Corrective Action Plans

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.

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.

VIDE is currently working towards developing formal procedures to establish controls operating at a level of precision that ensures timely and accurate reporting compliance. As part of this ongoing development, VIDE will govern these new procedures through the Integrated Fiscal Control Model within the Office of Federal Grants. To correct the discrepancies between the Annual Report and underlying data, VIDE will implement a mandatory multi-level reconciliation process. Prior to the submission of any Annual Report, Program Directors and the fiscal team must cross-reference and validate all reported programmatic and financial data against the ERP system of record and official source documents. A final sign-off will be required to certify data accuracy. Furthermore, to address the Transparency Act requirements, VIDE will institute a strict compliance workflow. The Office of Federal Grants will be required to identify, register, and report all applicable first-tier subawards of $30,000 or more into the FSRS portal within the federally mandated timeframe. To ensure FFATA submissions are consistently completed, a secondary review step will be implemented to verify the FSRS submission confirmation before any initial reimbursement drawdowns are approved for the respective subrecipient.

The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including period of performance. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.

Develop and document formal policies and procedures for grant management, including repo1iing, monitoring, and compliance. Implement these policies and ensure that each office is using them correctly.

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

Finding No.: 2024-011 Period of Performance Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director (DPHSS) The DPHSS WIC Program disagrees with the findings. All supporting documents related to the findings were provided promptly on March 3,2026 when request was received on February 26,2026. In accordance with WIC FY 2024 Closeout Guidance and the requirements under 2 CFR 200.344, the WIC Program is allowed 90 days after the end of the period of performance to submit all final financial reports, as well as 90 days to liquidate all obligations incurred during the period of performance. For FY 2024, the closeout timeline required that all obligations be liquidated no later than January 31, 2025. The program adhered to these federal requirements. All obligations were liquidated prior to the close of the fiscal year grant, and obligations were reported in the fiscal year in which they occurred, consistent with 7 CFR 246.17. Furthermore, the final closeout report was submitted within 120 days after the end of the fiscal year, fully complying with WIC closeout procedures. Based on the timely submission of all supporting documentation and adherence to federal closeout regulations, the DPHSS WIC Program maintains that the questioned costs were appropriately obligated, liquidated, and reported.

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