Corrective Action Plans

SF-425 Reporting Planned Corrective Action: American Bird Conservancy will prepare, review and maintain documented comparison of general ledger details to the SF-425 reports prepared. Person Responsible for Corrective Action Plan: Angela Modrick, Vice President of Finance Anticipated Date of Completion: Implemented

Management has implemented enhanced procedures to strengthen the tracking, reconciliation, and reporting of recipient share (matching) contributions associated with federal awards under ALN 14.265, Rural Capacity Building for Community Development and Affordable Housing Grants. Actions include: 1. Updating the internal matching contribution tracking system to improve documentation and cumulative tracking of recipient share contributions by grant and reporting period. 2. Establishing a formal reconciliation process between supporting documentation, grant records, and amounts reported on the SF-425 to ensure both federal expenditures and applicable recipient share amounts are accurately reflected. 3. Implementing a pre-submission review checklist and control requiring verification that recipient share (matching) information has been evaluated, reconciled, and included on the SF-425, when applicable, prior to submission to the awarding agency. 4. Requiring supervisory review and approval of the completed SF-425 to confirm completeness, accuracy, and compliance with reporting requirements under 2 CFR §200.328 before certification and filing. 5. Updating internal grant reporting procedures and providing additional guidance to staff responsible for federal financial reporting regarding SF-425 reporting requirements and recipient share reporting expectations. Management will evaluate the SF-425 reports submitted during the audit period to determine whether amendments are necessary. If required, amended SF-425 reports will be submitted to accurately reflect recipient share (matching) contributions. Anticipated Completion Date: The enhanced controls were implemented during 2026 and will be operational for the preparation, review, and certification of the SF-425 for the reporting period ending June 30, 2026, and all future reporting periods. For the reports submitted before June 30, 2026, management will confirm with HUD by July 20 if they would like an amended report. If HUD request one, the amended report will be submitted by August 15. Responsible Contact: Lakia Goodman, Controller (preparation and reconciliation of recipient share reporting) Chris Perry Authorized SF-425 Signer/Certifying Official (final review and certification)

Finding 2025-001 Corrective Action Plan: Management acknowledges the reporting lapse identified and notes that all required semi-annual reports have since been submitted as of the report date. The delay appears to have been an isolated oversight rather than a systemic breakdown in compliance. To enhance controls over grant reporting and prevent recurrence, the Organization has implemented the following corrective actions: Established a formal grant reporting calendar that includes all required reporting deadlines for each federal award. Assigned clear responsibility for report preparation and submission to specific personnel within the finance function. Implemented a secondary review process whereby management monitors upcoming deadlines and confirms timely submission of reports. Incorporated periodic compliance check-ins to ensure adherence to grant reporting requirements throughout the year. Management believes these measures strengthen oversight and will ensure timely preparation and submission of all required reports going forward. Anticipated Completion Date: December 31, 2026

City of Springdale, Arkansas Corrective Action Plan Contact Name: Cody Loerts Contact Phone Number: 479-750-8114 Audit Firm: Forvis Mazars, LLP Audit Period: December 31, 2025 Finding #2025-002 – Statement of Condition: The City did not submit the required annual Federal Financial Report (SF-425) to the FAA for the period under audit. Response: The City concurs with the finding. Management will implement additional controls related to reporting. The completion date for the above-mentioned corrective action was December 2026.

Finding Summary: Material noncompliance was noted in reporting as reported amounts did not agree to underlying supporting documentation. Responsible Individuals: Kim Clay, Corporate Controller and Paul DiTomasso, Site`2 Controller Corrective Action Plan: Management will review and improve internal controls over reporting to ensure that reported amounts agree to underlying supporting documentation. Anticipated Completion Date: June 30, 2026

Ecotrust is strengthening its controls over federal financial reporting to ensure required SF‑425 Federal Financial Reports are submitted (in a timely manner) in accordance with 2 CFR 200.328 and applicable award terms. Approximately three years ago, following turnover, Ecotrust shifted grantee and sub‑grantee management from a centralized model to a distributed model in which program managers assumed responsibilities for which tools and training were insufficient. To correct the underlying deficiency, Ecotrust is taking the following specific actions: • Assigning clear, documented responsibility for the preparation and timely submission of all federal financial reports (including the SF‑425), with a designated primary preparer and a backup to ensure continuity of reporting during staff absences or turnover. • Establishing a federal reporting calendar that tracks all federal financial report due dates, with proactive advance reminders shared across the finance and program teams. • Providing periodic training to finance and program staff to reinforce awareness of federal financial reporting requirements and deadlines. • Engaging an outside consultant, Jennifer Hutton, who has grantee‑management experience gained at Mercy Corps and other non‑profits, to work with the finance team and program managers to develop the supporting processes, tools, and accountability measures.

Finding No. 2025-001 – Late Report Filing (SF-425) Federal Program: Health Center Program Cluster, ALN 93.224 – U.S. Department of Health and Human Services (HHS) Contact Person Responsible for Corrective Action Guillermo J. Jiménez Ramos, Chief Financial Officer Views of Responsible Officials Management concurs with the finding. Corrective Action Planned 1. The Fiscal Department will implement a Federal Compliance Reporting Calendar covering all required federal financial reports, including the Federal Financial Report (SF-425) and Payment Management System (PMS) submissions, identifying for each report its due date, the individual responsible for its preparation, the reviewer, and the submission evidence to be retained. 2. Responsibility for the preparation of each SF-425 report will remain formally assigned to the Fiscal Department, under the oversight of the Chief Financial Officer (CFO). Each report will be subject to CFO review and approval prior to submission. Preparation of the reports will commence no later than thirty (30) days before the established due date, in accordance with internal control procedures and reporting timelines. 3. Automated reminders will be configured at thirty (30), fifteen (15), and five (5) days before each filing deadline, directed to both the preparer and the reviewer, to provide adequate oversight and prevent future delays. 4. Confirmation of each submission (PMS acknowledgment) will be retained and filed with the report workpapers as evidence of timely filing, and the status of federal reporting deadlines will be monitored monthly by the Chief Financial Officer. Anticipated Completion Date July 31, 2026

Finding No. 2025-006 – Internal control deficiencies over accounting for federal funds received from the United States Department of Homeland Security (DHS) Corrective Action Plan Single Audit 2025 Page 6 April 30, 2026 Condition During our procedures over the Authority’s funds received from FEMA we noticed the following: 1. Return of interest earned on FEMA-related funds totaling approximately $211,853 was not timely recorded in the general ledger and was subsequently recorded through a post-closing entry dated January 26, 2026. 2. Management initially misclassified approximately $6 million received under the Coronavirus State and Local Fiscal Recovery Funds as state funds rather than federal awards. As a result, the amount was originally excluded from the Schedule of Expenditures of Federal Awards (the Schedule). Views of Responsible Officials and Corrective Actions It should be noted that, although certain funds received were not properly identified as working capital advances, those funds were properly considered as received from FEMA through the COR-3 office of the Government of Puerto Rico. This situation basically arises because the federal funds coming from FEMA are being handled by outside consultants, without any coordination with the Federal Funds Management Office (FFMO). The Authority’s management will ensure that, in the future, the FFMO will coordinate with the assigned outside consultants all the efforts necessary for the proper handling, identification and classification of funds received from FEMA. Name(s) of the Contact Person(s) Responsible for Corrective Action Romel Pedraza Claudio. P.E. – Assistant Executive Director for Planning & Engineering Elena González – DEA Finance Miguel La Torre – Interim Finance Director Anticipated Completion Date During FY-2026-2027

Fergus has adopted and implemented policy: 252.0 Federal Funding Compliance to establish formal procedures and ensure ongoing compliance with applicable federal regulations, including 7 CFR 4280, Subpart A and 2 CFR 200. Anticipated completion date: August 31, 2026

The City will implement additional control procedures to ensure all reports are filed in a timely manner.

Finding 2025-002 Federal Agency Name: U.S. Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds FFALN # 21.027 Finding Summary: Eide Bailly LLP prepared our single audit for Federal Coronavirus State and Local Fiscal Recovery Funds where the Town is a subrecipient to Douglas County who is the recipient of the funds. Eide Bailly LLP identified that the Town did not have documented or consistently applied internal controls to ensure compliance with the County’s subrecipient guidance requiring the submission of formal special reports for ALN 21.027. Responsible Individuals: Mark Henderson, Assistant Director of Castle Rock Water Corrective Action Plan: Staff will complete quarterly reports including project progress and estimated project infrastructure costs. The reports will be reviewed by management prior to submission to the recipient of the Federal Funds (Douglas County). Anticipated Completion Date: Ongoing during the period that the Town is a subrecipient of these funds for the project.

Material Weakness in Internal Control over Compliance and Compliance - Reporting Federal Program: 93.939- HIV Prevention Activities: Non-Governmental Organization Based Federal Agency: U.S. Department of Health and Human Services. Award Number: NU65PS923746 Fiscal Year: July 1, 2024 – June 30, 2025 Recommendation: We recommend that management implement procedures to ensure that expenditures reported on the Federal Financial Report reflect actual costs incurred during the reporting period and are supported by appropriate documentation. Staff responsible for preparing the Federal Financial Report should be trained in federal reporting requirements to ensure compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: There is not currently a clear internal procedure on how to complete the Federal Financial Reports. This will be added to the finance department procedures and will be trained to all staff who will be responsible for this reporting. Name of the contact person responsible for corrective action: Simon Trowell, Chief Executive Officer. Planned completion date for corrective action plan: June 30, 2026

2025-008 Auditor’s Recommendation: We recommend the organization strengthen its internal controls over federal financial reporting by establishing and documenting procedures requiring that all reports submitted to federal awarding agencies or pass-through entities be prepared using actual expenditures recorded in the accounting system. These procedures should include a reconciliation of reported amounts to the general ledger and supporting documentation prior to submission, as well as an independent review process to ensure reported information is accurate, complete, and compliant with Uniform Guidance requirements. Corrective Action: UCM will develop and implement written procedures requiring that all financial reports submitted to federal awarding agencies or pass-through entities are prepared using actual expenditures recorded in UCM’s accounting system. Reported amounts will be reconciled to the general ledger and supported by appropriate documentation before submission, including general ledger detail, payroll records, accounts payable records, allocation schedules, invoices, receipts, proof of payment, and other records supporting the reported costs. UCM will implement a federal financial reporting checklist to document preparation, reconciliation, and review each report. The checklist will require verification that reported costs agree to actual expenditures, are recorded in the correct reporting period, are charged to the correct federal award, are supported by documentation, and are consistent with award terms and Uniform Guidance requirements. A qualified individual independent of the report preparation process will review and approve reports before submission, and evidence of review will be retained. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Independent Reviewer (CEO, Finance Committee Chair, or another qualified reviewer) Anticipated Completion Date: December 31, 2026

The City will review due dates to ensure proper reporting requirements are met.

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 .

2025-004 Reporting Cluster: Other major program referenced below Sponsoring Agency: Department of Labor Award Names: RETAIN Demonstration Projects Award Numbers: 1947RTN2-02B Assistance Listing Title: Disability Employment Policy Development Assistance Listing Number: 17.720 Award Year: 2024-2025 Pass-through entity: Vermont Department of Labor Management agrees with the finding related to Reporting. Management submitted monthly reports to the State of Vermont that covered all required information and thus did not believe quarterly reports were required.. The State of Vermont subsequently clarified that quarterly reports were required and we will work with them to ensure all required information is submitted for past quarters and going forward, as required. Individual Responsible: John Muhlen, System Vice President of Corporate Finance Anticipated Completion Date: September 30, 2026

Corrective Action Plan Finding 2025-001 – Allowable Costs Requirement – Time and Effort Reporting for Salaries Corrective Action: Management concurs with the findings. Day One will formalize and implement written procedures governing the documentation, review, and reconciliation of personnel costs charged to federal awards. Employees whose compensation is charged, in whole or in part, to federal awards, will be required to complete after-the-fact timesheets that accurately reflect the work performed and the total activity for which they are compensated. The documentation will be reviewed and approved by the employee's supervisor. The Finance Director is responsible for reconciling payroll allocations charged to federal awards to the certified time and effort documentation on a regular basis and ensuring that any differences identified are reviewed and corrected in a timely manner. The Finance Director is responsible for supporting documentation for payroll allocations and reconciliations is maintained in accordance with Day One's record retention policies. Day One will update its written policies and procedures to reflect these requirements and has provided training to employees and supervisors responsible for completing, reviewing, and approving time and effort documentation. The Executive Director will periodically review compliance with these procedures as part of Day One’s internal control monitoring process. We will also do a final year-end review of time and effort allocations and certification. These corrective actions are intended to strengthen internal controls over payroll allocations and ensure that personnel costs charged to federal awards are adequately documented, properly allocated, and supported in accordance with 2 CFR Part 200. Responsible Official: • Anne Patterson, Executive Director – Oversight of implementation and ongoing compliance. Anticipated Completion Date: The corrective actions will be implemented and effective as of September 1, 2026. We have already implemented this process for FY2025. Once the process is complete, Day One will update, after-the-fact documentation and approval to date and will continue the process thereafter.

Untimely Submission of Federal Financial Reports (SF 425) – Reporting – Assistance Listing Numbers: 93.224 and 93.527 Consolidated Health Center Cluster Type of Finding – Significant Deficiency in Internal Control over Compliance Cause – Controls and procedures designed to ensure timely preparation, review, and submission of required federal financial reports were not consistently followed, resulting in delayed submission of SF-425 reports. Corrective Actions: 1. Improvement of Data Entry and Documentation Management a. The process for submitting, processing, and storing sliding fee applications will be reviewed and streamlined to ensure that all supporting income level documents are properly collected, verified, and stored at the time of application submission. b. Employees involved in handling sliding fee applications and supporting documents will be provided with training on the importance of accurate documentation and the procedures for proper filing, both physically and electronically. 2. Implement Regular Monitoring and Auditing: a. A regular internal review and audit process will be revisited to ensure that backup, storage and retention practices are followed. These audits will focus on verifying that all sliding fee applications and related documents are stored correctly and are retrievable as needed. b. Any discrepancies or issues identified during audits will be addressed promptly, and corrective action will be taken to ensure compliance with the established procedures. 3. Staff Training and Awareness: a. Training sessions will be conducted for all relevant staff on the updated backup, storage and retention procedures for sliding fee applications and income documentation. This training will emphasize the importance of maintaining accurate and accessible records to comply with regulatory and organizational standards. b. Refresher training will be provided quarterly to ensure ongoing compliance and awareness.

Management acknowledges the finding. El Proyecto has implemented corrective actions, including tracking the FFR submission due dates separately from any closeout documentation submission due dates to help ensure both requirements are monitored and completed within the required timeframes. Person Responsible: Ricardo Ornelas Position of Responsible Party: Chief Financial Officer Completion Date: June 1, 2026

The County has implemented additional internal controls, including a workflow for sharing invoices during 2025 when it was discovered that the grant reporting was not done properly. The County also adopted a new grant policy in March 2026 to provide additional levels of review from the grant application process through closeout of a grant. This further ensures accurate and timely reporting going forward.

Finding Number: 2025-001 Anticipated Completion Date: 6/30/26 Responsible Contact Person: Bradley L McCain, CFO Planned Corrective Action: Management agrees with the finding. The Association's annual Federal Financial Report (FFR) was submitted 22 days after the required due date, and the semi-annual FFR was submitted 65 days after the required due date. The delays resulted from staffing disruptions, including employee turnover and an extended employee leave under the Family and Medical Leave Act (FMLA), which impacted the Association's ability to complete and submit required reports within the prescribed deadlines. To address this issue, the Association has strengthened its internal controls over Federal reporting by establishing a formal reporting calendar that identifies all required Federal reports, due dates, responsible individuals, and internal review deadlines. The Director of Grant Compliance is responsible for preparing and submitting Federal financial reports, while the Executive Director of Data and Grants Administration performs a final review to ensure completeness, accuracy, and timely submission. Management has also implemented cross-training and documented reporting procedures to reduce the risk of future delays caused by staff absences or turnover. Internal due dates have been established in advance of Federal deadlines to allow sufficient time for review and submission. The effectiveness of these corrective actions has already been demonstrated, as the subsequent semi-annual Federal Financial Report was submitted by the required deadline. Compliance with Federal reporting deadlines will be monitored on an ongoing basis.

2025-003: Reporting Compliance Requirement The City will review the current procedures for maintaining documentation for when quarterly project and expenditures reports are completed, reviewed and submitted. Contact Person: Rosie Cavazos, CFO Proposed implementation date: September 30, 2026

The Alabama Law Enforcement Agency will strengthen its review and reporting procedures to ensure Federal Financial Reports (SF-425) are submitted within the required reporting deadlines. Prior to submission, financial report information will be reviewed by multiple employees to verify the accuracy and completeness of the reported data. In addition, the Agency will implement enhanced monitoring of reporting due dates and establish internal deadlines to ensure sufficient time for review and timely submission. The Grants Section will coordinate with the Programs Office and financial staff to track quarterly reporting requirements and ensure all SF-425 reports are submitted to the federal awarding agency within 30 calendar days following the end of each reporting period. These procedures are intended to improve compliance with federal reporting requirements and ensure timely reporting for effective grant oversight and monitoring.

Finding 2025-002 Federal Agency Name: U.S. Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds FFALN # 21.027 Finding Summary: Eide Bailly LLP prepared our single audit for Federal Coronavirus State and Local Fiscal Recovery Funds where the Town is a subrecipient to Douglas County who is the recipient of the funds. Eide Bailly LLP identified that the Town did not have documented or consistently applied internal controls to ensure compliance with the County’s subrecipient guidance requiring the submission of formal special reports for ALN 21.027. Responsible Individuals: Mark Henderson, Assistant Director of Castle Rock Water Corrective Action Plan: Staff will complete quarterly reports including project progress and estimated project infrastructure costs. The reports will be reviewed by management prior to submission to the recipient of the Federal Funds (Douglas County). Anticipated Completion Date: Ongoing during the period that the Town is a subrecipient of these funds for the project.

The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying details. The Director of Grants will make sure this is done in a timely manner to comply with the reporting deadlines for each fiscal year.