Corrective Action Plans

Management concurs that reconciliation procedures can be strengthened. All accounting and reporting activities are performed using the Recipient systems, ensuring compliance with HUD reporting standards. Enhancements will focus on improving documentation and internal oversight.

Finding 2024-002: Insufficient Documentation of Management Review of Section 3 Quarterly and Annual Reporting Planned Corrective Action: Management agrees with the finding and will establish a formal review and approval process for all Section 3 quarterly and annual reports prepared and submitted by the grant administrator to the Texas General Land Office. Going forward, the City Secretary will review each report for accuracy and completeness prior to submission, and evidence of this review, such as signed approval or email confirmation, will be retained in the grant files. The City anticipates implementing this procedure for all future reporting periods to ensure compliance with federal reporting and internal control requirements. Anticipated Completion Date: December 2025

The Mental Health and Recovery Board of Portage County will submit program final expenditures in the GFMS system within the grant close-out reporting period.

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, 2023 – June 30, 2024 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: December 31, 2025

Condition and Context: During our audit of the Public Safety Partnership and Community Policing Grant (CFDA 16.710), we were unable to obtain a copy of the required SF-425 (Federal Financial Report) submitted by the County. Recommendation: We recommend that the County implement procedures to ensure that copies of all required federal reports are retained in accordance with federal record retention requirements and made available for audit purposes. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will establish procedures to ensure that all required federal reports are retained and readily available for future monitoring and audits.

This Finding is related to the Failure of a Department to timely file one quarterly status report. The employee in charge of quarterly reporting realized the omission herself in less than a week and corrected the action immediately, months before it was noticed and reported by the State Audit Team. The Director reports several calendaring mechanisms are in place and the reports are being tracked by duplicative methods since that error.

Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027 Recommendation: We recommend the City implement procedures to ensure the accuracy of quarterly reporting and maintain supporting documentation for each of the amounts reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All quarterly reports were reviewed and combined into a single report. All obligations and expenses as of 6/30/2024 were examined and a determination of correct obligation and expenses was determined. These new numbers will be used for the next reporting period. The new report will continue to be used moving forward. Name(s) of the contact person(s) responsible for corrective action: Angie Murray Planned completion date for corrective action plan: 10/15/2025

Management concurs with the audit recommendation and is taking the following corrective actions to improve cash management efficiency and ensure accurate and timely financial reporting: The District will implement a policy requiring that reimbursement requests are submitted at least quarterly to the grant administrator and reconciled to the SF-425 reporting. • This policy will ensure that federal drawdowns are performed timely and aligned with actual expenditures, improving cash flow management and reducing the risk of reporting discrepancies. • Procedures will reconcile all reimbursement requests with SF-425 financial reports to confirm that expenditures are accurately and consistently reflected in the corresponding SF-425 report, in compliance with 2 CFR 200.305 and 2 CFR 200.328. • Management will ensure staff is adequately trained in grant administration and financial reporting. These sessions will cover federal cash management standards, SF-425 reporting procedures, and internal controls to ensure consistency and compliance. These actions reflect the District’s commitment to improving financial management practices, enhancing grant compliance, and ensuring the timely and accurate reporting of federally funded expenditures.

Economic Development Cluster – Assistance Listing No. 11.307 Recommendation: We recommend the College review its reporting procedures to ensure all reports are completed and submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reporting procedures will be reviewed to ensure all reports are submitted timely. A grants management workbook template that is in place will be reviewed to determine if all reporting requirements have been included and the status of each reporting requirement. Name(s) of the contact person(s) responsible for corrective action: Saundra Buchanan and Sam Draper Planned completion date for corrective action plan: 8/7/2025

The City agrees with this finding. Having recognized this deficiency prior to commencement of this audit, the City implemented additional internal review requirements during FY25.

FINDING 2024-006 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Reporting Contact Person Responsible for Corrective Action: David M. Kennard Contact Phone Number and Email Address: 812-677-3959 clerk@princetoncity.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Clerk-Treasurer will prepare the Project and Expenditure report and someone else, who is knowledgeable about the awards and the reporting compliance requirement, will review the report prior to submission. Documentation of the review will be retained with the City’s records. Anticipated Completion Date: The corrective action plan will go into effect immediately.

FINDING 2024-004 Finding Subject: Water and Waste Disposal Systems for Rural Communities – Reporting Contact Person Responsible for Corrective Action: David M. Kennard Contact Phone Number and Email Address: 812-677-3959 clerk@princetoncity.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Clerk-Treasurer will prepare the annual data report and someone else, who is knowledgeable about the awards and the reporting compliance requirement, will review the report prior to submission. Documentation of the review will be retained with the City’s records. Anticipated Completion Date: The corrective action plan will go into effect immediately.

2024-002 The City did not submit the required Program Reports for all four quarters of 2024. Stephen Fricker, Director of Finance December 31, 2025 The City will implement additional control procedures to ensure all reports are filed in a timely manner.

Finding Number: 2024-001 Finding Name: Congressional Directives Assistance Listing Number 93.493 U.S. Department of Health and Human Services Finding Summary: Criteria or Specific Requirement - Performance and Financial Monitoring and Reporting, 2 CFR Section 200.328-329 Condition - The annual Federal Financial Report was not submitted timely and required performance reporting was not completed during the year. Questioned Costs - N/A Context - The Federal Financial Report for the reporting period end September 29, 2024 was due December 28, 2024, however, this was not submitted until February 25, 2025. Additionally, two (2) performance reports were due during the year, however, neither were completed. The first was for the period September 30, 2023 - March 31, 2024 and was due April 30, 2024, and the second was for the period April 1, 2024 - September 30, 2024 and was due October 30, 2024. Effect - The Company did not comply with federal reporting requirements. Cause - Management turnover caused uncertainty in assigned responsibilities, including this reporting requirement. Identification as a Repeat Finding - N/A Recommendation - The Company should review reporting requirements in grant award documents for all federal awards to ensure compliance. Client Planned Action: Benson Hospital agrees to the finding. The issue was identified in February of 2025 and the required reporting was completed and submitted. Going forward we have established a protocol by which reports for such Congressional Funding shall be submitted timely. Client Responsible Party: Mark Nellis, CFO; (520) 586-1873 Completion Date: February 22, 2025

Management acknowledges the audit finding regarding timely submission of reports and retaining documentation of submissions. We will implement a new combined monitoring and record retention internal control process for financial, performance, and special reporting requirements, to ensure timely submission and retention of supporting documentation for required sponsor reporting. This process will be implemented by December 31, 2025.

2024-006 Community Economic Adjustment of Establishment, Expansion, Realignment, or Closure of a Military Installation/ Finance Performance Reporting Deadlines Starting in Fiscal Year 2025-2026, LRA has implemented adequate tracking and oversight mechanisms to ensure timely submission of required reports. It developed and maintained a centralized compliance calendar listing all federal reporting deadlines with internals submission deadlines at least fifteen to thirty days before deferral due dates to allow for review and approval before final submission. Once the Finance Department recruits and gives adequate training to the additional staff it will strengthen its internal controls over grant reporting by assigning clear responsibilities to the preparation and timely submission of all required reports. The Finance Department has implemented within its monthly accounting closing procedures tracking and reporting calendar detailing pending reports, due dates, and completion status. Jamille E Muriente Díaz, Financial Affair Director Telephone: 787-705-7188 Email: Jamille.muriente@lra.pr.gov Target Completion Date - 6/30/2026

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL PROGRAMS FEDERAL AGENCY: DEPARTMENT OF THE TREASURY PASS THROUGH ENTITY: DOUGLAS COUNTY KANSAS PROGRAM NAME: CORONAVIRUS STATE AND LOCAL RECOVERY FUNDS (COVID-19) ASSISTANCE LISTING NUMBER: 21.027 AWARD PERIOD: JANUARY 1, 2024 – DECEMBER 31, 2024 2024-003 Double reported expenses (Material Weakness) Recommendation: We recommend expenditures be tracked against grant funding instead of only the project level, separate preparation and review of reporting, and additional review and oversight of those charged with governance. Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. Management will implement funding-level tracking, using unique “Class” identifiers within the accounting software for each funding source (as projects are tracked using “Customer” field). The Finance Committee will review reports of expenditures by grant twice per year to confirm no double reported expenses. Erin Koksal, Financial Controller, is responsible for this corrective action. Anticipated completion date is December 31, 2025.

Finding number 2024-004, significant deficiency in internal controls over compliance – reporting. Recommendation: We recommend that the Organization implement and document procedures to ensure that all required federal financial reports are prepared, reviewed and submitted within the required timeframes. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action planned in response to the finding: KRJC has now developed a clear procedure for ensuring that all program expenses are received and/or accrued for the period so that reporting can be completed and submitted no later than 30 days after the end of the quarter. All FFY2025 required financial and narrative reporting has been submitted within the required time frame. Planned completion date for corrective action plan: November 30, 2024.

Finding 2024-003 – As of the March 31, 2024 reporting date, the Town reported projects approved by the Select Board as obligated rather than purchases, contracts and agreements that met the Federal criteria of an obligation. The Projects and Expenditure report for the period ending March 31, 2024 was not filed until March 25, 2025. Corrective Action Planned: The Projects and Expenditure report for period ending March 31, 2024 was filed after the deadline due to a technological issue preventing access to the portal that was documented with both the U.S. Treasury and Login.gov Helpdesk. A new managed service provider working for the Town of Clinton was successful in correcting the issue for a timely filing of the 2025 report and all State and Local Fiscal Recovery Fund (SLFRF) projects were obligated by the 12/31/24 deadline. Completion Date: April 30, 2025 Contact: Michael J. Ward, Town Administrator

Management has reviewed the finding above and concurs. A corrective action plan addressing the deficiencies will be completed and submitted within 60 days of the report.

Each employee will have a payroll file that includes: • Date of hire • Title • Grant(s) they are assigned to if applicable • Pay amount • Any changes to the above and the date of the change Each employee will complete a timesheet weekly that includes the number of hours worked and if applicable broken out by what grant(s) they worked on. The bookkeeper provides a budget:actual report when invoices for federal contracts are prepared. The ED notes signs off that they have been approved for draw. That report is stored on the server. The Treasurer reviews the cost-reimbursement requests prepared by the ED, along with the detailed back up.

The City will review its process for accumulating data for required reports and implement additional procedures to reconcile reports with cash basis activities.

On behalf of Bebashi – Transition to Hope, I am submitting this corrective action plan in response to the material weakness finding identified in our recent federal audit. The finding noted a lack of effective internal controls over the maintenance of accurate accounting records, including the trial balance, general ledger, and the Schedule of Expenditures of Federal Awards (SEFA) and state financial assistance. These deficiencies resulted in material audit adjustments to the current year’s financial statements, multiple versions of the trial balance due to reconciling issues, and audit delays related to unreconciled supporting documentation. We take these findings with the utmost seriousness. As stewards of federal funds, it is our fiduciary duty to maintain strict compliance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200), as well as applicable state financial requirements. Corrective Action Plan 1. Strengthening Internal Controls o We are implementing enhanced internal control procedures to ensure timely reconciliation of the trial balance and general ledger. o Monthly reconciliations will now be prepared by the Finance Department, reviewed by the Chief Operating Officer, and formally approved by the President & Chief Executive Officer prior to closing. o Quarterly oversight reporting will also be provided to the Bebashi Board of Directors. 2. Accounting System Improvements o We will establish a standardized process to ensure one official version of the trial balance is maintained, with all adjustments tracked and documented in accordance with Generally Accepted Accounting Principles (GAAP). o We are upgrading our financial reporting system to include automated reconciliation checks, audit trails, and controls that will minimize the risk of discrepancies. 3. Staff Training and Accountability o Finance staff will undergo mandatory annual training on federal compliance, SEFA preparation, and reconciliation best practices. o Roles and responsibilities will be clearly defined, with a segregation of duties to prevent misstatements and errors. 4. Audit Readiness and Documentation o A comprehensive audit binder will be prepared and maintained to ensure that supporting documentation reconciles with the trial balance prior to submission. o A compliance calendar will be developed to track critical deadlines, reconciliation reviews, and reporting requirements. 5. Board and Executive Oversight o The Bebashi Board of Directors, through its Finance and Audit Committees, along with the President & CEO, will provide governance oversight of this corrective action plan. o Quarterly progress reports will be submitted to the Board, and the CEO and Board will formally document oversight in meeting minutes to ensure accountability and compliance. Responsible Party: The Finance Director, in collaboration with the Chief Operating Officer and with final accountability to the President & CEO as well as the Bebashi Board of Directors, will be responsible for implementing and monitoring this corrective action plan. Anticipated Completion Date: All corrective measures will be completed within ninety (90) days of the date of this letter, with ongoing monitoring and governance oversight by the CEO and Board of Directors to ensure sustainability. We regret the deficiencies that led to this finding and are committed to taking the corrective actions necessary to strengthen our financial management systems. Bebashi – Transition to Hope is dedicated to full compliance with federal and state requirements and to safeguarding the integrity of public funds entrusted to us. Respectfully submitted, Sincerely, Sebrina Tate President & Chief Executive Officer Bebashi – Transition to Hope On behalf of the Bebashi Board of Directors

Emergency Relief Fund (HEERF) Programs (significant deficiency) Condition (per audit): Non-compliance noted regarding untimely filing of quarterly and annual report. SwCC’s Explanation: The HEERF department and reporting systems were closed, and Grants personnel were unable to retrieve a copy of the required reports from the ESF Data Collection System by the suggested deadline of May 19, 2025. Corrective Actions (overseen by the President): 1. Grant Reporting Calendar o A compliance calendar with all DOE reporting deadlines was created in August 2025. o Internal deadlines are set two weeks before federal due dates. o Responsible Official: Director of Grants 2. Dual Review & Submission Tracking o All grant quarterly and annual reports must be reviewed and signed off by the Director of Grants, President, and Comptroller before submission. o Submission confirmations will be saved in the respective grants folder of the electronic filing system. o Responsible Officials: President, Director of Grants & Comptroller 3. Centralized Filing & Audit Readiness o Grant reports (quarterly, annual, and related correspondence) will be stored in the centralized electronic filing system for continuity and audit review. o Responsible Officials: Director of Grants & Business Office 4. Quarterly Compliance Checks o The President and Director of Grants will conduct quarterly compliance reviews to confirm all required reports are submitted timely. o Responsible Officials: President & Director of Grants 5. Time and Effort Reporting in Populi o Effective August 2025, time and effort reporting for all Title IV-funded student workers and grant-funded employees will be completed in Populi, capturing descriptions of duties and percentage of time worked, aligned with payroll and funding sources. o Responsible Officials: Director of Grants & Comptroller/Business Office Completion Date: Reporting calendar implemented August 2025; all future reports will be submitted timely under this protocol. Southwestern Christian College is committed to full compliance with federal regulations and the highest standards of financial accountability. The corrective actions outlined above address both Title IV and HEERF audit findings with immediate steps, ongoing monitoring, and strengthened internal controls. With the implementation of new reconciliation processes, expanded staffing in the Business Office, centralized electronic filing, enhanced verification and reporting protocols, and a structured compliance calendar, SwCC has established sustainable safeguards to prevent recurrence of deficiencies.

In 2024, 9/11 Day was unaware of this regulation, but agrees with this finding. 9/11 Day has adopted a written policy that shall ensure that all subgrants made are properly compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA). All subgrantees will be entered into a centralized tracking log, and for those receiving pass-through funds exceeding $30,000, the required reporting will be completed directly in SAM.gov, which now includes the Federal Subaward Reporting System (FSRS). Each subgrantee’s eligibility will be verified in SAM.gov, with the date and results of the verification recorded, and all supporting documentation retained on file. This corrective action ensures that all subawards are properly logged, reported, and compliant with FFATA requirements.