Corrective Action Plans

Identifying Number: Finding 2025-004 - Reporting and Internal Controls Corrective Actions Taken or Planned: All required federal financial reports must have documented management review and approval before submission to the granting agency. Evidence of approval, including the reviewer, date of review, and final report submitted, will be retained with the grant reporting documentation. Reports will not be considered complete until evidence of review and approval has been documented. Person(s) Responsible: Essence Montgomery, CFO and Abdul Hadi, Director of Financial Accounting Anticipated Completion Date: October 15, 2026 Management Oversight & Next Steps: Management will communicate these control requirements to accounting personnel and responsible departments and incorporate them into current accounting policies and procedures. Documentation supporting the performance of each control will be retained as part of applicable workpapers and made available for management review and future audit testing.

The SLFRF Project and Expenditure Report periods have been filed and no further reporting is required from these specific federal grant rewards. Future grants requiring reporting will be thoroughly reviewed for reporting specifications. Although no funds were misspent or inappropriately used, the County understands the need for correct timing when reporting the grant funds held, encumbered, and expended. The County has since created a grant acceptance template, required to be used by all departments, which will be used to identify who is responsible for future grant reporting requirements. The County will work to ensure all affected departments are aware of specific reporting requirements and that those requirements are followed.

The County Commissioners and Auditor will monitor this internally.

Federal Agency Name: Department of Veterans Affairs Assistance Listing Number: 64.003 Program Name: VA Supportive Services for Veteran Families Program Compliance Requirement: Reporting Finding Summary: No review and approval processes were in place over 2 quarterly progress reports. Corrective Action Plan: Management has implemented procedures and control processes to incorporate an independent review and approval over quarterly reporting effective for the quarterly report ending June 30, 2025. Responsible Individuals: Teena Conrad, SSVF Program Manager, Lysa Allison, Executive Director and Christina Thoelke, Business Manager Anticipated Completion Date: June 2025

The BOCC acknowledges the finding and I will improve reconciliation and review procedures used in preparing federal reports. County officials involved in grant reporting will work together to ensure repotted obligations and expenditures are reconciled to supporting records before submission.

Suspension and Debarment – Assistance Listing Number 14.251 Recommendation: We recommend that management establish and implement policies and procedures for internal staff to monitor all vendors for suspension and debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will establish and implement policies and procedures for internal staff to monitor all vendors for suspension and debarment. Name of the contact person responsible for corrective action: Joel Bailey Planned completion date for corrective action plan: December 31, 2026

Reporting – Assistance Listing Number 14.251 Recommendation: We recommend that management establish and implement a policy to record and retain review of all reports, and to retain proof of submission to verify timeliness of submission of required reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will establish and implement policies to record and retain review of all reports, and to retain proof of submission to verify timeliness of submission of required reports. Name of the contact person responsible for corrective action: Joel Bailey Planned completion date for corrective action plan: December 31, 2026

Cash Management – Assistance Listing Number 14.251 Recommendation: We recommend that management establish and implement policies to retain proof of amounts requested for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will establish and implement policies to retain proof of amounts requested for reimbursement. Name of the contact person responsible for corrective action: Joel Bailey Planned completion date for corrective action plan: December 31, 2026

Federal Agency Name: Corporation for National and Community Service Federal Financial Assistance Listing #94.012 Program Name: September 11th National Day of Service and Remembrance Grants Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: Reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA) was not completed for each of the four subrecipients in which pass through funds exceeded $30,000. Corrective Action Plan: Management agrees with the finding and has implemented procedures to ensure that applicable subawards are identified and reported in accordance with Federal Funding Accountability and Transparency Act (FFATA) requirements. Management will review subawards at the time of award to determine whether federal reporting requirements apply, complete required reporting within the applicable reporting period, and retain documentation supporting completion of the reporting. Responsibility for monitoring and completing required FFATA reporting has been incorporated into the organization's federal grant administration procedures. Responsible Individuals: David Paine - President, Dominique Carver – Operations Director, Miranda Cirtwell – Controller Anticipated Completion Date: December 15, 2025

Management acknowledges the delays identified in the submission of certain monthly progress reports corresponding to the 2025 reporting period. However, management respectfully notes that the dates reflected in PRDOH's reporting records should be considered in the context of PRDOH's established sequential reporting and approval process. Under the Puerto Rico Department of Housing's CDBG-DR/MIT Grant Compliance Portal (GCP) procedures, a subrecipient cannot submit a monthly report while a preceding report remains open and pending approval. Specifically, the PRDOH CDBG-DR/MIT Grant Compliance Portal (GCP) Manual, Version 5, dated April 4, 2024, page 35, states: “You cannot submit a report while there is an open past Report” and further provides that, “Once the open report is approved, you can submit the next monthly report.” Accordingly, delays in PRDOH's review, return, resubmission, and approval of one monthly report necessarily affect CRH's ability to submit the following month's report, even when CRH is otherwise prepared to proceed with the subsequent submission. Management therefore reviewed the complete submission and approval history for all twelvemonthly reports corresponding to 2025 in order to distinguish between reports that appear late based solely on the dates reflected in PRDOH's records and reports that were submitted late due to circumstances attributable to CRH. Out of the 12 months of 2025, five reports were submitted late. Of the five late submissions, three of which were due to the PRDOH’s delayed approval of the previous month’s report. Reporting Period Original CRH Submission PRDOH Approval Status January 3/26/25 4/3/25 Submitted late, in order to incorporate new PRDOH data and inventory requirements. February 4/23/25 5/26/25 Submitted late, in order to incorporate new PRDOH data and inventory requirements. March 5/28/25 5/28/25 Submitted late due to PRDOH approval date of previous report April 5/28/25 5/28/25 Submitted late due to PRDOH approval date of previous report. May 6/2/25 6/5/25 Submitted within term. June 7/1/25 7/9/25 Submitted within term. July 8/1/25 8/6/25 Submitted within term. August 9/2/25___ 9/19/25_ Submitted within term. September 10/2/25 10/17/25 Submitted within term. October 11/5/25 12/10/25 Submitted within term. November 12/15/25 12/23/25 Submitted late due to PRDOH approval date of previous report. December 1/5/26 2/4/26 Submitted within term. After considering the original submission dates, PRDOH approval dates, subsequent resubmissions, and the sequential reporting requirement established by PRDOH, only two reports were actually submitted late due to circumstances attributable to CRH. With respect to those reports that were actually submitted late by CRH, the delays occurred principally during a period in which PRDOH was establishing new requirements concerning the information, supporting documentation, classifications, and formatting required for inventory and data, which required overhauls of the CRH’s internal methodologies. In several instances, these requirements were communicated through comments and instructions associated with PRDOH's review of preceding reports, and in others, from e-mail requests establishing new inventory criteria. CRH has since incorporated PRDOH's data and inventory format requirements into its regular procedures, completed the necessary personnel transition and training, and strengthened its internal monitoring of monthly reporting deadlines. As of 2026, CRH's monthly reports have been submitted without a sinlge late submission. Management will continue documenting both CRH submission dates and PRDOH approval dates so that delays resulting from PRDOH's sequential review and approval process can be appropriately distinguished from delays attributable to CRH.

We will implement a process to reflect reviewer signature on D- 15s (County form) for financial reports.

We will implement a process to maintain documentation of review for all CalOES grants in the form of E-mail confirmation or screenshot signed by the reviewer.

The Department of Health and Human Services/Centers for Disease Control and Prevention – Assistance Listing No. 93.495 Recommendation: We recommend the organization create and or update policies and procedures to ensure all required reports are submitted timely and accurately Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has developed and continues to implement a tracking system for compliance with deadlines, including report submissions. Name(s) of the contact person(s) responsible for corrective action: Sharon Brown, CEO Planned completion date for corrective action plan: December 31, 2026

Finding #2025-002 Comments on the Finding and Each Recommendation: For the year ended December 31, 2025, the Corporation did not submit the Annual Reports to the City of Detroit within the time period required by Uniform Guidance. Action(s) taken or planned on the finding: The Corporation has initiated outreach with the City of Detroit to resolve portal setup delays and will submit the 2025 annual reporting packages immediately upon receiving functional system access. The Corporation is implementing formal internal covenant-tracking controls and review procedures to ensure all future reporting deadlines are monitored and met within required timeframes.

FINDING 2025-023 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Jenna Harrington, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, jharrington@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: A comprehensive Internal Controls Manual was written and released in December 2024 with implementation beginning July 1, 2025. This includes segregation of duties, purchasing processes, contacts process, grant processing, Grant Reimbursements The reimbursement process was updated to include all required supporting documentation, such as transaction detail and summary reports. Each request is also reviewed and signed by the supervisor to document approval. On a recurring basis, the Director of Federal Grants generates the detailed expenditure report and budget summary. The detailed report is filtered to capture only the transactions occurring since the previous reimbursement request, making new expenditures easy to identify. These amounts are added to the cumulative reimbursement totals, which are then compared to the total disbursements shown on the summary report to ensure they align. Once the totals match, the reimbursement request is reviewed by the Chief Financial Officer and submitted to the awarding agency. Since there was no reimbursement form for this grant, the supervisor review signature was not always collected. It has been added on one of the sheets within the supporting documents of the packet. Financial Reporting Reviewing The fiscal officers managing the grant will have their supervisor review financial reports prior to submission and sign their approval. Anticipated Completion Date: July 1, 2025

CORRECTIVE ACTION PLAN FINDING 2025-022 Finding Subject: Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Darice Austin-Phillips, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, daustin@sbcsc.k12.in.us , atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal Control Manual: Released a comprehensive manual covering segregation of duties, purchasing, and grant management. Reimbursement & Reporting Oversight: Added explicit supervisor review signatures to grant packet supporting documents and financial reports prior to final agency submission. Anticipated Completion Date: Grant Ended: December 2025 IC Updates: January 1, 2025

FINDING 2025-014 Finding Subject: Teacher and School Leader Incentive Grants (Formerly the Teacher Incentive Fund) – Condition of Records Contact Person Responsible for Corrective Action: Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Centralized Reporting: The Finance Department now mandates that all approved grant documentation (Grant Award Notifications, reimbursement forms, budget breakdowns) be submitted to Finance immediately. This grant is no longer in use. Anticipated Completion Date: September 30, 2024 (grant ended). January 1, 2025 is when grant award documentation sharing was required.

CORRECTIVE ACTION PLAN FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) - Condition of Records Contact Person Responsible for Corrective Action: Kwalfle Scott-Bradley, Ahnaf Tahmid & Marlaina Johns Contact Phone Number and Email Address: 574-393-6000, kscottbradley@sbcsc.k12.in.us, atahmid@sbcsc.k12.in.us, mjohns2@sbcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reimbursement & Approval Process: Standardized reimbursement requests to require full supporting documentation (transaction details and summary reports). The Director of Federal Grants filters expenditures since the prior request, reconciles totals against disbursements, and obtains CFO approval before submitting. Resolution of Over-Expenditures: Over-expenditures identified during the audit cycle were resolved in January 2026 via School Board approval by transferring unallowable and excess expenditures to the general fund. Category Monitoring: The Special Education Department will monitor budget limits continuously to ensure individual grant categories are not over-expended. Anticipated Completion Date: Completed January 2026

We agree that the State and Local Fiscal Recovery Funds (SLFRF) Project and Expenditure Report was overstated by $1,059,739.66 for the grant period ended December 31, 2025. We contract with Bricker, Graydon, Wyatt LLP to complete the SLFRF reporting. We understand that we should review the report as it is completed by the law firm. Interest earned on SLFRF funds do not have to be remitted to the US Department of Treasury and is not subject to the SLRFR program use restrictions. Therefore, the issue deals primarily with reporting and classification. The County will review and reconcile all expenditures reported under the SLFRF grant receipts, interest earnings, expenditures, and amounts reported to the US Department of the Treasury. The County will ensure expenditures are accurately classified and reported according to the source of funds and applicable Treasury reporting requirements. We will review the report after it is prepared by the law firm and approve the reconciliation before the report is submitted. The reconciliation will specifically distinguish SLFRF award funds from interest earnings and other non-SLFRF revenues.

Management concurs with the finding. The Organization will strengthen grant management and financial oversight procedures by maintaining centralized grant files containing approved budgets, budget revisions, amendments, and supporting approvals. Additional review procedures will be established to ensure all budget modifications receive appropriate authorization and documentation is retained in accordance with federal grant requirements. The Finance Director will provide oversight of grant budgeting, compliance monitoring, and documentation controls to ensure consistency across all funding sources.

To ensure all CDBG quarterly reports are completed and submitted within the required 30 calendar days after the reporting period 2026.

The reporting process for federal & state awarded funds will be reviewed with all parties involved in these funds.

FINDING 2025-006 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-677-3959 clane@vincennes.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All reports will be prepared by the clerk’s office and will be reviewed for errors and omissions by someone who is knowledgeable about the reporting requirements prior to submission. Anticipated Completion Date: The corrective action plan will be implemented by December 31, 2026.

FINDING 2025-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Allowable Costs/Cost Principles and Period of Performance Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-677-3959 clane@vincennes.in.gov Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The clerk’s office will work with the grant administrators and departments to assist in identifying non-compliant activities to ensure that funds are being used appropriately and according to the federal guidelines for the grant. We will consult with the relevant personnel to ensure understanding of allowable and disallowed costs as well as period of performance and help departments who may need additional training. Anticipated Completion Date: The corrective action plan will be implemented by December 31, 2026.

If we receive federal funds in the future, we will stay abreast of current and changing policies and procedures.