Corrective Action Plans

Staff responsible for managing CDBG grants have received remedial training and are now aware of reporting deadlines. Additionally, all grant agreements are now required to be reported to the County Auditor's office or secondary review.

Views of Responsible Officials and Planned Corrective Actions: Management acknowledges this finding, which is a repeat of finding 2023-003. ICFJ believes that all required reports were submitted to the Federal Government as required; however, we recognize that the inability to retrieve documentation during the audit is a control deficiency that must be addressed. ICFJ will implement a centralized document management system for all financial and programmatic reports, with a standardized filing protocol that includes confirmation of submission, submission date, and the name of the preparer and approver. Reports will be filed immediately upon submission and will be accessible for audit and compliance purposes.  Anticipated completion date: 9/30/26  Responsible position: Chief Financial Officer

FINDING 2024-009 Finding Subject: ESSER Grant Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ESSER program has concluded and corrections were made following leadership changes. Financial activity was reviewed and adjusted where possible. Reimbursement requests are now tied to general ledger activity with full documentation. The prior practice of correcting errors through transfers has been discontinued. Controls implemented apply to all future grants and monitoring is ongoing. Anticipated Completion Date: May 2026

FINDING 2024-008 Finding Subject: Special Education Cluster (IDEA) Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation partnered with Mazi Education for oversight. Separate funds are maintained for each project year. Payroll mapping has been corrected and reimbursement requests are based on ledger activity with supporting documentation. Transfers are documented and restricted. Monitoring procedures ensure ongoing compliance. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance control activities, and provide ongoing monitoring to ensure compliance with Special Education grant requirements and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

FINDING 2024-006 Finding Subject: Title I Grants Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation partnered with Mazi Education to provide oversight of grant compliance. Separate funds are maintained for each grant and project year. Payroll mapping has been corrected to ensure proper allocation. Reimbursement requests are based on general ledger activity and supported by documentation. Transfers are restricted and documented. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance control activities, and provide ongoing monitoring to ensure compliance with federal grant requirements and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

We agree with the recommendations offered for the relevant programs and will establish and implement policies that provide for documentary evidence of review of applicable reports by qualified individuals to ensure the timely submission of required reports to applicable federal agencies that can be easily reconciled to the underlying accounting records. The anticipated completion date is October 2026.

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

VIEWS OF RESPONSIBLE OFFICIALS We are resolving these deficiencies by leveraging the new Government ERP system, scheduled for launch in July 2026. This platform will provide the essential functionality to properly configure our Chart of Accounts, ensuring that all TANF and PTTA administrative expenditures are automatically segregated by federal award and Assistance Listing Number (ALN). This system will be the foundation for accurate, traceable, and reconcilable financial reporting, supported by robust internal controls and multi-level supervisory oversight. Action Steps: 1. ERP Chart of Accounts Configuration – Configure the ERP system with a granular Chart of Accounts that strictly segregates TANF and PTTA administrative expenditures, ensuring every transaction is coded to the correct federal grant and ALN. 2. Automated Reporting Workflow – Utilize the ERP's financial reporting modules to generate ACF-196TR reports directly from the General Ledger, ensuring reported expenditures are 100% traceable to source transactions. 3. Digital Reconciliation Workpaper – Require the ERP to generate an automated "Reconciliation Package" for every ACF-196TR submission, which links reported line items directly to General Ledger accounts, eliminating discrepancies. 4. Staff Training & ERP Stabilization – Execute comprehensive training for all finance staff on the new ERP accounting structure, reconciliation modules, and federal reporting requirements, ensuring the system is utilized for full audit compliance. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget

VIEWS OF RESPONSIBLE OFFICIALS ADFAN appreciates the observations presented in the audit and acknowledges the importance of strengthening its reporting processes. The agency recognizes that staffing limitations within the Finance Division have affected the ability to perform timely reviews and ensure adequate segregation of duties. Additionally, the Finance Procedures Manual referenced during the audit was approved in 2009 and is currently undergoing a comprehensive revision to reflect the agency’s present operational structure and accounting practices. ADFAN is committed to improving its internal controls, enhancing staff training, and implementing the necessary measures to ensure full compliance with federal reporting requirements moving forward. IMPLEMENTATION DATE December 31, 2026 RESPONSIBLE PERSON Yazmín Cruz Colón, Budget Director

VIEWS OF RESPONSIBLE OFFICIALS To resolve this, we are integrating these reporting requirements into the new Government ERP system, scheduled for launch in July 2026. This platform will provide the capability to generate accurate General Ledger data and automated financial reports, ensuring that all LIHEAP performance data is traceable to verified accounting sources and subject to multi-level supervisory approval workflows. Action Steps: 1. ERP-Driven Financial Reporting – Configure the ERP system to generate General Ledger reports that align precisely with LIHEAP financial data requirements. The ERP will serve as the "Single Source of Truth," eliminating discrepancies between accounting and reporting. 2. Automated Reconciliation Workflows – Utilize the ERP’s native reconciliation engine to automatically match expenditure records against reported LIHEAP budget obligations, ensuring figures are accurate and validated before submission. 3. Segregation of Duties (SOPs) – Formalize protocols where the ERP system enforces mandatory "Preparer-Approver-Certifier" roles. This ensures that performance data compiled by program staff is independently validated against ERP financial records by a supervisor. 4. Training on ERP Reporting – Train all staff on how to use ERP reporting modules for financial data extraction and the new protocols for reconciling this data with programmatic LIHEAP performance metrics. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Nesvia Fontanez Marín Principal Accountant Federal Reports

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to transitioning from manual, offline tracking to a fully integrated, system-based approach within our Enterprise Resource Planning (ERP) system. Action Step: 1. ERP System Configuration: Configure the ERP system to automatically flag and categorize transactions eligible for indirect cost calculation by class object, replacing manual Excel-based methods. 2. Indirect Cost SOP-Develop and implement written formal procedures detailing the extraction of data from the ERP, ensuring traceability back to the source transaction IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget

VIEWS OF RESPONSIBLE OFFICIALS ADSEF acknowledges the findings regarding weaknesses in the Random Moment Sampling (RMS) methodology used for allocating administrative costs. We conclude that the absence of formal written procedures, combined with insufficient communication between the Human Resources Appointments Office and the Finance Division, has contributed to inaccuracies in the distribution of administrative expenses across federal programs. ADSEF reaffirms its commitment to strengthening its cost allocation plan to ensure that only allowable costs, directly associated with the administration of federal awards, are charged to the TANF program, in strict compliance with 2 CFR §200.302. Action Steps: 1. Policy Formalization Develop, approve, and implement a comprehensive Standard Operating Procedure (SOP) that formalizes the RMS methodology, including clear and standardized definitions for all survey response categories. 2. HR–Finance Liaison Establish a structured monthly reporting protocol between the Human Resources Appointments Office and the Finance Division to ensure the RMS participant list remains accurate, complete, and current. 3. RMS Questionnaire Update Revise the RMS questionnaire to remove non-federal program selections and ensure that all response options align directly with federally allowable functions. 4. Quarterly Oversight Institute a mandatory quarterly review of RMS results by senior management to validate alignment between RMS survey data and accounting system allocations IMPLEMENTATION DATE March 31, 2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Coral M. Caceres Alvarez Auxiliary Administrator Human Resources Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Gerhil Medina Baez Auxiliary Administrator Operational Services Rafael Acosta Sepulveda Program Director

VIEWS OF RESPONSIBLE OFFICIALS The data will be evaluated by the IT department to verify the controls in place at the time the files identified as duplicates were issued. Regarding the issuance, the IT department acknowledges an error in the file transmission, which resulted in the information not being matched against the issuance. The data will be available as reference for evaluation. For reconciliation purposes, work will be performed efficiently and within the established timeframes to ensure that all transactions are recorded promptly in the system. This will enable the accurate completion of the reconciliation process, as well as the recording of issuances and any other related transactions, in accordance with established procedures. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Blanca M. Medina Díaz Administrator Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Carmen Ramírez IT Director

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.

All federal programs requiring engineering assistance will be also be tracked internally for compliance.

Finding Number: 2024-004 Planned Corrective Action: The Housing Authority along with Leggins Casterline & Company LLC accounting will continue working to rectify the accounting issues resulting from the former Executive Director and have all submissions done in a timely manner. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director

Type: Significant Deficiency Corrective Actions: - Establish compliance calendar and tracking system. - Assign responsibility and require supervisory review. - Monitor reporting timelines. Responsible Parties: Chief Executive Officer and Chief Financial Officer

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

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

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

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

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

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

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

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