Corrective Action Plans

MUNICIPALITY OF TOA ALTA CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2025 FINDING NUMBER 2025-004 U.S. DEPARTMENT OF HOMELAND SECURITY DISASTER GRANTS – PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) (ALN 97.036) PASS-THROUGH AGENCY CENTRAL OFFICE OF RECOVERY, RECONSTRUCTION AND RESILIENCY OF PUERTO RICO (COR3) FEDERAL EMERGENCY MANAGEMENT AGENCY (FEMA) REPORTING (L) SIGNIFICANT DEFICIENCY (SD) / NONCOMPLIANCE (NC) Corrective Action: The Municipality acknowledges the differences identified between the expenses reported in the Quarterly Progress Reports (QPRs) and the accounting records. To address this issue, the Municipality will implement a reconciliation process between the accounting records and the QPRs prior to their submission to the pass-through entity. Additionally, management will perform a supervisory review to ensure that the reported expenses agree with the accounting records and supporting documentation. Statement of Concurrence and Responsible Person: We concur with the auditors’ finding. Miguel Fonseca Federal Programs Director Implementation Date: Fiscal year 2026-2027

Finding Reference: 2025-001 – Reporting Condition: During testing of reporting compliance for major federal programs, we selected three of twelve monthly OAF reports submitted during the fiscal year. For each month tested, reported amounts did not reconcile to MOFC’s internal Poundage Distribution reports and Product Code – Agencies by County reports. Specifically, we identified material variances between the OAF reports and internal distribution records, including: October 2024: ACP distributions were omitted from the OAF report, resulting in a variance of approximately 821,528 pounds (projected dollar impact of $262,889). January 2025: VA/Holiday Purchase distributions were omitted from the OAF report, resulting in a variance of approximately 310,898 pounds (projected dollar impact of $155,449). June 2025: Donated distributions, primarily Direct Retail Pickup (DRP) quantities, were omitted from the OAF report, resulting in a variance of approximately 933,505 pounds (projected dollar impact of $1,764,324). Additional differences were noted in purchased distributions of 40,399 pounds (projected dollar impact of $16,968). Although management provided explanations indicating that certain distributions were omitted in error or excluded due to differences in reporting scope, MOFC did not maintain documented reconciliations supporting the reported amounts. Evidence of review and approval demonstrating that differences were identified, investigated, and resolved prior to report submission was not provided. Views of Responsible Officials Items 1 & 2 are both failures of a report in our former ERP to include exception components and needed to be added manually when reporting. This is a result of human error. Item 3 is a result of a WIP component currently being installed into the new ERP to add in programmatic data for agency pickups. This is currently added manually for reporting purposes – also human error. Planned Corrective Action: Implementation of the Direct Retail Pickup poundage integrations into the current ERP will negate the necessity to manually enter the numbers. While this install is occurring, we will continue to manually update. Anticipated Completion Date: Initial discussions have occurred with an anticipated solution provided, tested and approved before the end of FY26 timeframe.

COMMONWEALTH OF PUERTO RICO CORRECTIVE ACTION PLAN MUNICIPALITY OF NARANJITO FOR THE FISCAL YEAR ENDED JUNE 30, 2025 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Orlando Ortíz Chevres - Mayor Contact Person: Mrs. Meyleen Hernández, Finance Director Phone: (787) 869 – 2200 Finding Reference Number: 2025-005 Federal Award: Disaster Grants – Public Assistance (Presidentially Declared Disaster) (ALN 97.036) Compliance Requirement: Reporting (L) Type of Finding: Significant Deficiency in Internal Controls (SD), Instance of Noncompliance (NC) Description of Finding: In our Reporting Test, we evaluated the Quarterly Progress Reports of a total of eleven (11) projects for two quarters of fiscal year 2024-2025. During our audit procedures, we noted that the reports did not agree with the accounting and project records. Auditor’s Recommendations: We recommend that Program Administrators reconcile the differences between the quarterly report and the accounting records before the submission of the next submission to the pass-through entity. Corrective Action: We understand that only two reports did not agree with the accounting records. We have consultants that are responsible for the preparation of these reports. Instructions were given to the consultants in order to correct the reports that do not agree with the accounting records. There was a misunderstanding with the reports, in which the pass-through entity instructed that purchase orders and expenditures incurred should be reported. As subsequently clarified, only the expenditures incurred should be reported as expended. Name of Contact Person: Meyleen Hernández Rivera, Finance Director Projected Completion Date: June 30, 2026

Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Aiport Programs; We recommend that the City establish a tracking system to monitor all required reports and their due dates to ensure timely submission. Management's Response: City of Red Bluff contracts out airport grant compliance to a third-party contractor. The scope of services in that contract end at the completion and submittal of the grant closeout documents. Delays in the Federal Government review and comment of grant closeout documents have left a period where the final closeout documents have been submitted but the grant is not closed. In the period when the final closeout documents have been submitted but the grant was not closed, the City was required to submit annual SF-425 reporting package and will continue to be required to file the annual SF-425 reporting package until the Federal Government can process the closeout documents. This period was erroneously left out of the scope of services for the third-party contractor grant compliance, and the City failed to submit the proper reports.; Responsible Individual: Scott Miller, Public Works Director; Corrective Action Plan: The City will add to the scope of services template language to add compliance period of between submittal of the grant closeout documents and acceptance of those documents. The City will then monitor the contract for these new services. The City will also file the missing SF-425 forms.; Anticipated Completion Date: 4-30-2026

FINDING 2025-004 Subject: COVID -19 - Education Stabilization Fund - Cash Management Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation will implement and consistently apply a standardized two-level review and approval process for all grant reimbursements to ensure proper accounting, documentation, and compliance. The grants administrator (or designee) will prepare and conduct the initial review of each grant reimbursement to verify that all expenses and receipts contain the correct accounting information, are properly documented, and are recorded in the appropriate accounts within the Financial Management System (FMS). The Corporation Treasurer (or designee) will perform an independent secondary review of all grant reimbursements, including a review of supporting documentation and account coding, and will provide final approval and signature as evidence of authorization. On a monthly basis, grant accounts will be reviewed by the grants administrator for accuracy and completeness, with the Corporation Treasurer (or designee) conducting a secondary monthly review to confirm accuracy and compliance. This two-level review process ensures adequate segregation of duties, strengthens internal controls, and provides documented oversight of all grant reimbursement activity. Anticipated Completion Date: The ESSER grant is finished. If we were to receive this grant in the future, Silver Creek School Corporation would apply the procedures in the corrective action plan.

Corrective Action Plan for Finding 2025-001 We are in receipt of the Finding Required to be reported by the Uniform Guidance regarding the Reporting Compliance Requirement. Management agrees with the finding. The discrepancy in current-year reporting resulted from a computational oversight caused by a formula error within the reporting templates. Where possible, we will add automated check figures to the reporting spreadsheets to validate data accuracy and strengthen internal review procedures. Jamie Moore, Accounting Manager, will be responsible for ensuring this is accomplished. The correction action plan will be implemented by September 30, 2026.

Noncompliance/Material Weakness in Internal Control over Compliance: • Provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. • Develop and implement policies and procedures for financial and performance report preparation to ensure information is supported by proper documentation and agrees with the general ledger. These policies and procedures will also include a requirement that all reports are reviewed by a member of management who is not involved in the preparation of the reports.

Finding No. 2025-001: Segregation of Duties and Oversight – Payroll - Material Weakness in Internal Control over Financial Reporting Contact for Corrective Action: Matt Bergheiser, President Actions were taken to correct this finding immediately after the issuance of the FY2024 audit report in March 2025. As indicated in the FY2025 audit report, this weakness was noted for the period from July 2024 through March 2025. The weakness was corrected after March 2025 with the following actions: Preparation of timesheets and allocation of time prepared by the finance department with respect to federal grant awards are reviewed and approved by the department leaders where the federal grant dollars are being spent.Additionally, for better segregation of duties for financial reporting and grant reporting the following controls were added: The finance department instituted a monthly financial reporting package to be sent to the President of the organization which includes the monthly financial statements and any significant adjustments in the previous period. President will review and approve the packet monthly. The head of the finance department reviews all general ledger detail, a listing of all journal entries made, and significant accounts reconciliations, done by finance department staff. Aged payables and receivables are reviewed by the team internally and reported periodically to the President. Finally, reporting also includes an update to the Schedule of Federal Awards and other significant grant reporting done in conjunction with the advancement team. An executive member of management, reviews the federal grant reports prepared by the finance team prior to submission. In addition, UCD hired a full-time CPA Controller in April 2025 to manage and oversee compliance for the organization and ensure the timeliness of reporting. Expected Completion Date: 7/1/2025 Finding No. 2025-002: Reporting – Material Weakness in Internal Control over Compliance Contact for Corrective Action: Matt Bergheiser, President See Plan for Finding No. 2025-001, same plan applies here. Expected Completion Date: 7/1/2025

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

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

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

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

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

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

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

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

Finding 2025 – 003 - Reporting (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. To enhance the effectiveness of internal controls and ensure that all Title III reports are accurate, properly reviewed, and approved prior to submission, the Fiscal Service office will require management to review and sign off as confirmation of approval prior to submission.

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

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

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

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

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

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

The Morgan County Economic Development Office acknowledges the status and final reports for the CDBG and Home grant programs must be submitted by the required due dates. The office will actively monitor all deadlines and ensure that all reports are completed and submitted in a timely manner in accordance with those requirements.

The Municipality of Comerío made a contract with an auditing firm to work on the reports and submission of the FASS-PH financial report compliance for the years in which the reports were not submitted. Furthermore, instructions were given for the HUD Coordinator to monitor the delivery of reports by the contracted auditing firm and to ensure that the contract for this service is finalized.