Corrective Action Plans

2025-004 Reporting Cluster: Other major program referenced below Sponsoring Agency: Department of Labor Award Names: RETAIN Demonstration Projects Award Numbers: 1947RTN2-02B Assistance Listing Title: Disability Employment Policy Development Assistance Listing Number: 17.720 Award Year: 2024-2025 Pass-through entity: Vermont Department of Labor Management agrees with the finding related to Reporting. Management submitted monthly reports to the State of Vermont that covered all required information and thus did not believe quarterly reports were required.. The State of Vermont subsequently clarified that quarterly reports were required and we will work with them to ensure all required information is submitted for past quarters and going forward, as required. Individual Responsible: John Muhlen, System Vice President of Corporate Finance Anticipated Completion Date: September 30, 2026

Corrective Action Plan Finding 2025-001 – Allowable Costs Requirement – Time and Effort Reporting for Salaries Corrective Action: Management concurs with the findings. Day One will formalize and implement written procedures governing the documentation, review, and reconciliation of personnel costs charged to federal awards. Employees whose compensation is charged, in whole or in part, to federal awards, will be required to complete after-the-fact timesheets that accurately reflect the work performed and the total activity for which they are compensated. The documentation will be reviewed and approved by the employee's supervisor. The Finance Director is responsible for reconciling payroll allocations charged to federal awards to the certified time and effort documentation on a regular basis and ensuring that any differences identified are reviewed and corrected in a timely manner. The Finance Director is responsible for supporting documentation for payroll allocations and reconciliations is maintained in accordance with Day One's record retention policies. Day One will update its written policies and procedures to reflect these requirements and has provided training to employees and supervisors responsible for completing, reviewing, and approving time and effort documentation. The Executive Director will periodically review compliance with these procedures as part of Day One’s internal control monitoring process. We will also do a final year-end review of time and effort allocations and certification. These corrective actions are intended to strengthen internal controls over payroll allocations and ensure that personnel costs charged to federal awards are adequately documented, properly allocated, and supported in accordance with 2 CFR Part 200. Responsible Official: • Anne Patterson, Executive Director – Oversight of implementation and ongoing compliance. Anticipated Completion Date: The corrective actions will be implemented and effective as of September 1, 2026. We have already implemented this process for FY2025. Once the process is complete, Day One will update, after-the-fact documentation and approval to date and will continue the process thereafter.

Untimely Submission of Federal Financial Reports (SF 425) – Reporting – Assistance Listing Numbers: 93.224 and 93.527 Consolidated Health Center Cluster Type of Finding – Significant Deficiency in Internal Control over Compliance Cause – Controls and procedures designed to ensure timely preparation, review, and submission of required federal financial reports were not consistently followed, resulting in delayed submission of SF-425 reports. Corrective Actions: 1. Improvement of Data Entry and Documentation Management a. The process for submitting, processing, and storing sliding fee applications will be reviewed and streamlined to ensure that all supporting income level documents are properly collected, verified, and stored at the time of application submission. b. Employees involved in handling sliding fee applications and supporting documents will be provided with training on the importance of accurate documentation and the procedures for proper filing, both physically and electronically. 2. Implement Regular Monitoring and Auditing: a. A regular internal review and audit process will be revisited to ensure that backup, storage and retention practices are followed. These audits will focus on verifying that all sliding fee applications and related documents are stored correctly and are retrievable as needed. b. Any discrepancies or issues identified during audits will be addressed promptly, and corrective action will be taken to ensure compliance with the established procedures. 3. Staff Training and Awareness: a. Training sessions will be conducted for all relevant staff on the updated backup, storage and retention procedures for sliding fee applications and income documentation. This training will emphasize the importance of maintaining accurate and accessible records to comply with regulatory and organizational standards. b. Refresher training will be provided quarterly to ensure ongoing compliance and awareness.

Management acknowledges the finding. El Proyecto has implemented corrective actions, including tracking the FFR submission due dates separately from any closeout documentation submission due dates to help ensure both requirements are monitored and completed within the required timeframes. Person Responsible: Ricardo Ornelas Position of Responsible Party: Chief Financial Officer Completion Date: June 1, 2026

The County has implemented additional internal controls, including a workflow for sharing invoices during 2025 when it was discovered that the grant reporting was not done properly. The County also adopted a new grant policy in March 2026 to provide additional levels of review from the grant application process through closeout of a grant. This further ensures accurate and timely reporting going forward.

Finding Number: 2025-001 Anticipated Completion Date: 6/30/26 Responsible Contact Person: Bradley L McCain, CFO Planned Corrective Action: Management agrees with the finding. The Association's annual Federal Financial Report (FFR) was submitted 22 days after the required due date, and the semi-annual FFR was submitted 65 days after the required due date. The delays resulted from staffing disruptions, including employee turnover and an extended employee leave under the Family and Medical Leave Act (FMLA), which impacted the Association's ability to complete and submit required reports within the prescribed deadlines. To address this issue, the Association has strengthened its internal controls over Federal reporting by establishing a formal reporting calendar that identifies all required Federal reports, due dates, responsible individuals, and internal review deadlines. The Director of Grant Compliance is responsible for preparing and submitting Federal financial reports, while the Executive Director of Data and Grants Administration performs a final review to ensure completeness, accuracy, and timely submission. Management has also implemented cross-training and documented reporting procedures to reduce the risk of future delays caused by staff absences or turnover. Internal due dates have been established in advance of Federal deadlines to allow sufficient time for review and submission. The effectiveness of these corrective actions has already been demonstrated, as the subsequent semi-annual Federal Financial Report was submitted by the required deadline. Compliance with Federal reporting deadlines will be monitored on an ongoing basis.

2025-003: Reporting Compliance Requirement The City will review the current procedures for maintaining documentation for when quarterly project and expenditures reports are completed, reviewed and submitted. Contact Person: Rosie Cavazos, CFO Proposed implementation date: September 30, 2026

The Alabama Law Enforcement Agency will strengthen its review and reporting procedures to ensure Federal Financial Reports (SF-425) are submitted within the required reporting deadlines. Prior to submission, financial report information will be reviewed by multiple employees to verify the accuracy and completeness of the reported data. In addition, the Agency will implement enhanced monitoring of reporting due dates and establish internal deadlines to ensure sufficient time for review and timely submission. The Grants Section will coordinate with the Programs Office and financial staff to track quarterly reporting requirements and ensure all SF-425 reports are submitted to the federal awarding agency within 30 calendar days following the end of each reporting period. These procedures are intended to improve compliance with federal reporting requirements and ensure timely reporting for effective grant oversight and monitoring.

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.

The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying details. The Director of Grants will make sure this is done in a timely manner to comply with the reporting deadlines for each fiscal year.

Finding Number: 2025-001 Planned Corrective Action: City of Norton will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: June 2026 Responsible Contact Person: Pamela Keener, Finance Director

Significant Deficiency in Internal Control over Compliance, Other Matter Condition: During our testing, we noted that 3 of the 5 Airport Improvement Program grants tested for SF-425 were not submitted for Fiscal year ended June 30, 2025. Recommendation: CLA recommends that the County continue providing staff with training related to identifying and complying with grant reporting requirements. In addition, CLA recommends that the County maintain and enhance tracking procedures, such as a monitoring checklist, to ensure all required grant reports including those related to prior‑year activity are submitted accurately and in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Implement a tracking system, train support staff, continue to file past-due reports, and file ongoing reports timely. Name(s) of the contact person(s) responsible for corrective action: Aviation Director Planned completion date for corrective action plan: 6/30/2026

Audit Finding Reference: 2025-001 Planned Corrective Action: The Fund is in the process of implementing Agiloft, a comprehensive post-award grants and contracts management system. The system will track and manage post-award grant administration, including budgeting and spending, reporting, task and obligation compliance, etc. With this new software the Fund will be better able to monitor and ensure compliance with grant requirements and regulations, particularly the Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (Uniform Guidance). The Fund is also updating its processes for new award set-up and grant reporting to provide greater clarity around roles/responsibilities, review of award terms, and deliverable tracking and verification. Person(s) Responsible for Corrective Action: The Chief Strategy and Implementation Officer and Chief Financial Officer are coordinating on updating the procedures. The Chief Strategy and Implementation Officer will be responsible for implementing the new contract management software. Anticipated Completion Date: The new software is expected to be implemented by the end of Q4 in fiscal year 2026. The new policy will be updated and implemented by the end of fiscal year 2026.

Audit Finding 2025-002 in the area of Reporting An Authority official has been designated to develop and implement standardized processes and record-keeping procedures to ensure that all relevant divisions are informed of grant applications, award terms and conditions, financial responsibilities, and reporting requirements. The Finance Division will continue to provide monthly expenditure reports to assigned grant personnel to support ongoing monitoring, reconciliation, and timely reporting. In addition, a supervisory review will be conducted by the Controller, Assistant Chief Financial Officer, or Chief Financial Officer to verify the completeness, accuracy, and compliance of all submitted financial and programmatic reports. Furthermore, relevant personnel will be notified of and encouraged to participate in grants management training to enhance their understanding of reporting requirements, internal controls, and compliance obligations.

Management established corrective measures immediately upon identifying the deficiency related to the untimely submission of the required reports. The Municipality implemented formal procedures to monitor reporting deadlines and ensure the timely submission of reports required by ACUDEN. Management will continue monitoring compliance with these corrective measures to ensure the timely submission of reports in future periods.

The County was previously unable to access the SLFRF quarterly reports on the US Department of Treasury’s portal. The County has since received assistance from the US Department of Treasury and has been given access to the US Department of Treasury’s portal. The County is going to make it a priority to submit the SLFRF quarterly reports by the due dates listed in the SLFRF Compliance and Reporting Guidance. Management anticipates the completion of this item by November 30, 2026.

Finding 2025-004 – Reporting Significant Deficiency in Internal Control Over Compliance and Noncompliance Corrective Action Plan: The Town will strengthen controls over federal reporting by establishing a formal review and approval process prior to submission of financial and performance reports. Procedures will require verification that reported amounts agree to accounting records and that narrative descriptions accurately reflect the use of funds. Evidence of review and approval will be documented and retained. Responsible Official: Clerk/Treasurer Mayor Planned Completion Date: May 2026

FINDING 2025-001: Head Start Program Control Weakness of Filing the Required Semi-Annual and Annual Reports Response: The District Clerk will contact the Head Start Grant Specialist to ensure the SF424 semi and annual reports are reviewed and approved when submitted. The District Clerk has reached out to the office of Head Start for assistance and has not received assistance needed. The District Clerk will go to fiscal training and continue to be proactive with the office of Head Start fiscal reporting team to ensure this finding is closed out. The District will ensure procedures are in place requiring that all Head Start reports be submitted within 30 days of the reporting period end date. The District Clerk will put an internal control in place with the Head Start Director to make sure all SF424's are submitted on time.

Our program leadership are playing a more active role in reporting and compliance and are actively involving directors of programs in the process of reporting.

March 10, 2026 To: Clausell & Associates, P.C. From: Tabirus Lockhart, Chief Financial Officer of Enrichment Services Programs, Inc. Below is the Agency’s corrective action plan as it relates to the findings for the fiscal year ending July 31, 2024, Single Audit Act audit. Comment #2024-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED GENERAL (Repeat) Views of Responsible Officials and Planned Corrective Actions: We concur with this finding - Management is in the process of assessing the organizational structure, capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2024. Concerning preparation of external reports required by various funding sources (i.e., SF-425, DHS’s reports for LIHEAP, LIHWAP, etc.), the Agency will ensure adequate training is performed to improve the skills and knowledge of key personnel. Policies and procedures will also be revised to support external reporting. Implementation Date: The plan correction date will be completed no later than December 31, 2025. Responsible Person: Tabirus Lockhart, CFO, will be responsible for the corrective action. Comment #2025-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, CSBG, ASTHO, CACFP, and CSLFRF FAL # 93.600, 93.568, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - None) Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Management and staff are in the process of assessing and updating the policies and procedures over the accounting and reporting of federal and state grants and contracts. In connection with training staff on the new and updated accounting system, we are providing ongoing training on the requirements of the Uniform Guidance and the specific requirements for each individual grant award as outlined in each applicable Compliance Supplement issued by Office of Management and Budget (OMB). We are currently reconciling all cash accounts and completing and amending, where necessary, all SF-425 reports and other external reports required by each funding source (state and federal). We anticipate completing this corrective action by June 30, 2026. See also the response to Comment #2025-001. Implementation Date: The plan correction date will be completed no later than June 30, 2026. Responsible Person: Tabirus Lockhart, CFO, will be responsible for the corrective action.

Certain matters were brought to our attention as a result of the audit process. These are described more fully in the Schedule of Findings and Questioned Costs. We evaluated the matters as noted below and have described our planned actions as a result. 2025-001: FINANCIAL REPORTING OF FEDERAL PROGRAMS Management Assessment: We concur with the audit assessment regarding this matter. Planned Corrective Action: The County will implement procedures to help ensure required reports are submitted timely. Responsible Party: Moses Sanzo, Administrator/Controller and Jacky Bennett, Interim Chief Financial Officer Date of Planned Corrective Action: September 30, 2026

Finding: 2025-059 - Unliquidated obligations as reported in two of three tested SF-425 Federal Financial Reports were inaccurate. Questioned Costs: None Assistance Listing Number: 66.202 Assistance Listing Title: Congressionally Mandated Projects (CMP) Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): DEC agrees with the finding 2025-059. The department has established procedures and supervisory reviews in place for the preparation and submission of SF-425 Federal Financial Reports. The reporting errors identified relate to 2024 reporting activity and resulted from a misapplied filter within the encumbrance pivot tables, which caused State appropriations to be included in the federal share of unliquidated obligations. Corrective Action (corrective action planned): Revised reports were submitted to the EPA on December 26, 2025. To prevent future errors, DEC will reinforce existing SF-425 preparation procedures by documenting required report logic, including validation of pivot table filters and exclusion of State appropriations from federal reporting. Procedures will require confirmation that only the federal share of unliquidated obligations is included prior to submission. The department will also provide refresher guidance and targeted training for staff responsible for SF-425 preparation, including proper use of encumbrance tabs, pivot tables, and filters. This will ensure continuity of established procedures and reduce reliance on manual assumptions. Completion Date (list anticipated completion date): March 31, 2026 Agency Contact (name of person responsible for corrective action): Christina McCoskey, DEC Finance Officer

Finding: 2025-042 - Two of four randomly selected FY 25 PCSRT SF-425 federal financial reports tested did not include the recipient share of expenditures. Questioned Costs: None Assistance Listing Number: 11.438 Assistance Listing Title: PCSRT Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): ADFG respectfully disagrees with the audit finding regarding SF-425 reporting and recipient share. During the audit period, the federal awarding agency transitioned to a new reporting system but did not issue updated written instructions, revised award terms, or formal guidance clarifying new SF-425 fields or reporting expectations. Under 2 CFR §200.328, recipients are required to submit financial reports as specified in the Federal award, and agencies may require only 0MB-approved, government-wide data elements. No updated award terms or instructions were provided to ADFG during this transition. System behavior clearly indicated that certain fields were not applicable. In Grants Online, the fields were grayed out, signaling they were not required. In contrast, eRA Commons left these fields open without any explanation or guidance. NOAA now requires these fields, but this requirement was not communicated at the time of the transition. This inconsistency demonstrates that the agency had not finalized or communicated enforceable requirements for these fields during the reporting period. DFG acted reasonably and consistently based on the information available. It would be inappropriate to penalize DFG for continuing to report under prior requirements or omitting data in fields that were not previously required. The Uniform Guidance places responsibility on awarding agencies to provide clear written guidance, transition timelines, and clarification on new reporting requirements before they become enforceable. For these reasons, DFG requests that this finding be reconsidered. Our reporting complied with the award terms and the system instructions available at the time, and any changes introduced by the agency were not formally communicated or incorporated into our award during the relevant reporting period. Corrective Action (corrective action planned): We will contact the awarding agency to confirm whether previously submitted reports must be revised to include the recipient share. We will also verify if this requirement applies only to future reporting and adjust our procedures accordingly. Completion Date (list anticipated completion date): April 30, 2026 Agency Contact (name of person responsible for corrective action): Jessica Hood, Accountant 5

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. The second (2025-002) finding pertains to compliance with federal eligibility requirements for the TRIO Upward Bound Program. Federal regulations require at least two-thirds of program participants to be both low-income and first-generation college students. The audit identified that the program fell below the required threshold. To address this issue, the College is strengthening participant eligibility verification procedures and implementing additional monitoring to ensure compliance throughout the program year. Recruitment strategies are also being enhanced to increase the number of eligible participants served by the program. In addition, staff will continue to receive targeted training to ensure accurate eligibility documentation and consistency between program records and federal reporting requirements. Corrective Action 2025-002: Strengthen participant eligibility verification, improve recruitment of eligible participants, enhance APR reporting accuracy, and provide compliance training for TRIO staff. Target resolution 2025-2026 Program Year

2025-102 The County did not develop internal control procedures over program reporting and cash management requirements, increasing risk of report errors to awarding agencies and wrongly receiving monies Cluster Name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and program names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award Numbers and years: IGA DI21-002286 July 1, 2024 through June 30, 2025 IGA DI23-002389 July 1, 2023 through June 28, 2028 Assistance Listings numbers and program name: 21.027 COVID-19—Coronavirus State and Local Fiscal Recovery Funds Award Numbers and years: 1505-0271 March 3, 2021 through December 31, 2024 CT-FM-22-149 October 1, 2024 through September 30, 2025 SLFRFP1962 January 5, 2023 through December 31, 2026 CTR069300 January 1, 2024 through December 30, 2026 GTAW-FM-23*123 October 3, 2022 through July 3, 2026 ACJC-VC-25-001A July 1, 2024 through December 31, 2024 Assistance Listings numbers and program name: 93.268 Immunization Cooperative Agreements Award numbers and years: CTR062571 July 1, 2022 through June 30, 2025 CTR059891 July 1, 2022 through June 30, 2027 Name of contact person: Art Cuaron, Director, Finance and Risk Management Anticipated completion date: June 30, 2027 The County recognizes the need to strengthen internal controls over federal reporting and cash management requirements. F&RM will complete the following actions to ensure compliance with 2 CFR Part 200: 1. Establish written internal control policies and procedures for federal program reporting. All federal financial reports will undergo an independently documented review before submission to ensure accuracy, allowability, and proper reporting periods. 2. Implement documentation standards requiring staff to retain supporting materials such as system reports, financial queries, screenshots, and reconciliations, in accordance with federal and County retention requirements. 3. Pima County has been working with each of its grant implementing entities to use Euna Grants calendaring and reminders to prompt the entities’ timely reporting activities. Grants Management and Innovation (GMI) Department sets the reminders schedule at the onset of the performance period. The reminders are then automatically emailed to the grants manager and the assigned accountant for each grant on a set schedule throughout the course of the grant. GMI and Finance – Grants will continue to work with grant implementing entities to use these reminders to trigger the necessary actions in a timely manner. Pima County was still in the process of institutionalizing this system during FY25. 4. Provide training for staff who prepare and review federal reports, focusing on reporting requirements, documentation standards, internal controls, and record retention. 5. Conduct periodic management oversight reviews to confirm that internal controls are followed and that reports are complete, accurate, and submitted on time. The County is also planning to implement the Workday Grants Module with an anticipated go-live of July 1, 2027. This solution will enhance our ability to manage the full fiscal lifecycle of grant awards and ensure compliance with federal reporting requirements. The Workday Grants Module is a native Workday solution, purpose-built to support the full fiscal grant lifecycle. The module supports the following financial grant objectives: • Grant setup and award and fiscal tracking • Cost allocation and allocability controls • Real-time grant financial reporting • Compliance with federal Uniform Guidance (2 CFR 200) • Integration with Workday Financial Management, Procurement and Human Capital Management (HCM) In addition, F&RM has submitted FY 2026/27 budget requests to fund three additional Accountant III positions in our Finance – Grants Division. These positions will expand our capacity to manage our grant portfolio and strengthen our reconciliation, billing and SEFA preparation processes. The contract for the Workday Grants Module is scheduled to go before the Board of Supervisors for approval in April. These new positions will be included in the County Administrator’s Recommended Budget and will be considered by the Board as part of the full budget adoption process in June.