of January, 2026. In FY26 reconciliation will be performed quarterly, and will be up to date no later than end of March 2026. Anticipated Completion Date: March 2026 Contact: Anna Noyes, Town Accountant

Views of Responsible Officials: CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. CIF made adjustments and improvements in this area during FY 25 to such an extent that this finding is cleared in the FY 25 Audit Report.

Condition: During our testing, we noted that for each of the County’s seven Airport Improvement Program grants, only Form SF-271 was submitted for the audit period, despite requirements to submit five distinct report types per grant. Recommendation: CLA recommends that the County provide staff with training related to identifying and complying with grant requirements. Additionally, CLA recommends that the County implement tracking procedures, such as a monitoring checklist, to ensure all required reports are submitted in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Department is working with the FAA to complete past-due reports and has improved tracking of required reports and deadlines. Name(s) of the contact person(s) responsible for corrective action: Aviation Director Planned completion date for corrective action plan: Fiscal year ended June 30, 2026

Response to finding 2024-004 – Reporting Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2024-004. During the audit period, recordkeeping was not centrally maintained, and key documents were often stored under individual employee drives rather than within a shared, organization-controlled system. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, the Organization had limited capacity to implement formal reporting controls; however, foundational corrective steps were initiated in 2025 to support full compliance during the 2026 operating year. This finding continued into the 2024 audit period due to the decentralized recordkeeping practices described above. Corrective Action taken in 2025: The Operations Manager conducted a full triage of existing accounts and transferred organizational documents into centralized CSforALL Drives. Files were reorganized by year and subject matter to ensure accessibility, consistency, and proper retention. This restructured system now provides a unified location for all grant-related documents, reporting records, and compliance materials, establishing a baseline for future Uniform Guidance reporting requirements. Corrective Action Planned for 2026: Beginning in 2026, CSforALL will implement formalized policies and procedures to ensure records are maintained in accordance with applicable compliance requirements and that all Uniform Guidance reports are submitted timely. The Operations Manager and Accounting team will oversee ongoing documentation, retention, and periodic internal review to ensure the reporting structure remains organized, accessible, and compliant throughout the 2026 operating year and beyond.