Corrective Action Plans

Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: RAED will develop a set of procedures the will allow them to be in compliance for subrecipient monitoring. Official Responsible for Ensuring CAP: Savannah Walsh, Executive Director, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: June 30, 2026 Plan to Monitor Completion of CAP: The Board of Education will be monitoring this corrective action plan. Savannah Walsh Executive Director

2025-003 Lack of Formal Subrecipient Monitoring Criteria: According to 2 CFR §200.332 (Requirements for Pass-Through Entities), a pass-through entity must monitor the activities of subrecipients as necessary to ensure that federal funds are used for authorized purposes and in compliance with applicable statutes, regulations, and terms and conditions of the Federal award. Required monitoring includes, but is not limited to, the following: a. Reviewing financial and programmatic reports; b. Performing risk assessments of subrecipients; c. Following up on deficiencies identified through audits or reviews; and d. Ensuring subrecipients have required audits under 2 CFR §200.501. Lack of documented subrecipient monitoring constitutes noncompliance with Uniform Guidance. Client Response: While the organization was in constant contact with subrecipients regarding the progress of their programming, those meetings were not transcribed. In the future, the organization will require mid year and year-end impact reports from each grant subrecipient. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444

Views of Responsible Officials: In practice, BRAC USA has consistently evaluated subrecipient risk prior to issuing subawards by considering factors such as prior experience with similar awards, historical audit results, organizational capacity, and financial stability. However, we acknowledge that these assessments were not formalized or consistently documented in a standardized format, as required by 2 CFR § 200.332(c). To address this gap, BRAC USA will develop and implement written procedures and a standardized subrecipient risk assessment tool to be completed and filed prior to issuing Federal subawards. The tool will capture required criteria, including prior audit results, prior performance under similar awards, financial stability indicators, internal control considerations, and any recent staffing or systems changes. These procedures will be incorporated into BRAC USA’s Fiscal Policies and Procedures Manual. The results of each risk assessment will be used to tailor the level and nature of ongoing subrecipient monitoring, and records will be maintained in the grant file to evidence compliance with 2 CFR § 200.332(c). Planned Completion Date: April 30, 2026

The following actions will be taken to ensure compliance with the Uniform Guidance requirements over internal controls: Management concurs with the finding. Effective immediately, The Greater Washington Community Foundation has implemented the following corrective actions: (1) Prior to entering into any subaward agreement involving federal funds as well as at the time of each payment, designated staff will verify that potential subrecipients are not suspended or debarred by conducting searches in the System for Award Management (SAM) at www.sam.gov, with documentation maintained in the grant file. This verification will also be performed when subaward agreements are amended or extended. (2) The standard subaward agreement template will be updated to include all required information specified in 2 CFR §200.332(b)(1), including the federal assistance listing number, subrecipient's unique entity identifier, federal award project description, amount of federal funds obligated, total federal award amount, applicable compliance requirements, and reporting and monitoring requirements. To strengthen ongoing compliance, the Foundation's procurement and cash management policies have been updated to incorporate these federal compliance requirements and will be reviewed annually. Given that federal funding is not received on a recurring basis, upon receipt of future federal funding, the Controller will serve as the Compliance Coordinator with full oversight of compliance activities. The Controller will review applicable federal regulations, update internal procedures as necessary, and provide comprehensive training to appropriate staff managing the contract to ensure adherence to all grant requirements. The finance team will complete a quarterly review process to verify that all active federal subawards contain required compliance elements, with the Controller maintaining oversight of this review and reporting any deficiencies to the Chief Financial Officer for immediate remediation. Individual Responsible for Corrective Action Plan: Contact: Rachel Crawford Title: Controller Phone Number: 202-303-2437 Estimated Completion Date: December 31, 2025

Finding Number: 2025-001 Condition: The Authority did not provide sufficient evidence that there was adequate monitoring of subrecipients. Planned Corrective Action: SMART has implemented a subrecipient review schedule and created a monitoring checklist. All entities receiving any passthrough funding from SMART are included on the schedule. This will ensure no missed subrecipients, including Monroe agencies. The new checklist will ensure all required monitoring activities are considered during the review and will document all monitoring performed. SMART believes this new schedule and checklist will satisfy all federal monitoring requirements. Contact person responsible for corrective action: Ryan Byrne, CFO; Allyssa Gartrelle, Manager of Community Mobility Programs Anticipated Completion Date: 6/30/2026

Item: 2025-002 Assistance Listing Number: 93.332 Program: Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges Federal Agency: U.S. Department of Health and Human Services Pass-Through Agencies: N/A Pass-Through Grantor Identifying Number: N/A Award Year: August 27, 2021 through August 26, 2024; August 27, 2024 through August 26, 2029 Compliance Requirement: Subrecipient Monitoring Criteria: In accordance with 2 CFR 200.332 (e), (g) and (h) - pass-through entities must monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Condition: While AACHC performed several of the required subrecipient monitoring tasks, AACHC’s system of internal controls did not include a process to monitor the subrecipients’ financial and performance reports by verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Name of Contact Person: Brenda Hanserd, CFO Phone Number: 602-288-7559 Anticipated Completion Date: March 31, 2026 Views of Responsible Officials and Corrective Action Plan: AACHC will update their subrecipient monitoring policies and procedures to specifically include a process to monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. AACHC will also regularly attend trainings on the Uniform Guidance to ensure they are knowledge of the required compliance procedures.

Item: 2025-001 Assistance Listing Number: 21.027 Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agencies: Maricopa County Pass-Through Grantor Identifying Number: None Award Year: November 1, 2021 through September 30, 2026 Compliance Requirement: Subrecipient Monitoring Criteria: In accordance with 2 CFR 200.332 (e), (g) and (h) - pass-through entities must monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Condition: While AACHC performed several of the required subrecipient monitoring tasks, AACHC’s system of internal controls did not include a process to monitor the subrecipients’ financial and performance reports by verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Name of Contact Person: Brenda Hanserd, CFO Phone Number: 602-288-7559 Anticipated Completion Date: March 31, 2026 Views of Responsible Officials and Corrective Action Plan: AACHC will update their subrecipient monitoring policies and procedures to specifically include a process to monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. AACHC will also regularly attend trainings on the Uniform Guidance to ensure they are knowledge of the required compliance procedures.

Audit Finding Number 2024-006 Audit Finding Title Subrecipient Monitoring Planned Corrective Action Effective September 2026, procedures were put in place for each subgrantee to complete an attestation and submit their internal or audited financials before we contract with them. Any findings or issues are documented along with the resulting resolution. BWHI has always maintained close contact with our subgrantees and monitored their performances with frequent meetings. This process will now be formally documented. Name(s) and title(s) of contact person(s) responsible for corrective action Kim Cockerham, Sr. Director of Finance and Accounting Zsanai Epps, Interim EVP Programs and Advocacy

Finding 2024-001: Subrecipient Monitoring Federal Agency: U.S. Department of Housing and Urban Development Program Name: COVID 19 — HOME Investment Partnerships Program and HOME Investment Partnerships Program (HOME) - ALN 14.239; Award Identification Number: MC420501 Criteria of Specific Requirement: Per 2 CFR 200.332, a pass-through entity must monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Condition: During our testing of subrecipient monitoring, we noted that the City did not perform required monitoring procedures during the year. Questioned Costs: Unknown Cause: The City did not have adequate internal controls in place to ensure compliance with subrecipient monitoring requirements, and staffing turnover contributed to the lack of oversight. Effect: The City was not in compliance with subrecipient monitoring requirements. Identification as a Repeat Finding: This is not a repeat finding from the prior audit. Recommendation: We recommend the City implement controls to ensure compliance with subrecipient monitoring, documenting monitoring activities performed and following up on any identified deficiencies in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management agrees; see corrective action plan below. History The City initiated monitoring of the HOME program in March 2023, and the local office of the Department of Housing and Urban Development (HUD) initiated its own monitoring in June 2023. To avoid duplicative work, the City shifted its approach and reviewed closed programs while HUD monitored open programs. These monitoring efforts resulted in significant updates to program policies and procedures. The City's monitoring was completed in October 2023 and HUD's monitoring was finalized in October 2024. Corrective Action Plan Since October 2024, the City has collaborated with its subrecipient, the Urban Redevelopment Authority (URA), to implement a streamlined, informal quarterly review process. While formal HOME monitoring has not occurred since the end of the HUD monitoring, the City will initiate a review before the end of 2025 to return to compliance. Monitoring will occur annually moving forward.

Finding: 2024-003 Material Weakness in Internal Control over Compliance and Material Noncompliance U.S. Department of Treasury Federal Financial Assistance Listing 21.027 Subrecipient Monitoring Finding Summary: During our testing, we evaluated the procedures for evaluating subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward. We noted the following:  For three (3) of three (3) subrecipients selected, the required evaluation of the subrecipient’s risk of noncompliance was not documented.  For one (1) of three (3) subrecipients selected, the County did not provide a formal subrecipient agreement including the required information noted in 2 CFR 200.332. Responsible Individuals: Dana Aschenbrenner, Finance Director Corrective Action Plan: The understanding of current staff is that the risk assessments were completed as appropriate, however, due to staff turnover the documents have been misplaced and no longer seem to be available. Applicable County teams are working to adopt standards for what documentation is necessary to establish the basis for a transaction, as well as standardizing the repository for such documentation. Anticipated Completion Date: Ongoing

Management agrees with the finding. Management has downloaded 2 CFR Part 200 for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

FINDING 2024-002 – Subrecipient Monitoring (Partially Repeated from Prior Year Findings 23-002, 22-002, 21-003, 20-004, 19-005, 18-004, and 17-003) CONDITION: The Regional Office of Education #47 did not perform subrecipient monitoring procedures including the preparation and retention of audit documentation. During audit testing procedures it was determined that: For one (1) of two (2) subrecipients tested, ROE #47: • Did not identify the subaward and applicable requirements in the agreements. • Did not conduct subrecipient monitoring procedures during the year ended June 30, 2024. For two (2) of two (2) subrecipients tested, ROE #47: • Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. • Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. PLAN: Moving forward, The Regional Office will formally identify the subaward and applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit. ANTICIPATED DATE OF COMPLETION: Fiscal Year 2025 CONTACT PERSON: Mr. Chris Tennyson, Regional Superintendent for Lee, Ogle, and Whiteside Counties.

In 2025, POP Biotechnologies, Inc is implementing subrecipient monitoring process. POP Biotechnologies, Inc will create and maintain dedicated folders for subrecipients receiving greater than $75,000 in funding.

Condition 1. On July 31, the newly developed pre-award risk assessment tool was rolled out to all subrecipients and ministries with oversight, effective FY2027. Conditions 2-3: On July 29, July 31 and August 5, 2026, training was conducted on Majuro and Ebeye to introduce new and enhanced tools to strengthen subrecipient monitoring. It covered the following topics: 1. Audit findings related to subrecipient arrangements. 2. Grants Management Manual with emphasis on its scope and the Management Decision Letter (MDL). 3. Unique Entity Identifier (UEI), which is mandatory. 4. Memorandum of Agreement and the significance of each section. 5. MOA circulation process. 6. Procurement Code 2023 7. Reporting and Required Supporting Documents: - Pre-award Risk Assessment - Site Visit Checklist - Enhanced SubGrant Forms and Review Checklist (SG1/Subgrant Objectives and Budget Proposal and SG2/Performance and Financial Evaluation) - SG Forms supporting documentation (salaries & wages, fuel purchase, food purchase, vehicle rental, housing allowance, travel, etc.) 8. Conflict of Interest In September 2026, officers from the Compliance and SOE Monitoring Unit will start going out to conduct the pre-award risk assessment. Results of the assessment will determine whether the entity can sign an MOA with the MOF or not as well as the entity's risk rating, which will determine the frequency of site visits to be conducted by Compliance beginning FY2027. Condition 4 Effective 3rd quarter of FY2025, all transactions charged to the Enewetak grant go through the national procurement and payment process.

1. Person Responsible: County Auditor-Controller 2. Corrective Action Plan: The County agrees with the finding and recommendation. The County has drafted policy and procedures for subrecipients. In addition, the County has drafted a subrecipient agreement template to identify subrecipients based on criteria in § 200.332. The County will provide a comprehensive training to program managers to implement the monitoring program and subrecipient agreement template. In addition, the County will include direction to project managers to review current awards to identify existing subrecipients that were not provided a subrecipient agreement with all of the required elements from CFR § 200.332. 3. Anticipated Implementation date: June 30, 2027

Finding Number 2024-014 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) partially concurs with these findings. • OMES disagrees that they had sufficient and timely notice to make full corrective actions prior to this FY2024 audit for the following reasons: the FY2021 State auditor & Inspector (SAI) audit was released four days prior to the beginning of FY2024, the FY2022 SAI audit was released near the end of FY2025, and the FY2023 audit was released in FY2026; therefore, OMES could not take corrective action prior to the FY2024 audit began. At the beginning of FY2025, OMES began corrective measures as noted in SAI’s Condition and Context in this finding. • OMES acknowledges OMES subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI as noted in SAI’s Condition and Context in this finding. Beginning with FY2025, OMES has taken the following measures:  Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience.  OMES ensured that the subrecipient agreement included all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) executed an updated Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies.  OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed.  OMES-GMO has in place a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements.  Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMESGMO conducted bi-weekly monitoring meetings with CFO and reviewed documentation provided by CFO to ensure all ERA projects were eligible under the ERA guidelines and that CFO exercised the proper oversight over their subrecipients and spending. Anticipated Completion Date Completed Responsible Contact Person Brandy Manek

Finding Number 2024-093 Subject Heading (Financial) or AL no. and program name (Federal) 97.036 – Disaster Grants – Public Assistance Planned Corrective Action Management acknowledges risk assessments were not performed in SFY24. Going forward, OEM will conduct risk assessments that are an annual review for all open projects and a monthly review for any new applicants. They will involve feedback from both the subrecipient and OEM’s data and is completed in EMGrants. Anyone has the ability to see the applicant risk rating on the applicant homepage in the system. While there was a grant wide extension for period of performance, management acknowledges the applicants identified by SAI did not request time extensions for their specific project and therefore, did not meet period of performance requirements. OEM will implement procedures to ensure applicants meet period of performance deadlines and have proper time extensions documented when required. Anticipated Completion Date 6/30/2025 9/27/2026 Responsible Contact Person Abby Anderson Sofia Checketts

Finding Number 2024-025 Subject Heading (Financial) or AL no. and program name (Federal) 93.658 – Foster Care Planned Corrective Action Oklahoma Human Services (OKDHS) concurs with the recommendation. OKDHS has been working to centralize and strengthen its contract and subrecipient monitoring processes to improve consistency in the identification, documentation, risk assessment, and monitoring of subrecipient relationships across the agency. As part of this effort, OKDHS is updating its procedures and standardized documentation to better ensure that subawards include required federal award information, program responsibilities and deliverables are sufficiently defined, required documentation is obtained and retained, and subrecipient risk assessments and monitoring activities are completed and documented consistently. OKDHS will implement updated, centralized contract and subrecipient monitoring procedures, including standardized tools and documentation requirements designed to address the conditions identified in the finding. The updated process will clarify responsibilities for documenting subrecipient risk assessments, required federal award information, contractual requirements, deliverables, and ongoing monitoring activities. Anticipated Completion Date 9/30/2026 Responsible Contact Person Kayla Urtz

Finding Number 2024-016 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; #84.425U) Planned Corrective Action The agency acknowledges that certain ESSER II and ARP ESSER III claims were approved without adequate review of supporting documentation by authorized claims reviewers. To address this finding, the agency has strengthened its claims review procedures and internal controls related to reimbursement processing. Additional training will be provided for all claims reviewers regarding: • allowable use of funds requirements, • supporting documentation standards, • verification of invoice documentation, • program coding requirements, and • review and approval expectations for federal claims. The agency will also implement enhanced supervisory review and monitoring procedures to help ensure claims are consistently reviewed in accordance with federal requirements prior to approval. The agency acknowledges that allocation notices were not consistently generated and provided to certain LEAs in accordance with the requirements of 2 CFR § 200.332(a)(1). Additionally, one allocation notice did not contain all required elements, including the Federal Award Identification Number (FAIN) and Federal award date. Although the audit confirmed that allocation amounts and approved budgets within the grants management system were accurate, the agency recognizes the need to strengthen procedures related to issuance and documentation of subrecipient award notifications. To address this finding, the agency will revise and strengthen internal procedures to ensure all required allocation notices are generated, maintained, and distributed timely and consistently to subrecipients. The agency will also coordinate with our third party vendor to implement additional quality control measures and staff training to ensure all required federal award information, including the FAIN and Federal award date, is included in future allocation notices in accordance with 2 CFR § 200.332 requirements. Anticipated Completion Date Sept-26 Responsible Contact Person Tammy Smith

Finding Number 2024-001 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.010 TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425U) Planned Corrective Action OSDE agrees with the recommendation and will strengthen its subrecipient risk assessment and monitoring processes to ensure LEAs are consistently and accurately evaluated. Specifically, OSDE will: • Revise and formalize written policies and procedures governing the Risk Assessment Ranking Tool, including detailed guidance for assigning and documenting risk scores. • Implement a standardized review process requiring supervisory review and approval of all annual risk assessments prior to finalizing LEA risk classifications. • Develop a risk assessment checklist to ensure all required risk factors are evaluated consistently and supporting documentation is maintained. • Provide annual training to staff responsible for completing and reviewing risk assessments to ensure consistent application of scoring criteria. • Perform periodic quality assurance reviews of completed risk assessments to verify scoring accuracy, identify trends or errors, and implement corrective measures when needed. Anticipated Completion Date Aug -26 Responsible Contact Person Tammy Smith

Finding Number 2024-018 Subject Heading (Financial) or AL no. and program name (Federal) 20.509 – Formula Grants for Rural Areas Planned Corrective Action Contract Template and Review Process Improvements: OMPT has updated and corrected the standard contract templates to ensure all required federal award information is accurate and consistently included. In addition, the contract agreement review process has been strengthened and formalized into a two-step review. Agreements are now reviewed by a supervisor and/or manager prior to submission to the division head for final signature. This enhanced review structure is designed to ensure the completeness and accuracy of grant information and to reduce the risk of errors in subrecipient agreements. For active subrecipient agreements identified as containing incorrect federal award information, OMPT will issue formal written notifications (via letter or email) to provide corrected grant details and ensure subrecipients have accurate information for compliance purposes. Subrecipient Monitoring and Single Audit Procedures: OMPT will continue implementation of enhanced subrecipient risk assessment procedures as part of its monitoring process. This includes formal documentation of risk assessments, as well as required inquiries with subrecipients to determine the appropriate audit type based on expected federal expenditures. Procedures related to Single Audit tracking and followup are being strengthened. The Single Audit Tracking Sheet will be updated monthly and reviewed for completeness and timeliness. Anticipated Completion Date 12/31/2026 Responsible Contact Person Eric Rose / Bobby Parkinson (OMPT)

Finding Number 2024-013 (Repeat 2023-009) Corrective Action Plan Subrecipient Monitoring — AL 15.875 (U.S. Department of the Interior) • Establish and formally document the subrecipient monitoring framework, policies and procedures, aligned to the pass-through entity requirements of the Uniform Guidance and to the classification agreed with DOI, for implementation from the effective date agreed with DOI/OIA. • Update the annual subrecipient agreement transmitted to the FSM State Governments and signed by the President and the Governors as allottees, facilitated by the Office of Compact Management, to expressly incorporate the clauses required by the 2023 Amended Compact, the identification of the subaward, and acknowledgement of the requirements imposed on the sub-grantees. • Perform and document, prior to approval of each subaward, verification of the sub-grantee’s awareness of the requirements imposed upon it and its ability to meet the financial management standards of the Fiscal Procedures Agreement. • Perform and document an annual risk assessment of each subrecipient, together with the resulting monitoring activities, including review of the subrecipients’ audit reports and follow-up on findings affecting the program. • Maintain records of the date of receipt and date of disbursement of funds to the FSM State Governments, evidencing that disbursements are made within the month of receipt through the required wire-out approval process. • Pursue resolution of the questioned costs of $94,422,154 through the audit resolution process with DOI/OIA. Management’s position is that the conditions are internal control deficiencies arising from the absence of formally documented policies and procedures and that questioned costs of $0 are warranted under the definition in 2 CFR § 200.1, including paragraph (3)(i), as all samples were provided, vouched and cleared, and the amounts represent Compact sector grant allocations approved through JEMCO. Anticipated Completion Date 9/30/2027 Responsible Person (Contact Details) Ms. Melynda Irons Acting Assistant Secretary, Treasury Email: melynda.irons@dofa.gov.fm Mr. Peni Tikoisireli Financial Advisor Email: peni.tikoisireli@dofa.gov.fm Ms. Julyn Lawrence Email: julyn.lawrence@gov.fm Ms. Senny Phillip Assistant Secretary, Investment Email: senny.phillip@gov.fm

Views of Responsible Officials: Management acknowledges the condition noted regarding the pre-award risk assessment. ICFJ is committed to ensuring that all subrecipient monitoring procedures are followed consistently and documented completely. Going forward, a pre-award risk assessment will be completed and approved for all subrecipients prior to execution of any subaward agreement. ICFJ will also ensure that all subrecipient reporting includes the name and date of the submitter and reviewer, and that applicable RCA audits are obtained and reviewed annually with documentation of that review maintained on file.  Anticipated completion date: 9/30/26  Responsible position: Chief Financial Officer

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: This was the first and only grant Housing Hope has administered that required subrecipient monitoring. The grant has since ended and the organization does not anticipate entering any future agreements that would require subrecipient monitoring. To ensure compliance should such an agreement arise again, Housing Hope adopted a Subrecipient Monitoring Policy. This policy outlines the criteria for identifying subrecipient relationships and establish a standardized process for monitoring subrecipients, if any are engaged in the future. Anticipated completion date: The Subrecipient Monitoring Policy was adopted October 2025 by the Board.

2024-003 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA011008 and 2019 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness Management’s or Department’s Response: Imperial County Workforce Development Office (ICWDO) agrees with the finding. Views of Responsible Officials and Corrective Action Plan: The questions from finding 2021-008 relate to a formalization of the fiscal processes and protocols. ICWDO operates under WIOA guidelines and follows Imperial County’s fiscal policies. Internal policy will be formally updated to reflect compliance with WIOA regulations, as well as Imperial County policies. These policies will include formal controls and procedures to evaluate each subrecipient’s risk of noncompliance. Once the formal procedure is drafted, it will go through the ICWDO Policy Committee for comment and direction, and then finally reviewed and approved for implementation by the full Workforce Development Board. Additionally, for any future Memorandums of Understanding (MOUs) between this Imperial County department and any outside agency, there will be an additional step to include review by Imperial County Counsel to reflect that recital around the funding source will specify the following required information: • Federal Award Identification Number • Federal award date of award to recipient by the Federal agency • Name of Federal awarding agency • CFDA Number • Specific identification of whether the award is research and development ICWDO will develop internal policies for formalizing all subrecipient monitoring process. ICWDO operates under WIOA guidelines for monitoring; therefore a formal internal policy for future contracts will be developed and implemented using the usual review and approval procedures followed by the department. ICWDO will develop a formal internal documentation system, with appropriate checks and signatures, for the evaluation and assessment of each subrecipient’s risk of noncompliance. ICWDO will utilize this formal process to properly document the risk assessment of all subrecipients. ICWDO anticipates to implement the corrective action by December 31, 2025. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2025