Corrective Action Plans

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.

Finding No. 2024-002 Loan Originations Involving Fraudulent Documentation Federal Agency: U.S. Department of Commerce Economic Development Administration Program Titles and ALN Numbers: EDA Revolving Loan Fund Program Capital Allocation - New York Contractor Loans (a non major program) (11.307) Federal Grant Numbers: Award #01-79-15074 Compliance Requirements: Activities Allowed and Unallowed and Allowable Costs Contact Person: James H. Bason, President and Chief Executive Officer, TruFund Financial Services, Inc., 9 East 40th, NY 10016 Corrective Action: (1) Federal agency notification: Management has notified the U.S. Department of Commerce Economic Development Administration of this finding and the questioned cost, and will cooperate fully with any federal review or recovery process. (2) Federal corrective action plan: Management has provided EDA with a corrective action plan addressing the specific internal control deficiencies applicable to federally funded loan programs. (3) Enhanced internal controls over federally funded programs: All corrective actions implemented under Finding 2024-001 apply equally to all federally funded loan programs, including enhanced verification, segregation of duties, and suspicious activity monitoring. (4) Replenishment of EDA Revolving Loan Fund: Subsequent to year-end and prior to the issuance of this report, TruFund replenished $410,000 in non-federal, unencumbered funds to the EDA Revolving Loan Fund, in response to EDA's request to restore the fund balance. Anticipated Completion Date: April 30, 2026

Assistance listing numbers and program names: 21.023 COVID-19 Emergency Rental Assistance Program 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Agency: Department of Economic Security (DES) Name of contact person and title: Molly Bright, Community Services Division Assistant Director Anticipated completion date: June 30, 2026 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: 1. Ensure benefit payments are for allowable costs paid to or on behalf of eligible program applicants. The Division will review and confirm that benefits payments paid to or on behalf of eligible program applicants are allowable expenditures of the federal funding being disbursed. 2. Update existing policies and procedures to include a post-review of the benefits subsystem’s automated review of eligibility requirements, such as verifying the income thresholds and geographic location aligned with the Division’s written policies and procedures, and supported by required documentation. The Division should correct any inaccurate eligibility determinations identified during the post-review. Emergency Rental Assistance Program policies and procedures require validation of eligibility based upon substantiating applicant documentation, including household income and geographic location. The Division will update Division policy to include a post-review process to identify and correct any errors or discrepancies. 3. Allocate sufficient staffing resources to perform a thorough evaluation of program benefits applications and provide training on eligibility requirements and allowable benefit payments. The Division will allocate sufficient staffing resources to evaluate program benefits applications and provide training on eligibility requirements and allowable benefit payments. 4. Work with the federal agencies to resolve the $64,131 in program funds that were spent in violation of federal regulations, policies and procedures, and may need to be returned to the federal agencies. The Department of Economic Security will address the audit recommendations as follows: 1. Ensure benefit payments are for allowable costs paid to or on behalf of eligible program applicants. The Division will review and confirm that benefits payments paid to or on behalf of eligible program applicants are allowable expenditures of the federal funding being disbursed. 2. Update existing policies and procedures to include a post-review of the benefits subsystem’s automated review of eligibility requirements, such as verifying the income thresholds and geographic location aligned with the Division’s written policies and procedures, and supported by required documentation. The Division should correct any inaccurate eligibility determinations identified during the post-review. Emergency Rental Assistance Program policies and procedures require validation of eligibility based upon substantiating applicant documentation, including household income and geographic location. The Division will update Division policy to include a post-review process to identify and correct any errors or discrepancies. 3. Allocate sufficient staffing resources to perform a thorough evaluation of program benefits applications and provide training on eligibility requirements and allowable benefit payments. The Division will allocate sufficient staffing resources to evaluate program benefits applications and provide training on eligibility requirements and allowable benefit payments. 4. Work with the federal agencies to resolve the $64,131 in program funds that were spent in violation of federal regulations, policies and procedures, and may need to be returned to the federal agencies. The Division will coordinate with applicable federal agencies to resolve these unallowable costs.

Finding Reference: 2024-006 Finding Title: Indirect Cost Rate Pool, Noncompliance and Significant Deficiency CAP Contact Persons: • John Morris, Chief Financial Officer, Financial Affairs, (312) 322-6420 • Alan Ochab, Senior Director, Budget Management & Analysis, (312) 322-1519 Planned Corrective Actions: 1. Correction Adjustment: Management has communicated to its consultant, Maximus, its expectation that the final 2026 indirect cost rate report will incorporate an adjustment to remove the disallowed expense related to the unallowable tax penalty for all affected 2026 rates. Metra will not authorize submission of the final report to the Federal Transit Administration (FTA) until the Finance team confirms that the adjustment has been appropriately reflected and its impact fully evaluated. The adjustment, including relevant background information and its general impact on the rates, will be disclosed in the transmittal letter submitted to the FTA with the final report. 2. Independent Review Controls: Management will strengthen internal review controls by implementing a secondary review of the indirect cost rate data, including consulting with Internal Audit to improve review procedures. This review will verify that costs included in the indirect cost pool are allowable, reasonable, and adequately supported in accordance with 2 CFR Part 200, prior to submission to the Federal Transit Administration (FTA). Anticipated Completion Date: 09/30/2026

Finding Number: 2024-023 Finding Name: Failure to Provide Supporting Documentation for Payroll and Related Costs Finding Condition(s): The Illinois Department of Child and Family Services (DCFS) could not provide adequate supporting documentation to substantiate payroll and related costs claimed for federal reimbursement under the Foster Care – Title IV-E (Foster Care), Adoption Assistance, and Temporary Assistance for Needy Families (TANF) programs. Additionally, the auditors noted the controls to ensure required documentation is obtained to support payroll and related costs and maintained to evidence management approval of payroll information were not operating effectively. Finally, the auditors noted adequate internal controls have not been established to ensure the data included in the timekeeping system and used to allocate personal services expenditures to Foster Care, Adoption Assistance, TANF, and other programs operated by DCFS is consistent with the hours reported on manual timesheets prepared by the employees and approved by supervisor. Name of Contact Person(s): David Riley, Director – Illinois Department of Child and Family Services, Budget and Finance Division Corrective Action(s): The new quality controls introduced have helped to identify and correct errors, but system modernization is needed to fully implement. The DCFS is working with the Illinois Department of Innovation and Technology to implement the systems to shift to electronic timesheets. Proposed Completion Date: October 31, 2026

Finding Number: 2024-022 Finding Name: Inadequate Process for Foster Care Daycare Maintenance Assistance Payments Finding Condition(s): The Illinois Department of Child and Family Services (DCFS) does not have an adequate process in place to ensure Foster Care daycare maintenance assistance payments are accurately paid based on its approved rate schedule. Name of Contact Person(s): Stacy Mixon, Daycare Eligibility Administrator – Illinois Department of Child and Family Services, Office of Contract Administration Corrective Action(s): In July 2025, the daycare eligibility program discontinued the use of certification rate forms. As a result, all childcare providers now receive the state established reimbursement rate, regardless of the rate they charge private-paying families. This change ensures that all childcare providers receive the funding that they are entitled to. Proposed Completion Date: July 1, 2025 – Completed

Finding Number: 2024-011 Finding Name: Unallowable Costs Charged to the TANF and CCDF Cluster Programs Finding Condition(s): The Illinois Department of Human Services (IDHS) could not provide documentation to support payments made on behalf of beneficiaries of the Temporary Assistance for Needy Families (TANF) and Child Care and Development Fund (CCDF) Cluster programs. Additionally, the auditors noted that the IDHS does not have adequate controls in place to ensure information provided by providers is accurate and the related child care payments made were appropriate. Name of Contact Person(s): Maureen Bilek, Audit Compliance and Programmatic Monitoring Administrator – Illinois Department of Human Services, Division of Early Childhood (DEC) Corrective Action(s): The IDHS will (1) develop and implement internal procedures to conduct quarterly reviews of billing certificates for payments entered through the Interactive Voice Response (IVR) system, (2) assess existing deliverables, its Child Care Assistance Program (CCAP) policy and its CCDF State Plan responses related to IVR payments and determine and implement any necessary revisions, (3) develop external guidance for providers and Child Care Resource & Referral (CCR&R) agencies outlining IVR payment requirements, documentation standards, record-retention expectations, and the review process, (4) initiate and continue implementation of a communication plan to announce upcoming reviews, including the Service Employees International Union (SEIU), the Division of Early Childhood (DEC), CCR&Rs, and all providers utilizing IVR (additional communications will be issued as the process is refined), (5) commence IVR payment reviews in June 2026 and continue on a quarterly basis, and (6) Establish and maintain a master tracking log of provider reviews by year, subject to management review and oversight. Proposed Completion Date: June 30, 2026

Finding Number: 2024-010 Finding Name: Improper TANF Beneficiary Payments Finding Condition(s): The Illinois Department of Human Services (IDHS) made improper payments to beneficiaries of the Temporary Assistance for Needy Families (TANF) program. In addition, the IDHS identified a system error in June 2025 impacting beneficiaries whose benefit payments were calculated using diverted income. Finally, the IDHS did not establish control procedures at an adequate level of precision to ensure TANF program benefits were accurately calculated based on the beneficiary’s case file supporting documentation. Name of Contact Person(s): Kasey Reagan, Interim Director – Illinois Department of Human Services, Division of Family and Community Services Corrective Action(s): The IDHS has submitted a repair ticket to repair the system it uses to calculate its diverted income. Additionally, the cases affected by the diverted income error are being reviewed and referend to the Bureau of Collections for overpayment, as needed. The cases with incorrect beneficiary payments, outside of the diverted income errors, have been corrected and overpayment/supplements have been completed. Finally, the IDHS will require its TANF managers to conduct a monthly review of TANF cases to include all components of the cases. Proposed Completion Date: June 30, 2026

Finding Number: 2024-002 Finding Title: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Daniel Rahkola, Division Director Finance Corrective Action Planned: The County will review program-related costs to ensure compliance with applicable grant requirements and to confirm that all costs are allowable, allocable, and properly supported. Supporting documentation must sufficiently demonstrate the allowability of each cost. This review will include the following: • Submitted payroll reports that detail individual hours worked, descriptions of work performed, and a clear link between the work performed and allowable grant program activities. • General ledger reports that support each cost and clearly document the relationship between the expenditure and allowable grant program expenses. Anticipated Completion Date: June 30, 2026

Retain Supporting Documentation for Journal Entries (Material Weakness, Compliance Finding) Planned Corrective Action Effective March 1, 2026, the District implemented procedures requiring that all journal entries include appropriate supporting documentation prior to posting in the accounting system. Supporting documentation can range from invoices, written explanations describing the purpose of the entry, and calculations. The accounting system has been changed so all entries have supervisory review and approval. The Business Offi ce has established a standardized review process to ensure journal entries affecting federal programs are properly supported and retained within the District’s fi nancial records. Documentation will be maintained electronically to ensure availability for audit and internal review. The Business Offi ce will also provide guidance to staff responsible for fi nancial reporting and grant accounting regarding the requirement to maintain adequate documentation for journal entries in accordance with Uniform Guidance fi nancial management requirements. Periodic internal reviews will be conducted to ensure compliance with these procedures. Name of Contact Person and Completion Date Nancy J. Konisky, Business Manager Completion Date: Implemented March 1, 2026

The Board of Directors for the district will be monitoring all filing to be able to account for documentation available within the district. Also, there will be implementing document control procedures for all costs and invoices within the district.

U.S. Department of Health and Human Services • Material Weakness in Internal Control over Compliance Community Service Block Grant – Assistance Listing No. 93.569 Condition: During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/23/23 - 1/5/24, which the first nine days were prior to the start of the period of performance. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization will strengthen internal controls over the recording of grant-related invoices and payroll expenditures by requiring expenses to be recorded based on the actual date services are incurred rather than invoice date or payroll period end date. Finance staff will be retrained on period-of-performance requirements for federal programs, and a secondary review will be implemented for all federal grant postings to verify proper timing prior to submission for reimbursement or drawdown. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.

NDS will implement a time study process to determine the appropriate allocation of staff time to federally funded programs due to limitations in the payroll system. This will replace the prior flat-rate allocation method and ensure salary charges to federal grants are supported by documented time and actual work performed, consistent with Uniform Guidance requirements. Human Resources will maintain documentation of approved pay rates for audit and compliance purposes Management expects to have this implemented by April 30, 2026. The process is being monitored by Anthonia Ibe, Chief Financial Officer.

Finding 2024-004 Internal control weakness over activities allowed/allowable costs Name of responsible official: Evan Howard – Business Manager Corrective action: With stabilized staffing in place, management is currently updating the District’s federal funds procurement and compliance policies to address Uniform Guidance requirements related to allowable and unallowable costs. In conjunction with this effort, management will design and implement internal control procedures to ensure that expenditures charged to grants are reviewed for allowability prior to payment. These procedures will include documented review and approval processes, supervisory oversight, and periodic monitoring to ensure ongoing compliance. Anticipated completion date: June 30,2026

2024-001– Allowable Costs – Internal Control over Payroll and Non-Payroll Costs Programs 64.024 Veteran Affairs Homeless Providers Grant and Per Diem Program 64.055 Staff Sergeant Parker Gordon Fox Suicide Prevention Grant Program Responsible Officials Stephanie Marchetti, Executive Director Cynthia Newsham, Director of Finance Plan Detail Based on the on the findings, the Executive Director and Director of Finance will review the organizational policies and procedures and create a cost allocation plan based on employment status. Once finalized the cost allocation plan will be reviewed and approved by the board of directors, who approve any policy changes before they are implemented. Anticipated Completion Date June 30, 2025

Finding Number: 2024-006 Finding Title: Financial Policies and Procedures Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Financial Management and Standards of Financial Management Systems (2 CFR §200.302(b)); Allowable Costs (2 CFR §200.403-405); Procurement (2 CFR §200.317-327); Cash Management (2 CFR §200.305); Travel Costs (2 CFR §200.475) Note: Organization has existing Conflict of Interest policy in compliance with 2 CFR §200.318(c)(1). Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization will establish formalized accounting policies and procedures that adhere to the requirements of the Uniform Guidance. Corrective Action Plan: Corrective Action #1: Comprehensive Policy Manual Development • Action: Engage consultant or work with Contract Accountant to develop comprehensive written financial policies and procedures manual addressing all Uniform Guidance requirements, including: (a) Allowable costs (2 CFR §200.403-405); (b) Procurement (2 CFR §200.317-327); (c) Cash management (2 CFR §200.305); (d) Travel costs (2 CFR §200.475); (e) Time and effort documentation; (f) Equipment management; (g) Subrecipient monitoring; (h) Financial reporting; and (i) Record retention. Ensure policies address financial management system requirements under 2 CFR §200.302. Tailor policies to Organization's all-volunteer structure. [Note: Organization already has Conflict of Interest policy complying with 2 CFR §200.318(c)(1).] • Responsible Person/Title: Board Treasurer with Contract Accountant • Anticipated Completion Date: April 30, 2026 Corrective Action #2: Board Approval and Adoption • Action: Present draft policies to full Board of Directors for review and input. Board will formally adopt policies by resolution. Document approval in Board meeting minutes. • Responsible Person/Title: Board President • Anticipated Completion Date: May 31, 2026 Corrective Action #3: Dissemination and Training • Action: Distribute approved policies to all Board members and Contract Accountant. Conduct training session for Board members and Contract Accountant on new policies and procedures. Board members and Contract Accountant will sign acknowledgment of receipt and understanding. Make policies readily accessible (e.g., shared drive, Board portal). • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026 Corrective Action #4: Implementation Tools and Support • Action: Develop templates, forms, and tools to support policy implementation. Create workflow diagrams and checklists for common transactions. Establish Board Treasurer as primary resource for policy implementation questions. • Responsible Person/Title: Board Treasurer and Contract Accountant • Anticipated Completion Date: July 31, 2026 Corrective Action #5: Annual Policy Review Process • Action: Schedule annual review of policies to ensure continued Uniform Guidance compliance. Update policies as needed for regulatory or organizational changes. Submit material policy changes to full Board for approval. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: Annually, beginning June 2027 Corrective Action #6: Governance Structure Assessment • Action: Board will evaluate establishing Audit Committee or combined Finance/Audit Committee to provide enhanced oversight of financial management, internal controls, and federal compliance. If Board size prohibits separate committee, designate at least two Board members with specific oversight responsibilities. • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026

All journal entries related to the grant will be submitted by the Finance Director to the Director in charge of the grant for approval.