Corrective Action Plans

2025-002 Corrective Action: We will correct the application of indirect costs and reduce the very next future request for reimbursement by the overcharged indirect costs. We have also changed the circumstances that caused the limitation to be overlooked related to this specific contract.

Condition: Expenditures for the Child and Adult Care Food Program were incorrectly reported as expenditures to other nutrition programs. Recommendation: The auditors recommend that the School properly identify and report nutrition program expenditures by program. Contact Name: Anastacia Europa Ruiz, Chief Operating Officer Corrective Action Planned: The School Management will identify nutrition program expenditures by each separately funded program and report such expenditures by each separately funded program. Anticipated Completion Date: June 30, 2026

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Jill VanDriessche Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. We believe this finding to be the result of an isolated incident that was reported to SBOA and Title. Description of Corrective Action Plan: The Business Manager/Treasurer provides to the corporation grant administrator monthly grant reports, as well as a grant tracking spreadsheet. The appropriations for each grant are entered into Komputrol, according to the budget located in the approved grant documents. The appropriations are presented to the Grant Administrator for approval. All spending from each grant is approved by the corporation grant administrator. Any wages paid via the corporation payroll that is charged to grant funds is approved by the business manager/treasurer and the corporation grant administrator. The Payroll Specialist/Deputy Treasurer completes the payroll and sends the distribution account records to the Business Manager/Treasurer and Grant Administrator. Any payroll claims for payment via grant funds is required to have three signatures for approval. We believe the system of internal control in place has been strong and in compliance since March 2025. Anticipated Completion Date: March 1, 2025 and ongoing

FINDING 2025-004 Finding Subject: Child Nutrition Cluster, Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Amy Kraszyk Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Since January 2025, the internal controls that resulted in this finding have been corrected. The finding stated that “The lack of internal controls and noncompliance over Allowable Activities and Allowable Costs/Cost Principles is an isolated incident.” The Food Service Director and the Business Manager/Treasurer meet monthly to review the school lunch accounts and to concur with the month end balances. The Deputy Treasurer approves all monthly fund transfers completed by the Business Manager. Anticipated Completion Date: January 1, 2025 and ongoing

The formal policy was written, incorporated in to our comprehensive accounting policies manual, and approved by the board of directors on February 25, 2026.

The City will review the requirements for written policies and will adopt policies, as needed, or will revise its current policies as needed to comply with Uniform Guidance.

Westminster College Corrective Action Plan (CAP) Federal Program: Economic Adjustment Assistance Program, Assistance Listing Number 11.307 Finding 2025-001: Questioned Costs – Allowable Costs/Costs Principles (material weakness) Name of Contact Person: Gerald J. Ganz, Jr., Vice President, CFO Specific Corrective Action: To prevent recurrence, the College is implementing the following measures: 1. Enhanced Funding Source Review Procedures: The College will develop and enforce a standardized review process requiring staff to verify and document the original funding source for any expenditure prior to charging it to a federal award. This process will include mandatory cross-checking between project accounting records, bond expenditures logs, and grant reimbursement requests. 2. Strengthened Internal Controls Over Capital Project Accounting: The College will implement additional controls within the accounting system to ensure expenditures tied to capital projects are flagged and reviews for potential dual funding before being charged to any federal program. 3. Training and Guidance for Staff: All personnel involved in grant management, accounting, and capital project administration will receive updated training on Cost Principles under 2 CFR 200.400-200.406, with emphasis on allocability, reasonableness, and the proper handling of applicable credits. 4. Ongoing Monitoring and Review: Quarterly internal compliance reviews will be conducted to confirm adherence to the new procedures, and corrective measures will be taken immediately if discrepancies are identified. The College is committed to ensuring full compliance with federal regulations and strengthening internal controls to safeguard all funding sources. We appreciate the opportunity to improve our processes and will implement the recommended procedures to ensure the integrity of future federal program expenditures. Anticipated Completion Date: June 30, 2026

Indirect Cost Rate Review Auditor Description of Condition and Effect. The University does not have a formal review process related to indirect cost rate automated entries. As a result of this condition, there is an increased risk of unallowable charges to the grants, inaccurate financial reporting, and other potential noncompliance with federal regulations. Auditor Recommendation. We recommend the University implement procedures to review the indirect cost rate input and automated entries by responsible individual on a monthly or quarterly basis. Corrective Action. The University will establish formal procedures to review the indirect cost rate input and automated entries by additional individual on a monthly or quarterly basis. Responsible Person. Yah-Sheba Jenkins, Controller Anticipated Completion Date. June 30, 2026

Finding 2025-002 Lack of Internal Controls over Activities Allowed and or Unallowed and Allowable Costs/Activities – Cash Disbursements Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD will modify the written credit card policy that details rules for using the card, which includes employees taking responsibility for the use of the credit card and for the safekeeping of the credit card. Credit cards will be limited to the Superintendent, BOE President and the Academic Director. The cardholder will follow the general purchasing processes that begin with approval to purchase. Procedures for reporting credit card use with monthly reconciliations with receipts will be shared with cardholders. DocuSign will be used for electronic signature approval. Proposed Completion Date: Implemented July 1, 2025.

Finding 2025-006 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Activities Name of Contact Person: Tamara VanderPool, Payroll Director and Lisa Pearce, Business Manager Root Cause: **Insufficient staffing level. Inconsistent application of the personnel action forms and required documentation for changes to payroll details. Corrective Action Plan: • Clarify roles and responsibilities regarding payroll processing. • Establish a review process of all payroll transactions and documentation. Proposed Completion Date: Fall of 2025.

As part of the proposal negotiations for the federal program, initial discussions with the sponsoring office of the federal program included a limitation for allowable compensation for employees that were not the Executive Director. Although the limitation was intended to be removed from the final agreement, the budgeted requested salaries were not updated. The Assistance Agreement has been modified to remove any such limitation prospectively beginning with Modification 0015 in April 2024. Implementation Date – April 2025

Audit Finding: 2024-001 – Lack of Documentation of Review and Approval Planned Corrective Action(s): SIG-NAL will enhance internal controls by implementing formal review and approval processes for payroll, expenses, and financial reporting. The organization will require documented evidence (digital or written) of all reviews and approvals and will maintain these records in a standardized, centralized system. The Finance Team will ensure that all controls are performed and documented in accordance with 2 CFR Part 200 requirements. Updated internal control policies and procedures were formally adopted in 2025 and implementation began immediately. Standardized review documentation is now required for payroll, expenses, and financial reporting, and oversight by the external accounting firm is ongoing to ensure compliance with 2 CFR Part 200. Anticipated Completion Date ● Implemented in 2025 (Monitoring ongoing) Responsible Party ● Director of Operations, with support from the Finance Team and Executive Director

Review and update the Accounting Manual as needed • Re-train employees in the need for proper use of purchase orders, needed documentation to support charges to federal awards, and detailed receipts to show taxes paid (if any) according to the Accounting Manual

FINDING 2024-012 Finding Subject: Title I Grants to Local Educational Agencies - Level of Effort – Maintenance of Effort, Earmarking Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will document all parent involvement expenditures with the object code 661 and all homeless set-aside funds with the object code 660 to ensure that Matching, Level of Effort, and Earmarking compliance requirements are consistently met. Any funds not expended will be carried over under the same Earmarking for the following grant period. The school corporation will properly document all Title I grant expenditures from accounts payable vouchers to payroll and fringe benefits. This documentation will ensure that we can calculate and substantiate that we met earmarking requirements for the grant prior to the closing of the allowable period. Anticipated Completion Date: The school district will comply with this plan for the FY25 Title I grant and for all Title grants moving forward. This corrective action will be fully completed by June 30, 2026.

We have conducted a thorough review of our existing procedures for managing Title III funds to identify gaps and areas of improvement. Management hired a Title III consultant to assist with proper accountability and to establish clear guidelines for fund allocation, monitoring, and reporting. Management will conduct periodic internal reviews to verify adherence to established controls and address discrepancies promptly.

If ED has questions regarding this plan, please contact Dr. Douglas Allen, Vice President for Finance and Administration, Talladega College at (256) 761-6100.

Finding 2024-214: The Department does not have documented internal controls for cash draws and requested reimbursement for the same $175,500 grant expenditure twice. Related to Prior Finding: N/A Agency’s view: Agree Corrective Action Plan: DEQ has had significant turnover in the fiscal office, which has resulted in gaps of knowledge of policies and practices. In summer 2025, DEQ leadership reorganized the fiscal department to improve efficiency, enhance oversight of grants and contracts, and strengthen financial controls. The fiscal office is currently in a rebuilding phase and is dedicated to training and developing staff, implementing best practices, and documenting processes and procedures, including those for federal grant compliance. The duplicate payment in question was issued but not redeemed. The issuance was to a similar, but incorrect, vendor name and was caught by staff before it was sent to the vendor. The transaction was cancelled in Luma but was not properly recorded in the following draw request. Fiscal staff now perform a thorough review of transactions before a loan draw is finalized in Luma, reconciling the transactions from the Loans and Grants Tracking System (LGTS) to the information generated in the Luma draw invoice. The reconciling and supporting documentation from LGTS is attached to the Luma draw invoice. Anticipated Corrective Action Date: January 31, 2026 Responsible for Corrective Action: Linda Brown, Financial Executive Officer, at 208-373-0292 or linda.brown@deq.idaho.gov

Finding 2024-212: The Department’s Indirect Cost Rate Proposal (ICRP) contained multiple errors. Related to Prior Finding: N/A Agency’s view: Agree Corrective Action Plan: DEQ has had significant turnover in the fiscal office, which has resulted in gaps of knowledge of policies and practices. In summer 2025, DEQ leadership reorganized the fiscal department to improve efficiency, enhance oversight of grants and contracts, and strengthen financial controls. The fiscal office is currently in a rebuilding phase and is dedicated to training and developing staff, implementing best practices, and documenting processes and procedures, including those for federal grant compliance. The agency has new staff that will be preparing and submitting the indirect cost rate proposal this year and will take the auditor’s recommendations very seriously in our development and preparation. We have reached out to our federal oversight agency for assistance and direction Page 2 of 3 and are committed to maintaining a file with all supporting documentation used to compile and prepare the proposal, as required by 2 CFR 200. Anticipated Corrective Action Date: January 31, 2026 Responsible for Corrective Action: Linda Brown, Financial Executive Officer, at 208-373-0292 or linda.brown@deq.idaho.gov

Finding 2024-202: The Cost Allocation Plan (CAP) used in fiscal year 2024 was not approved by the RSA as required and contained multiple errors. Related to Prior Finding: N/A Agency’s view: Agree Corrective Action Plan: ICBVI recognizes it did not submit its Cost Allocation Plan for annual recertification as required and that the CAP contained errors due to transition challenges with the new accounting software (Luma). CAP Update and Approval: The CAP will be revised to reflect the current chart of accounts and reporting parameters of the Luma system. We have a meeting scheduled with the Director of the Indirect Cost Division at the US Dept of Education on 12/10/25. We will be submitting an updated CAP for review and approval. Annual submission for federal recertification will be scheduled and tracked. Documentation: All expenditure data and supporting documentation will be sourced directly from Luma and retained for verification Anticipated Corrective Action Date: 1-15-26 Responsible for Corrective Action: Corey Bresina, Administrative Services Manager, 208-639-8369, cbresina@icbvi.idaho.gov

Finding 2024-201: Multiple errors were identified in the amounts reported on the Rehabilitation Services Administration (RSA) reports required for the Rehabilitation Services-Vocational Rehabilitation Grants to States. Related to Prior Finding: N/A Agency’s view: Agree Corrective Action Plan: These errors in quarterly and final RSA-17 reports are acknowledged, and immediate measures are being taken to address root causes: Accurate Financial Reporting: ICBVI will develop detailed procedures to ensure all amounts reported on federal forms are reconciled to supporting documentation in the accounting system (Luma) prior to submission. Review and Oversight: A two-person review process will be formalized, ensuring every report is checked for accuracy by a knowledgeable reviewer before submission. Documentation and Training: Supporting documentation for all line items will be archived securely. Staff will receive training in federal grant reporting standards. Anticipated Corrective Action Date: 1-15-26 Responsible for Corrective Action: Corey Bresina, Administrative Services Manager, 208-639-8369, cbresina@icbvi.idaho.gov

Finding 2024-001 (A/B – Activities Allowed or Unallowed and Allowable Costs / Cost Principles) US Department of Homeland Security Federal Emergency Management Agency (FEMA), Assistance Listing 97.036 COVID-19 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) Name of contact person: Warren Pate, Vice President Finance Corrective action: The Vice President Finance will oversee repayment to FEMA a total of $79,118.82, representing invoices that were submitted for reimbursement more than once ($77,521.50), and an invoice for which reimbursement was requested greater than the invoice amount ($1,597.32). Additionally, a review of all project amounts planned to be submitted for future FEMA reimbursement will be conducted at the direction of the Vice President Finance, to ensure the completeness and accuracy of all project details. Proposed completion date: March 31, 2025

Official: Janelle Lawrence, Executive Director. Date of Discussion: October 3, 2025. Planned Corrective Actions: To reduce misidentification of expenses for allowed activities, the Organization has implemented a dual-review process for all grant expenses to ensure that eligible costs are identified and submitted. Staff will also receive updated training on allowable expense categories to reduce misinterpretation. In monitoring payroll activities, the Organization has revised its grant payroll allocation process to ensure that duties performed under specific roles are billed at the appropriate rate. Future budgets will more clearly distinguish between roles and corresponding pay rates to prevent overages. All projects will undergo budget-to-expense reconciliation on a monthly basis to safeguard against missed claims and ensure that grant resources are maximized without exceeding allowable limits.

Finding 2024-002: Allowable Costs Condition: The Organization did not allocate shared costs appropriately between program and non-program related activities, resulting in approximately $15,078.56 in costs charged incorrectly to the Weatherization Assistance Program. Corrective Action: Management has developed and implemented a cost allocation methodology consistent with 2 CFR 200.400. Beginning in 2025, costs will be allocated between programs (Weatherization Assistance Program and others) based on employee time distribution. This allocation policy will be documented and reviewed annually. Staff involved will be trained to ensure consistent application of cost allocation procedures. Responsible Party: Program/Fiscal Director

COVID-19-Coronavirus State and Local Relief Funds (CSLRF)-Assistance Listing No. 21.027 Allowable Activities/Costs Recommendation: The Town should review and enhance controls and procedures where necessary. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will continue to review and enhance controls where necessary to ensure that all State and Local Fiscal Recovery Funds (SLFRF) expenditures support an eligible COVID-19 public health or economic response. Name(s) of the contact person(s) responsible for corrective action: Tyler Home, Director of Finance Planned completion date for corrective action plan: 07/01/2024

2024-015 Oregon Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program Management Response: We agree with this recommendation. Interest related to past due amounts will be charged to general funds only. Expenditures will be reviewed both by staff and approving parties to ensure only allowable expenditures are charged to the federal grants. The questioned costs of $68 will be refunded and reported to CMS on the CMS 64. The agency will ensure that future contracts that include any incentive funds for surveys will be structured such that incentives are billed under separate coding that will be charged to general funds only. The questioned costs of $28,801 will be refunded and reported to CMS on the CMS 64 Anticipated Completion Date: April 30, 2025 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director