Corrective Action Plans

Management's Response: Management concurs with the above finding and all documentation for annual reports will be held and kept as required moving forward. This will be implemented with the 2025 annual report.

Finding Number: 2024-001 Planned Corrective Action: Towpath Trail High School will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 2/14/2025 Responsible Contact Person: Dave Massa, Treasurer

As part of the 2023-2024 FY audit, there was a finding of non-compliance on financial reporting for a late filing. The corrective action plan is to implement new policies to ensure timely financial compliance with all grant requirements. For questions, please contact Katie Harris, the Director of Finance. The board plans to enact these new policies as of June 30th, 2025.

2024-001 Investments for Public Works and Economic Development Facilities – Assistance Listing No. 11.300 Recommendation: The College should implement formal review procedures to document review and approvals over required reports in addition to procedures to ensure reports are being submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Routine communication between program directors and accounting staff will include discussion of reporting timeline in order to ensure timely submission. The Finance Department will review and approve required reports that are prepared by grant program directors. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler, Chief Financial Officer Planned completion date for corrective action plan: February 28, 2025.

Corrective Action: Management will continue to stress the importance of following the detailed procedures for preparation and review of the SEFA. The SEFA checklist is updated to include a thorough review of expenditure details to ensure no prior-year expenses are reported. Responsibility for compiling the SEFA was assigned to a Senior Program Accounting Manager who is tasked with assuring the schedule and all the support reconciliation are complete and accurate. Both the Director of Program Accounting and the Executive Director of Finance/Controller will review the SEFA for completeness, accuracy, and compliance with CFR Section §200.510(b). Estimated completion date: June 30, 2025 Individual Responsible for Corrective Action Plan: Contact: Reginald Gregory Title: Executive Director/Controller Phone Number: 202-772-4300

FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School District in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in 2 place to prevent, or detect and correct, errors. During tie out of the Year 3 report, a variance between the underlying records and reported expenditures of $187,649 was noted due to the lack of effective controls surrounding annual data reporting. 84.425U expenditures submitted within the Year 3 report were overstated by $187,649. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will implement a formal review process over data reporting to ensure compliance with reporting requirements for federal awards. A Grant Coordinator has been hired and is already in place. Both the Grant Coordinator and Treasurer will review and sign off of required reporting and ensure it is completed in a timely manner. Responsible Party and Timeline for Completion: Andrew Grismore - Grant Coordinator and Moriah Crane - Treasurer will be responsible. These corrective measures are already in place.

2024 – 003B – Reporting Grantor: Department of Health and Human Services Passthrough Agency: N/A Program Name: Community Project Funding/Congressionally Directed Spending - Construction Award Name: Congressional Directives Award Year: 2024 Award Number: 6 CE1HS47194-01-10 Assistance Listing Number: 93.493 The Alliance management acknowledges that the Federal Financial Report (FFR) for the Congressional Directives award reporting period ending August 31, 2023 was filed late. The form was filed four business days after the due date. Through the date of this FFR filing, the Alliance had not drawn down any funds on this grant and the FFR was a $0 filing. The Alliance is up to date and in compliance with all FFR filings under the grant.

Response: Management agrees with the finding and acknowledges that a significant deficiency was identified related to report submission delay. To prevent this issue from recurring, we are implementing several corrective actions. These include establishing a stricter communication schedule with Post Award Administrators to ensure timely submission of reports and strengthening of our internal monitoring procedures by tracking submission deadlines more closely. Contact person responsible for corrective action: Lynne Duong, Post Award & Compliance Manager Anticipated completion date: December 31, 2024

Recommendation We recommend that management: ▪ Establish a formal reporting calendar outlining all required financial and performance reports, including due dates ▪ Implement procedures to ensure reports are prepared accurately, reviewed, and submitted timely ▪ Maintain documentation of submitted reports, including confirmation of submission and supporting schedules ▪ Assign clear responsibility for reporting compliance and implement supervisory review controls ▪ Provide training to relevant personnel on federal reporting requirements Strengthening reporting processes will improve compliance, enhance transparency, and ensure that the organization meets its obligations under federal awards.

2023-004 Financial Reporting Requirements Recommendation: Auditors recommend that CIES modify its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed. Criteria: 2 CIR 200.328 – Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report) or such future OMB approved, governmentwide data elements available from the OMB designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: CIES will implement a process whereby financial information required to be reported to the Federal awarding agency will be prepared by CIES administrative staff (i.e., Administrative Assistant, Chief Operations Officer) and reviewed and approved before submittal by the Executive Director. The review and approval process will be documented and stored within CIES internal electronic files, as appropriate, for each fiscal year. Name(s) of the contact person(s) responsible for corrective action: Michael Parker, Executive Director Planned completion date for corrective action plan: March 2026

FINDING 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Required IDOE templates (JotForm) are completed using AS400 budget detail reports and Position Control data, with revisions submitted during the September window to correct classifications and remove ineligible set-aside amounts. Adjustments were made to align ESSER I reporting and to avoid timing discrepancies by using budget detail rather than summary reports. The completed report will be reviewed for accuracy and approved prior to submission. Beginning in fall 2023, the reimbursement process was updated to include all required supporting documentation, such as transaction detail and summary reports. Each request is also reviewed and signed by the supervisor to document approval. On a recurring basis, the Director of Federal Grants generates the detailed expenditure report and budget summary. The detailed report is filtered to capture only the transactions occurring since the previous reimbursement request, making new expenditures easy to identify. These amounts are added to the cumulative reimbursement totals, which are then compared to the total disbursements shown on the summary report to ensure they align. Once the totals match, the reimbursement request is reviewed by the Chief Financial Officer and submitted to the awarding agency. Completion Date 6/30/25

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the findings Description of Corrective Action Plan: Beginning in fall 2023, reimbursement requests have included all required supporting documentation, such as transaction detail and summary reports. Each request is also reviewed and signed by the supervisor to document approval. On a regular basis, the Director of Federal Grants will generate the detailed expenditure report and budget summary. The detailed report will be filtered to capture only the transactions occurring since the previous reimbursement request, making it easy to identify new expenditures. These amounts will be added to the cumulative reimbursement totals. The updated total will then be compared to the total disbursements shown on the summary report to ensure they align. Once the totals match, the reimbursement request will be reviewed by the Chief Financial Officer and subsequently submitted to the awarding agency. Correction Date 06/30/2025

FINDING 2023-005 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Earmarking All expenditures related to parental involvement are tracked using a designated expenditure code. The required homeless set-aside is monitored using department-level data. The same expenditure code is applied to both the mandatory parental involvement set-aside and any additional parental involvement funds. This allows the district to track the spend-down of the mandatory set-aside and determine how much must be carried over into the next grant year. Schools are expected to use the mandatory set-aside funds first, following a FIFO (first-in, first-out) approach, before accessing any parental involvement funds beyond the required amount. We are actively coordinating with the homeless liaison to ensure that fund balances remain current and transparent to all stakeholders. This collaboration supports more effective planning and helps ensure that the funds are spent down appropriately and on schedule. Correction Date 6/30/2025

Corrective Action Plan Action Item Responsible Party Timeline Monitoring Establish procedures to track and monitor all federal reporting deadlines, including SF-425 and UDS reports. CFO Immediate Monthly review Maintain supporting documentation for federal financial and program reports in accordance with record-retention policies. CFO / Accounting Staff Immediate Periodic internal review Implement supervisory review procedures to verify the accuracy and timeliness of federal reports prior to submission. CFO / Executive Management Immediate Each reporting cycle Establish formal turnover procedures for federal reporting responsibilities to ensure continuity of reporting and documentation during personnel transitions. CFO Within 30 days Management oversight ________________________________________ Management Response Management, under the direction of the Chief Financial Officer, acknowledges the findings related to the timeliness of federal financial reporting. Management recognizes that the late submission of certain SF-425 reports resulted from prior turnover in accounting and executive management personnel and the absence of formal procedures for monitoring federal reporting deadlines and maintaining supporting documentation. As of FY2026, management implemented supervisory oversight and a personnel exit clearance process to ensure continuity and completeness of financial records. Management also provides the Board with updates on personnel transitions and associated risks to support proper oversight and timely remediation of identified issues. As of FY2026, procedures have been implemented requiring that all supporting documentation and attachments be uploaded and maintained within the online accounting system and google shared drive to strengthen internal controls, improve transparency, and ensure consistent documentation practices.

Reference Number: 2023-010 Finding: Improve Controls and Compliance with Reporting Name of Contact Person: Lorina Esposito Corrective Active Plan: In the past year, the City has fully staffed the division of housing and community development which has led to the successful submission of the 2024 CAPER. The staff worked diligently to find all required data for the report and participated in training courses to prepare for future CAPERs. Proposed Completion Date: 3/31/26

Reference Number: 2023-008 Finding: Improve Controls and Compliance with Reporting Name of Contact Person: Christine Chamberland Corrective Active Plan: The City will develop and implement formal written procedures for preparing, submitting, and retaining all required quarterly performance and evaluation reports in compliance with program requirements. Designated staff will be responsible for tracking reporting deadlines, ensuring timely submissions, and maintaining thorough documentation of all reports. Management will conduct regular reviews to monitor compliance and address any deficiencies promptly. Proposed Completion Date: 6/30/26

Finding Number: 2023-002 Planned Corrective Action: City Auditor has confirmed the ARPA 3/31/24 and 3/31/25 Project and Expenditure Reports submitted agree to City Accounting records. Anticipated Completion Date: July 3, 2025 Responsible Contact Person: City Auditor Sherri Hess

Audit Finding: 2023-002 – Lack of Documentation of Review and Approval Planned Corrective Action(s): SIG-NAL will enhance internal controls by implementing formal review and approval processes for payroll, expenses, and financial reporting. The organization will require documented evidence (digital or written) of all reviews and approvals and will maintain these records in a standardized, centralized system. The Finance Team will ensure that all controls are performed and documented in accordance with 2 CFR Part 200 requirements. Updated internal control policies and procedures adopted in 2025 address these requirements and are being fully implemented. Anticipated Completion Date ● March 2026 Responsible Party ● Director of Operations, with support from the Finance Team and Executive Director

The City will work to ensure all reports for grant funding are completed.

Response to finding 2023-005 – Reporting Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2023-005. 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. 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. Page

We agree with the recommendations offered for the relevant programs and will establish and implement policies that provide for documentary evidence of review of applicable reports by qualified individuals to ensure the timely submission of required reports to applicable federal agencies that can be easily reconciled to the underlying accounting records.

Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Compliance) We recommend that management establish and enforce procedures to ensure all required federal financial and progress reports are submitted by the applicable due dates. Management's Response: The County concurs with the findings; Responsible Individual: Nicole Reinert, Public Health Director; Corrective Action Plan: Administrative staff will schedule out all required report dates in the Outlook calendar at least three weeks before the due date to keep responsible parties informed of deadlines. These set reminders will ensure timely submissions. The Department Head will review the submission process to eliminate congested workflow to ensure efficiency and identify any tasks that can be automated or improved. Regular check-ins will take place to discuss the status of ongoing reports.; Anticipated Completion Date: June 30, 2026.

Schools and Roads - Grants to States (Compliance) We recommend that the County establish internal control procedures to ensure that required certifications for Title III expenditures and unobligated funds are completed, reviewed, and submitted timely in accordance with federal requirements. Management's Response: The County concurs with the findings. Responsible Individual: Allen Hisky, Clerk of the board of Supervisors; Corrective Action Plan: The Clerk of the Board will ensure that sufficient internal controls are in place for proper notification of Certification Title III Expenditures and Unobligated Funds by statutory deadline. This process should include clear assignment to responsibilities and retention of documentation as part of grant compliance records.; Anticipated Completion Date: June 30, 2026.

Person Responsible: Fiscal Administrator (Grants and Budget) Deadline: CUC agrees to develop and create a more refined tracking system and staffing for compliance purposes. A tracking system is in place as of this writing.

Views of Responsible Officials and Planned Corrective Action We will give instructions to the accounting staff in charge of the preparation of the quarterly progress reports of the Program, in order to comply with the FEMA reporting requirements. Responsible Official: Mrs. Irma M. Vargas Aguirre, Finance and Budget Director Implementation Date: December 31, 2025