Corrective Action Plans

The district will create an SOP for the reporting process, including reviewing procedures to ensure accuracy of reporting periods. The district will also create and maintain an SOP for maintaining supporting documentation in the reporting package for all amounts and keeping staff trained on these SOPs.

U.S. Department of Treasury • Material Weakness in Internal Control over Compliance Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Condition: During audit testing of financial reporting for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to locate three of ten financial reports requested for review. As a result, auditors were unable to verify the accuracy, completeness, or timeliness of the reported financial information for those reporting periods. Recommendation: The Organization should strengthen internal controls over financial reporting and record retention by establishing clear procedures to ensure that all required reports are accurately prepared, timely submitted, and retained in accordance with federal requirements. Management should designate responsible personnel and implement monitoring procedures to verify compliance with reporting and documentation standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization will require that all supporting documentation related to financial reporting—including reports, source data, approvals, and correspondence—be retained electronically within Sage Intacct using standardized attachment and naming conventions. Management will implement periodic monitoring procedures, including supervisory review and internal spot checks, to verify that reports are timely submitted and that documentation is properly retained in Sage Intacct in accordance with applicable federal record-retention requirements. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.

Finding Number: 2024-009 Finding Title: Untimely or Incomplete Performance and Financial Reporting Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program Compliance Requirement: Reporting - Performance and Financial (2 CFR §200.328 and §200.329) Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization relied on subrecipients or partners to submit reports and was not aware of its responsibility to ensure the reports were submitted timely. Procedures are being implemented to ensure all reports are provided to the Organization to ensure compliance with the federal grants. Corrective Action Plan: Corrective Action #1: Federal Reporting Tracking System • Action: Create comprehensive federal reporting calendar/tracker identifying all required reports, responsible parties, and due dates for each federal award. Implement tracking system (spreadsheet or database) with automated reminders at 60, 30, and 15 days before deadlines. Include fields documenting report completion, review, and submission dates. Board President will review tracking system monthly. • Responsible Person/Title: Board President • Anticipated Completion Date: February 28, 2026 Corrective Action #2: Responsibility Assignment • Action: Formally assign responsibility for federal reporting by Board resolution for each grant. Designate specific Board member(s) responsible for each federal grant. Establish backup designees for each report. Consider engaging consultant or part-time grants administrator if reporting volume warrants. • Responsible Person/Title: Board of Directors • Anticipated Completion Date: January 31, 2026 Corrective Action #3: Report Preparation and Review Procedures • Action: Develop standardized procedures for preparing, reviewing, and submitting federal reports. Require all reports drafted at least 10 days before due date. Implement mandatory Board Treasurer review and approval before submission. Create checklists ensuring reports are complete and supported by adequate documentation. • Responsible Person/Title: Board President • Anticipated Completion Date: February 28, 2026 Corrective Action #4: Subrecipient Reporting Requirements • Action: Include specific reporting requirements and deadlines in all subaward agreements. Require subrecipients to submit information to Restoration Christian Ministries at least 15 days before federal reporting deadlines. Implement follow-up procedures for delinquent subrecipient submissions. Designate Board member responsible for subrecipient communication. • Responsible Person/Title: Board President • Anticipated Completion Date: February 28, 2026 Corrective Action #5: Board Oversight Process • Action: Include federal reporting compliance status as standing agenda item at monthly Board meetings. Report any missed deadlines or compliance issues immediately to full Board. Conduct quarterly reviews of federal reporting tracking system to ensure accuracy and completeness. • Responsible Person/Title: Board President • Anticipated Completion Date: March 31, 2026 (initial); Ongoing monthly/quarterly thereafter Corrective Action #6: Training and Technical Assistance • Action: Board members assigned to grants will receive training on federal reporting requirements, deadlines, and procedures. Ensure Contract Accountant is available to provide financial data needed for federal reports. Consider engaging consultant to provide training and technical assistance on federal reporting. • Responsible Person/Title: Board President

Now that Treasury Portal is updated with all obligations the County will utilize Oracle reporting to input all remaining expenditures in the applicable quarterly report.

In reference to audit finding 2024-003, wp.ich refers to submitting a project and expenditure report within the required timeframe. The city will train the city's finance department in how to file the project and expenditure report within the required timeframe by working with the city's third-party financial consultant and the city manager.

Audit Finding: 2024-001 – 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 were formally adopted in 2025 and implementation began immediately. Standardized review documentation is now required for payroll, expenses, and financial reporting, and oversight by the external accounting firm is ongoing to ensure compliance with 2 CFR Part 200. Anticipated Completion Date ● Implemented in 2025 (Monitoring ongoing) Responsible Party ● Director of Operations, with support from the Finance Team and Executive Director

Management concurs with the finding. The Authority has developed a Compliance Reporting Schedule listing all required HUD submissions, their due dates, and the responsible staff. Calendar reminders and verification checkpoints have been implemented to ensure timely submissions. In addition, the Authority will conduct quarterly internal audits to confirm adherence to HUD reporting requirements. Management anticipates full corrective action by December 2025.

Finding 2024-006 – Compliance; Internal Control over Compliance, Reporting (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of AgricultureFederal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Under 2 CFR 200, recipients must submit performance and financial reports as required by the terms and conditions of the award and must retain records sufficient to demonstrate compliance (see (§200.301Monitoring and reporting program performance, and §200.328 Financial reporting, §200.329 Monitoring and reporting program performance, and §200.334 Retention requirements for records). The grant agreements for awards above require timely submission of performance / progress reports by specified due dates, with documentation maintained to support the submitted information. Condition: For the fiscal year ended June 30, 2024, the auditee could not provide sufficient evidence that required reports for the programs listed were prepared, reviewed, and submitted in accordance with grant terms. Specifically:  No provided required financial reports, and Partnership for the Umpqua Rivers lacked copies or evidence of submission, and support for reported amounts requested.  Auditors were not provided with performance/progress reports and were instructed that Partnership for the Umpqua Rivers had no retained copies, review sign-offs, or submission confirmation.  Where payments were received, support for the required reports or metrics were not retained and could not be supplied to auditors for reconciling to underlying records. Cause: Management has not implemented formal reporting controls, including:  A documented reporting calendar with due dates and responsible staff,  Reconciliation of report amounts to the accounting records,  Retention procedures for report copies, underlying support, and submission confirmations, and  Supervisory review evidenced by signatures or workflow approvals. Effect or Potential Effect: Absent evidence of timely, accurate reporting and adequate record retention:  The organization is at risk of noncompliance with federal award conditions,  Inaccurate financial or performance information may be reported to the funding agency, and  The entity may be subject to remedial actions, including heightened monitoring, repayment of questioned amounts, or potential suspension of funding. Questioned Cost: None directly noted, but potential risk if reports were incomplete or inaccurate.Context: During our audit, it was found that the Partnership for the Umpqua Rivers experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. Award files provided to auditors did not contain information related to reporting of activity, expenditures, or progress of the awards. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers:  Establish a formal reporting and retention policy aligned with 2 CFR 200 and grant terms.  Implement a centralized reporting calendar that tracks due dates, preparers, reviewers, and submission methods.  Require reconciliations of financial reports to the general ledger and supporting schedules, retain the reconciliation with the reporting package.  Create standard workpapers for performance metrics for each award.  Configure the grant portal or document management system to retain submission confirmations, reports, receipts, and version -controlled copies of all reports for awards.  Document supervisory review through sign-offs prior to submission and with evidence retained.  Provide training to staff on Uniform Guidance requirements and record retention (§200.334). District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: ____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _____________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

2024-008 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: As part of the reporting requirements for the CBS Food Program under the National School Lunch Program (NSLP) and Summer Food Service Program (SFSP), management is responsible for submitting the FNS 10 (NSLP) and FNS 418 (SFSP) reports within 30 days after month-end. However, management was unable to provide five (5) monthly NSLP reports and one (1) monthly SFSP report requested for audit testing. Recommendation: The Organization should establish and enforce strengthened internal controls over federal reporting to ensure that all required monthly reports (FNS 10 and FNS 418) are: (a) completed accurately, (b) submitted on time, and (c) retained in accordance with federal record retention requirements (2 CFR 200.334). Management should designate responsible personnel and implement a monitoring process to ensure compliance. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Effective, July 1, 2024, Community Benefit Solutions no longer administers the National School Lunch Program. In the event Community Benefit Solutions should begin administering the NSLP, Community Benefit Solutions will develop and implement requisite policies and procedures to ensure proper reporting requirements including, but not limited to, completion and submission of the FNS10. Planned completion date for corrective action plan: June 30, 2025

The City will assign responsibillity for the filing of the Federal Financial Reports and will verify that the reports have been submitted.

2024-007 Untimely Submission of Project and Expenditure Report: Management acknowledges the finding related to the untimely submission of the American Rescue Plan Act (ARPA) Project and Expenditure Report. To address this issue and prevent future occurrences, the City is implementing an ARPA reporting process that clearly defines reporting requirements, deadlines, and responsible personnel, along with a centralized compliance calendar to track all federal grant reporting deadlines and provide reminders to ensure timely submission. Primary responsibility for ARPA reporting has been assigned to designated Finance Department staff, with supervisory review by senior management to ensure reports are complete, accurate, and submitted on time. In addition, Finance staff have received training on federal and ARPA specific reporting requirements, and cross-training will be implemented to ensure continuity in the event of staff absences or turnover. Management will continue to monitor compliance with federal reporting requirements and update internal controls as necessary.

FINDING 2024-014 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation in the form of dated expenditure reports for all federal grant reimbursements and for the final expenditure reports. The Business Office will implement a system of internal control and review where after each month is reconciled and closed, the Federal Grants Administrator will review the program expenditures, ensuring they are correctly posted prior to filing the reimbursements. All reimbursements will be reviewed and signed off on by the Federal Grants Administrator and an additional reviewer prior to submission for reimbursement. In addition, the final expenditure reports will be reviewed and signed off on by Grants Administrator and an additional reviewer prior to submission. Anticipated Completion Date: The school district began the practice above on January 1, 2024, and anticipate it will be completed by June 30, 2026.

Significant Deficiency in Internal Controls over Compliance Condition: As of the March 31, 2024 reporting date, the Town’s Project and Expenditure report had reported cumulative expenditures that were approximately $29,900 less than what was recorded in the grant fund on the general ledger Corrective Action Planned: FY2026 Grant activity is being reconciled to the General Leger with the help of the outside consultant. This process will be completed by the end of January, 2026. In FY26 reconciliation will be performed quarterly, and will be up to date no later than end of March 2026. Anticipated Completion Date: March 2026 Contact: Anna Noyes, Town Accountant

Views of Responsible Officials: CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. CIF made adjustments and improvements in this area during FY 25 to such an extent that this finding is cleared in the FY 25 Audit Report.

Condition: During our testing, we noted that for each of the County’s seven Airport Improvement Program grants, only Form SF-271 was submitted for the audit period, despite requirements to submit five distinct report types per grant. Recommendation: CLA recommends that the County provide staff with training related to identifying and complying with grant requirements. Additionally, CLA recommends that the County implement tracking procedures, such as a monitoring checklist, to ensure all required reports are submitted in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Department is working with the FAA to complete past-due reports and has improved tracking of required reports and deadlines. Name(s) of the contact person(s) responsible for corrective action: Aviation Director Planned completion date for corrective action plan: Fiscal year ended June 30, 2026

Response to finding 2024-004 – Reporting Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2024-004. 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. This finding continued into the 2024 audit period due to the decentralized recordkeeping practices described above. 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.

Finding Number: 2024-001 Planned Corrective Action: City of Norton will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: June 2025 Responsible Contact Person: Pamela Keener, Finance Director

Finding: Material weakness in internal control over documenting supervisory reviews of financial and performance reports prior to submission Corrective action: Pacific Forum has adopted a policy that requires the Executive Director to review performance and financial reports prior to submission to relevant grantor. The Grants Manager has established a suspense system to ensure reports are submitted in a timely manner. These procedures will be incorporated into PFI financial reporting guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director

Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-011: Reporting - Insufficient Policies to Ensure Completeness and Accuracy of Reports (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Management will implement a standardized reporting checklist and will ensure that all reports undergo supervisory review and sign-off prior to submission Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2025. Plan to Monitor Completion of CAP: Management will conduct quarterly reviews of submitted reports and related documentation.

Views of Responsible Officials and Planned Corrective Actions The Grants Administrator and the Finance Department is working closely to compare all expenditures incurred by quarter to the expenditures as reported to the grantor in the quarterly reports. The Grants Administrator and Finance Department have been working to make any corrections necessary for reporting purposes and to address the timing and presentation issues of expenditures as incurred versus as reported. Going forward, the Grants Administrator will be more involved in communicating with the Finance Department, at a minimum on a monthly basis, in regard to the reporting of expenditures that are being funded by federal, state, and local awards.

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

Finance Director Rice will work closely with grant managerment advisor to resolve the past reporting issues. An accurate report will be filed March 2026.

Finding #2024-003 – Lack of Reporting Description of Finding: The Town did not submit required performance reports for the Rural eConnectivity Pilot Program during the 2024 audit. The Town was unaware of the specific reporting requirements required by the USDA and had challenges in communicating with the awarding agency to clarify these expectations. Statement of Concurrence of Nonconcurrence: Concurrence. Contact Person: Courtney Delaney, Town Administrator Planned Corrective Action: Establish clarification as to applicable performance reports for the ReConnect program and submit required performance reports. Anticipated Completion Date: The Town has submitted several outstanding reports to the awarding agency as of this date and addressed challenges in communication and access to reporting portals. Two performance reports were not available until the initial report was filed. The Town is finalizing the outstanding performance reports currently and awaits technical information from the ISP and subrecipient for completion. Anticipated completion no later than September 30, 2025.

Finding Number: 2024-044 Audit Type: Single Audit Finding Title: Untimely Submission of Required Performance Reports Related Finding: 2024-029 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will establish a reporting calendar and assign staff to monitor deadlines for all federal performance reports. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will ensure timely submission of all required reports. 5. Status of Prior Year Finding This is a new finding.

City will establish a clear policy with grant management firm to provide an opportunity for review and approval of monthly and quarterly reports to GLO.