Corrective Action Plans

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. The second (2025-002) finding pertains to compliance with federal eligibility requirements for the TRIO Upward Bound Program. Federal regulations require at least two-thirds of program participants to be both low-income and first-generation college students. The audit identified that the program fell below the required threshold. To address this issue, the College is strengthening participant eligibility verification procedures and implementing additional monitoring to ensure compliance throughout the program year. Recruitment strategies are also being enhanced to increase the number of eligible participants served by the program. In addition, staff will continue to receive targeted training to ensure accurate eligibility documentation and consistency between program records and federal reporting requirements. Corrective Action 2025-002: Strengthen participant eligibility verification, improve recruitment of eligible participants, enhance APR reporting accuracy, and provide compliance training for TRIO staff. Target resolution 2025-2026 Program Year

2025-102 The County did not develop internal control procedures over program reporting and cash management requirements, increasing risk of report errors to awarding agencies and wrongly receiving monies Cluster Name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and program names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award Numbers and years: IGA DI21-002286 July 1, 2024 through June 30, 2025 IGA DI23-002389 July 1, 2023 through June 28, 2028 Assistance Listings numbers and program name: 21.027 COVID-19—Coronavirus State and Local Fiscal Recovery Funds Award Numbers and years: 1505-0271 March 3, 2021 through December 31, 2024 CT-FM-22-149 October 1, 2024 through September 30, 2025 SLFRFP1962 January 5, 2023 through December 31, 2026 CTR069300 January 1, 2024 through December 30, 2026 GTAW-FM-23*123 October 3, 2022 through July 3, 2026 ACJC-VC-25-001A July 1, 2024 through December 31, 2024 Assistance Listings numbers and program name: 93.268 Immunization Cooperative Agreements Award numbers and years: CTR062571 July 1, 2022 through June 30, 2025 CTR059891 July 1, 2022 through June 30, 2027 Name of contact person: Art Cuaron, Director, Finance and Risk Management Anticipated completion date: June 30, 2027 The County recognizes the need to strengthen internal controls over federal reporting and cash management requirements. F&RM will complete the following actions to ensure compliance with 2 CFR Part 200: 1. Establish written internal control policies and procedures for federal program reporting. All federal financial reports will undergo an independently documented review before submission to ensure accuracy, allowability, and proper reporting periods. 2. Implement documentation standards requiring staff to retain supporting materials such as system reports, financial queries, screenshots, and reconciliations, in accordance with federal and County retention requirements. 3. Pima County has been working with each of its grant implementing entities to use Euna Grants calendaring and reminders to prompt the entities’ timely reporting activities. Grants Management and Innovation (GMI) Department sets the reminders schedule at the onset of the performance period. The reminders are then automatically emailed to the grants manager and the assigned accountant for each grant on a set schedule throughout the course of the grant. GMI and Finance – Grants will continue to work with grant implementing entities to use these reminders to trigger the necessary actions in a timely manner. Pima County was still in the process of institutionalizing this system during FY25. 4. Provide training for staff who prepare and review federal reports, focusing on reporting requirements, documentation standards, internal controls, and record retention. 5. Conduct periodic management oversight reviews to confirm that internal controls are followed and that reports are complete, accurate, and submitted on time. The County is also planning to implement the Workday Grants Module with an anticipated go-live of July 1, 2027. This solution will enhance our ability to manage the full fiscal lifecycle of grant awards and ensure compliance with federal reporting requirements. The Workday Grants Module is a native Workday solution, purpose-built to support the full fiscal grant lifecycle. The module supports the following financial grant objectives: • Grant setup and award and fiscal tracking • Cost allocation and allocability controls • Real-time grant financial reporting • Compliance with federal Uniform Guidance (2 CFR 200) • Integration with Workday Financial Management, Procurement and Human Capital Management (HCM) In addition, F&RM has submitted FY 2026/27 budget requests to fund three additional Accountant III positions in our Finance – Grants Division. These positions will expand our capacity to manage our grant portfolio and strengthen our reconciliation, billing and SEFA preparation processes. The contract for the Workday Grants Module is scheduled to go before the Board of Supervisors for approval in April. These new positions will be included in the County Administrator’s Recommended Budget and will be considered by the Board as part of the full budget adoption process in June.

Finding 2025-004 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Participation of Private School Children Summary of Finding: The School Corporation did not provide supporting documentation for the amounts disbursed for Participation of Private School Children. No time sheets or logs were provided to support the hours paid to employees for working with the Private School Children. Contact Person Responsible for Corrective Action: Randi Libby, Chief Operating Officer Contact Phone Number and Email Address: (260)431-2030, rlibby@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement procedures to ensure consistent documentation supporting Title I services provided to non-public school students. All Title I staff providing services to non-public schools will be required to submit consistent, detailed timesheets documenting hours and/or days worked by non-public school, activity, and grant year. Timesheets will be completed, reviewed, and approved prior to payroll processing. The Payroll Manager will not process payroll for Title I non-public services unless the required timesheets are submitted and approved. Approved timesheets will be retained in the payroll files and organized by payroll dates, and will be made available for audit review. Anticipated Completion Date: July 1, 2026 _________________________ _Randi Libby (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)

Finding Number: 2025-015 ALN Number(s) and Program Title(s): 21.029 – Coronavirus Capital Project Funds Views of Responsible Officials and Planned Corrective Action: ASBO acknowledges the auditor’s observation regarding cumulative obligation amounts reported for two projects in the Q2 2025 Project and Expenditure Report submitted to the U.S. Department of the Treasury. The variances identified were the result of an administrative reporting error within a quarterly submission spreadsheet and did not reflect improper expenditures, questioned costs, or misuse of funds. The Agency identified the discrepancy during its internal review process and submitted corrected information to Treasury. By the time of audit review, the corrected reporting had already been provided. This issue was isolated to a specific reporting period and did not impact the underlying financial integrity of the projects. Anticipated Completion Date: June 30, 2026 Contact Person: Name: Glen Howie Title: State Broadband Director Agency: Arkansas State Broadband Office Address: 1 Commerce Way City, State, Zip: Little Rock, AR 72202 Phone Number: 501-683-6000 Email Address: broadband@arkansas.gov

Conduct a full review of all FEMA funds received in FY 2024-2025 to properly reclassify them as Federal Revenue/Income in the General Ledger. Implement a mandatory review of FEMA Project Worksheets (PWs) and Obligation Notifications to distinguish between "Reimbursements" and "Capital Advances" upon receipt. Create separate General Ledger (GL) accounts for FEMA disaster/project and Federal Funds to track expenditures vs. drawdowns in real-time. Establish a semi-annual meeting between the FEMA Coordinator and Finance departments to verify that all FEMA-funded work performed matches the reported expenditures. Update the SEFA preparation process to ensure FEMA expenditures are reported in the period they were incurred, regardless of when the reimbursement was received. Provide specialized training for the finance team on Federal Funds accounting.

Federal Program Title: Higher Education Institutional Aid Assistance Listing Number: 84.031 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Recommendation: We recommend that UEC strengthen its reporting procedures to ensure required performance reports are reviewed and approved prior to submission and that documentation is retained to support evidence of management review and report submission in accordance with Federal award requirements. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: Sponsored Programs, in coordination with the Office of Academic Research, will implement formal procedures requiring documented review and approval of all performance and annual reports prior to submission. Standardized processes, including approval documentation and retention of supporting records, will be established in accordance with Federal requirements. Roles and responsibilities will be defined, and compliance will be monitored. Targeted training will be provided to ensure staff understand reporting requirements and the updated procedures. Contact(s) Responsible for Corrective Action: Director of Sponsored Programs Planned Completion Date for Corrective Action: June 30, 2026

Condition: During audit testing of the Sliding Fee Discount Program for the fiscal year ended June 30, 2025, NeoMed Center, Inc. identified deficiencies in the documentation, retention, and supervisory review of patient eligibility determinations. Specifically, patient financial information was updated in a manner that overwrote prior eligibility evaluations, resulting in the loss of historical eligibility records. In addition, patient files were not consistently closed or retained in accordance with established policies and federal program requirements. These conditions reflected weaknesses in internal controls over eligibility documentation and supervisory oversight, which increased the risk of inconsistent application of the sliding fee scale, noncompliance with HRSA Health Center Program and Ryan White Part C requirements, inaccurate patient billing adjustments, and potential misstatement of patient service revenue. Planned Corrective Action: Management implemented corrective actions to strengthen internal controls over the Sliding Fee Discount Program and ensure sustained compliance with applicable federal requirements. Policies and procedures governing eligibility determinations and sliding fee discount applications were revised to require preservation of historical eligibility records, standardized documentation, and proper file‑closure practices. Clear supervisory review responsibilities were established to ensure eligibility determinations and fee assessments are reviewed for accuracy, completeness, and compliance. Targeted training was provided to staff responsible for patient registration, eligibility determinations, and fee assessments to ensure consistent application of the sliding fee scale and adherence to federal program requirements. In addition, management implemented periodic internal reviews of patient files to verify compliance with documentation, retention, and eligibility reassessment requirements, and to promptly identify and remediate any deficiencies. These corrective actions were designed to enhance internal control effectiveness, support accurate financial reporting, and prevent recurrence of the identified condition. Key internal controls include: • Revised and strengthened Sliding Fee Discount Program policies and procedures. • Implemented controls to preserve historical eligibility determinations and documentation. • Established standardized eligibility documentation and file‑closure processes. • Defined supervisory review responsibilities and escalation procedures. • Provided targeted training to eligibility and registration staff. • Implemented periodic internal reviews of patient files to ensure compliance. Monitoring: Management will conduct periodic supervisory reviews of patient eligibility determinations and sliding fee discount applications beginning April 1st, 2026, to ensure compliance with established policies and federal program requirements. Monitoring will include sample testing of patient files to verify proper documentation, preservation of historical eligibility records, and timely reassessments. Results of monitoring activities will be documented and reviewed by management, and corrective actions will be implemented as needed to address any deficiencies identified. Responsible Official: Jose A. Guzman Machuca Time frame: This condition was resolved in March 2026 upon the implementation of revised policies, enhanced documentation controls, staff training, and supervisory review procedures

Findings and Questioned Costs Relating to Federal Awards: Late Filing Report To address this issue, the Department will strengthen its administrative and management control processes to ensure accurate preparation and timely submission of all federal reports. The following corrective actions will be implemented: 1. Establish Internal Reporting Calendar: The Department will implement a centralized reporting calendar that includes all federal reporting deadlines related to all Federal Funds managed by the Department including, the Coronavirus State and Local Fiscal Recovery Funds to ensure adequate time for preparation and review. 2. Assign Reporting Responsibility: A designated staff member will be responsible for monitoring federal reporting requirements and deadlines and coordinating report preparation and submission. 3. Review and Approval Process: Management will implement an internal review and approval process prior to report submission to ensure accuracy and completeness. 4. Monitoring and Oversight: Department management will periodically monitor compliance with reporting deadlines to ensure reports are submitted accurately and on time.

The Department agrees with the finding. During fiscal year 2024–2025, DHSEM experienced significant turnover within the Finance Bureau, which disrupted established processes for the timely preparation and submission of required SF-425 Federal Financial Reports as required under 2 CFR 200.328. While financial transactions continued to be recorded in the Department’s accounting system, staffing vacancies limited the Department’s capacity to compile, review, and submit certain quarterly reports within the required 30-day timeframe. The untimely submissions primarily impacted reporting periods ended March 31, 2025, and June 30, 2025. The Department acknowledges that reports were not submitted within required deadlines during that period; however, DHSEM is current with all federal financial reporting as of FY2026.To prevent recurrence, DHSEM has strengthened internal controls over federal financial reporting. The Department has implemented a formal supervisory review process for all SF-425 reports prior to submission to ensure completeness, accuracy, and compliance with federal requirements. DHSEM has also established cross-training within the Finance Bureau to ensure alternate personnel are capable of preparing, reviewing, and submitting required reports in the event of staff vacancies or absences.Additionally, the Department has conducted federal financial reporting trainings for Finance and Grants staff and has worked closely with FEMA representatives to ensure alignment with reporting requirements and expectations. DHSEM is revising and formalizing written financial management and reporting policies and procedures to incorporate supervisory review controls, alternate personnel assignments, escalation protocols for reporting deadlines, and standardized documentation of report preparation.These actions are intended to strengthen compliance with federal reporting requirements and ensure timely and accurate submission of financial reports going forward.

Condition: The Organization did not report unliquidated financial obligations on the final federal financial report SF-425, in violation of the federal financial reporting requirements under 2 CFR Section 200.328. Corrective Action Steps: Establish a written procedure for preparing and reviewing the SF-425 Federal Financial Report, including a checklist that specifically addresses the identification and reporting of unliquidated obligations. Prior to submission, require a preparatory review step in which finance staff identify all outstanding obligations and confirm they are correctly reflected on the SF-425. Implement a secondary review and approval of all final SF-425 reports by the Finance Director or equivalent prior to submission to the federal awarding agency. Provide training to finance staff responsible for federal reporting on the requirements of 2 CFR Section 200.328 and the correct completion of the SF-425. Retain copies of all submitted SF-425 reports along with the supporting workpapers used to prepare them, including documentation of the unliquidated obligations review. Responsible Party: CLC NWI Executive Director. Target Date: Executive Director Partially Completed. All funds have been liquidated as of 3/23/26. All other corrective action steps to be implemented by May 15, 2026.

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2025-003 Statement of Concurrence or Non concurrence: We concur with the findings. Corrective Action: During the past year, the Corrective Action Plan (PAC) has been implemented and expense reconciliation efforts have been ongoing. Currently, we are in the process of collecting all supporting documentation related to work performed for projects funded by FEMA. It is expected that the reconciliation of expenses will be completed over the next few quarters, and that expense reporting will continue during the quarters in which payments are made. Implementation Date: Fiscal Year 2025-2026. Responsible Person: José A. Torres Otero Program Accountant

Audit Finding: Pursuant to 2 CFR 200.512 Report submission, Army West Point Athletic Association Inc. ("AWPAA") did not submit interim performance reports within 30 days after completion of the reporting period through the term of the agreement. Specifically, the interim performance report for one of two quarters selected during the period July 1, 2024 – June 30, 2025 was not submitted within 30 days after completion of the reporting period. Root Cause Analysis: The frequency of the reporting has not consistently aligned with material updates. Deadlines were not strictly monitored. Corrective Action Plan: Monitor Reporting Compliance and track submission of Interim Performance Reports to ensure submission by the due date(s). Estimated Completion Date: June 30, 2026 Point of Contact: Thomas Theodorakis, Athletic Director/CEO

Audit Finding Reference: 2025-002 Improve Internal Controls and Compliance with Reporting Requirements Planned Corrective Action: BDCC has established a centralized compliance calendar with automated alerts to ensure all Department of Labor (DOL) financial and performance reports are submitted within the required 45-day window. BDCC has implemented a mandatory secondary review for all quarterly reports. Before submission, the Director of Finance & Grant Management will perform a formal reconciliation of report data against the underlying general ledger to ensure accuracy and alignment with federal reporting standards. Planned Implementation Date of Corrective Action: April 1, 2026 Person Responsible for Corrective Action: Joshua Pacheco, Controller

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Finance Director Phone: (787) 788-0404 Original Finding Number: 2025-005 Statement of Concurrence or Nonconcurrence: We concur we the finding. Corrective Action: Adopted Measures • Expense Synchronization: A protocol will be implemented requiring contracted consultants to record and report incurred expenses only when a validated disbursement voucher is available, thereby ensuring the integrity of the financial flow. • Reconciliation: The office will conduct a detailed comparison between the draft quarterly report and the general ledger to identify and correct any discrepancies prior to final submission. • Compliance Timeline: An internal deadline will be established for the submission of the report, ensuring attainment of the minimum percentage required under the Quality Activities category through accurate financial data. Expected Outcome To ensure that all financial information submitted is complete, accurate, and fully aligned with the Municipality’s accounting records, thereby eliminating the risk of audit findings. Implementation Date: March 2026. Responsible persons: • Person responsible for the implementation: Mr. Carlos Flores, Federal Program’s Subdirector • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director

Annual performance reports will be submitted on time as required by the funding agency. Management has developed a comprehensive listing of all reporting requirements and will utilize this information to ensure all reporting requirements are met.

Management concurs. The City will strengthen its policies and procedures over the grant reporting process to ensure that the review and approval of federal reports is documented. This will be implemented by September 2026.

The Municipality agrees with the finding and stated that it will implement corrective actions to improve compliance with reporting requirements. Management plans to formalize reporting procedures, assign responsible personnel, and require reconciliations between reported amounts and accounting records prior to submission of reports to ACUDEN, along with enhanced supervisory review. Implementation Date: July 1, 2026 Responsible Person: Mr. Luis A. Velez Rivera, Finance Director

Views of Responsible Official: Management agrees with the finding. Management will institute additional calendar alerts and accountability procedures to ensure reports are filed on time. Recognizing that technical issues, illness, and other unforeseen circumstances can arise, Management will institute a requirement that all late filings must be communicated to the Contract Monitor as soon as the delay is anticipated.

FINDING 2025-008 Finding Subject: COVID-19 - Education Stabilization Fund – Condition of Records Federal Agency: Department of Education Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls will be put in place to ensure all COVID 19 ESSER Funds are reported accurately to the State and Federal Department of Education. Reimbursements will be attached to State Email for disbursement. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

FINDING 2025-005 Finding Subject: Child Nutrition Cluster - Reporting Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Lela Simmons, CFO Contact Phone Number and Email Address: 219 391 4100 Ex 12365: lesimmons@ecps.org Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service director responsibilities is to overseeing all function of the Food Management Company. Food Service Director will be required to draft internal controls and detail instruction for the school corporation to ensure all documentation procedures match the FSMC invoice. The school corporation will upgrade all POS software throughout the district. Students will be required to scan Student IDs to account for all meals served. Counts will be check weekly to ensure Federal report is accurate. Anticipated Completion Date: We anticipate having the above corrective action plan in place by October 31, 2026

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Jill VanDriessche Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. We believe this finding to be the result of an isolated incident that was reported to SBOA and Title. Description of Corrective Action Plan: The Business Manager/Treasurer provides to the corporation grant administrator monthly grant reports, as well as a grant tracking spreadsheet. The appropriations for each grant are entered into Komputrol, according to the budget located in the approved grant documents. The appropriations are presented to the Grant Administrator for approval. All spending from each grant is approved by the corporation grant administrator. Any wages paid via the corporation payroll that is charged to grant funds is approved by the business manager/treasurer and the corporation grant administrator. The Payroll Specialist/Deputy Treasurer completes the payroll and sends the distribution account records to the Business Manager/Treasurer and Grant Administrator. Any payroll claims for payment via grant funds is required to have three signatures for approval. We believe the system of internal control in place has been strong and in compliance since March 2025. Anticipated Completion Date: March 1, 2025 and ongoing

FINDING 2025-004 Finding Subject: Child Nutrition Cluster, Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Amy Kraszyk Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Since January 2025, the internal controls that resulted in this finding have been corrected. The finding stated that “The lack of internal controls and noncompliance over Allowable Activities and Allowable Costs/Cost Principles is an isolated incident.” The Food Service Director and the Business Manager/Treasurer meet monthly to review the school lunch accounts and to concur with the month end balances. The Deputy Treasurer approves all monthly fund transfers completed by the Business Manager. Anticipated Completion Date: January 1, 2025 and ongoing

DEPARTMENT OF THE TREASURY Coronovirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend that the Town implement stronger internal controls over federal reporting, including establishing a formal reconciliation process between the general ledger and the Project and Expenditure Report, requiring Town Administrator's review and approval of all federal reports prior to submission, and providing additional training to staff on Federal reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will strengthen its reconciliation procedures requiring the Director of Finance to reconcile all federal expenditures reported in the Project and Expenditure report to the general ledger. Name of the contact person responsible for corrective action: Kelly Baldwin, Director of Finance Planned completion date for corrective action plan: April 1, 2026.

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Ronaldo Ortiz Velázquez, Mayor Contact Person: Mrs. Eunice Díaz, Finance and Budget Director Phone: (787)738-3211 Original Finding Number: 2025-004 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: During the testing of reports, the Quarterly Progress Reports of five (5) projects, corresponding to two (2) quarters of fiscal year 2024-2025, were evaluated. It was found that in two (2) projects, the quarterly reports did not match the accounting records or the project documentation. Therefore, for the purposes of this audit, the municipal accounting controls and procedures did not ensure that the reported information was accurate, up-to-date, and fully reconciled with the financial records. In light of the above, the reports will be reconciled with the accounting records, and the discrepancies found will be identified, documented, and adjusted in the system where the error originated, as appropriate. Furthermore, from this point forward, once the Quarterly Reports (QPR) are issued, a copy must be sent to the Program Accountant, the Finance Director, and myself for validation and reconciliation prior to official filing, thus preventing situations like this to occur. This process will form part of the internal control required to ensure that the reported information is accurate, current, complete, and consistent with the accounting records, in accordance with applicable federal requirements. Implementation Date: From March 2026. Full implementation is expected in fiscal year 2026-2027. Responsible Person: Mrs. Natasha Vázquez Federal Programs Director

Corrective Action Plan - Federal Award Finding Finding 2025-001 Federal Agency Name: US DOT, Federal Railroad Administration Assistance Listing: 20.325 Program Name: Consolidated Rail Infrastructure and Safety Improvements (CRISI) Initial Year Finding Occurred: Fiscal Year 2025 Reporting Finding Summary: The auditor identified an instance in which one quarterly SF-425 (report) did not reflect cumulative federal cash receipts and disbursements as required by the reporting instructions. Instead, the report reflected only the current quarter's ended federal cash activity. No additional reporting errors were identified by the audit, and the other reporting lines were prepared correctly. Auditor’s Recommendation: The auditor recommends that management continue to strengthen review procedures over SF-425 preparation, including documented review of cumulative cash reporting and verification of all report attributes, particularly during periods when backup personnel are responsible for report preparation. Management’s Response: Management concurs that an error occurred on one SF-425 report for a single reporting period. The error occurred during a sta􀆯ing transition and involved a field that FRA does not require, and that had not historically been populated. Additionally, FRA and FTA use the same SF-425 form but apply di􀆯erent reporting conventions; FTA requires the field to be reported quarterly rather than cumulatively, which contributed to the confusion. As noted in the audit finding, this was a reporting error only. There were no questioned costs, no billing inaccuracies, and no impact on the underlying financial activity. Corrective Action: Management has implemented the following actions to prevent recurrence: • Updated internal procedures to clearly distinguish FRA and FTA reporting requirements. • Implemented a two-step review process in which one sta􀆯 member prepares all federal financial reports and a second sta􀆯 member performs an independent review prior to submission. • Expanded procedure on reporting when primary sta􀆯 are unavailable, including cross training and adding backup for both reporting and review. These actions strengthen internal controls, ensure consistency across federal reporting, and reduce the risk of future reporting discrepancies. Responsible Individual: Heather McKillop, Chief Financial O􀆯icer Anticipated Completion Date: March 2026