Corrective Action Plans

Reporting California Governor’s Office of Emergency Services Based on CSA's Federal Compliance Audit Report for the Fiscal Year Ended June 30, 2024 - Finding 2024-020, Cal OES revised its FFATA reporting procedures and has taken several actions to strengthen internal controls, resolve discrepancies among reporting systems, and ensure staff are fully trained to maintain compliance with all FFATA reporting requirements. In March of 2025, Cal OES developed the Financial Administrative Branch (FAB) FFATA SOP (Attachment #1) for FFATA reporting which outlines steps for collecting subrecipient data, preparing reports, and submitting reports within the required time frames. In addition, Cal OES enhanced its existing FFATA reporting procedures using a software platform to provide accurate data reports for federally funded grant projects. These reports are then used to ensure accurate reporting and timely updates to existing FFATA records. To ensure clear assignment of accountability, Cal OES FAB analysts are responsible for completing and submitting FFATA reporting accurately, with all required fields completed, and obtaining review and approval from their respective peer reviewer analysts and managers to verify accuracy and completeness. Furthermore, in June of 2025, Cal OES FAB staff were provided with a comprehensive FFATA training course to ensure staff understand the process and reporting requirements for FFATA (Attachment #2). Cal OES continues to provide training for staff responsible for submitting FFATA reports during onboarding and on an as-needed basis. Because the revised FFATA reporting procedures were not fully implemented by the close of Fiscal Year 2024-2025, Cal OES was not able to capture all projects concluding the reporting cycle. Moreover, the procedures have been fully implemented and in effect since the start of Fiscal Year 2025-2026. Estimated Implementation Date: Implemented Contact: - Heidi Palchik, Chief, Recovery Financial Administration Branch lnteragency, Recovery Coordination Section

Reporting California Department of Social Services CDSS will implement improved procedures and consider if a grant management solution would be feasible and necessary. CDSS has already begun establishing a process that determines and documents whether funding actions are reportable subrecipients or contractors. CDSS has also begun establishing a field within the CDSS accounting system that identifies subrecipients at the contract level so this data is automatically included when extracted for FFATA reporting, which will ensure reports are submitted accurately and timely. CDSS is also developing a Federal Reporting Dashboard to track all grants with FFATA reporting requirements, including due dates and completion status. Additionally, CDSS will designate a primary point and a backup person within the Federal Reporting Section to monitor all FFATA reporting deadlines. This designated staff member will issue 45 days advance notifications to the grant owner and reviewing manager, set calendar reminders for grant owners, and provide regular status updates to Accounting Management. To strengthen timely compliance, these reminders will also instruct grant owners to complete the FFATA submission 10 days before the federal deadline, ensuring sufficient time to resolve any errors that may occur during the upload process. Estimated Implementation Date: November 2026 Contact: - Rosali Bautista, Chief, Accounting and Reporting Bureau, Accounting and Fiscal Systems Branch, Finance and Accounting Division

Reporting California Department of Social Services CDSS agrees with this finding and has already begun developing appropriate procedures that will support this recommendation, using the CCDF program area as a model. CDSS will implement improved procedures and consider if a grant management solution would be feasible and necessary. CDSS has already begun establishing a process that determines and documents whether funding actions are reportable subrecipients or contractors. CDSS has also begun establishing a field within the CDSS accounting system that identifies subrecipients at the contract level so this data is automatically included when extracted for FFATA reporting, which will ensure reports are submitted accurately and timely. CDSS is also developing a Federal Reporting Dashboard to track all grants with FFATA reporting requirements, including due dates and completion status. Additionally, CDSS will designate a primary point and a backup person within the Federal Reporting Section to monitor all FFATA reporting deadlines. This designated staff member will issue 45 days advance notifications to the grant owner and reviewing manager, set calendar reminders for grant owners, and provide regular status updates to Accounting Management. To strengthen timely compliance, these reminders will also instruct grant owners to complete the FFATA submission 10 days before the federal deadline, ensuring sufficient time to resolve any errors that may occur during the upload process. Estimated Implementation Date: November 2026 Contact: - Jeff Fowler, Child Care Administration Bureau Chief Central Operations Branch, Child Care and Development Division - Rosali Bautista, Chief, Accounting and Reporting Bureau, Accounting and Fiscal Systems Branch, Finance and Accounting Division

Reporting California Department of Social Services CDSS does not agree with this finding and its characterization as an ACF-696 reporting inaccuracy. The discrepancy between the ACF-696 and the general ledger is primarily due to timing differences. The ACF-696 was due on July 30, 2025, and relies on preliminary figures that were prepared before final cost allocations and accruals were posted. In contrast, the general ledger is based on the final expenditure data, including all adjustments, and finalized in September 2025. Any discrepancies or adjustments from the June 2025 quarter were reported in the following quarter. The Administration for Children and Families has confirmed with CDSS Accounting that the current practice of reflecting these adjustments in the subsequent quarter for federal reporting is acceptable. CDSS began performing the reconciliation of the ACF-696 and the general ledger following the close of FY 2024–25. However, completion of this process was delayed due to an unprecedented volume of ongoing audit activities and the significant demands associated with supporting the Department, the California Health and Human Services Agency, the continual flux of federal funding changes, and federal shutdown preparedness drills. CDSS submitted a Budget Change Proposal in response to the previous audit finding 2024-015 to complete this reconciliation between ACF-696 and the general ledger. This request has been approved, and we are in the process of hiring for this position. Once this position is filled, responsibility for the reconciliation activities will be transferred to the newly assigned staff member to ensure consistent oversight, timely completion, and ongoing maintenance of the reconciliation process. Estimated Implementation Date: September 2026 Contact: - Rosali Bautista, Chief, Accounting and Reporting Bureau, Accounting and Fiscal Systems Branch, Finance and Accounting Division

Reporting California Department of Social Services CDSS does not agree with this finding that the FFATA reporting deadline was not met for the subaward reporting for all 58 counties for the Foster Care grant. The FFY 2025 FFATA report was originally submitted on November 27, 2024, which met the federal submission deadline of November 30, 2024. During this initial submission, however, data lines for two counties failed to upload into the legacy FSRS.gov system and required additional research. The corrected data was subsequently submitted on December 10, 2024. Since that time, FSRS.gov has migrated to SAM.gov, and the new system only displays the most recent submission date as the official record. It appears that SAM.gov does not retain or display the historical log of submissions FSRS.gov. As a result, the system reflects only the December 10 submission date, even though the original, timely submission occurred on November 27, 2024. CDSS is developing a Federal Reporting Dashboard to track all grants with FFATA reporting requirements, including due dates and completion status. Additionally, CDSS will designate a primary point and a backup person within the Federal Reporting Section to monitor all FFATA reporting deadlines. This designated staff member will issue 45 days advance notifications to the grant owner and reviewing manager, set calendar reminders for grant owners, and provide regular status updates to Accounting Management. To strengthen timely compliance, these reminders will also instruct grant owners to complete the FFATA submission 10 days before the federal deadline, ensuring sufficient time to resolve any errors that may occur during the upload process. Estimated Implementation Date: November 2026 Contact: - Rosali Bautista, Chief, Accounting and Reporting Bureau, Accounting and Fiscal Systems Branch, Finance and Accounting Division

Subrecipient Monitoring California Department of Public Health The California Department of Public Health (CDPH) agrees with this finding. CDPH has not yet formalized procedures governing the issuance of Direct Allocation Letters. CDPH is currently developing a comprehensive process in collaboration with the Program Support Division and the Office of Legal Services to ensure compliance with federal audit requirements and state contracting guidelines. The revised procedures will require each Direct Allocation Letter to include the applicable Assistance Listing Number (ALN) and Federal Award Identification Number (FAIN). CDPH is prioritizing this effort and expects to publish written procedures that establish consistent practices and provide clear guidance to ensure compliance with all applicable requirements. Estimated Implementation Date: December 2026 Contact: - Louise Karsten, Emergency Funding Coordination Branch Manager, Center for Preparedness and Response

Reporting California Department of Aging California Department of Aging (CDA) partially agrees with this finding as this was a prior audit finding that was communicated to CDA. CDA has implemented corrective actions in response to that finding, but the actions were implemented during the scope of this current audit. The cause of the lack of FFATA reporting was due to a lack of staffing for the reporting responsibilities. CDA has already created processes and procedures and is continuing to update them as more information is available or roles and responsibilities change within the Budget Team. CDA hired an employee in April 2024 to fulfill the FFATA duties and CDA has been able to keep current with FFATA reporting. In addition, CDA has recently updated the FFATA procedures to include a Review and Approval process and to include a process for identifying when FFATA reporting needs to be completed. This process involves multiple members of the Budget Team depending upon the program. Since this has been a recent update to the procedures, this will not be in effect if there is an audit next year. In addition, the analyst assigned to FFATA reporting is continually monitoring the Federal website (SAM.gov) for any additional training or guidance. Please note that FFATA reporting has been converted to SAM.gov and the FSRS website mentioned in the Reporting Requirements is no longer valid. Any links for training that were on the FRSR website are no longer valid and can’t be viewed. Estimated Implementation Date: Procedures and processes updated July 2026. Contact: - Kim Elliott, Chief Budget Officer

Reporting Employment Development Department Recognizing the finding does not include any questioned costs, EDD agrees that during the sampled time period it did not have a formal reconciliation process to ensure Form 9130 reports align with the general ledger. As a result, differences emerged between the amounts reported on the Form 9130 and those reflected in the Administrative Fund (0870) general ledger. Since then, EDD’s Fiscal Programs Division (FPD) formed a workgroup at the end of 2025 to identify key staff responsible for establishing a formal reconciliation process. This effort is documented in an artifact titled, General Ledger 9130 to SEFA Recon Procedure (Final)’. The workgroup consisted of representatives from the Budget and Forecasting Section and the Accounting Section and resulted in the creation of a draft reconciliation procedure. FPD assigned Accounting Section personnel to lead the overall process, including coordinating deadlines, reviewing completed reconciliations, and ensuring any issues are investigated and resolved. Budget and Forecasting Section staff are responsible for providing accurate and timely expenditure data, while the Accounting Section prepares the reconciliations and documents any variances. In addition, EDD provided initial training to staff to ensure a consistent understanding of the new procedures and responsibilities. In late May 2026, EDD began its first pilot testing of the new reconciliation procedure using data from the quarter ending March 2026. The pilot was successful, and EDD has finalized the reconciliation procedures and distributed them to all relevant staff. Estimated Implementation Date: Currently implemented Contact: - Diane Underwood, Division Chief, Unemployment Insurance Branch

Reporting California Department of Social Services California Department of Social Services (CDSS) agrees with this finding. CDSS is developing a Federal Reporting Dashboard to monitor all federal reporting requirements, including due dates and completion status. This dashboard will be used by both staff and management to track upcoming deadlines and ensure timely submission of all federal reports. While the dashboard is still in development, the preparer and reviewer of the FNS-46 have implemented interim controls by setting calendar reminders for the FNS-46 reporting deadlines. Estimated Implementation Date: October 2026 Contact: - Rosali Bautista, Chief, Accounting and Reporting Bureau, Accounting and Fiscal Systems Branch, Finance and Accounting Division

Reporting California Department of Education Partially Concur. The Department agrees that timely submission of FFATA reports is an important requisite. However, the circumstances that triggered the late submission were created by the control agency shifting to a new system without ensuring it met everyone’s needs, not by a lack of Department staffing or resources. Nevertheless, to strengthen existing procedures, the Department will review processes and determine if contingency procedures are appropriate and feasible. Management will also continue to monitor federal system changes, document implementation challenges, and maintain communication with federal agencies to ensure awareness of external system limitations that could affect reporting timelines. The Department will continue to work with the U.S. General Services Administration on automated reporting solutions to mitigate any future late submittals and to ensure timely submission of all FFATA reports. Estimated Implementation Date: September 30, 2026 Contact: - Yiping Hu, Accounting Administrator, Fiscal and Administrative Services Division

SF-425 Reporting Planned Corrective Action: American Bird Conservancy will prepare, review and maintain documented comparison of general ledger details to the SF-425 reports prepared. Person Responsible for Corrective Action Plan: Angela Modrick, Vice President of Finance Anticipated Date of Completion: Implemented

Management has implemented enhanced procedures to strengthen the tracking, reconciliation, and reporting of recipient share (matching) contributions associated with federal awards under ALN 14.265, Rural Capacity Building for Community Development and Affordable Housing Grants. Actions include: 1. Updating the internal matching contribution tracking system to improve documentation and cumulative tracking of recipient share contributions by grant and reporting period. 2. Establishing a formal reconciliation process between supporting documentation, grant records, and amounts reported on the SF-425 to ensure both federal expenditures and applicable recipient share amounts are accurately reflected. 3. Implementing a pre-submission review checklist and control requiring verification that recipient share (matching) information has been evaluated, reconciled, and included on the SF-425, when applicable, prior to submission to the awarding agency. 4. Requiring supervisory review and approval of the completed SF-425 to confirm completeness, accuracy, and compliance with reporting requirements under 2 CFR §200.328 before certification and filing. 5. Updating internal grant reporting procedures and providing additional guidance to staff responsible for federal financial reporting regarding SF-425 reporting requirements and recipient share reporting expectations. Management will evaluate the SF-425 reports submitted during the audit period to determine whether amendments are necessary. If required, amended SF-425 reports will be submitted to accurately reflect recipient share (matching) contributions. Anticipated Completion Date: The enhanced controls were implemented during 2026 and will be operational for the preparation, review, and certification of the SF-425 for the reporting period ending June 30, 2026, and all future reporting periods. For the reports submitted before June 30, 2026, management will confirm with HUD by July 20 if they would like an amended report. If HUD request one, the amended report will be submitted by August 15. Responsible Contact: Lakia Goodman, Controller (preparation and reconciliation of recipient share reporting) Chris Perry Authorized SF-425 Signer/Certifying Official (final review and certification)

Finding 2025-001 Corrective Action Plan: Management acknowledges the reporting lapse identified and notes that all required semi-annual reports have since been submitted as of the report date. The delay appears to have been an isolated oversight rather than a systemic breakdown in compliance. To enhance controls over grant reporting and prevent recurrence, the Organization has implemented the following corrective actions: Established a formal grant reporting calendar that includes all required reporting deadlines for each federal award. Assigned clear responsibility for report preparation and submission to specific personnel within the finance function. Implemented a secondary review process whereby management monitors upcoming deadlines and confirms timely submission of reports. Incorporated periodic compliance check-ins to ensure adherence to grant reporting requirements throughout the year. Management believes these measures strengthen oversight and will ensure timely preparation and submission of all required reports going forward. Anticipated Completion Date: December 31, 2026

City of Springdale, Arkansas Corrective Action Plan Contact Name: Cody Loerts Contact Phone Number: 479-750-8114 Audit Firm: Forvis Mazars, LLP Audit Period: December 31, 2025 Finding #2025-002 – Statement of Condition: The City did not submit the required annual Federal Financial Report (SF-425) to the FAA for the period under audit. Response: The City concurs with the finding. Management will implement additional controls related to reporting. The completion date for the above-mentioned corrective action was December 2026.

Finding Summary: Material noncompliance was noted in reporting as reported amounts did not agree to underlying supporting documentation. Responsible Individuals: Kim Clay, Corporate Controller and Paul DiTomasso, Site`2 Controller Corrective Action Plan: Management will review and improve internal controls over reporting to ensure that reported amounts agree to underlying supporting documentation. Anticipated Completion Date: June 30, 2026

Ecotrust is strengthening its controls over federal financial reporting to ensure required SF‑425 Federal Financial Reports are submitted (in a timely manner) in accordance with 2 CFR 200.328 and applicable award terms. Approximately three years ago, following turnover, Ecotrust shifted grantee and sub‑grantee management from a centralized model to a distributed model in which program managers assumed responsibilities for which tools and training were insufficient. To correct the underlying deficiency, Ecotrust is taking the following specific actions: • Assigning clear, documented responsibility for the preparation and timely submission of all federal financial reports (including the SF‑425), with a designated primary preparer and a backup to ensure continuity of reporting during staff absences or turnover. • Establishing a federal reporting calendar that tracks all federal financial report due dates, with proactive advance reminders shared across the finance and program teams. • Providing periodic training to finance and program staff to reinforce awareness of federal financial reporting requirements and deadlines. • Engaging an outside consultant, Jennifer Hutton, who has grantee‑management experience gained at Mercy Corps and other non‑profits, to work with the finance team and program managers to develop the supporting processes, tools, and accountability measures.

Finding No. 2025-001 – Late Report Filing (SF-425) Federal Program: Health Center Program Cluster, ALN 93.224 – U.S. Department of Health and Human Services (HHS) Contact Person Responsible for Corrective Action Guillermo J. Jiménez Ramos, Chief Financial Officer Views of Responsible Officials Management concurs with the finding. Corrective Action Planned 1. The Fiscal Department will implement a Federal Compliance Reporting Calendar covering all required federal financial reports, including the Federal Financial Report (SF-425) and Payment Management System (PMS) submissions, identifying for each report its due date, the individual responsible for its preparation, the reviewer, and the submission evidence to be retained. 2. Responsibility for the preparation of each SF-425 report will remain formally assigned to the Fiscal Department, under the oversight of the Chief Financial Officer (CFO). Each report will be subject to CFO review and approval prior to submission. Preparation of the reports will commence no later than thirty (30) days before the established due date, in accordance with internal control procedures and reporting timelines. 3. Automated reminders will be configured at thirty (30), fifteen (15), and five (5) days before each filing deadline, directed to both the preparer and the reviewer, to provide adequate oversight and prevent future delays. 4. Confirmation of each submission (PMS acknowledgment) will be retained and filed with the report workpapers as evidence of timely filing, and the status of federal reporting deadlines will be monitored monthly by the Chief Financial Officer. Anticipated Completion Date July 31, 2026

Finding No. 2025-006 – Internal control deficiencies over accounting for federal funds received from the United States Department of Homeland Security (DHS) Corrective Action Plan Single Audit 2025 Page 6 April 30, 2026 Condition During our procedures over the Authority’s funds received from FEMA we noticed the following: 1. Return of interest earned on FEMA-related funds totaling approximately $211,853 was not timely recorded in the general ledger and was subsequently recorded through a post-closing entry dated January 26, 2026. 2. Management initially misclassified approximately $6 million received under the Coronavirus State and Local Fiscal Recovery Funds as state funds rather than federal awards. As a result, the amount was originally excluded from the Schedule of Expenditures of Federal Awards (the Schedule). Views of Responsible Officials and Corrective Actions It should be noted that, although certain funds received were not properly identified as working capital advances, those funds were properly considered as received from FEMA through the COR-3 office of the Government of Puerto Rico. This situation basically arises because the federal funds coming from FEMA are being handled by outside consultants, without any coordination with the Federal Funds Management Office (FFMO). The Authority’s management will ensure that, in the future, the FFMO will coordinate with the assigned outside consultants all the efforts necessary for the proper handling, identification and classification of funds received from FEMA. Name(s) of the Contact Person(s) Responsible for Corrective Action Romel Pedraza Claudio. P.E. – Assistant Executive Director for Planning & Engineering Elena González – DEA Finance Miguel La Torre – Interim Finance Director Anticipated Completion Date During FY-2026-2027

Fergus has adopted and implemented policy: 252.0 Federal Funding Compliance to establish formal procedures and ensure ongoing compliance with applicable federal regulations, including 7 CFR 4280, Subpart A and 2 CFR 200. Anticipated completion date: August 31, 2026

The City will implement additional control procedures to ensure all reports are filed in a timely manner.

Finding 2025-002 Federal Agency Name: U.S. Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds FFALN # 21.027 Finding Summary: Eide Bailly LLP prepared our single audit for Federal Coronavirus State and Local Fiscal Recovery Funds where the Town is a subrecipient to Douglas County who is the recipient of the funds. Eide Bailly LLP identified that the Town did not have documented or consistently applied internal controls to ensure compliance with the County’s subrecipient guidance requiring the submission of formal special reports for ALN 21.027. Responsible Individuals: Mark Henderson, Assistant Director of Castle Rock Water Corrective Action Plan: Staff will complete quarterly reports including project progress and estimated project infrastructure costs. The reports will be reviewed by management prior to submission to the recipient of the Federal Funds (Douglas County). Anticipated Completion Date: Ongoing during the period that the Town is a subrecipient of these funds for the project.

Material Weakness in Internal Control over Compliance and Compliance - Reporting Federal Program: 93.939- HIV Prevention Activities: Non-Governmental Organization Based Federal Agency: U.S. Department of Health and Human Services. Award Number: NU65PS923746 Fiscal Year: July 1, 2024 – June 30, 2025 Recommendation: We recommend that management implement procedures to ensure that expenditures reported on the Federal Financial Report reflect actual costs incurred during the reporting period and are supported by appropriate documentation. Staff responsible for preparing the Federal Financial Report should be trained in federal reporting requirements to ensure compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: There is not currently a clear internal procedure on how to complete the Federal Financial Reports. This will be added to the finance department procedures and will be trained to all staff who will be responsible for this reporting. Name of the contact person responsible for corrective action: Simon Trowell, Chief Executive Officer. Planned completion date for corrective action plan: June 30, 2026

2025-008 Auditor’s Recommendation: We recommend the organization strengthen its internal controls over federal financial reporting by establishing and documenting procedures requiring that all reports submitted to federal awarding agencies or pass-through entities be prepared using actual expenditures recorded in the accounting system. These procedures should include a reconciliation of reported amounts to the general ledger and supporting documentation prior to submission, as well as an independent review process to ensure reported information is accurate, complete, and compliant with Uniform Guidance requirements. Corrective Action: UCM will develop and implement written procedures requiring that all financial reports submitted to federal awarding agencies or pass-through entities are prepared using actual expenditures recorded in UCM’s accounting system. Reported amounts will be reconciled to the general ledger and supported by appropriate documentation before submission, including general ledger detail, payroll records, accounts payable records, allocation schedules, invoices, receipts, proof of payment, and other records supporting the reported costs. UCM will implement a federal financial reporting checklist to document preparation, reconciliation, and review each report. The checklist will require verification that reported costs agree to actual expenditures, are recorded in the correct reporting period, are charged to the correct federal award, are supported by documentation, and are consistent with award terms and Uniform Guidance requirements. A qualified individual independent of the report preparation process will review and approve reports before submission, and evidence of review will be retained. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Independent Reviewer (CEO, Finance Committee Chair, or another qualified reviewer) Anticipated Completion Date: December 31, 2026

The City will review due dates to ensure proper reporting requirements are met.

Provide all management staff with annual training on federal grant requirements, perform periodic internal reviews and a final year-end reconciliation, maintainall grant-related records on a shared organizational drive accessible to all responsible staff, provide formal onboarding and off boarding procedures for federal grant management, and update the Finance Manual .