Corrective Action Plans

Management's Response/Planned Corrective Action: The Controller will ensure a process of dual review/approval on reporting is followed going forward to aid in identifying any reporting inconsistencies or misunderstanding of reporting instructions. This will be undertaken immediately.

Finding 2025-003 Lack of Internal Controls over Reporting Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: The District will save copies and related supporting documentation of required reports submitted to granting agencies in a file accessible to appropriate individuals to ensure information is available to more than one District employee. This will mitigate issues in obtaining compliance documents when requested. Proposed Completion Date: December 2025.

Finding 2025-002 Lack of Internal Control Over Reporting Name of Contact: Rayna Bowdre Corrective Action: The District will ensure all federal reports are properly prepared and values reflect actual values in the accounting software. Proposed Completion Date: December 31, 2025.

Strengthening Institutions Program – Department of Education Federal Financial Assistance Listing #84.031 P031A080196 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: Section 3 of the Title III Endowment Report for the year ending June 30, 2024, was completed materially incorrect for Type of Savings Account Security line items and Total Invested line item. Responsible Individuals: Michael Van Surksum, Vice President for Business and Finance Corrective Action Plan: Management will review their current process to ensure reporting requirements are met and amounts are materially correct. Anticipated Completion Date: Already complete – annual report for the year-ending June 30, 2025 has now been submitted with the correct amounts.

Pam McMahan became the party responsible for the reporting. All reporting to date has been completed.

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

VIDE is currently working towards developing formal procedures to establish controls operating at a level of precision that ensures timely and accurate reporting compliance. As part of this ongoing development, VIDE will govern these new procedures through the Integrated Fiscal Control Model within the Office of Federal Grants. To correct the discrepancies between the Annual Report and underlying data, VIDE will implement a mandatory multi-level reconciliation process. Prior to the submission of any Annual Report, Program Directors and the fiscal team must cross-reference and validate all reported programmatic and financial data against the ERP system of record and official source documents. A final sign-off will be required to certify data accuracy. Furthermore, to address the Transparency Act requirements, VIDE will institute a strict compliance workflow. The Office of Federal Grants will be required to identify, register, and report all applicable first-tier subawards of $30,000 or more into the FSRS portal within the federally mandated timeframe. To ensure FFATA submissions are consistently completed, a secondary review step will be implemented to verify the FSRS submission confirmation before any initial reimbursement drawdowns are approved for the respective subrecipient.

2024-011– EDUCATION STABILIZATION FUND - REPORTING – ALN 84.425 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 did not maintain documentation for the data that was submitted to the North Dakota Department of Public Instruction (NDDPI) for the state’s completion of the Annual Report for the Education Stabilization Fund program. We were able to obtain the information that was submitted from NDDPI; however, due to issues identified with the accuracy of underlying accounting records we were unable to determine if the information included in the report is accurate. Management’s Response: We agree. WBSD#7 created a new Grants Coordinator position in July 2023 with one of the specific responsibilities for that position being oversight of all Federal programs. This oversight responsibility includes monitoring expenditures to ensure all expenditures are allowable within the parameters of each program and also that proper documentation for those expenditures has been maintained. It has taken the district some time to get this area cleaned up. Anticipated Completion Date: FY 2025

Develop and document formal policies and procedures for grant management, including repo1iing, monitoring, and compliance. Implement these policies and ensure that each office is using them correctly.

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 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

Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the Organization develop and implement formal policies and procedures to ensure required performance reports are prepared, reviewed, and submitted in a timely manner. Such procedures should include clearly defined roles and responsibilities, tracking of reporting deadlines, and documented evidence of supervisory review and approval prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was related to a one-time ARPA grant during a period of staff transition, where performance reports were not consistently documented as reviewed and approved prior to submission. Since then, management has implemented formalized procedures for grant reporting. All performance reports are now prepared by designated program staff, tracked against reporting deadlines, and subject to supervisory review and approval by the Executive Director prior to submission. These procedures establish clear roles and responsibilities and ensure timely, documented review and submission of required reports. Name(s) of the contact person(s) responsible for corrective action: Monique Valenzuela, Executive Director and Theo Everhearts, Senior Director of Finance. Planned completion date for corrective action plan: June 2024

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

CORRECTIVE ACTION PLAN: Assign Responsibility Designate the GIS Analyst and Lead Coordinator (or Controller, if applicable) as the individuals responsible for coordinating the preparation and submission of all required progress reports. Require the Chief Financial Officer or Executive Director to review and approve each report prior to submission. Implement a Compliance Calendar Develop a centralized compliance calendar listing all reporting requirements, due dates, responsible personnel, and review deadlines. Establish automated reminders at least 30, 15, and 5 days before each due date. Create a Reporting Checklist Develop a standardized checklist to ensure that all financial and programmatic information is complete, accurate, and supported by appropriate documentation before submission. Improve Interdepartmental Coordination Conduct regular meetings among program, accounting, and compliance personnel to gather required information and monitor progress toward upcoming deadlines Management Review and Approval Require documented evidence of management review and approval before each progress report is submitted. Maintain Submission Documentation Retain copies of submitted reports, supporting schedules, and confirmation of receipt from PRDOH. Staff Training Provide training to relevant personnel on grant reporting requirements and internal procedures to ensure continued compliance

The Village will submit required reports on time.

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

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

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.