Corrective Action Plans

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.

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

2024-014 Oregon Department of Human Services/Oregon Health Authority Implement control procedures around cost allocation system inputs Management Response: We agree with this recommendation. The Office of Financial Services will review the existing controls in Cost Allocation system and identify areas that need additional or new control procedures to ensure system inputs are appropriately identified and processed. In addition, we will review the noted errors and make appropriate corrections. Anticipated Completion Date: June 30,, 2025 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director

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

2024-014 Oregon Department of Human Services/Oregon Health Authority Implement control procedures around cost allocation system inputs Management Response: We agree with this recommendation. The Office of Financial Services will review the existing controls in Cost Allocation system and identify areas that need additional or new control procedures to ensure system inputs are appropriately identified and processed. In addition, we will review the noted errors and make appropriate corrections. Anticipated Completion Date: June 30,, 2025 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director

Dear Mr. Waguespack: The Department of Children and Family Services (DCFS) has received the finding titled “Control Weakness and Noncompliance Related to Cost Allocation Process" and appreciates the opportunity to provide this response to your office's finding. Finding: The Department of Children and Family Services did not have adequate controls in place to ensure the correct allocation of expenditures in accordance with the Cost Allocation Plan, which assigns costs to federal programs. Recommendation: DCFS should strengthen internal controls over the cost allocation review process. DCFS Response: DCFS concurs with the LLA's finding and recommendation. Corrective Action Plan: DCFS's Division of Management and Finance has implemented a corrective action plan aimed at addressing the identified issue and strengthening internal controls. 1. Internal Procedure Revisions: The Division of Management & Finance has trained relevant stakeholders on proper cost allocation procedures, emphasizing compliance with federal regulations and accurate reporting. Additionally, internal procedures have been revised to strengthen the review process, ensuring expenditures are correctly allocated in accordance with the Cost Allocation Plan. 2. Strengthening Internal Controls & Ongoing Monitoring: To prevent recurrence, the Cost Allocation team has implemented a more rigorous review process for cost allocation supporting documentation. This includes, but is not limited to, generating a LaGov report during the three-day fiscal month close to proactively identify any expenditures incorrectly allocated to a closed grant. This step will ensure a real-time review process, allowing errors to be detected and corrected promptly. DCFS acknowledges the importance of accurate cost allocation to ensure compliance with federal regulations and the proper distribution of expenditures across programs. Strengthening our internal controls and reviewing processes remains a top priority to prevent misallocations. Should you require additional information, please contact Christopher Bahm at Christopher.Bahm.DCFS@la.gov or (225) 219-0536.

Lower East Side Tenement Museum will adopt written policies and procedures, and standards of conduct as required by 2 CFR 200, Subparts D and E.

Views of Responsible Officials and Planned Corrective Action: Moving forward the Department will require recipients to provide a list of invoices with the invoice date, period of performance, invoice amount and amount requested/disbursed from ARPA and/or other funding sources to be included with each disbursement request. Staff training will be modified to ensure staff understand allowable expenditures and period of performance restrictions. Anticipated Completion Date: June 30, 2025 Contact Person: Debby Dickson Water Development Division Manager Arkansas Department of Agriculture-Natural Resources Division 1 Natural Resources Drive Little Rock, AR 72205 (501) 225-1598 Debra.Dickson@agriculture.arkansas.gov

Views of Responsible Officials and Planned Corrective Action: The Arkansas Department of Education (ADE), Division of Elementary and Secondary Education (DESE), Health and Nutrition Unit (HNU), concur with the finding. The HNU Finance staff implemented procedures for meal claim payment requests which include an initial and final review of all requests to be conducted by two (2) staff. The review process includes, but is not limited to, ensuring expenditures are assigned correct codes related to the appropriate funding source within the appropriate grant year, mitigating the Child Nutrition Program (CNP), Child and Adult Care Food Program (CACFP) Sponsor Administrative expenditure errors going forward. When the request is determined to be compliant, the Associate Director of Finance and Training approves payments before being forwarded to the ADE Finance team for payment. Anticipated Completion Date: March 15, 2025 Contact Person: Sheila Chastain Associate Director Arkansas Department of Education, DESE, Nutrition Services #4 Capitol Mall, Box #12 Little Rock, AR 72201 (501) 324-9502 Sheila.Chastain@ade.arkansas.gov Pamela Burton Director Arkansas Department of Education, DESE, Nutrition Services #4 Capitol Mall, Box #19 Little Rock, AR 72201 (501) 320-8978 Pamela.Burton@ade.arkansas.gov

Management’s Response: The Finance team of Financial Controller and Senior Accountant are responsible for the reconciling grant revenue, grant receivables and unearned revenue accounts monthly. Proper monitoring and accurate documentation of COVID-19 related activities, including any and all expenditures will be tracked, properly documented and reconciled. Training and monitoring of grant activity will continue in fiscal year 2025. This will be completed by September 30, 2025. Estimated Completion Date: September 30, 2025 Responsible Position: Brochelle Shirley, Financial Controller, and Dawn Bowens, Senior Accountant

Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention. To further stabilize and formalize these improvements, a Certified Public Accountant will be added as a consulting CFO. This role supports the ongoing development of fiscal operations. Additionally, it is recognized that the payroll vendor, ADP, was initially slow to address issues with uploaded data when notified by CAPNC, responded officially after CAPNC alerted repeatedly that it had now elevated to an audit issue. This issue has since been remedied. Staff have shown marked improvement over previous legacy staff in documentation, accountability, and monitoring. Payroll services in general are able to provide real-time features and accountability for time, resulting in more accurate, reliable, and allocable time recording. Payroll records are reviewed, and time studies are performed for all staff to ensure the allocation methodology is appropriate, consistent, and aligned with staff performance. Wipfli Consulting is providing technical assistance over an additional contract period to update policies and procedures for the fiscal area, in accordance with Uniform Guidance, and allow for advance reporting, as well as provide CPA support. The curriculum includes comprehensive training for all administrative leadership staff, covering fiscal oversight, grants management, and compliance. Allocations are regularly reviewed by the leadership team to ensure appropriate methodology and consistency with grant expectations and regulations. Board members have access to the accounting software through a Board portal for further oversight, enhancing transparency and accountability. Review of finance in conducted monthly by Board of Director’s Finance Committee.

FINDING 2024-003 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: Material Weakness, Other Matters The School District is required to set aside a reasonable amount of funds to meet the needs of the homeless population in the school community. These funds cannot be used for any other purpose than the needs of the homeless population. At the end of the grant period, unspent funds must be carried forward to the next grant year. If the school district meets the obligation of attempting to spend the homeless set-aside funds, the funds may be carried over into the general Title I award for the next grant. The funds are not required to go back into the homeless reservation. The 2021-2022 grant award homeless reservation was $8,600. The School Corporation did not spend any of these funds, but was determined to have met their obligation based on documentation provided. The School Corporation did not provide evidence that the $8,600 was carried over to the next school year. However, it was determined that $276 of the $8,600 was used inappropriately in the current school year for other Title I, Part A activities, and not for the needs of the homeless student population. This noncompliance and lack of internal controls was isolated to the 2022-23 school year. Contact Person Responsible for Corrective Action: Kari Dyer Contact Phone Number and Email Address: (574)825-9425; dyerk@mcsin-k12.org Views of Responsible Officials: The School District concurs with this finding. Homeless Reservation funds should only be used for the needs of the homeless student population. Description of Corrective Action Plan: The School District is implementing new monitoring procedures for the Title I Fund to verify unspent funds for the Homeless Reservation are not used for any other Title I expenses. After the 2022-23 school year, the School District changed the way in which it expends the Homeless Reservation by utilizing these funds for salary and benefits of a Homeless Laision. Monitoring these expenditures requires dual signature approvals by the Business Assistant and the Title I Program Director prior to being released. Anticipated Completion Date: Immediate