Corrective Action Plans

Finding No.: 2025-009 Federal Agency: U.S. Department of Education AL Program: 84.181 Special Education – Grants for Infants and Families Federal Award No.: H181A220008 Area: Period of Performance Questioned Costs: $32,733 Views of Auditee and Corrective Actions GDOE agrees with the condition but does not agree with the cause. Management notes that the exception represented one of 36 transactions selected for testing and was identified as an isolated instance. The 2022 grant was approved for a late liquidation and was only opened for a short period of time. Nevertheless, GDOE recognizes that all federal expenditures must be liquidated within the applicable timeframe and that adequate controls should be maintained to identify and resolve outstanding obligations before the expiration of the liquidation period. Management will strengthen its grant closeout monitoring procedures to reduce the risk of outstanding obligations remaining unresolved beyond applicable federal liquidation deadlines. Plan of action and completion date: GDOE will strengthen controls over the monitoring and timely liquidation of federal award obligations. GDOE will: 1. Perform periodic reviews of outstanding obligations and unpaid expenditures in advance of applicable liquidation deadlines. 2. Coordinate among Federal Programs Division, applicable program personnel, Procurement, receiving personnel, Accounts Payable, Financial Affairs and office in-charge of the drawdown to identify and resolve outstanding transactions before the liquidation deadline. 3. Establish escalation procedures for obligations that remain outstanding as the liquidation deadline approaches so that responsible personnel and management can take timely corrective action. 4. Evaluate the need for an extension request when circumstances prevent timely liquidation and an extension is permitted under applicable federal requirements. 5. Document the resolution of outstanding obligations and retain supporting documentation demonstrating that expenditures were liquidated within the applicable timeframe. 6. Periodically review grant closeout activity to identify recurring processing delays and implement additional corrective measures when necessary. Plan to monitor and responsible officials: The Federal Programs Division, applicable program management, and Financial Affairs Accounts Payable will be responsible for monitoring the implementation of corrective actions. Corrective actions will be initiated with the FY2026 grant closeout cycle, with ongoing monitoring thereafter.

The BOCC acknowledges the finding and I will improve reconciliation and review procedures used in preparing federal reports. County officials involved in grant reporting will work together to ensure repotted obligations and expenditures are reconciled to supporting records before submission.

Corporation's Response: 1. The amount undisbursed, $15,000, was notified to the Project of awareness that we intend to return it as soon as possible. We will be contacting the Awarding Agency Officer to allow us the specific instructions for returning funds through the Payment Management System (PMS) following the agency's refund rules. Also, we have procedures to determine whether any interest earned in the advance must be remitted under 2 CFR§ 200.305(b)(9). 2. We have developed and implemented written cash management procedures to ensure that advance requests are limited to immediate cash needs and each of them is backed by paid invoices. 3. A monthly reconciliation is done for each of the funds, comparing federal disbursements with actual disbursements to avoid excessive requests for unused funds. 4. Constant monitoring has been established. Analyses are carried out of the approved and used budget. This analysis is done by someone who doesn’t handle payments, for the segregation of duties and supervision and the senior management does reviews to make sure everything gets done on time. 5. A formal training program on federal award requirements has been developed and implemented for all staff involved in administration, financial management, procurement, and reporting of federal awards. PR CONCRA management traces all CFR 200-related training and federal fund management training for the staff who can attend or participate in these seminars virtually.

2025-002 – Subrecipient Monitoring Corrective action plan: 1. The subaward template was corrected in September 2026 and is in use. The corrected form was used for the subaward executed September 18, 2026 and carries the full set of federal award identification elements required by 2 CFR 200.332(b)(1). 2. Obtain the current unique entity identifier for each subrecipient from SAM.gov and confirm it against subrecipient records. 3. Issue Modification No. 1 to each of the seven Round 1 subaward agreements, adding the Assistance Listing Number and title, the subaward budget period start and end dates, and the unique entity identifier where it was omitted, and issue an amended award notification supplying the same information for the Round 1 award made by award letter. Article IV, Section 6.11 of each subaward agreement permits NFEAIE to issue non-substantive modifications unilaterally in writing, so issuance is not contingent on subrecipient countersignature. Each modification will be transmitted to the subrecipient's authorized official and fiscal contact by email and the transmittal retained in the subaward file. 4. Issue Modification No. 1 on the same basis to Round 2 subawards R201 through R206, which were executed on the prior template. 5. Adopt a written subaward issuance procedure incorporating a checklist of the information required by 2 CFR 200.332(b)(1), completed, signed, and retained in the subaward file before execution, with CFO review of the executed instrument required before any disbursement. Personnel responsible for corrective action: Nicholas Cunningham, CFO Estimated corrective action completion date: November 30, 2026

CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program ‘Quarterly Cash On Hand Reconciliations’, and ‘Final Expenditure Reports (FER)’, I noted that the School District did not file the required Quarterly Cash on Hand Reconciliations and required Final Expenditure Report (FER) for the 2024-2025 fiscal year Title 1 grant program within the required reporting timeframes as specified by the Pennsylvania Department of Education and the Uniform Guidance. CRITERIA: The Department of Education requires the completion of the Quarterly Cash on Hand Reconciliation by the 10th working day after each quarter, and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance (or an earlier date as agreed-upon by the pass-through entity and subrecipient, which in this case is 30 days as required by PDE). RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Quarterly Cash on Hand Reconciliations’ and ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions such as suspension of grant payments by PDE as a result of not filing these reports in a timely manner. These procedures should include, at a minimum, cross-training of business office personnel with regard to the completion of these reports so that the absence of one individual would not result in these reports not being filed in a timely manner. MANAGEMENT’S PLANNED CORRECTIVE ACTION: The School District will implement procedures for timely and accurate reporting of the Quarterly Cash on Hand Reconciliation Reports and Final Expenditure Report (FER). The financial information in the Quarterly Cash on Hand Reconciliation Report and FER will accurately reflect internal reporting contained in the School District’s general ledger according to the Manual of Accounting and Financial Reporting for Pennsylvania Local Educational Agencies and the PA Chart of Accounts. The timeframe for completion will commence during the later part of the 2025-2026 fiscal year and continue into the first half of 2026-2027 fiscal year until completed. These procedures will be applied going forward to ensure the accurate and timely filing of the required federal program Quarterly Cash on Hand Reconciliation Reports and the Final Expenditure Report (FER) for submission to the Pennsylvania Department of Education.

CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program ‘Quarterly Cash On Hand Reconciliations’, and ‘Final Expenditure Reports (FER)’, I noted that the School District did not file the required Quarterly Cash on Hand Reconciliations and required Final Expenditure Report (FER) for the 2024-2025 fiscal year Title 1 grant program within the required reporting timeframes as specified by the Pennsylvania Department of Education and the Uniform Guidance. CRITERIA: The Department of Education requires the completion of the Quarterly Cash on Hand Reconciliation by the 10th working day after each quarter, and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance (or an earlier date as agreed-upon by the pass-through entity and subrecipient, which in this case is 30 days as required by PDE). RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Quarterly Cash on Hand Reconciliations’ and ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions such as suspension of grant payments by PDE as a result of not filing these reports in a timely manner. These procedures should include, at a minimum, cross-training of business office personnel with regard to the completion of these reports so that the absence of one individual would not result in these reports not being filed in a timely manner. MANAGEMENT’S PLANNED CORRECTIVE ACTION: The School District will implement procedures for timely and accurate reporting of the Quarterly Cash on Hand Reconciliation Reports and Final Expenditure Report (FER). The financial information in the Quarterly Cash on Hand Reconciliation Report and FER will accurately reflect internal reporting contained in the School District’s general ledger according to the Manual of Accounting and Financial Reporting for Pennsylvania Local Educational Agencies and the PA Chart of Accounts. The timeframe for completion will commence during the later part of the 2025-2026 fiscal year and continue into the first half of 2026-2027 fiscal year until completed. These procedures will be applied going forward to ensure the accurate and timely filing of the required federal program Quarterly Cash on Hand Reconciliation Reports and the Final Expenditure Report (FER) for submission to the Pennsylvania Department of Education.

The Board of County Commissioners will ensure that the reports are accurate and reported in the proper period.

The Board of County Commissioners have hired a grant administrator to assist with the reporting process. We will ensure that the reports are accurate and reported in the proper period.

The Organization filed the required reports in 2026.

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

Corrective Action Plan Finding No. 2025-004 Condition – The District submitted an expenditure report for $19,165,569 for the quarter ending March 31, 2025, which included amounts that were properly obligated but not yet expended as of the report date. The District reported $14,638,097 in ESSER funds on the Schedule of Expenditures of Federal Awards (SEFA), resulting in an unsupported difference of $4,527,472. Plan – The District will implement additional review processes to ensure material errors are detected and corrected. The District requested all ESSER obligated funds as of March 2025 as directed by the state. Anticipated Date of Completion: 03.06.26 Name of Contact Person: Delfaye Jason, Chief School Business Official

Improve Controls over Subrecipient Monitoring Name of contact person: Connie DeKemper Anticipated completion date: 06/30/2026 Condition – During our audit, we noted the County did not complete the required monitoring until six months after the fiscal year end. Response - Subrecipient monitoring will be completed during the fiscal year.

Condition: The Organization did not liquidate all financial obligations incurred under the NASA federal award within 120 calendar days after the conclusion of the period of performance, as required by 2 CFR Section 200.344(c). Corrective Action Steps: Establish a written close-out procedure for federal awards that identifies all required actions, including liquidation of all financial obligations, within the 120-day close-out window prescribed by 2 CFR Section 200.344(c). Designate a responsible staff member to monitor upcoming award end dates and initiate the close-out checklist no later than 30 days before the period of performance ends. Maintain a federal award close-out tracker that documents the award end date, the 120-day liquidation deadline, all outstanding obligations, and the date each obligation is liquidated. Coordinate with program staff to identify and process all outstanding invoices, subcontractor payments, and other obligations prior to the liquidation deadline. Review all active and recently expired federal awards to assess whether any obligations remain unliquidated and remediate as needed. Responsible Party: CLC NWI Executive Director. Target Date: Executive Director Partially Completed. All funds have been liquidated as of 3/23/26. All other corrective action steps to be implemented by May 15, 2026.

This letter is the Wisconsin Department of Transportation's response and corrective action plan for the finding and recommendations made by the State of Wisconsin Legislative Audit Bureau (LAB) in the interim memo dated February 18, 2026. Finding 2025-501: Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airports Programs—Financial Reporting The Wisconsin Department of Transportation (WisDOT) agrees with the audit finding. Planned Corrective Action: • The Bureau of Aeronautics (BOA) will update the current APS-30 BOA Airport Improvement Program Reporting (Grant Reporting) policy and procedures to include a secondary review by the Bureau of Financial Management (BFM). This update will include how corrections will be documented and handled prior to reporting submission to the federal government. • BOA and BFM will develop and implement written procedures for a coordinated internal secondary review of the final SF-271 and SF-270 forms, and the annual and final SF-425 reports, including procedures for maintaining sufficient documentation of the internal review. • BOA will obtain and maintain documentation of the project completion information to be used to initiate the closeout of a grant and/or airport development project. Anticipated Completion Date: May 2026 Person responsible for corrective action: Tami Weaver, Section Chief Airport Program Section WisDOT- Division of Transportation Investment Management, Bureau of Aeronautics tamera.weaver@dot.wi.gov

Finding Number: 2025-002, Grant Closeouts Condition: The University did not complete full grant closeout procedures in a timely manner for 8 out of 40 grants that were tested with a period of performance that ended in the year ended June 30, 2025. Corrective Actions: Penn State will raise awareness of the late closeout issue at various committee, workgroup, and council meetings during Spring 2026, and enforce compliance with our existing policy. These meetings involve research leadership at all colleges, such as Associate Deans for Research, College Research Administration Officers, and College Strategic Financial Partners. Penn State will provide additional trainings throughout the year to educate colleges on the closeout process through the Financial Analysis and Compliance Office. Contact person responsible for corrective action: Jason Guilbeault, Assistant Vice President for Research – Post Award Contractual Compliance Anticipated Completion Date: March 31, 2026

Planned Corrective Action: The district will implement controls for monitoring reporting grant requirements and grant expenditures to ensure compliance with reporting and period of performance requirements for federal grants. Anticipated Completion Date: 6/30/26 Responsible Contact Person: Hiwot Abraha

2025-001 Costs Incurred Beyond the Period of Performance Criteria: According to 2 CFR §§200.1, 200.308, 200.309, 200.344, and 200.403(h), a non-Federal entity may only charge allowable costs incurred during the approved budget period of the Federal award’s period of performance, and any costs incurred before the Federal award was made that were authorized by the Federal awarding agency or pass-through entity. All financial obligations incurred under the Federal award must be liquidated within the required time period. Costs incurred outside the approved period of performance are unallowable and constitute questioned costs. Client’s Response: During the grant cycle, the Organization submitted for an extension but did not receive confirmation of said extension. During the current fiscal year, the Organization has implemented additional controls to ensure that all grant funding is expended within the timeframe allotted. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444

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

Planned Corrective Action 1.Corrective Action Already Taken •Staff involved in ARP-ESSER closeout have been briefed on the specific compliance failure and the regulatory requirement under 2 CFR § 200.344(c). 2.Corrective Actions to Prevent Recurrence A . Strengthened Reimbursement Request Review Process •No reimbursement request may be submitted without a two-step compliance review: 1.Grant Coordinator Review – Verifies liquidation occurred before the federal deadline and confirms documentation accuracy. 2.Finance Director Approval – Confirms federal compliance and signs off before submission. •Claims based solely on obligation without liquidation confirmation are now prohibited. B. Staff Training and Compliance Reinforcement •Annual training on federal grant compliance—including obligations, liquidation, period of performance, and closeout requirements under 2 CFR Part 200—will be provided to all finance, grants, and program staff. •Staff with direct responsibility for reimbursement claims will receive targeted training on liquidation rules. C. Internal Monitoring and Audit Review •Quarterly internal audits will be conducted to ensure: oExpenditures are liquidated within allowable periods. oThe new controls are functioning as intended. oAny exceptions are immediately corrected and reported to the Superintendent. 3.Person(s) Responsible for Corrective Action •Finance Director – Oversight of grant compliance, monitoring, approvals, and reporting. •Grant Coordinator – Daily oversight of liquidation timelines, tracking logs, documentation, and extension requests. 4.Anticipated Completion Date •Initial corrective actions implemented: March 2026. •Full implementation of revised policies, procedures, training, and documentation: June 30, 2026.

The College acknowledges the repeated finding and recognizes the need to strengthen internal controls to ensure that expenditures charged to federal programs are incurred within the approved period of performance. During FY2025–FY2026, the College continued implementing corrective measures, including the use of an upgraded cloud-based filing system to improve documentation, monitoring, and verification of grant funding periods. The College has also continued strengthening coordination among the Business Office, Human Resources, and program personnel to ensure that payroll expenditures are properly reviewed and aligned with the applicable grant award periods. Additionally, the College continues to improve its review procedures to ensure that payroll costs are charged based on the actual period in which services were performed rather than the payment date. The College will also review the identified questioned costs and determine whether any adjustments or additional corrective actions are necessary. These ongoing efforts are intended to strengthen compliance with federal period of performance requirements and prevent recurrence of similar findings in future audits.

The current Board of County Commissioners acknowledges the finding, and I will improve reconciliation and review procedures used in preparing federal reports. County officials involved in grant reporting will work together to ensure repotted obligations and expenditures are reconciled to supporting records before submission.

The current Board of County Commissioners acknowledges the finding. The Board will continue working with county officials, consultants, and auditors involved in grant administration to improve reconciliation and reporting procedures. Additional review steps will be performed to ensure obligations and expenditures reported to federal agencies are supported by county records and accurately reported.

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

Management will: Establish grant closeout deadlines based on project award defined end date, Implement automated compliance calendar reminders and list of important dates for grant period, and Annual Uniform Guidance compliance training.

Once payroll is processed by the Department of Finance (DOF), a Flex Earnings Report is generated by the Analyst on each payday. A reconciliation is then performed to ensure that all employees, along with their respective fringe benefits, are accurately captured and drawn. Following this process, DOF posts the payroll to the accounting system. However, staffing has identified that deficiencies can occur in DOF’s postings, sometimes arising in periods subsequent to the actual payday. To address this, the Department of Human Services (DHS) has incorporated an internal control requiring retrospective reconciliation of accounts against the Flex Earnings Report to verify accuracy. Additionally, DHS plans to engage with DOF to better understand the underlying factors and nuances that result in discrepancies between DOF postings and the account coding reflected in the Flex Earnings Report. The Federal Grants Financial Analyst also plays a key role in ensuring that transactions are recorded in the appropriate accounting period and that costs are properly allocated. In this particular instance, no federal funds were drawn.