Corrective Action Plans

Each employee will have a payroll file that includes: • Date of hire • Title • Grant(s) they are assigned to if applicable • Pay amount • Any changes to the above and the date of the change Each employee will complete a timesheet weekly that includes the number of hours worked and if applicable broken out by what grant(s) they worked on. The bookkeeper provides a budget:actual report when invoices for federal contracts are prepared. The ED notes signs off that they have been approved for draw. That report is stored on the server. The Treasurer reviews the cost-reimbursement requests prepared by the ED, along with the detailed back up.

The City will review its process for accumulating data for required reports and implement additional procedures to reconcile reports with cash basis activities.

On behalf of Bebashi – Transition to Hope, I am submitting this corrective action plan in response to the material weakness finding identified in our recent federal audit. The finding noted a lack of effective internal controls over the maintenance of accurate accounting records, including the trial balance, general ledger, and the Schedule of Expenditures of Federal Awards (SEFA) and state financial assistance. These deficiencies resulted in material audit adjustments to the current year’s financial statements, multiple versions of the trial balance due to reconciling issues, and audit delays related to unreconciled supporting documentation. We take these findings with the utmost seriousness. As stewards of federal funds, it is our fiduciary duty to maintain strict compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200), as well as applicable state financial requirements. Corrective Action Plan 1. Strengthening Internal Controls o We are implementing enhanced internal control procedures to ensure timely reconciliation of the trial balance and general ledger. o Monthly reconciliations will now be prepared by the Finance Department, reviewed by the Chief Operating Officer, and formally approved by the President & Chief Executive Officer prior to closing. o Quarterly oversight reporting will also be provided to the Bebashi Board of Directors. 2. Accounting System Improvements o We will establish a standardized process to ensure one official version of the trial balance is maintained, with all adjustments tracked and documented in accordance with Generally Accepted Accounting Principles (GAAP). o We are upgrading our financial reporting system to include automated reconciliation checks, audit trails, and controls that will minimize the risk of discrepancies. 3. Staff Training and Accountability o Finance staff will undergo mandatory annual training on federal compliance, SEFA preparation, and reconciliation best practices. o Roles and responsibilities will be clearly defined, with a segregation of duties to prevent misstatements and errors. 4. Audit Readiness and Documentation o A comprehensive audit binder will be prepared and maintained to ensure that supporting documentation reconciles with the trial balance prior to submission. o A compliance calendar will be developed to track critical deadlines, reconciliation reviews, and reporting requirements. 5. Board and Executive Oversight o The Bebashi Board of Directors, through its Finance and Audit Committees, along with the President & CEO, will provide governance oversight of this corrective action plan. o Quarterly progress reports will be submitted to the Board, and the CEO and Board will formally document oversight in meeting minutes to ensure accountability and compliance. Responsible Party: The Finance Director, in collaboration with the Chief Operating Officer and with final accountability to the President & CEO as well as the Bebashi Board of Directors, will be responsible for implementing and monitoring this corrective action plan. Anticipated Completion Date: All corrective measures will be completed within ninety (90) days of the date of this letter, with ongoing monitoring and governance oversight by the CEO and Board of Directors to ensure sustainability. We regret the deficiencies that led to this finding and are committed to taking the corrective actions necessary to strengthen our financial management systems. Bebashi – Transition to Hope is dedicated to full compliance with federal and state requirements and to safeguarding the integrity of public funds entrusted to us. Respectfully submitted, Sincerely, Sebrina Tate President & Chief Executive Officer Bebashi – Transition to Hope On behalf of the Bebashi Board of Directors

Emergency Relief Fund (HEERF) Programs (significant deficiency) Condition (per audit): Non-compliance noted regarding untimely filing of quarterly and annual report. SwCC’s Explanation: The HEERF department and reporting systems were closed, and Grants personnel were unable to retrieve a copy of the required reports from the ESF Data Collection System by the suggested deadline of May 19, 2025. Corrective Actions (overseen by the President): 1. Grant Reporting Calendar o A compliance calendar with all DOE reporting deadlines was created in August 2025. o Internal deadlines are set two weeks before federal due dates. o Responsible Official: Director of Grants 2. Dual Review & Submission Tracking o All grant quarterly and annual reports must be reviewed and signed off by the Director of Grants, President, and Comptroller before submission. o Submission confirmations will be saved in the respective grants folder of the electronic filing system. o Responsible Officials: President, Director of Grants & Comptroller 3. Centralized Filing & Audit Readiness o Grant reports (quarterly, annual, and related correspondence) will be stored in the centralized electronic filing system for continuity and audit review. o Responsible Officials: Director of Grants & Business Office 4. Quarterly Compliance Checks o The President and Director of Grants will conduct quarterly compliance reviews to confirm all required reports are submitted timely. o Responsible Officials: President & Director of Grants 5. Time and Effort Reporting in Populi o Effective August 2025, time and effort reporting for all Title IV-funded student workers and grant-funded employees will be completed in Populi, capturing descriptions of duties and percentage of time worked, aligned with payroll and funding sources. o Responsible Officials: Director of Grants & Comptroller/Business Office Completion Date: Reporting calendar implemented August 2025; all future reports will be submitted timely under this protocol. Southwestern Christian College is committed to full compliance with federal regulations and the highest standards of financial accountability. The corrective actions outlined above address both Title IV and HEERF audit findings with immediate steps, ongoing monitoring, and strengthened internal controls. With the implementation of new reconciliation processes, expanded staffing in the Business Office, centralized electronic filing, enhanced verification and reporting protocols, and a structured compliance calendar, SwCC has established sustainable safeguards to prevent recurrence of deficiencies.

In 2024, 9/11 Day was unaware of this regulation, but agrees with this finding. 9/11 Day has adopted a written policy that shall ensure that all subgrants made are properly compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA). All subgrantees will be entered into a centralized tracking log, and for those receiving pass-through funds exceeding $30,000, the required reporting will be completed directly in SAM.gov, which now includes the Federal Subaward Reporting System (FSRS). Each subgrantee’s eligibility will be verified in SAM.gov, with the date and results of the verification recorded, and all supporting documentation retained on file. This corrective action ensures that all subawards are properly logged, reported, and compliant with FFATA requirements.

Federal Program: Community Development Block Grant – Disaster Recovery (CDBG-DR) (ALN 14.228) Condition: Untimely submission of monthly progress reports. Planned Corrective Action: Management acknowledges the finding related to the timeliness of monthly report submissions. Although reports were prepared internally by the required due date, submission to the PRDOH reporting system was delayed pending review and approval of the prior month’s report by PRDOH . To strengthen compliance with reporting requirements, the Organization will implement the following corrective actions: • Internal documentation: Maintain dated copies of all monthly reports prepared by the 5th day following the reporting period to demonstrate timely preparation. • Communication with PRDOH: Retain written communications with PRDOH when reports cannot be submitted due to pending approvals, documenting the cause of delay. • Formal request: Submit a written request to PRDOH seeking clarification of reporting requirements and advocating for a process that permits timely submission regardless of system approval delays. • Monitoring: assign responsibility to the Finance and Compliance Officer to track reporting deadlines and ensure documentation of both preparation and submission efforts. Responsible Official: Thomas P. King Anticipated Completion Date: Ongoing – procedures to be implemented beginning with reports due for October 2025.

Finding: The County’s first quarter 2024 performance report incorrectly included expenditures that were incurred throughout fiscal year 2023. Cause: The County did not have adequate controls or procedures in place to identify the applicable reporting requirements and ensure the information was filed accurately and timely. Recommendation: Management should implement policies and procedures to ensure required reports are completed accurately and filed by their respective due dates as required by the grant agreement and Uniform Guidance. Corrective Action Plan: Effective immediately, the County will put in additional controls and verify all grants are monitored under additional scrutiny and are reported accurately in quarterly reports. Staff Responsible for Implementation: Matt Davis, County Auditor; Mike Sloan, Senior Associate; Jordan Wilson, Grant Associate Implementation Date: December 31, 2025 Status: In progress

April 30, 2025 To: Clausell & Associates, P.C. From: Camille Vickers, Executive Director of West Central Georgia Community Action Council, Inc. Below is the Council’s corrective action plan as it relates to the findings for the fiscal year ending September 30, 2024, Single Audit Act audit. Comment #2024-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED GENERAL (Repeat) Views of Responsible Officials and Planned Corrective Actions: We concur with this finding – Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Council’s financial funding sources, the Council will provide additional training to support the new fiscal officer. The fiscal officer will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. All enhancements will be implemented by July 31, 2025. Concerning the preparation of external reports required by various funding sources, the Council will ensure adequate training is provided to improve the skills and knowledge of key personnel. Policies and procedures will also be revised to support external reporting. Implementation Date: The plan correction date will be completed no later than July 31, 2025. Responsible Person: Camille Vickers, Executive Director, will be responsible for the corrective action. Comment #2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED LIHEAP FALN 93.568 (Questioned Costs – Undetermined) Views of Responsible Officials and Planned Corrective Actions: We concur with this finding – Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Council’s financial funding sources, the Council will provide additional training to support the new fiscal officer. The fiscal officer will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. All enhancements will be implemented by July 31, 2025. Concerning the preparation of external reports required by various funding sources, the Council will ensure adequate training is provided to improve the skills and knowledge of key personnel. Policies and procedures will also be revised to support external reporting. Implementation Date: The plan correction date will be completed no later than July 31, 2025. Responsible Person: Camille Vickers, Executive Director, will be responsible for the corrective action.

The previous audit firm did not find this to be an issue, we were told that reporting to FFATA was needed once a year for the previous year’s disbursements and that is what we have done. Now we will report every time we pass the $30,000 disbursement to a subrecipient.

The corrective action for this finding was completed following the 2023 audit. The finding did not reoccur since that time but rather the reissue of the finding for reporting periods that occurred prior to the implementation of the 2023 corrective action plan. The position of Grants Coordinator was created and filled to handle grants management functions which ensures proper quarter end dates and expenditures appropriate for the period are reported. Under this process, the Grant Coordinator collaborates with the Construction Financial Administrator to complete forms which are then reviewed with the Director of Grants and CFO prior to submission.

The Administrator and Fiscal Officer will work to ensure all reports for grant funding are completed.

FINDING 2024-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-882-6426 clane@vincennes.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All reports will be prepared by the clerk’s treasurer’s office and will be reviewed by someone who is knowledgeable about the reporting requirements prior to submission. They will review reports for errors and omissions. After this additional review, the report will be submitted. Anticipated Completion Date: This corrective action plan will go into effect immediately.

FINDING 2024-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-882-6426 clane@vincennes.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Clerks office will identify non- compliant activities to ensure that funds are being used appropriately and according to federal guidelines and principals. We will consult with the relevant personnel to ensure understanding of allowable and unallowable activities and identify areas that may need additional training. We will enhance our review and approval process and provide clear documentation requirements to our departments. Anticipated Completion Date: This corrective action plan will go into effect immediately.

FINDING 2004-006 Finding Subject: COVID-19-Coronavirus State and Local Fiscal Recovery Funds Reporting Contact Person Responsible for Corrective Action: Celita Green, City Controller Contact Phone Number and Email Address: 219-881-5085 Views of Responsible Officials: We concur with the finding that Total Cumulative Expenditures reported for Quarter 2 report (April 1, 2024 to June 30, 2024) and Quarter 3 report (July 1, 2024 to September 30, 2024) were understated. However, there is no mechanism to file corrective to the State and Local Fiscal Recovery Funds (“SLFRF”) Compliance Quarterly Reports with the Treasury reporting system once they are submitted. The City did make cumulative adjustments in the Quarter 4 report (October 1, 2024 to December 31, 2024) to agree with Cumulative Expenditures in the Report with the City’s accounting records, once the City determined the cumulative totals were inaccurate prior to being audited. Description of Corrective Action Plan: As stated above, the City did make cumulative adjustments in the Quarter 4 report (October 1, 2024 to December 31, 2024) to agree with Cumulative Expenditures with the City’s accounting records, in accordance with the periodic updates to the “Compliance and Reporting Guidance for State and Local Fiscal Recovery Funds” issued by the U.S. Department of the Treasury, which indicates how to make cumulative adjustments in the current quarter’s report. Since the 4th Quarter 2024 Compliance Report, the City’s totals agree with Treasury Quarterly Reports to date. . Anticipated Completion Date: Actions were completed on January 30, 2025

Finding 2024-002 Finding Subject: Economic Development Cluster – Reporting Summary of Finding: Material Weakness, Other Matters The data submitted in the SF-425 report submitted by the city for the reporting period ending on 9/30/24 contained the following errors: • Cash Receipts Understated by $1,037,155 • Cash Disbursements Understated by $1,037,155 The lack of internal controls and noncompliance was isolated to the award 06-79-06420 EDA-Davis Road Construction project. Contact Person Responsible for Corrective Action: Weston Reed Contact Phone Number and Email Address: 765-456-7380 wreed@cityofkokomo.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: City of Kokomo will design and implement a procedures where the Federal Financial Report and the Quarterly progress report will be reviewed by the director of development to ensure that there is oversight and that the report is complete and accurate. Anticipated Completion Date: December 31, 2025

2024-006 Improve Internal Controls Over Reporting Management Response and Corrective Action Plan (DPW): Management concurs with the finding. The City / DPW will implement enhanced reconciliation procedures to ensure all SF-425 reports agree to the general ledger and SEFA, with independent review prior to submission. Management Response and Corrective Action Plan (Planning): Management concurs with the finding. The City / Planning Department will implement enhanced reconciliation procedures to ensure all SF-425 reports agree to the general ledger and SEFA, with independent review prior to submission. Planned Implementation Date: 12/17/2025 Person Responsible for Corrective Action: Julianne Pelletier

Management’s Corrective Action Plan In response to finding 2024-001, management will improve the reporting timeliness of grant details by the identified timeframe. Management intends to implement a monitoring process to ensure compliance with the reporting requirements of the grants. This would include adherence to meeting the reporting timelines. Individual Responsible for Corrective Action Plan Nicole DuPont Director of Strategic Development & Grants (269) 986-0077 Anticipated Completion Date: October 1, 2025

Criteria: Federal and state grant agreements typically require recipients to maintain effective internal controls over financial reporting. These include accurate and timely submission of required reports; proper documentation and retention of supporting records and review and approval processes to ensure compliance and accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Containment: To prevent miscoding of expenses, we implemented a change in the prior fiscal year to allocate all CACFP-related expenses to a distinct program code. This ensures that CACFP costs are tracked independently and not charged to direct programs. Root Cause Reconciliation of the reimbursement from USDA can vary on the reimbursement of the cost of food. Where there is less cost than reimbursement we are reconciling the overage to staff wages of kitchen staff and supplies for the kitchen at the end of the year instead of monthly. Action Taken Reconciliation of the monthly reimbursement amount from CACFP to the food expenses will be reviewed each month by the 10th (for the following month) and reconciliation to the appropriate programs will be journal entries and included in the monthly review of revenue and expenses.

Corrective Action: 4-C has implemented a procedure for reviewing and approving all financial reports to external entities. Responsible for Corrective Action: Management Team Anticipated Completion Date: 8/26/2025

Views of responsible officials and planned corrective actions: The Public Works Department implemented several measures to ensure compliance with grant reporting requirements, including scheduling quarterly meetings with Project Managers, attend training sessions provided by the grant sponsor, and send reminders to the Project Managers no less than 15 days before the reporting deadline.

FINDING 2024-002 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Valeriano Gomez, City Controller Contact Phone Number and Email Address: (219) 391-8220, vgomez@eastchicago.com Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: To ensure proper implementation of the policies and procedures in place related to SLFRF reporting, in the future, no submittal of reports will be approved without the City Controller and a Senior Staff Accountant reviewing and approving the P&E reports. This will ensure policies and procedures are followed and possibly added to, if needed, to ensure compliance over SLFRF reporting. Anticipated Completion Date: Corrective action is now in effect as of August 18, 2025.

Condition: As of the March 31, 2024, reporting date, the Town reported project amounts voted by the Select Board as obligated rather than purchases, contracts and agreements that met the Federal criteria of an obligation. Corrective Action Plan: Misinterpretation of Federal reporting requirements regarding the definition of an obligation. Reliance on local budgetary approvals (Select Board votes) rather than federally defined contractual commitments. Lack of documented procedures for distinguishing between appropriations/votes and obligations in Federal reporting. This was primarily due to the many changes by the US Treasury on ARPA Federal Reporting. The Select Board did obligate funds for the Town to hire a compliance accountant as an administrative service which is allowable under ARPA to ensure compliance. In addition, the Town hired a full-time grants coordinator to oversee the grants. All future reports will reflect only qualifying obligations supported by contracts, purchase orders, or agreements. Anticipated Completion Dates: o Completed in 2025: Correction of prior misreporting and adoption of revised obligation reporting practice. o By September 30, 2025: Grant Coordinator additional training and issuance of updated reporting checklist. o Ongoing: Federal obligation reports prepared quarterly, reviewed by the Grant Coordinator prior to submission. Quarterly compliance checks will be performed by the Grant Coordinator to confirm obligations are federally compliant. Contact Information: Donna Cotterell, Grant Coordinator

Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager

Description of Finding: Reporting - Significant Deficiency in Internal Controls Over Compliance and Noncompliance · Criteria: In accordance with 2 CFR 200.328 (Uniform Guidance), recipients of federal funds must file complete, accurate, and timely financial reports using the prescribed standard reporting forms (e.g., SF-425). These reports must be supported by the recipient's underlying accounting records and signed by authorized personnel. · Condition/Context: The Tribe was unable to provide documentation demonstrating that the required Federal Financial Report (FFR) for the year ended September 30, 2024, was submitted. As a result, the auditors could not determine whether FFR was filed in a timely manner or whether it included the proper authorization signature. · Cause/Effect: The apparent lack of formal procedures or controls for retaining evidence of FFR submissions contributed to the unavailability of supporting documentation. The absence of evidence of submission and authorization could result in noncompliance with federal reporting requirements. If the report was not submitted timely or was not signed by authorized personnel, the Tribe may be subject to adverse consequences, including potential questioning of costs, additional oversight, or delays in future funding. Statement of Concurrence or Nonconcurrence: Tribe agrees with the finding as stated by the auditors. Corrective Action: The Tribe has drafted a comprehensive Financial Management Policies and Procedure Manual, which includes a section specific to grants management and procurement, that will provide guidance for month end close, asset management and preparation of the Schedule of Expenditures of Federal Awards. Reporting, etc. The Financial Management Policies and Procedure Manual will be presented to the Tribal Council for review and adoption by December 2025. Additionally, the Tribe has a third-party CPA firm to conduct mandatory Uniform Guidance training and regular grant compliance and accounting training for all program and accounting staff working with grant awards. Persons Responsible: Leslie Williams, Senior Vice President of Finance Wendy Collazo, Executive Director of Accounting - Tribal Government Name of Contact Person: Leslie M. Williams Senior Vice President of Finance Leslie.williams@29palmsbomi-nsn.gov 760.984.4514 Sincerely yours, Lapoli( W/. William) Leslie M. Williams Senior Vice President of Finance

Corrective Action Plan: The Organization has updated its internal review procedures to reflect the need to submit the quarterly Federal Financial Reports within the timeframe prescribed by the terms and conditions of the Federal award.