Corrective Action Plans

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.

Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence. County Clerk: I was not the County Clerk in office at this time. To correct this issue. the County plans to develop a SOP to timely and accurately track and report on federal funds. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners. County Treasurer: The County was under the understanding that once we established we were reporting as Loss Revenue, we would not have to submit the report annually. The final reporting was submitted prior to deadline.

Condition: One Education Stabilization Fund final financial report has not been submitted that is overdue. Corrective Action Planned: Upon review, the District confirmed that the grants identified in this finding have either already had their final financial reports submitted or were operating under approved late liquidation extensions, during which final reporting is not yet required. The District has verified all reporting statuses and updated its internal grant tracking to ensure documentation of late-liquidation approvals is consistently stored with each grant file. No further action is needed beyond maintaining the existing reporting calendar and reconciliation procedures now in place. Anticipated Completion Date: Procedures are already implemented. Contact: Liz Latoria, School Director of Finance and Operations

Condition: Two final financial reports were not filed in a timely manner for Special Education Cluster grants. Corrective Action Planned: The District experienced delays in filing final financial reports due to difficulties reconciling grant revenues in the Town’s accounting system, as certain receipts were not clearly identifiable during the grant closeout process. To address this, the District implemented a monthly reconciliation process with the Town and created an internal grant reporting calendar with secondary review to ensure timely submission. These procedures are now in place and will prevent future delays. Anticipated Completion Date: These procedures are currently in place. The District will complete the final financial reporting process for outstanding grants within 60-90 days, with all remaining reports finalized no later than March 31, 2026. Contact: Liz Latoria, School Director of Finance and Operations

Assistance Listing 14.231 Emergency Solutions Grants Program Views of the Responsible Officials and Corrective Action Plan: The Office of Homeless Services acknowledges the finding. The delay in liquidating obligations resulted from internal control procedures that appropriately identified a potential contract concern involving the Resources for Human Development. In accordance with established financial oversight protocols, the Finance Department placed a temporary hold on related payments pending further review. Once the review was concluded, the payments were released. Additionally, limitations within the FAMIS system, specifically its inability to retain original voucher creation dates after rejection and resubmission, contributed to the appearance of delayed liquidation. To prevent recurrence, the Office of Homeless Services will strengthen its closeout procedures to ensure timely review and liquidation of all obligations in accordance with 2 CFR § 200.344. The Office will also initiate earlier coordination with the Finance Department when payment holds arise and reinforce staff training on grant closeout and escalation protocols. These corrective actions will enhance compliance and reduce the likelihood of future delays. Contact Person: Jerome Hill, Director of Compliance, OHS, 215-686-0371

Finding Number: 2024-032 Audit Type: Single Audit Finding Title: Delayed Final Reimbursement Due to Unresolved Agency Requests Related Finding: 2024-023 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will designate a grants coordinator to monitor agency requests and ensure timely responses. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will improve communication with funding agencies. 5. Status of Prior Year Finding This is a newt finding.

Finding 2024-010 – Period of Performance (Material Weakness) Finding: The Organization did not have good controls to ensure the period of performance requirements was met due to staff turnover. Management Response: Management concurs. Corrective action plan: •Implement a grant compliance checklist and training for staff by the end of 2025 to ensure expenditures are within the grant period. •Require pre-approval for all expenditures near grant end dates. •Quarterly compliance reviews. Responsible Party: CFO Completion Date/Status: Expected to be Implemented by end of 2025; ongoing review.

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

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

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.

2023-002: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout procedures, consequently, the district will monitor closely all grants spending throughout each grant cycle. For both state-administered and direct grants, regardless of the period of availability, the District must liquidate all obligations incurred under the award Reports not later than 90 days after the end of the funding period unless an extension is authorized. These procedures are included in the Financial Procedures Manual (pages 226-230 under Section G— Timely Obligation of Funds) Key Control Key Actions Resources Needed Timeline Outcome Grants Management Use appropriate resources to mitigate any errors, omissions and ensure timely maintenance of records and reporting Grant Management Form Grant Award Letter Internal Controls Guide GEM$ Trainings FY24, FY25 ongoing Implementation of preventive controls for ALL grant funding Contacts: School Business Manager & Town Accountant Submitted by, Annette Colón, Business Manager MBA, MCPPO, Notary Public Clinton Public Schools 150 School St. Clinton, MA 01510 (978) 365-4200 x 12241 colona@clinton.k12.ma.us

The Foundation immediately paid the vendor the full amount upon learning of this finding from the auditor and verified that the vendor received the payment. The recording of Grant Revenue/Accounts Receivable and Grant Expenses/Accounts Payable is now done for each grant expense immediately upon approval from the Foundation and submission to New York State for reimbursement. This was previously not done. The changes to the recognition of revenue and expenses are already in effect and should eliminate any future finding related to the non-payment of expenses that have been reimbursed through grants.

Finding Number 2024-007: Period of Performance – Material Weakness in Internal Control over Compliance and Noncompliance Corrective Action: To ensure compliance with 2 CFR §200.344(b), Management will implement formal policies and procedures requiring that all financial obligations under federal awards be liquidated within 120 calendar days after the end of the period of performance. Grants Accounting will establish a documented review and tracking process to monitor grant deadlines, identify outstanding obligations, and ensure timely payments. These actions are intended to strengthen controls, ensure timely liquidation of expenditures, and prevent recurrence of prior year findings. Name of Responsible Individual(s): Jason Brenier, Shelly Courtois, Judy Bokhari, and Sandra Shannon Anticipated Completion Date: September 2025

Communicate with the Budget Board regarding this finding. We have already introduced to the budget board, a form guideline called "Payne County Grant Administration Plan" to aid in proper documentation, repo1ting and proper spending of all grant awards, including creating a capital outlay sub account as recommended.

Management will ensure Federal expenditures are obligated during proper period and reported appropriately.

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration.

Finding: 2024-035 -Six of seven award extensions for the NGMOMP program were untimely. Additionally, one award was not closed timely. Questioned Costs: None Assistance Listing Number: 12.401 Assistance Listing Title: NGMOMP Views of Responsible Officials (state whether your agency agrees or disagrees with the finding if you disagree, briefly explain why): DMVA concurs with the finding. Corrective Action (corrective action planned): Administrative Services has consistently provided notification and set clear deadlines to the Federal and State Program Managers of an expiring award under the Cooperative Agreement (CA). This notification has included a financial report detailing posted expenses and open obligations and when applicable, a copy of the most resent approved extension for reference. Due to inconsistent and untimely responses, the Finance officer in conjunction with the Administrative Services Director will update and strengthen written procedures, elevating responsibility for follow-up when responses are not received to ensure timely submission of extension requests and award closeouts following 2 CFR 200.303(a), 2 CFR 200.308(e), and 2 CFR 200.344. Updated documented procedures and training will be provided to the components under the CA. Completion Date (list anticipated completion date): 06/30/2025 Agency Contact (name of person responsible for corrective action): Bob Ernisse Pamela Wiederspohn

Finding: The Housing Finance Commission did not have adequate internal controls over reporting requirements for the Homeowner Assistance Fund program. Questioned Costs: Assistance Listing # 21.026 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: To address the deficiencies identified by the auditors in completing annual performance reports, the Commission has taken the following corrective actions to strengthen controls over reporting for the Homeowner Assistance Fund (HAF) program: • Updated procedures to require: o Homeownership Division and Finance Division staff to perform regular reconciliation of records to identify any discrepancies and to ensure all records are complete and accurate. o Supporting data obtained for reporting be vetted by the contractor and the Homeownership Division staff. o Leadership (division manager or above) to perform final review of data as well as the quarterly or annual report prior to submission to the grantor. • Designated the records maintained by the Finance Division, specifically the general ledgers, as the source of financial data for the quarterly and annual reports for the Washington HAF program. • Required third parties to develop or update a program manual regarding data used for reporting purposes. The manual incorporated recommendations of the audit finding. As of June 30, 2024, the Commission consulted with the U.S. Department of the Treasury to determine if revision and resubmission of the reports are necessary to correct amounts reported. No corrective action was required. The conditions noted in this finding were previously reported in finding 2023-025. Completion Date: June 2024 Agency Contact: Lucas Loranger Senior Finance Director 1000 Second Ave, Suite 2700 Seattle, WA 98104-3601 (206) 464-7139 Lucas.Loranger@wshfc.org