Corrective Action Plans

November 18, 2025 Donovan CPAs 9292 N. Meridian Street, Suite 150 Indianapolis, IN 46260 The PATH School already has or will take the following actions to address the FY2025 supplemental audit report comments: Required Reports 1. We will implement additional procedures and internal controls to ensure that all required student documentation is consistently collected and maintained. As part of these enhanced controls with our front office staff including receptionist and office manager, our enrollment process now includes a mandatory step requiring all students to complete the Free/Reduced Lunch Application on an annual basis. This will be implemented immediately. This measure will help ensure accurate reporting and compliance with program requirements. Sincerely, Theodore Brannum Chief Operations Officer E: tbrannum@thepathschool.org

The Corporation will take the following corrective actions: • Compliance Calendar Implementation - Develop a formal compliance calendar including all Uniform Guidance reporting deadlines. • Designated Reporting Oversight - Assign a responsible management-level individual to monitor timely submission of federal reporting requirements. • Financial Close Acceleration - Improve internal financial close timelines to meet audit deadlines. • Monitoring and Reporting - Provide periodic updates to executive management regarding compliance status. • Staffing Structure Enhancement – Continue strengthening the finance and budget department structure to improve compliance. Jesús A. Rodríguez Avilés – Financial Planning and Analysis Director Anticipated Completion date June 30, 2026

Corrective Action Plan • Policies and Procedures Reinforcement – Review and reinforce procurement policies to ensure all purchases are supported by approved requisitions and required quotations. • Documentation Retention Controls - Implement controls to ensure all procurement documentation is properly filed and retrievable. • Staff Training and Development – Provide training on procurement requirements under uniform guidance. This training will focus on compliance with policies and procedures and emphasize the importance of require documentation for each process and best practices. • Monitoring and Compliance Review - Establish periodic internal review procedures to ensure adherence to procurement policies. Name of the contact person responsible for corrective action plan Jesús A. Rodríguez Avilés – Financial Planning and Analysis Director Anticipated Completion date June 30, 2025

U.S. Department of Treasury • Material Weakness in Internal Control over Compliance Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Condition: During audit testing of financial reporting for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to locate three of ten financial reports requested for review. As a result, auditors were unable to verify the accuracy, completeness, or timeliness of the reported financial information for those reporting periods. Recommendation: The Organization should strengthen internal controls over financial reporting and record retention by establishing clear procedures to ensure that all required reports are accurately prepared, timely submitted, and retained in accordance with federal requirements. Management should designate responsible personnel and implement monitoring procedures to verify compliance with reporting and documentation standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization will require that all supporting documentation related to financial reporting—including reports, source data, approvals, and correspondence—be retained electronically within Sage Intacct using standardized attachment and naming conventions. Management will implement periodic monitoring procedures, including supervisory review and internal spot checks, to verify that reports are timely submitted and that documentation is properly retained in Sage Intacct in accordance with applicable federal record-retention requirements. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.

Finding 2024-005 - Major Program – Reporting Support and Review Corrective Action Plan: Procedures will be implemented to:  Retain detailed support for all Federal reports, including reconciliations to the general ledger  Require documented supervisory review prior to submission  Maintain documentation of adjustments occurring after report submission  Establish standardized reporting workpapers for each reporting period Responsible Party: Fiscal Officer (preparation), Executive Director (review and approval) Planned Completion Date: Effective March 11, 2026; procedures implemented for all future reports.

The Organization hired a new grant and partnership specialist. This specialist attaches all relevant support for expenditure to the internal monthly grant reporting and ensures that all expenditures are fully supported by appropriate detail. This detail is on a shared drive with finance and is reviewed by the vice president of finance.

Inadequate Record Retention and Documentation for Federal Expenditures Planned Corrective Action: Management acknowledges the documentation deficiencies identified and recognizes the importance of maintaining complete and compliant records for federal awards. Management will implement a standardized grant documentation and recordkeeping system that complies with the Uniform Guidance requirements under 2 CFR 200.334. All federal award expenditures will be supported by complete documentation, including required approvals, and retained in a centralized location for the applicable retention period. These procedures have been implemented and will be reviewed periodically to ensure ongoing compliance. Person Responsible for Corrective Action Plan: Christine Pfeifler, Consultant Anticipated Date of Completion: Year End 2025

Finding 2024-006 – Compliance; Internal Control over Compliance, Reporting (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of AgricultureFederal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Under 2 CFR 200, recipients must submit performance and financial reports as required by the terms and conditions of the award and must retain records sufficient to demonstrate compliance (see (§200.301Monitoring and reporting program performance, and §200.328 Financial reporting, §200.329 Monitoring and reporting program performance, and §200.334 Retention requirements for records). The grant agreements for awards above require timely submission of performance / progress reports by specified due dates, with documentation maintained to support the submitted information. Condition: For the fiscal year ended June 30, 2024, the auditee could not provide sufficient evidence that required reports for the programs listed were prepared, reviewed, and submitted in accordance with grant terms. Specifically:  No provided required financial reports, and Partnership for the Umpqua Rivers lacked copies or evidence of submission, and support for reported amounts requested.  Auditors were not provided with performance/progress reports and were instructed that Partnership for the Umpqua Rivers had no retained copies, review sign-offs, or submission confirmation.  Where payments were received, support for the required reports or metrics were not retained and could not be supplied to auditors for reconciling to underlying records. Cause: Management has not implemented formal reporting controls, including:  A documented reporting calendar with due dates and responsible staff,  Reconciliation of report amounts to the accounting records,  Retention procedures for report copies, underlying support, and submission confirmations, and  Supervisory review evidenced by signatures or workflow approvals. Effect or Potential Effect: Absent evidence of timely, accurate reporting and adequate record retention:  The organization is at risk of noncompliance with federal award conditions,  Inaccurate financial or performance information may be reported to the funding agency, and  The entity may be subject to remedial actions, including heightened monitoring, repayment of questioned amounts, or potential suspension of funding. Questioned Cost: None directly noted, but potential risk if reports were incomplete or inaccurate.Context: During our audit, it was found that the Partnership for the Umpqua Rivers experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. Award files provided to auditors did not contain information related to reporting of activity, expenditures, or progress of the awards. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers:  Establish a formal reporting and retention policy aligned with 2 CFR 200 and grant terms.  Implement a centralized reporting calendar that tracks due dates, preparers, reviewers, and submission methods.  Require reconciliations of financial reports to the general ledger and supporting schedules, retain the reconciliation with the reporting package.  Create standard workpapers for performance metrics for each award.  Configure the grant portal or document management system to retain submission confirmations, reports, receipts, and version -controlled copies of all reports for awards.  Document supervisory review through sign-offs prior to submission and with evidence retained.  Provide training to staff on Uniform Guidance requirements and record retention (§200.334). District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: ____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _____________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

2024-008 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: As part of the reporting requirements for the CBS Food Program under the National School Lunch Program (NSLP) and Summer Food Service Program (SFSP), management is responsible for submitting the FNS 10 (NSLP) and FNS 418 (SFSP) reports within 30 days after month-end. However, management was unable to provide five (5) monthly NSLP reports and one (1) monthly SFSP report requested for audit testing. Recommendation: The Organization should establish and enforce strengthened internal controls over federal reporting to ensure that all required monthly reports (FNS 10 and FNS 418) are: (a) completed accurately, (b) submitted on time, and (c) retained in accordance with federal record retention requirements (2 CFR 200.334). Management should designate responsible personnel and implement a monitoring process to ensure compliance. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Effective, July 1, 2024, Community Benefit Solutions no longer administers the National School Lunch Program. In the event Community Benefit Solutions should begin administering the NSLP, Community Benefit Solutions will develop and implement requisite policies and procedures to ensure proper reporting requirements including, but not limited to, completion and submission of the FNS10. Planned completion date for corrective action plan: June 30, 2025

we do not need to rehire another individual for the program. The program ended and the employee responsible for this program left. Management was unable to locate some of the files in the absence of that employee. Management has decided to have a vendor scan all our files to have electronic files moving forward. Employees will scan all files moving forward

FINDING 2024-015 Finding Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation of all payroll and stipend amounts to ensure allowability and compliance with grant agreements. All stipend and other payroll payments will be approved by the School Board. The school corporation will include supporting documentation for all accounts payable vouchers Anticipated Completion Date: The school district began the practice above on January 1, 2024, and anticipate it will be completed by June 30, 2026.

FINDING 2024-014 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation in the form of dated expenditure reports for all federal grant reimbursements and for the final expenditure reports. The Business Office will implement a system of internal control and review where after each month is reconciled and closed, the Federal Grants Administrator will review the program expenditures, ensuring they are correctly posted prior to filing the reimbursements. All reimbursements will be reviewed and signed off on by the Federal Grants Administrator and an additional reviewer prior to submission for reimbursement. In addition, the final expenditure reports will be reviewed and signed off on by Grants Administrator and an additional reviewer prior to submission. Anticipated Completion Date: The school district began the practice above on January 1, 2024, and anticipate it will be completed by June 30, 2026.

FINDING 2024-013 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation of the nonpublic schools’ rosters with supporting poverty documentation in the form of free and reduced meal applications saved on file with the Title I application annually. Anticipated Completion Date: The school district began the practice above for the 2023-24 school year. The school district has supporting documentation of free and reduced lunch status for nonpublic school students for the 2023-24 school year and moving forward. This corrective action will be fully completed by June 30, 2026.

FINDING 2024-011 Finding Subject: Title I Grants to Local Education Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain time and effort documentation for all staff paid by federal grants for each six-month period from January 1-June 30 and July 1-December 31. In addition to the ongoing time and effort documentation for all staff paid by federal grants, the district will maintain wage and benefit distribution reports that reflect staff paid from federal grant funds. The school corporation will include supporting documentation for all accounts payable vouchers. Anticipated Completion Date: The school district began the practice above on January 1, 2024 and anticipate it will be completed by June 30, 2026.

FINDING 2024-007 Finding Subject: Special Education Cluster (IDEA) - Cash Management Contact Person Responsible for Corrective Action: Susie Swango, Director of Special Education Contact Phone Number and Email Address: swangos@nlcs.k12.in.us (812) 277-3220 ext. 16243 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business office has worked with the Director of Special Education to create a system of internal control and review where after each month is reconciled and closed the Director of Special Education reviews the program expenditures ensuring they are correctly posted prior to filing for reimbursements. The Business Office will then notify the Director of Special Education when reimbursements for their funds are received and the Director can check that the deposit has been posted correctly. Proper expenditure and receipt documentation will be kept on hand for each reimbursement submitted. Anticipated Completion Date: June 30, 2026

FINDING 2024-006 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Susie Swango, Director of Special Education Contact Phone Number and Email Address: swangos@nlcs.k12.in.us (812) 277-3220 ext. 16243 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All payments and expenditures corporation wide, including those made with Federal Special Education Funds, will be properly documented. Accounts payable vouchers will be primarily entered by the Deputy Treasurer/Accounts Payable Specialist and reviewed by the Treasurer/Director of Business. Purchase requests will be submitted by the Director of Special Education thereby authorizing that the purchase is an allowable cost from the designated fund. Documentation will be provided to identify specific staff members included in payroll and fringe benefit payments from Federal Special Education funds. Anticipated Completion Date: June 30, 2026

FINDING 2024-003 Finding Subject: CHILD NUTRITION CLUSTER - ACTIVITIES ALLOWED OR UNALLOWED, ALLOWABLE COSTS / COST PRINCIPLES Contact Person Responsible for Corrective Action: BONNIE SANDERS, Director of Food Services Contact Phone Number and Email Address: Sandersb@nlcs.k12.in.us (812) 277-3220 ext. 48014 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All payments and expenditures coming out of the Food Service Fund (Fund 800) will be documented and accompanied by supporting additional documents detailing the reason and application of the funding. All payments will be accompanied by vouchers signed by 2 parties (the requestor and their supervisor), as well as an invoice and, if applicable, quote for merchandise or services. In addition, the Accounts Payable staff will also review these documents prior to signature by the Supervisor. Student meal account reimbursements will also be handled in this way, ensuring the appropriate account, Prepaid Food Account (Fund 8400), is the account these funds will be withdrawn from. Stipend requests will be in writing and approved by the Business Director and the School Board prior to being processed by payroll. This will be documented in writing along with any payment documentation. Anticipated Completion Date: Immediately (December 1, 2025)

COVID 19 ARPA Local Fiscal Recovery EXP – Assistance Listing No. 21.027 Recommendation: We recommend the Town design controls to ensure all documentation is retained in accordance with the Uniform Guidance record retention requirements under 2 CFR 200.334. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will implement a policy to ensure all documentation is retained in according with Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Julie Chapman, Director of Finance Planned completion date for corrective action plan: December 2025

Management Response: Feeding South Florida complied with LFPA contract provisions for food purchases by meeting and invoicing the required food purchase minimum. Freight was an allowable cost for the contract. Despite miscategorizing 5 freight invoices, Feeding South Florida complied with the LFPA contract for freight by meeting and invoicing the total amount allowable for freight. To ensure ongoing compliance, we established and implemented a comprehensive Standard Operating Procedure (SOP) for all contracts and grants, including the LFPA program, which has been consistently followed since LFPA Plus began. To strengthen oversight and enhance audit readiness, administrative responsibility for this contract has transitioned from the Grants Department to the Finance Department. This restructuring reinforces our compliance framework, improves operational support, and embeds stronger accountability measures across all organizational levels and throughout our region.

Condition and Context: During our audit of the Public Safety Partnership and Community Policing Grant (CFDA 16.710), we were unable to obtain a copy of the required SF-425 (Federal Financial Report) submitted by the County. Recommendation: We recommend that the County implement procedures to ensure that copies of all required federal reports are retained in accordance with federal record retention requirements and made available for audit purposes. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will establish procedures to ensure that all required federal reports are retained and readily available for future monitoring and audits.

1. Documentation Recovery — Completed (September 2025) ○ Contacted vendors to obtain duplicate invoices and receipts for all transactions with missing documentation. 2. Current Transaction Review — Completed (October 2025) ○ Conducted a comprehensive review of all pending and recent transactions. 3. Documentation Requirements Policy — Completed (September 2025) ○ Corrected identified gaps and implemented a Pending Documentation File system to track incomplete transactions. ○ Prepared expense memoranda describing goods/services, business purpose, and program benefit for any unrecoverable items. ○ Organized all recovered documentation into auditable files for review. ○ Establishes documentation standards for all expenditures. ○ Implements enhanced requirements for federal awards in compliance with 2 CFR §200.302 and § 200.303. ○ Requires submission of receipts/invoices within five (5) business days. ○ Aligns retention and compliance standards with federal and state regulations. ○ Defines clear consequences for non-compliance. 4. Strengthened Documentation Controls — Completed (October 2025) Purchases over $500 require prior written approval. ○ All receipts must be submitted within five (5) business days of the transaction. ○ Missing documentation triggers a 48-hour follow-up hold on spending authorizations. ○ Monthly certifications confirm all transactions are fully supported. 5. Enhanced Federal Award Documentation — Completed (October 2025) ○ Implemented a federal expenditure checklist requiring itemized receipts, program benefit descriptions, budget references, and authorizing signatures. ○ The Finance Director conducts monthly reviews of all federal expenditures. 6. Staff Training — Completed (October 2025) ○ Conducted mandatory training on documentation standards, federal compliance, and allowable costs under 2 CFR Part 200. ○ Training materials added to new employee orientation with annual refreshers scheduled. 7. Ongoing Monitoring — Ongoing ○ Monthly sample audits conducted by the Finance Director to verify compliance. ○ Quarterly reporting to the COO summarizing documentation metrics. ○ Annual compliance results presented to the Board Finance/Audit Committee.

Management has reinforced the effective execution of existing controls around proper documentation of all expenditures and record retention for these expenditures. Monthly and year-end procedures have been updated to ensure compliance with these procedures. Anticipated completion date: June 30, 2025.

Name of Contact Person: Grace Leatherman – Executive Director Contact Information: 410-440-9066 Corrective Action Plan: Finding 2024 – 002 Management is in agreement with the findings and will remind staff to include supporting calculations when submitting for reimbursement per Organization policies. Senior staff will review payroll data to ensure calculations are being made and reported. Expected Completion Date: The Organization expects all findings to be resolved by December 31, 2025

Management agrees with the recommendation and will implement stronger review processes to ensure proper documentation is in place to support program activities and reports submitted to the grantor. All staff charged with maintaining client documentation will receive updated training on recordkeeping requirements, supporting documents specifying such requirements, and supports throughout the year to ensure documents are properly maintained and verified. Documents will be reviewed regularly for completeness and specifically cross-checked with quarterly report and invoice information directly by program leadership prior to submission. This process will be led by the Vice President of Family Empowerment and Self Sufficiency with support from operational and compliance staff.

anagement agrees with the recommendation and will implement stronger processes to ensure that records confirming the eligibility of program participants are obtained and properly maintained. All program staff will receive updated training on eligibility requirements, supporting documents to track such requirements, and supports throughout the year to ensure eligibility requirements are met and documented. Documents will also be reviewed regularly to ensure completeness against eligibility requirements. This process will be led by the Vice President of Family Empowerment and Self Sufficiency with support from operational and compliance staff.