Corrective Action Plans

Findings and Questioned Costs Relating to Federal Awards: Eligibility of Individuals, Allowable Costs DDEC is implementing a series of corrective actions to ensure full compliance with WIOA eligibility documentation requirements, internal controls, and participant file management. The primary corrective strategy is the establishment of the PRIS system as the official digital participant file, combined with strengthened internal controls, mandatory documentation requirements, system validations, staff training, and ongoing monitoring. These corrective actions are designed to ensure that: • Eligibility documentation is completed and verified before services are provided. • Costs are only charged to WIOA programs for eligible participants. • Internal controls comply with 2 CFR 200 requirements. • Monitoring and validation processes ensure long-term compliance and sustainability. 1.Official Digital Participant File (PRIS) DDEC will designate the PRIS system as the official participant file repository for all WIOA programs. Services may not be recorded, and costs may not be charged unless the participant’s digital file contains complete eligibility documentation and a signed eligibility certification. Key Actions: • Issue formal directive establishing PRIS as the official file system. • Update operational manuals and program guidance. • Notify all subrecipients of implementation requirements. 2. Required Eligibility Documentation Controls DDEC will require that all eligibility documentation be uploaded to PRIS before participant activation or service entry. Required documentation includes proof of age, work authorization or citizenship, Selective Service registration (if applicable), proof of residence (if applicable), and signed eligibility certification. Key Actions: • Establish mandatory documentation checklist by participant type. • Require digital upload of all eligibility documentation. • Establish document quality and digital format standards. 3. PRIS System Controls and Validations DDEC will implement system controls within PRIS to prevent the entry of services or costs for participants with incomplete eligibility documentation. Key Actions: • Configure required fields for eligibility documentation. • Develop exception reports for incomplete participant files. • Pilot system controls with one subrecipient prior to full implementation. 4. Internal Controls and Monitoring DDEC will strengthen internal controls to ensure that eligibility documentation is verified prior to service delivery and cost charging. Key Actions: • Monthly PRIS exception reports identifying incomplete files. • Required correction within established timeframe. • Suspension of services or payments for non-compliant files. • Integration of digital file review into monitoring visits. • Standardized eligibility checklist for all subrecipients. 5. Training and Technical Assistance DDEC will provide training to subrecipients and internal staff on WIOA eligibility requirements, documentation standards, PRIS usage, and federal compliance requirements under Uniform Guidance (2 CFR 200). Training Topics: • WIOA eligibility requirements • Acceptable documentation • PRIS document upload procedures • Allowable costs and federal compliance • Internal control responsibilities 6. Ongoing Monitoring and Compliance Validation DDEC will implement quarterly compliance validation through sampling of participant files in PRIS to ensure documentation completeness and sustained compliance. Monitoring Measures: • Quarterly file sampling by subrecipient • Documentation completeness verification • Corrective action plans for subrecipients with deficiencies • Escalation procedures for repeated non-compliance • Annual compliance review after full implementation

PDA: PDA is creating mechanisms to fulfill the requirements for pass-through entities within 4 to 6 months after FAC acceptance date of the audit, which include: 1. Evaluation of single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. 2. Issuance of management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR §200.521. 3. To impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. PDA has developed a SEFA reconciliation process that will ensure that the SEFA is accurate, allowing for major programs to be properly identified and subjected to audit. PDA is developing a procedure for all programs to follow for any entity that is in non-compliance with the audit requirements and is failing to comply with the provisions of Subpart F. Anticipated Completion Date: 06/30/2026 Contact Name: Nichole Nedinsky, Fiscal Management Specialist, PDA Audit Coordinator PDOA: 1. Strengthen written policies and procedures governing subrecipient monitoring and audit resolution. 2. Update the audit tracker to proactively ensure the six-month management decision due date is met. 3. Implement segregation of duties between reconciliation review and management decision issuance. 4. PDOA will develop and utilize a standardized SEFA Review Checklist. 5. Conduct annual Uniform Guidance training for fiscal staff. Anticipated Completion Date: 06/30/2026 Contact Names: Jason Kavulich, Secretary of Aging; Jennifer Beck, Fiscal Management Specialist & PDOA Audit Liaison PDE: Implemented 2/17/26: Audit Coordinator verifies finding status of all single audit packages uploaded to the PDE single audit SharePoint site. Implemented 7/1/25: PDE audit section has begun to enforce timely audit submission by using remedial action within its authority as granted by federal guidelines. Implemented 7/1/25: PDE has expanded the resources available through the use of the compliance office for audit finding review and resolution in an effort to resolve all audit findings timely. Anticipated Completion Date: Completed Contact Name: Clayton P. Carroll, II, Audit Coordinator PENNVEST: PENNVEST will maintain a comprehensive tracking list that contains all equivalency projects that have disbursed any funds during the audit period. All those projects will be reviewed and reconciled to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward, including the timely submission of the single audit to the FAC. Once received, PENNVEST will reconcile the SEFA to ensure the information is accurate. PENNVEST will complete the reconciliation within six months of the FAC’s acceptance of the audit report and respond to the subrecipient with any adverse findings. Anticipated Completion Date: Completed Contact Names: Steven Anspach, Dep. Exec. Dir.; Heather Brookmyer, Loan Service Officer; Robert Boos, Exec. Dir.

FINDING 2025-003 Finding Subject: Teacher and School Leader Incentive Grants – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Teacher and School Leader Incentive Grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

2025-002: Student Financial Audit Cluster - Special Tests: Return of T itle IV Funds and NSLDS Reporting Anticipated completion date: done - June 18, 2025 Contact person: Brandi Payne Cervera Corrective actions: The two late aid returns were made under the following circumstances. Student's effective date of the withdrawal was March 25, 2025. However, the withdrawal was not processed in our Colleague system until April 9, 2025. The backdated effective date of the withdrawal in Colleague did not appear on our enrollment activity report that is used to identify complete withdrawals because this report is run weekly using a defined date range. As a result, the student's withdrawal was not identified in a timely manner. The withdrawal was identified by our Assistant Director upon her review of students with all non-passing grades at the end of the semester prior to the audit testing (see existing procedure/internal control below). The return-of-funds was processed as soon as the withdrawal was discovered, but it was out of the 45-day required timeframe. We have implemented a new procedure, as follows. New procedure (backdated withdrawal): The Registrar's Office will immediately notify Financial Aid of any withdrawals received by the Registrar's Office that require a backdated effective date in Colleague to ensure that we are returning funds within the required timeframe. The Financial Aid Director, Assistant Director of Financial Aid, and the Registrar met and developed this new procedure. The procedure was implemented on June 18, 2025. An institution must certify enrollment information to the National Student Loan Data System (NSLDS) every 60 days. Because of the issue with the backdated effective date of the withdrawal described above, the enrollment reporting for this student was made outside of the 60-day reporting window. I request the removal of the NSLDS reporting deficiency since the late processing of the student's withdrawal and return-of-funds was the root cause of the late NSLDS reporting, and there were no other enrollment reporting issues. The second late return was due to human error. After a R2T4 calculation has been performed, there is an "Update Student Aid" button on the ROFC screen in Colleague that must be manually marked "yes" in order for the return of- funds to post to the student's account. This step was missed for one student which caused the late return-of-funds outside of the required 45-day timeframe. New procedure (human error): Assistant Director has put a standing item on her calendar to review RT24's every Wednesday with a notation to check the "Update Student Aid" box in Colleague so that the return will occur. The Assistant Director will also check the list of withdrawals after each weekly aid transmittal to make sure the aid returns have all posted to the student accounts as expected. This procedure was put into place on June 18, 2025. Existing Procedure/Internal Control: We can say with certainty that out of the 165 withdrawals for the 2024/2025 award year, the two students identified in the audit were the only two late returns. The Assistant Director of Financial Aid reviews all students with non-passing grades at the end of each semester to identify unofficial withdrawals and to ensure that all returns were made appropriately and that no R2T4 calculations were missed. Potential issues are identified through this end-of-semester review. This is how the issue with the backdated withdrawal date described above was discovered. She will continue this effective internal control process each semester which will confirm that our new procedures are working as intended.

2025-001 Student Financial Aid Cluster- Reporting Anticipated completion date: Done Contact person: Nola Rocha Corrective actions: The incorrect inclusion of non-credit course data for new programs in the annual FISAP report resulted from a misinterpretation of reporting criteria. This isolated error affected one reporting element within an otherwise accurate submission. The issue was promptly addressed through clarification of FISAP guidance, staff retraining, and updates to procedural documentation and review checklists to ensure non-credit course activity is properly excluded in future reports. While the dollar amount could be viewed as measurable the financial reporting would not result in any financial impact, as the Department of Education allocates Campus-Based Program funds based on institutional requests and does not provide allocations in excess of those requests.

2025-003: Student Financial Audit Cluster - Special Tests and Provisions: Disbursements to, or on Behalf of, Students (Significant Deficiency) Corrective Action: The College updated its award notification process, which took effect for the Spring 2025 term. All current and future award notifications now comply with 34 CFR 668.165(a)(1). Including the required information regarding when Title IV funds will be disbursed. Referencing the academic calendar, which clearly identifies the official disbursement dates for the term. To prevent recurrence of this finding, the College has implemented the following permanent measures: • Revised Award Notification Templates: All digital and physical award notification templates have been permanently updated to include dedicated fields for the disbursement date or a direct, clear reference to where the student can find the disbursement schedule. • Enhanced Pre-Release Compliance Review: A mandatory two-step review process has been added to the award notification workflow. This step verifies that all notifications meet the “amount, how, and when” Title IV disclosure requirements before they are sent to students. • Mandatory Staff Training: All Financial Aid staff have received and will receive annual training refreshers on the current federal notification requirements, specifically emphasizing the timing of disbursement disclosure, and the use of the updated, compliant templates. • Ongoing Monitoring and Internal Audits: The College will implement a quarterly internal review process where a sample of student award notifications will be checked for accuracy and full compliance with 34 CFR 668.165(a)(1) to ensure sustained adherence. Anticipated Completion Date: 6/30/2026 Contact Person: Joyce Lubeck-Sonenberg

2025-002: Student Financial Audit Cluster - Reporting (Significant Deficiency) Corrective Action: The College has taken the following actions to implement the required additional control and ensure accurate tuition and fees reporting in the FISAP. • Systemic Data Isolation Control: The College has collaborated with its Institutional Research and Business Office staff to develop and implement a new report or query within the Student Information System (SIS). – This new control will automatically isolate and extract tuition and fees revenue only for students who meet the Section D criteria (regular students enrolled in credit-bearing classes). – This ensures that non-eligible tuition (e.g., non-credit, high school) is systematically excluded from the FISAP input data. • Segregation of Duties and Dual Review: The process for FISAP preparation has been revised to include a required dual-review step: – The Financial Aid Office will prepare the draft FISAP data using the new controlled data isolation report. – The Controller will perform a mandatory secondary verification of the total tuition and fee revenue reported in Part II, Section E, against the specific data extracted by the new systemic report. • Training and Procedure Documentation: Financial Aid and Business Office staff involved in the reporting process have been trained on the updated FISAP instructions and the mandatory use of the new systemic control to calculate Section E tuition and fees. The new control procedure has been documented in the College’s official FISAP preparation manual. Each different entity has the detailed instructions from the FISAP information. Anticipated Completion Date: 9/30/2025 Contact Person: Joyce Lubeck-Sonenberg

2025-004: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Casper College will implement a multifaceted plan to ensure compliance with enrollment reporting requirements under 34 CFR 690.83, 34 CFR 685.309, and NSLDS guidelines. Key corrective steps include: • Policy Revision: Formally updating institutional policies (Sections 10 and 3.11) to clarify and align the reporting roles of the Registrar and Financial Aid, mandating specific timelines for all status changes, including withdrawals. • Strengthened Internal Controls: Establishing a mandatory dual-verification process for withdrawal effective dates and R2T4 alignment and implementing weekly NSLDS monitoring by Financial Aid and monthly Registrar–Financial Aid reconciliation meetings. • Documentation and Training: Improving documentation standards, including a centralized digital archive, and providing mandatory joint cross-office training on NSLDS rules, SSCR error resolution, and accurate, effective date determination. Anticipated Completion Date: 4/30/2026 Contact Person: Joyce Lubeck-Sonenberg

Western Wyoming Community College experienced an unexpected turnover in the Director position and had a consultant from Dynamic Campus and an Interim Director of Financial Aid step in to help assist staff during this time. Due to lack of communication, reporting of a return of Title IV funds for the one student found in the audit did not occur as it normally would. Corrective Action A new Director of Financial Aid has been hired and has worked with the Assistant Director of Financial Aid to train on the process of Return to Title IV and timely reporting. • Each day the total withdrawal list is checked to determine the students who are receiving federal aid and may need to have a Return of Title IV calculation performed. • The students who are determined to require a Return of Title IV calculation are then processed for the Return of Title IV funds. This process is completed by the Assistant Director or Director of Financial Aid. • Once the process is complete and funds have been adjusted appropriately the Assistant Director or Director of Financial immediately run the process to export the files and funds out to the Common Origination and Disbursement (COD). • The next day COD is checked to ensure no reject(s) of the file(s) have occurred. If there are errors/rejects of the file the issue is researched and fixed to be accepted by COD. This process will ensure the timely reporting and return of funds to the Department of Education. Anticipated Completion Date: October 24, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid

Western Wyoming Community College experienced a transition in leadership within the Financial Aid Office, resulting in a change in the Director of Financial Aid position. This transition caused disruptions in communication and process continuity between the Financial Aid, Registrar, and Institutional Effectiveness offices. As a result, inconsistencies were identified in the timing and accuracy of enrollment reporting to the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS). Corrective Action Plan 1. Leadership and Process Realignment a. A new Director of Financial Aid has been appointed and is collaborating with the Institutional Effectiveness Office and the Registrar to define clear processes and timelines for Records & Registration and Financial Aid operations. b. The Director of Financial Aid and Registrar will maintain continuous communication to ensure timely and accurate enrollment reporting and prompt correction of any identified discrepancies. c. The Director of Financial Aid and Registrar will work together to develop a Standard Operating Process (SOP) to ensure if any future attrition occurs in either department that anyone else in those departments will be able to step in and continue processing without interruption ensuring timely and accurate enrollment reporting continues. 2. Implementation of Controls for Third-Party Reporting a. Recognizing the benefits and responsibilities of using the National Student Clearinghouse (NSC) for enrollment reporting, the institution has implemented controls to verify the accuracy of data transmitted through this third-party servicer. b. The Assistant Director (or the Director of Financial Aid in the Assistant Director’s absence) will generate the Summary Return of Funds Report (ROFS) from Colleague each term and provide a copy to the Registrar for enrollment verification and reconciliation. 3. Quarterly Reconciliation and Internal Review a. The Financial Aid Office will conduct a quarterly comparison between Colleague and NSLDS records to ensure consistency of enrollment and status dates. b. Any discrepancies identified will be communicated to the Registrar for prompt resolution. c. Results of the quarterly reviews will be documented and used for internal compliance monitoring and training. 4. Updated End-of-Term Procedure To ensure ongoing accuracy and compliance, the following revised steps will be followed each term: a. The Director or Assistant Director of Financial Aid will run an All F Report after final grades are posted. b. The Director and Assistant Director of Financial Aid will jointly calculate Return to Title IV (R2T4) funds. c. The Return of Funds Report (ROFS) will be provided to the Registrar monthly to verify last date of attendance and withdrawal dates against Colleague records. d. The Registrar will verify subsequent semester enrollments and continuously monitor student enrollment, reporting any changes to Financial Aid leadership. e. The Registrar will submit end-of-term enrollment data to the National Student Clearinghouse as usual, and one week before the next term begins, will submit the end-of-term R2T4 list to prevent overwriting by subsequent semester reporting. 5. Training and Internal Audit Enhancement a. The Financial Aid and Registrar’s Offices will use findings from this audit to develop staff training on identifying and correcting data discrepancies during the quarterly reconciliation process. b. The Director of Financial Aid will review 80% of R2T4 files during each semester for accuracy in reporting and documentation. 6. Graduation Data Accuracy a. The Registrar’s Office utilizes the Update Academic Credentials File (UACF) in Colleague to batch post student degrees and certificates three times per year (end of spring, summer, and fall terms). b. It was determined that the automatic graduation date populates correctly only when students have a single program with no changes. For students with multiple programs or program changes, the graduation date must be entered manually to ensure accuracy. c. The Registrar will oversee the upload of graduates and verification of accurate credential dates, ensuring these dates are correctly reflected in NSC and the Director or Assistant Director of Financial Aid will make sure the dates are correctly reflected in the NSLDS system. d. The Registrar and Director of Financial Aid will conduct joint reviews to verify that all graduation and enrollment data are reported correctly. Anticipated Completion Date: June 30, 2026 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, and Kayla Miller, Registrar

Western Wyoming Community College experienced unexpected turnover in the Director of Financial Aid position, which impacted financial aid reporting and reconciliation processes. Due to access issues with federal systems required for conducting reconciliations and the departure of a consultant who did not retain documentation for completed reconciliations, no reconciliations were available for review for the 2024/2025 Academic Year and 2025 Fiscal Year. Corrective Action Plan 1. Staffing and Training a. A new Director of Financial Aid has been hired and has completed training on the reconciliation process for both Pell Grants and Direct Loans in collaboration with the Assistant Director of Financial Aid. b. Cross-training has been implemented to ensure continuity of operations in the event of future staff turnover. 2. Establishment of Standard Operating Procedures (SOP) a. The Financial Aid Office has worked with the Business/Bursar’s Office to develop and document a Standard Operating Procedure (SOP) governing: • The drawdown of Title IV funds. • The reconciliation process for Pell and Direct Loan programs. b. The SOP outlines responsible parties, required documentation, and timelines for reconciliation and reporting. 3. Monthly Reconciliation Schedule a. A reconciliation schedule has been established requiring completion of Pell and Direct Loan reconciliations by the 15th of each month, or as soon thereafter as federal reports become available. b. Once reconciliations are confirmed as accurate and complete with the Business/Bursar’s Office, drawdowns of funds will occur on or near the 15th of each month, depending on calendar dates and federal system availability. 4. Compliance Alignment a. This process ensures timely and accurate reconciliation of Pell Grant and Direct Loan funding in accordance with 34 CFR 685.300(b)(5) and related federal cash management requirements. Anticipated Completion Date: November 15, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, Assistant Director of Financial Aid, Business/Bursar’s Office

Western Wyoming Community College experienced an unexpected turnover in the Director position which impacted the timeliness of reporting. Corrective Action A new Director of Financial Aid has been hired and has worked with the Assistant Director of Financial Aid to train on the process of reporting to COD within the 15 day period after disbursing federal aid. • Any available funds are disbursed each Monday throughout the semester, except for when a holiday falls on a Monday. Funds are then disbursed on the next working business day. • The process to export these disbursements to the Department of Education are performed the same day or the following day after the Business office has ran the transmittal process. This process is completed by the Assistant Director or Director of Financial Aid. • Once the process is complete and funds have been exported to the Department of Education through the Common Origination and Disbursement (COD) portal the Assistant Director or Director of Financial will to ensure no reject(s) of the file(s) have occurred. If there are errors/rejects of the file the issue is researched and fixed until accepted by COD. This process will ensure the timely reporting to the Department of Education. Anticipated Completion Date: October 24, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid

The Administrative Services Office and the Student Affairs Office, or the Grant Manager/Principal Investigator responsible for any specific grants going forward, will work closely with the granting agency to ensure that any unanticipated changes/reductions in funding periods are communicated in time to allow the College to effectively close out the grant, or to obtain permission for funding of expenditures that will not be incurred/and or liquidated timely. Anticipated Completion Date: N/A Contact Person(s): Willie Noseep, Vice President for Administrative Services Coralina Daly, Vice President for Student Affairs

The Municipality Administration is currently addressing the control and compliance issue. Starting on January 2026 prior year reports will be submitted. Full compliance expected to start on January 2026 going forward.

All monthly reports were delivered on time to AFAAF as established on the guidelines and following the agency’s reporting guidelines and support. The Municipality is full compliance with the Puerto Rico Fiscal Agency and Financial and Financial Advisory Authority

CHA currently has a general procurement plan in place to guide its purchasing and contracting activities. However, to ensure full compliance with federal regulations, CHA will be updating its existing procurement policy to align with the Uniform Guidance requirements. This update will formalize procedures related to vendor selection, competitive bidding, and documentation to maintain transparency, accountability, and consistency across all procurement processes.

2024-004 Water and Waste Disposal Loans and Grants (Section 306C) (Not A Major Program) Reserve Account The Finance Department will transferer the amount of $151,462 to fully fund the Reserve Account to meet the $201,982 balance required by the loan agreement. Starting in Fiscal Year 2025-2026, LRA’s Finance Department will implement within its monthly accounting closing procedures the reconciliation and review of all transfers from General Account to Reserve Account. The monthly reconciliations and review will provide full compliance with USDA reserve account requirements, eliminates repeated findings in future audits and will improve transparency in reporting strengthening accountability and reduced risk of federal payments. LRA Finance Department will establish a formal review process to ensure all prior year findings are properly tracked and resolved. Jamille E Muriente Díaz, Financial Affair Director Telephone: 787-705-7188 Email: Jamille.muriente@lra.pr.gov Target Completion Date - 6/30/2026

FINDING 2024-003 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Subrecipient Monitoring Contact Person Responsible for Corrective Action: Gretchen Parker Contact Phone Number and Email Address: 765-648-6113 gparker@cityofanderson.com Views of Responsible Officials: "We concur with the finding." Description of Corrective Action Plan: The city has several individuals involved in the monitoring of activities related to the COVID 19 Coronavirus State and Local Fiscal Recovery federal award. The city has implemented procedures to ensure oversight and review of subrecipient reports is properly documented. Anticipated Completion Date: September 1, 2025

FINDING 2024-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Contact Person Responsible for Corrective Action: Debra Carnes Contact Phone Number and Email Address: 317.477.1105 Views of Responsible Officials: We concur with the audit finding and will enhance our internal controls and procedures for subrecipient monitoring. Specifically, we will: Corrective Action Plan for Finding 2024-001 l. Include the Assistance Listing Number (ALN) and Federal Award Identification Number (FAIN) in subaward agreements. 2. Verify that subrecipients have been audited as required. Implementation Timeline We will update our written internal controls by August 29, 2025, to reflect these enhancements. Current Status We have already verified that our subrecipient has been audited, and to the best of our knowledge, there are no findings related to ARPA funding. Sincerely, Debra A. Carnes Hancock Co. Auditor

Finding: 2024-032 - During FY 24, Department of Commerce, Community, and Economic Development (DCCED) staff did not sufficiently monitor the subrecipient tasked with administering the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Tourism and Other Businesses program. Furthermore, DCCED management did not take action with respect to the subrecipient’s noncompliance with requirements to obtain a single audit. Questioned Costs: None Assistance Listing Number: 21.027 Assistance Listing Title: SLFRF - COVID- 19 Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): DCCED agrees with this finding. Corrective Action (corrective action planned): Division of Finance presented subrecipient monitoring training to DCCED grant management staff in December 2024. DCCED will continue to work with department grant staff to ensure compliance with federal subrecipient monitoring requirements by strengthening grant management procedures. DCCED is working with the subrecipient to obtain single audits for outstanding periods. DCCED and the Division of Finance worked collaboratively to address previously unidentified communication gaps when subrecipients are notified of outstanding single audit requirements, and have made adjustments to communication procedures to ensure departments are notified of outstanding single audits for grantees. Completion Date (list anticipated completion date): 12/31/2025 Agency Contact (name of person responsible for corrective action): Lisa Van Bargen

To address this issue, the department will be taking the following corrective actions: 1. Training: Staff responsible for sub-recipient monitoring will complete updated training focused on federal Uniform Guidance requirements, as well as best practices for oversight and documentation. 2. Policy Review and Clarification: The department will review and revise its internal policies and procedures to align more closely with federal guidelines and institutional expectations. Clear protocols for sub-recipient monitoring activities will be disseminated to relevant personnel. 3. Ongoing Oversight: Upon implementation, the Department will conduct periodic reviews of sub-recipient monitoring activities to ensure compliance and for purposes of identifying any areas requiring further improvement. These actions are intended to strengthen compliance efforts and prevent similar issues in the future. Party(ies) responsible for overseeing the corrective action plan for the grant programs: - Nader Abusumayah, Chief Accountant, nader.abusumayah2@cookcountysao.org, 312.603.1840 - Nicole Kramer, Director of Programs and Development, nicole.kramer@cookcountysao.org, 312.603.1879 The department plans on completing the above corrective action on 8/30/2025

2024-040 Oregon Department of Emergency Management Assign responsibility to ensure review of subrecipient audit reports Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM is undertaking the following corrective actions to address the recommendations made by the Secretary of State’s Audits Division: • OEM will identify sufficient and appropriate grant accounting staff to perform this work on an ongoing basis, ensure that this work is added to their Position Descriptions, provide them with appropriate training, support, and guidance regarding subrecipient audit reviews. • OEM will establish an annual plan to assign this work out, establish and utilize tracking sheets, and follow up for timely completion. • OEM will work to address the past due FY 24 subrecipient reviews noted in the audit finding letter and above, and will then work to address those from FY23 and FY22. Anticipated completion date: December 31, 2026. Contact person: Amy Mettler, Chief Financial Officer.

2024-037 Oregon Business Development Department Assign responsibility to ensure review of subrecipient audit reports Management Response: We agree with this recommendation. In January 2025, Business Oregon started the initial work by meeting with DAS SARS team on identifying specific tasks for Business Oregon as the assigned audit agency for the SLFRF award. Business Oregon completed the preliminary reviews and confirmed that 23 out of 24 recipients of the SLFRF award are required for the single audit. Business Oregon contacted the recipients and requested financial reports to proceed with review of subrecipient audits. As of March 2025, the work is still ongoing, and Business Oregon is currently communicating with the recipients. The estimated completion date of this review is 6/30/2025 Anticipated Completion Date: June 30, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager

2024-040 Oregon Department of Emergency Management Assign responsibility to ensure review of subrecipient audit reports Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM is undertaking the following corrective actions to address the recommendations made by the Secretary of State’s Audits Division: • OEM will identify sufficient and appropriate grant accounting staff to perform this work on an ongoing basis, ensure that this work is added to their Position Descriptions, provide them with appropriate training, support, and guidance regarding subrecipient audit reviews. • OEM will establish an annual plan to assign this work out, establish and utilize tracking sheets, and follow up for timely completion. • OEM will work to address the past due FY 24 subrecipient reviews noted in the audit finding letter and above, and will then work to address those from FY23 and FY22. Anticipated completion date: December 31, 2026. Contact person: Amy Mettler, Chief Financial Officer.

2024-037 Oregon Business Development Department Assign responsibility to ensure review of subrecipient audit reports Management Response: We agree with this recommendation. In January 2025, Business Oregon started the initial work by meeting with DAS SARS team on identifying specific tasks for Business Oregon as the assigned audit agency for the SLFRF award. Business Oregon completed the preliminary reviews and confirmed that 23 out of 24 recipients of the SLFRF award are required for the single audit. Business Oregon contacted the recipients and requested financial reports to proceed with review of subrecipient audits. As of March 2025, the work is still ongoing, and Business Oregon is currently communicating with the recipients. The estimated completion date of this review is 6/30/2025 Anticipated Completion Date: June 30, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager