Corrective Action Plans

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

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

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

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

Response to finding 2024-004 – Reporting Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2024-004. During the audit period, recordkeeping was not centrally maintained, and key documents were often stored under individual employee drives rather than within a shared, organization-controlled system. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, the Organization had limited capacity to implement formal reporting controls; however, foundational corrective steps were initiated in 2025 to support full compliance during the 2026 operating year. This finding continued into the 2024 audit period due to the decentralized recordkeeping practices described above. Corrective Action taken in 2025: The Operations Manager conducted a full triage of existing accounts and transferred organizational documents into centralized CSforALL Drives. Files were reorganized by year and subject matter to ensure accessibility, consistency, and proper retention. This restructured system now provides a unified location for all grant-related documents, reporting records, and compliance materials, establishing a baseline for future Uniform Guidance reporting requirements. Corrective Action Planned for 2026: Beginning in 2026, CSforALL will implement formalized policies and procedures to ensure records are maintained in accordance with applicable compliance requirements and that all Uniform Guidance reports are submitted timely. The Operations Manager and Accounting team will oversee ongoing documentation, retention, and periodic internal review to ensure the reporting structure remains organized, accessible, and compliant throughout the 2026 operating year and beyond.

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

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

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

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

Views of Responsible Officials and Planned Corrective Action We will give instructions to the accounting staff in charge of the preparation of the quarterly progress reports of the Program, in order to comply with the FEMA reporting requirements. Responsible Official: Mrs. Irma M. Vargas Aguirre, Finance and Budget Director Implementation Date: December 31, 2025

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

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

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

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

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.