Corrective Action Plans

Views of Responsible Officials – Finding 2024-001 – Procurement, Debarment, and Suspension: The Town of Van Buren acknowledges the finding regarding the lack of documented procurement steps related to suspension and debarment verification, as well as the absence of federally required contract clauses. This occurred during a time when the Town was newly implementing federal grant administration procedures following the adoption of a procurement policy. As noted in the auditor’s report, this is a repeat finding; however, improvements have been made, and the Town is committed to further strengthening our internal controls to ensure full compliance with federal procurement standards. Corrective Action Plan – Finding 2024-001: To address this finding and mitigate the risk of noncompliance with federal procurement regulations, the Town will take the following actions: 1. Procurement File Checklists: Develop and implement a standardized procurement checklist that includes verification of debarment/suspension via SAM.gov, inclusion of all federally required contract provisions, and documentation of cost or price analysis. 2. Contract Review Procedures: All federally funded contracts will be subject to internal review by the Town Manager or a designated compliance officer prior to execution to ensure inclusion of required language and documentation. 3. Staff Training: Town personnel involved in procurement activities will receive annual training specifically covering 2 CFR 200.214 and 2 CFR 200.317–200.327, with emphasis on federal requirements for third-party contracts. 4. SAM.gov Verification: All vendors selected for federally funded projects will be screened through SAM.gov and appropriate documentation (screenshot or printout) will be placed in the procurement file. These measures will ensure that the Town of Van Buren maintains full compliance with federal procurement standards going forward. Responsible Official: Luke Dyer, Town Manager Town of Van Buren Date: June 28, 2025 Anticipated Completion Date: July 1, 2025

Views of Responsible Officials – Finding 2024-001 – Procurement, Debarment, and Suspension: The Town of Van Buren acknowledges the finding regarding the lack of documented procurement steps related to suspension and debarment verification, as well as the absence of federally required contract clauses. This occurred during a time when the Town was newly implementing federal grant administration procedures following the adoption of a procurement policy. As noted in the auditor’s report, this is a repeat finding; however, improvements have been made, and the Town is committed to further strengthening our internal controls to ensure full compliance with federal procurement standards. Corrective Action Plan – Finding 2024-001: To address this finding and mitigate the risk of noncompliance with federal procurement regulations, the Town will take the following actions: 1. Procurement File Checklists: Develop and implement a standardized procurement checklist that includes verification of debarment/suspension via SAM.gov, inclusion of all federally required contract provisions, and documentation of cost or price analysis. 2. Contract Review Procedures: All federally funded contracts will be subject to internal review by the Town Manager or a designated compliance officer prior to execution to ensure inclusion of required language and documentation. 3. Staff Training: Town personnel involved in procurement activities will receive annual training specifically covering 2 CFR 200.214 and 2 CFR 200.317–200.327, with emphasis on federal requirements for third-party contracts. 4. SAM.gov Verification: All vendors selected for federally funded projects will be screened through SAM.gov and appropriate documentation (screenshot or printout) will be placed in the procurement file. These measures will ensure that the Town of Van Buren maintains full compliance with federal procurement standards going forward. Responsible Official: Luke Dyer, Town Manager Town of Van Buren Date: June 28, 2025 Anticipated Completion Date: July 1, 2025

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: GHN has developed and is in the process of implementing a tracking system for compliance deadlines, including report submissions. Name of the contact person responsible for corrective action: Amber Henderson, Chief Organization Excellence & Strategy Officer Planned completion date for corrective action plan: December 31, 2025

This Finding is related to the failure to correctly report grant funds being expended and to the lack of a Department’s filing one quarterly report timely related to the SLFRF Funds. The Department has been contacted and is carefully reviewing guidance for all future remaining reports. Future Reports are expected to be filed correctly and timely, with future education being sought as needed.

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants,

Director of Operations & Impact will draft an 18-month reporting deliverables schedule to be reviewed quarterly. The schedule of reporting deliverables will be added to a dedicated calendar in SharePoint, shared with the President and programs team staff, and a series of reminders and notifications will be integrated into the system. The system itself will be reviewed every six months going forward to address any technological issues and make recommendations for improved functionality. Planned Implementation Date of Corrective Action: 9/22/25 Person Responsible for Corrective Action: Director of Operations & Impact

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.

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

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

Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.

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.

April 30, 2025 To: Clausell & Associates, P.C. From: Camille Vickers, Executive Director of West Central Georgia Community Action Council, Inc. Below is the Council’s corrective action plan as it relates to the findings for the fiscal year ending September 30, 2024, Single Audit Act audit. Comment #2024-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION 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 and capacity to provide adequate financial reporting. With Board review and approval of the Council’s financial funding sources, the Council will provide additional training to support the new fiscal officer. The fiscal officer 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. All enhancements will be implemented by July 31, 2025. Concerning the preparation of external reports required by various funding sources, the Council will ensure adequate training is provided 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 July 31, 2025. Responsible Person: Camille Vickers, Executive Director, will be responsible for the corrective action. Comment #2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED LIHEAP FALN 93.568 (Questioned Costs – Undetermined) Views of Responsible Officials and Planned Corrective Actions: We concur with this finding – Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Council’s financial funding sources, the Council will provide additional training to support the new fiscal officer. The fiscal officer 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. All enhancements will be implemented by July 31, 2025. Concerning the preparation of external reports required by various funding sources, the Council will ensure adequate training is provided 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 July 31, 2025. Responsible Person: Camille Vickers, Executive Director, will be responsible for the corrective action.

The Administrator and Fiscal Officer will work to ensure all reports for grant funding are completed.

FINDING 2024-005 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: 812-882-6426 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 treasurer’s office and will be reviewed by someone who is knowledgeable about the reporting requirements prior to submission. They will review reports for errors and omissions. After this additional review, the report will be submitted. Anticipated Completion Date: This corrective action plan will go into effect immediately.

FINDING 2024-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-882-6426 clane@vincennes.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Clerks office will identify non- compliant activities to ensure that funds are being used appropriately and according to federal guidelines and principals. We will consult with the relevant personnel to ensure understanding of allowable and unallowable activities and identify areas that may need additional training. We will enhance our review and approval process and provide clear documentation requirements to our departments. Anticipated Completion Date: This corrective action plan will go into effect immediately.

Finding 2024-002 Finding Subject: Economic Development Cluster – Reporting Summary of Finding: Material Weakness, Other Matters The data submitted in the SF-425 report submitted by the city for the reporting period ending on 9/30/24 contained the following errors: • Cash Receipts Understated by $1,037,155 • Cash Disbursements Understated by $1,037,155 The lack of internal controls and noncompliance was isolated to the award 06-79-06420 EDA-Davis Road Construction project. Contact Person Responsible for Corrective Action: Weston Reed Contact Phone Number and Email Address: 765-456-7380 wreed@cityofkokomo.org Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: City of Kokomo will design and implement a procedures where the Federal Financial Report and the Quarterly progress report will be reviewed by the director of development to ensure that there is oversight and that the report is complete and accurate. Anticipated Completion Date: December 31, 2025

Conservation and Rehabilitation of Natural Resources on Military Installations – Assistance Listing No. 12.005 Recommendation: CLA recommends for the Organization to place emphasis on stronger controls around the timely filing of required reports, such as retaining a monthly checklist of required reconciliations and reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previous corrective actions were completed in October 2024 following FY 2022 & 2023 Audits, including creating a calendar of required reconciliations and reports for all agreements. We also updated our procedure for review, approval, and documentation of Federal Financial Reports. We intend to add an additional and stronger control by adding performance and financial report schedules as part of our internal project software (Asana). Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 10/1/2025

Communicate with the Budget Board regarding this finding. We have already introduced to the budget board, a form guideline called "Payne County Grant Administration Plan" to aid in proper documentation, repo1ting and proper spending of all grant awards, including creating a capital outlay sub account as recommended.

Auditor's Recommendation: Strengthen policies and procedures to ensure proper documentation retention for review and approval of all Programmatic Reports prior to grantor submission. Management Response: While ODI does not disagree with the audit finding, the Agency does clarify the context of the finding. ODI has a process for monitoring activities under Federal awards: Program Managers and Directors are responsible for monitoring activities under Federal awards, with the support of the Agency’s Compliance Specialist. The Agency tracks comparisons of program accomplishments to program objectives and reports these data to grantors as required and, where necessary, communicates significant development to the Federal agency and/or pass-through entity. Corrective Action: Establish comprehensive guidelines to retain documentation of quality control and review for programmatic reports through electronic approvals via email and/or approved tracked changes or review notes within software platforms demonstrating review and approval. Responsible Personnel: Jessie Mabry, CEO; Jeremy Huynh, Compliance Specialist Implementation Date: Immediate implementation to assess tracking methods for Federal programmatic reports, and to develop written guidelines for documenting programmatic report quality control.

Contact person responsible for correction action – Linda Aziz, Chief Financial Officer Anticipated completion date – August 29, 2025 Corrective action The YWCA agrees with the finding. Grant reporting responsibilities will be clarified in policy updates. A Grant Compliance Manager position will be created to support timely, accurate reporting. Staff will receive additional training, and regular internal reviews will be conducted to ensure compliance and address discrepancies.

Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager