Corrective Action Plans

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.

Finding Number: 2024-011 Planned Corrective Action: The district will strengthen procedures for preparing and reviewing Final Expenditure Reports to ensure all reported expenditures agree to the underlying accounting records and supporting documentation. The Treasurer will reconcile grant expenditures to system reports prior to submission and implement additional review procedures to ensure accurate and compliant federal reporting. Anticipated Completion Date: 05/31/2026 Responsible Contact Person: Ashley Miller

CSLFRF Reporting (ALN 21.027) Condition The required Treasury report was not submitted due to insufficient tracking mechanisms and lack of internal controls. Corrective Action Plan To ensure timely and accurate CSLFRF reporting, the City will: • Establish a Treasury reporting calendar with all required deadlines. • Assign a designated preparer and reviewer for each reporting cycle. • Provide training on the Treasury reporting portal. • Implement a pre-submission checklist to ensure completeness and accuracy. • Conduct semiannual internal reviews of reporting processes and documentation. Responsible Staff Chief Financial Officer (CFO) Target Completion Date July 31, 2026

Concerning Finding 2024-002 Reporting Contact Person Responsible for Corrective Action: William Dobbins, Superintendent Corrective Action: The Limestone Public Schools will take the following actions to address finding 2024-002: Limestone Community School will strengthen internal controls over federal reporting to ensure all required reports are completed, submitted timely, and properly retained. The school will develop written procedures outlining reporting requirements for all federal programs, including ESSER (ALN 84.425). These procedures will identify responsible personnel, submission deadlines, and documentation retention requirements. Copies of all submitted federal reports, including Annual Performance Reports and Annual Performance and Expenditure Reports will be saved electronically and maintained in a centralized grant compliance file. The School will also maintain documentation confirming submission, such as submission receipts or screenshots from the online reporting system."Please note, all Invoices, and back up materials were available along with the draft of the final report. The final report was not obtainable due to the web page being closed. Also, the audit was competed half way through FY-26." Anticipated Completion Date: February 2, 2026

Finding No.: 2024-052 Reporting Responding Agency: Guam Homeland Security (GHS) Responsible Personnel: Esther Aguigui, Director GHS will work with DOA to make sure reports are submitted on time. GHS will also retain documentation of submitted reports.

Finding No.: 2024-024 Reporting Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency is reviewing its federal grants management to ensure robust handover and succession plans are in place of future programs.

Finding No.: 2024-015 Reporting Responding Agency: Bureau of Budget and Management Research (BBMR) Responsible Personnel: Lester Carlson, Director BBMR will work with DOA to keep soft copies of submitted and approved Federal Financial Reports (FFR) on hand.

Assistance listing numbers and program names 97.024 Emergency Management Performance Grants Agency: Department of Emergency and Military Affairs (DEMA) Name of contact person and title: Keith Tagaban, Audit Supervisor Anticipated completion date: September 18, 2026 Agency’s Response: Concur The Department of Emergency and Military Affairs (DEMA) will maintain complete, accurate, and auditable documentation to support all federal award expenditures, matching contributions, and financial reporting in accordance with 2 CFR Part 200 and applicable award terms and conditions, with records retained for a minimum of three years following submission of the final Federal Financial Report (FFR). DEMA will ensure all FFRs are reviewed for accuracy, completeness, and compliance prior to submission and will promptly correct any identified discrepancies in coordination with the federal awarding agency. The Department will implement and enforce written policies and procedures governing reimbursement requests, financial reporting, matching requirements, and record retention, including management review to ensure costs reported are allowable, allocable, reasonable, and adequately supported, and will maintain sufficient staffing and oversight to sustain ongoing compliance.

Finding 2024-011 Material Weakness and Material Noncompliance Finding, Reporting – Special Reporting Condition: For Coronavirus State and Local Fiscal Recovery Funds (ALN# 21.027), none of the quarterly Project and Expenditure Reports were submitted as required, and instead the City elected to submit an annual Project and Expenditure Report that was submitted past the deadline for the fourth quarterly report. Contact Person: Kara Prunty, Assistant Director of Finance – Grants, City of Danbury Corrective Actions Completed: We agree with the finding. The City has implemented a centralized SLFRF quarterly reporting process under a designated grants/finance lead, including a recurring quarterly close schedule and a two-level review (preparer and approver) prior to submission. All submitted reports, supporting documentation, and submission confirmations are retained in a central repository.

Finding Number: 2024-050 Finding Name: Failure to Accurately Prepare Financial Reports for the Aging Cluster Finding Condition(s): The Illinois Department on Aging (IDOA) did not prepare accurate federal financial status reports for the Aging Cluster (Aging) program. We further noted the supervisory review procedures performed for this report were not designed to operate at an appropriate level of precision to ensure financial reports are accurately prepared. Additionally, IDOA does not perform analytical procedures to identify potential errors or unusual fluctuations in reported amounts. Name of Contact Person(s): • Teri McKeon, Deputy Chief Financial Officer / Bureau Chief Business Services - Illinois Department on Aging, Division of Financial Administration • Sarah Harris, Chief Financial Officer - Illinois Department on Aging, Division of Financial Administration Corrective Action(s): The IDOA will tighten up the internal controls over its internal spreadsheet that is used to prepare the federal reports, as well as any corrections needed upon review, prior to entering the report into the payment management system. Proposed Completion Date: October 31, 2026

Finding Number: 2024-003 Finding Name: Failure to Accurately Prepare Performance Reports for the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Program Finding Condition(s): The Illinois Governor’s Office of Management and Budget (GOMB) did not prepare accurate federal project and expenditure reports (Paperwork Reduction Act (PRA) 1505-0271) for the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program. Name of Contact Person(s): Lesley Winbush, Accountant – Illinois Governor’s Office of Management and Budget Corrective Action(s): GOMB will improve the reporting process by implementing checks to ensure that all expenditures are reported by State agencies. The checks will include comparing reported data against agency financial reports to ensure that the data is complete. Proposed Completion Date: June 30, 2026

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.

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.