Corrective Action Plans

OTAG has reviewed the payroll transactions identified during the audit and has initiated corrective measures to strengthen controls over payroll documentation, appendix charging, and period-of-performance compliance. Payroll expenditures charged to Master Cooperative Agreement Appendices will be subject to quarterly review to verify that timesheets, payroll registers, and supporting documentation are complete, accurate, and retained in accordance with the SF-270 submission requirements. Payroll charges will also be reviewed against periods of performance before posting to ensure costs are assigned to the correct award. OTAG will revise its SOPPs to establish formal procedures for payroll certification, documentation retention, reconciliation of payroll records to timesheets, and review of Master Cooperative Agreement funded personnel costs. Training will be conducted for personnel on documentation standards and allowable cost requirements. To prevent recurrence, monthly reconciliations between payroll records and supporting timesheets will be performed and documented. Quarterly compliance reviews will evaluate payroll charges and supporting documentation for accuracy and completeness. Monitoring & Accountability: The Adjutant General and Executive Director will jointly oversee implementation. Results of monthly reconciliations and quarterly reviews will be reported to executive management.

DHS adopted the electronic Timeforce (STATS) system for payroll, replacing manual processes. Time and attendance are approved through management levels, with payroll based on Notice of Personnel Action (NOPA) cost centers. Financial Analysts reconcile payroll, and a workflow ensures accurate NOPA listings for payroll purposes. Additionally, in order to ensure that Notices of Personnel Actions are updated on a timely basis, ensuring that salaries are charged to the respective account, DHS has implemented the following process: Provisional Payroll Codes are requested prior to the close of the Fiscal Year by the Department of Finance through the Office of Management and Budget through the established process. Once the codes are received, the Division of Human Resources will update the most current Personnel Distribution Sheets to reflect active employees. The sheets will be submitted to Fiscal for certification by the CFO.NOPA’s are updated with the provisional codes. Lastly, 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. The Federal Grants Financial Analyst, once onboarded, will also play a key role in ensuring that transactions are recorded in the appropriate accounting period and that costs are properly allocated. DHS has added an additional layer of monitoring with the onboarding of a Director of Federal Grants. The newly created unit of Audit and Compliance, once staffed will play a crucial role with periodic monitoring.

2024-010 – EDUCATION STABILIZATION FUND - LACK OF SUPPORT OVER ESSER FUNDS – ALN 84.425 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 was unable to provide supporting documentation for expenses charged to the Education Stabilization Fund. 13 of the 60 we sampled did not have any support, leaving them with known questioned costs of $171,408. Management’s Response: We agree. WBSD#7 created a new Grants Coordinator position in July 2023 with one of the specific responsibilities for that position being oversight of all Federal programs. This oversight responsibility includes monitoring expenditures to ensure all expenditures are allowable within the parameters of each program and also that proper documentation for those expenditures has been maintained. It has taken the district some time to get this area cleaned up. Anticipated Completion Date: FY 2025

2024-009 – TITLE I –INADEQUATE SUPPORTING DOCUMENTATION – ALN 84.010 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 was unable to provide supporting documentation for expenses charged to the Title I program. 54 of the 60 expenditures we sampled did not have any support, leaving them with known questioned costs of $136,372. Management’s Response: We agree. WBSD#7 created a new Grants Coordinator position in July 2023 with one of the specific responsibilities for that position being oversight of all Federal programs. This oversight responsibility includes monitoring expenditures to ensure all expenditures are allowable within the parameters of each program and also that proper documentation for those expenditures has been maintained. It has taken the district some time to get this area cleaned up. Anticipated Completion Date: FY 2025

UCM will develop and implement comprehensive written policies and procedures addressing cost eligibility, documentation standards, and the requirement that only actual costs are charged to federal awards. The procedures will require costs to be supported by appropriate source documentation, such as invoices, receipts, payroll records, allocation schedules, contracts, approvals, proof of payment, and other relevant records. UCM will implement a review process to ensure costs charged to federal awards are based on actual expenditures recorded in the accounting system, properly supported, charged to the correct funding source, and consistent with Uniform Guidance requirements. Budgeted, estimated, or unsupported amounts will not be charged to federal awards unless specifically permitted by the award terms and adjusted to actual costs within the required reporting period. UCM will also strengthen controls over electronic signatures used in grant, payroll, expenditure, or approval documentation. Electronic signature procedures will require appropriate IT controls so that only the individual providing approval can select or apply their own name. UCM will review user access, system permissions, and approval workflows to ensure signatures are tied to the appropriate user and that evidence of approval is retained. Staff responsible for grant accounting, payroll allocation, accounts payable, electronic approval workflows, and federal award compliance will receive Uniform Guidance training and training on the updated documentation, actual cost, and electronic signature procedures. Responsible for Corrective Action: Cristina Schoendorf, Chief Program Officer Shruti Jha, Senior Director of Finance Deborah Ewell, Director of Human Resources Laura D’Ambrogi, Grants Manager IT Partner Anticipated Completion Date: December 31, 2026

VIEWS OF RESPONSIBLE OFFICIALS The PRDF Human Resources Department will conduct personal file reviews at the beginning of next fiscal year; to include any missing paperwork and the department will establish as a procedure a periodical review of all files. IMPLEMENTATION DATE First quarter of Fiscal Year 2026-2027 RESPONSIBLE PERSON Waleska Lopez Faria Assistant Secretary for Human Resources

VIEWS OF RESPONSIBLE OFFICIALS ADSEF acknowledges the findings regarding the lack of documentation for one employee and the payroll discrepancies identified in the FY 2024 single audit. We conclude that the inability to provide personnel files for validation of wages charged to the federal program constitutes a material weakness in internal controls over allowable costs. ADSEF will conduct a comprehensive reconciliation of all payroll registers against personnel records for the affected periods to ensure that only eligible, verified, and properly documented costs are charged to the TANF program. Action step: 1. Personnel Record Audit 2. Policy Update 3. Payroll Reconciliation 4. Training IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Coral M. Caceres Alvarez Auxiliary Administrator Human Resources Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget

Recommendations: Management should implement procedures to ensure that all payroll-related costs, including bonuses and stipends, are properly classified within the accounting system. Management should also establish review controls over coding of expenditures to ensure consistency with Uniform Guidance and grant reporting requirements. Views of responsible officials and planned corrective actions: Management agrees with the finding and indicates that it will strengthen review procedures over expense classification and ensure that compensation costs are properly recorded within payroll-related accounts going forward. Anticipated Completion Date: September 30, 2026

Recommendations: Management should implement procedures to review all non-routine or capital-related expenditures for allowability and compliance with grant terms prior to charging such costs to federal awards, including obtaining required approvals where applicable. Views of responsible officials and planned corrective actions: Management agrees with the finding and indicates that it will implement additional review procedures to ensure that all expenditures charged to federal programs are evaluated for allowability and properly approved prior to being incurred. Anticipated Completion Date: September 30, 2026

Finding Number: 2024-009 Planned Corrective Action: The district will implement enhanced procedures for monitoring and tracking federal grant expenditures to ensure expenditures do not exceed awarded grant amounts and are properly reported. The Treasurer will review grant agreements, monitor available grant balances on a regular basis, and maintain supporting documentation for all federal expenditures and reporting to ensure compliance with federal requirements and accurate reporting on the Schedule of Expenditures of Federal Awards. At the time of the creation of this corrective action plan all COVID-19 related grants have been totally expended. The district is required to provide the board, ODEW, and the Financial Planning Commission with monthly monitoring documents. Within these documents is contained a worksheet that requires the treasurer to list each fund balance for all accounts and explain any negative balances and whether a PCR has been created to eliminate negative balances. This policy forces the district to pay close attention to any grant funds that are carrying negative balances. Anticipated Completion Date: 05/31/2026 Responsible Contact Person: Ashley Miller

Finding 2023-006 ● Criteria or Specific Requirement: 2 CFR Section 200.403 states the factors that determine allowability of costs charged to federal awards and requires costs to be determined in accordance with generally accepted accounting principles. ● Condition: We identified costs incurred in 2023 that were incorrectly recorded as 2024 costs and charged to federal awards. ● Corrective Action Plan: Management agrees with the finding and they will evaluate our findings to determine an appropriate corrective action. After evaluation, Glacierland will designate specific tasks to the ‘Bookkeeper’ and ‘Executive Assistant’. These tasks will be reviewed by one another and the Executive Director. Creation of these two roles and review procedures will allow for increased internal controls to ensure costs are recorded in accordance with GAAP. Contact Person: Kirsten Jurcek Anticipated Date of Completion: September 1, 2026

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

The agency proactively enacted rigorous internal controls and systemic enhancements for FY25 to ensure optimal oversight and adherence to federal guidelines. Management has addressed this recommendation by deploying a strict, comprehensive expense request process to ensure robust internal controls over all Other Than Personal Services (OTPS) expenditures. To ensure full compliance with 2 CFR 200.303 and 200.403, Finance has deployed the following enhancements to our accounts payable workflows: • Strict Electronic Approval Workflow: Finance has established a stringent review and approval protocol that requires direct involvement from Program Directors and Department Heads. All OTPS expenditures are now routed through a formalized electronic workflow, which mandates documented review and secure electronic signatures from authorized leadership prior to any payment processing. • System-Integrated Documentation: The new process strictly requires that all supporting documentation-including invoices, receipts, and evidence of allowability-be provided upfront. These documents are now uploaded and attached directly to the specific transaction within the accounting program, creating a permanent, easily accessible, and audit-ready trail for every federal charge. • Targeted Training and Oversight: To support this modernized workflow, Finance is providing targeted training to all staff responsible for initiating and approving transactions, ensuring a clear understanding of Uniform Guidance requirements. Furthermore, Finance leadership conducts periodic supervisory reviews directly within the accounting system to verify that all electronic approvals are captured and source documents are properly attached.

The Parish has written a Standard Operating Procedure for "Grant Maangement - Financial Reporting & Reconciliation" which outlines the role of the Finance Department in monitoring grant activities including measures to ensure correct general ledger coding for budget planning, complete and accurate recording of grant expenditures and revenues, and administrative review to confirm reconciliation of grant activities against the general ledger on a monthly basis.

U.S. Department of Health and Human Services - Community Service Block Grant Material Weakness in Internal Control over Compliance - Other Matters Recommendation: We recommend the Neighborhood Service Center, Inc require both check signers to evidence review and approval of supporting documentation prior to signing the check. Documentation of that review and approval shold be readily for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: All checks presented for signatures have supporting documentation attached. Authorized check signers are instructed to review all documentation for appropriate authorization, payee name, and amounts prior to signing checks. No checks are signed without supporting documentation. The agency will require check signers to initial the check request page or other supporting documentation when signing checks for grant expenditures. The Neighborhood Service Center, Inc. is implementing a procedure to provide the Finance Committee of the Board with a listing of all checks issued between Board meetings for their review/reference. The Finance Director keeps all check stock locked in their office to avoid any potential misuse of the check stock. Name of the contact persons responsible for corrective action: R. Andrew Hollis, Executive Director Michele Lednum, Finance Director Planned completion date for corrective action plan: For immediate implementation and ongoing.

Audit Finding: 2024-001 Non-Material Non-Compliance – Allowable Costs and Activities; 2024-002 Revenue Recognition – Material Weakness Corrective Actions: This plan outlines the steps to address the staffing shortage and implement necessary controls to ensure financial statement accuracy and compliance. Phase 1: Immediate Actions Prioritize Key Hires: The immediate priority is to recruit and hire a Controller with significant non-profit accounting experience. This individual will be crucial in designing and implementing the necessary internal controls. 1. Interim Support (If Needed): While searching for permanent staff, explore options for interim accounting support through a consulting firm or temporary staffing agency specializing in non-profit organizations. This can provide immediate assistance with critical tasks and help bridge the gap until permanent staff are in place and sufficiently trained. 2. Documented Job Descriptions: Develop detailed job descriptions for the Controller, Senior Accountant, and Staff Accountant positions. These descriptions should clearly outline the required qualifications, responsibilities, and reporting lines. Emphasis should be placed on experience with non-profit accounting principles (GAAP), fund accounting, and relevant regulations. 3. Recruitment Strategy: Implement a robust recruitment strategy that includes: ○ Posting job openings on relevant job boards (e.g., Idealist, LinkedIn, specialized non-profit job sites). ○ Networking with professional organizations (e.g., state non-profit associations, accounting professional groups). ○ Partnering with recruitment agencies specializing in non-profit finance. Phase 2: Staffing and Implementation 1. Hire Controller: Complete the recruitment process and hire a qualified Controller with proven non-profit accounting experience. 2. Hire Senior Accountant: Once the Controller is in place, begin the recruitment process for a Senior Accountant to support the Controller and manage day-to-day accounting operations. Experience with fund accounting and grant management is highly desirable. 3. Hire Staff Accountants: Recruit and hire the necessary number of Staff Accountants to handle transaction processing, reconciliations, and other accounting tasks. 4. Control Design and Implementation: The Controller, in collaboration with the Senior Accountant, will be responsible for designing and implementing the necessary internal controls. This includes: ○ Segregation of duties (e.g., authorization, custody, recording). ○ Approval processes for expenditures and journal entries. ○ Regular reconciliations of bank accounts and other key accounts. ○ Documentation of accounting policies and procedures. Phase 3: Review and Monitoring (Ongoing) 1. Training: Provide comprehensive training to all finance staff on non-profit accounting principles, internal controls, and the organization's specific policies and procedures. 2. External Review (Optional): Consider engaging an external accounting firm to review the implemented controls and provide recommendations for improvement. This can provide an independent assessment of the effectiveness of the controls. 3. Regular Monitoring: The Controller will be responsible for regularly monitoring the effectiveness of the internal controls and reporting any deficiencies to the Executive Director and the Board of Directors. 4. Policy Updates: The Controller will ensure that accounting policies and procedures are reviewed and updated regularly to reflect changes in regulations and best practices. Responsible Parties: ● Executive Director (Todd Hixson) : Overall responsibility for implementation of the plan. ● Board of Directors: Oversight and approval of the plan and budget. ● Controller: Responsible for designing, implementing, and monitoring internal controls. Timeline: Phases 1 and 2 were completed as of January 2025. As noted above, phase 3 is an ongoing process. Regular progress updates have been and will continue to be provided to the Executive Director, Finance Steering Committee, and the Board of Directors as appropriate. This Corrective Action Plan demonstrates Safe Harbor Crisis Center’s commitment to addressing the identified control deficiencies and strengthening its financial management practices. By implementing this plan, the agency will be better positioned to ensure financial accountability, transparency, and compliance in service of the mission.

Finding 2024-002 Information on the federal program: Federal Agency: Federal Transportation Administration Pass-Through Entity: N/A Federal Program: Federal Transit Cluster Assistance Listing Number: 20.507 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs – Cost Principles Audit Findings: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Within the sample of 42, we noted that 9 timecards for bus operators did not have documented review. Documented review was implemented in September 2024. All instances of the error were prior to September 2024. We also noted 1 timecard showed 2 hours more than reflected on the pay register, resulting in a net underpayment. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding. Each department is responsible for ensuring proper timecard records with approval are maintained. A documented review process for bus operators was implemented over timecard records in September 2025. Payroll is responsible for ensuring that the appropriate number of hours are paid to each employee. Additional review will be performed prior to issuance of pay checks to ensure that the appropriate number of hours are being paid.

Planned Corrective Action: The Division will implement their control of ensuring that they only charge allowable costs incurred during the approved budget period of a federal award’s period of performance or will obtain authorization from the grantor for any costs incurred before the grant's approved budget period. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller

Finding No.: 2024-049 Activities Allowed or Unallowed: Allowable Costs/Cost Principles Responding Agency: Guam Homeland Security (GHS) Responsible Personnel: Esther Aguigui, Director Guam Homeland Security (GHS) will make sure that proper supporting documentation is available. GHS will also identify department personnel responsible.

Finding No.: 2024-040 Activities Allowed or Unallowed: Allowable Costs/Cost Principles Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director The Bureau of Child Care Services (BCCS) disagrees with this finding. The questioned transactions relate to a major system migration from the AS400 to the D365 system, which temporarily impacted the traceability of certain records. During this transition, some data identifiers were reformatted to fit the new system's structure. However, this was a synchronization issue rather than a lack of oversight, and BCCS maintains that all costs are allowable, necessary, and reasonable under CCDF requirements. Supporting documents exist and were provided after a subsequent request on February 9, 2026, via One Drive link.

Finding No.: 2024-032 Activities Allowed or Unallowed: Allowable Costs/Cost Principles Responding Agency: Guam Environmental Protection Agency (GEPA) Responsible Personnel: Michelle Lastimoza, Director Request to DOA will require immediate collaboration between Guam EPA and DOA to gather, reconcile, and provide all documentation supporting compliance of allowable costs incurred during the federal award period of performance as specified in the terms and conditions of the federal award or in the approved extension.

Finding No.: 2024-025 Activities Allowed or Unallowed: Allowable Costs/Cost Principles Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency disagrees with this finding. Please refer to a letter dated March 31, 2026, regarding Reports on Compliance September 30, 2024.

Finding No.: 2024-021 Activities Allowed or Unallowed: Allowable Costs/Cost Principles Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency disagrees with this finding. Please refer to a letter dated March 31, 2026, regarding Reports on Compliance September 30, 2024.

Finding No.: 2024-018 Eligibility Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency is reviewing the management of Federal Grants to ensure robust handover and succession plans are in place for future programs. The sudden passing of the ERA Program Coordinator directly impacted overall management of the program.

Finding No.: 2024-013 Allowable Costs/Cost Principles: Procurement, Suspension, and Debarment Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director Agency disagrees with 2 out of the 3 findings. • Condition 1 regarding the Authorization To Proceed (ATP), as per the Grant and Cooperative Agreement and the Grant Terms and Conditions, it did not state that an ATP is required to begin work on the grant for D20AP00048 and D21AP10145.The Government complies with ATP requirements for grants which mandate such compliance. If the grant is silent, no ATP is required.. • Condition 2 GSA will continue to verify vendor eligibility through SAM.gov prior to contract award. Documentation of the verification will be retained in the procurement file for each transaction. • Condition 3 The necessary controls will be strengthened when the updated Federal Grant module is fully implemented.