Corrective Action Plans

Action taken: The district is hiring an additional account clerk (N: Tonn) and the deputy treasurer (R. Heimer) will begin working with the treasurer (C. Meher) so that the treasurer can focus more closely on reporting and more of the duties of the business manager. Review of the final cost reports is ongoing and the Comptroller's Office and/or Office of Grants Finance will be contacted once the internal audit is complete to make any necessary adjustments. This will be done by the treasurer, C. Meher. Anticipated completion date: will begin January 5, 2026 and continue throughout the school year

Finding 2025.004 – Period of Performance Federal Program Name: Continuum of Care Federal Assisted Listing Number:: 14.267 Recommendation We recommend that management implement additional controls and policies over period of performance. Staff who purchase items with grant funds should have additional training on period of performance requirements. Planned Corrective Action: TVCCA is strengthening its period of performance controls through the following actions: 1. Training – All employees with purchasing power will be trained on the deadlines of the grants they are responsible for. This training includes what the definition of obligation truly is, as well as allowable spend down period of their grants. Finance staff will also be trained on the timing and definitions of obligations. 2. Revised internal controls and workflow – Cutoff testing will be performed and added to the month close checklist on a quarterly basis to align with grant closing schedules. 3. Monitoring – Cutoff testing will be monitored on a quarterly basis in association with quarter ending checklist. Name of Contact Person: Max Logan, CFO, 860-425-6506, mlogan@tvcca.org Anticipated Completion Date: March 31, 2026

Duplicate Title I Draw Condition: 2 CFR 200.403 of the Uniform Guidance mandates that only necessary, and allowable costs be drawn down off of federal grants. During the audit, we found that the prior fiscal year's accrued payroll, which was drawn off of the grant In the previous fiscal year, was drawn off of the grant a second time in the current fiscal year, creating questioned costs of $53,509. We recommend that management implement procedures to ensure that all accruals charged to federal grants are properly reversed in the subsequent fiscal year to ensure that duplicate draws on those same expenses are not made. Corrective Action: The District understands what happened and will work on developing procedures to prevent such duplicate draws do not occur in the future. Contact Person Responsible for Corrective Action: Chanda Cleaves, Executive Director of Finance Completion Date: This issue will be corrected moving forward.

Reference Number: 2025-001 Description: Finding 2025-001 - Federal ALN 93.778 Medicaid Cluster Corrective Action Plan: The District will update the setup for Medicaid reporting in Skyward Qmlativ to back out expenditures coded to federal grants, specifically project numbers 341 and 347. Anticipated Corrective Action Plan Completion Date: Corrective action was implemented on July 23, 2025. The district has reviewed reports generated after this date and verified the accuracy of reporting. Contact Information: For additional information regarding this finding please contact Beth Sheridan, Assistant Superintendent of Finance and Operations, at 262-560-2119. Beth Sheridan Assistant Superintendent of Finance and Operations

Research and Development Cluster— Assistance Listing Nos. Various Recommendation: We recommend that the University review its procedures around review and approval of R&D expenditures to ensure that only valid expenditures are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University does have existing internal control processes over its federal grants. The principal investigators code, approve, and submit expenditures for payment. In addition, principal investigators receive periodic grant reports which include the detail of all transactions charged to their grants for review. The University will add an additional control step to review coding of research and development payment requests in the ERP system prior to payment. Names of the contact persons responsible for corrective action: Gerri Stepanek and Carole Kampf Planned completion date for corrective action plan: September 1, 2025

2025-003 Period of Performance (repeat of finding 2024-005) Corrective action planned: Beginning April 1, 2025, when the organization was made aware of this finding in last year’s audit, OMC took immediate corrective actions. The CFO/Designee will monitor expenses, and a separate prepaid schedule has been developed to track future period expenses. OMC’s current CFO/Designee has a basic understanding of GAAP. All coding will be reviewed and approved by an authorized, knowledgeable CFO/Designee. Anticipated completion date: Corrective Action taken on April 1, 2025. Contact person responsible for corrective action: Allen Boyd, Director of Fiscal Operations

The College acknowledges the finding and recognizes the need to strengthen internal controls over payroll expenditures charged to federal programs, particularly in ensuring that employee compensation, approved timesheets, leave payments, and related benefits are adequately supported and properly authorized. During FY2025–FY2026, the College continued implementing corrective measures to improve compliance with federal allowable cost requirements. These efforts include strengthening documentation and record retention procedures through the use of a cloud-based filing system, improving verification of employment contracts and approved pay rates, and reinforcing supervisory review and approval of payroll transactions. The College continues to strengthen coordination among the Human Resources, Payroll, and Grants Offices to ensure that expenditures charged to federal programs are properly documented, authorized, and consistent with applicable federal requirements. Additionally, ongoing staff training and improved oversight are intended to address the identified deficiencies and prevent recurrence of similar findings in future audits.

4. Allowable Costs / Cost Principles Type of Finding: Other Noncompliance Finding Management acknowledges the findings related to compliance with Uniform Guidance requirements under 2 CFR §§ 200.403 and 200.404, which require that costs charged to federal awards be allowable, reasonable, allocable, and adequately supported. During audit testing, it was identified that $695 in late fees and penalties were charged to the federal program. While properly supported by documentation, these costs are unallowable under federal regulations. As a result, questioned costs totaling $26,656 were identified. Corrective Action Plan - Management agrees that unallowable costs were charged due to a breakdown in expenditure review controls. To address this issue, the Organization will implement: - Mandatory training for staff responsible for coding and approving federal expenditures regarding allowable cost requirements. - Implementation of a secondary review process for all federal expenditures prior to posting. - Development of an allowable cost checklist to be used during expenditure approval. - Enhanced supervisory review of all costs charged to federal awards. These controls will be implemented immediately and applied to all federal programs going forward.

Audit Finding Number 2024-002 Audit Finding Title Activities Allowed or Unallowed, Allowable Costs/Cost Principles Planned Corrective Action Other than Personnel Services: In April of 2025, we discontinued the previous credit card usage processes and began using Ramp for all credit card purchases. The Ramp system requires employees to upload an itemized receipt, document the business reason for the expense, and select the grant that expense should be coded to. Each transaction is approved by the employee’s manager and reviewed by the AP staff before it is synched over to the general ledger. If a transaction cannot be properly documented the system will notify the employee of the need for repayment. The repayment is drafted from the employee’s personal bank account, and the expense is reversed in the general ledger. Indirect Costs: In Year 1 $200,000 was deemed unallowable because while there was a provisional indirect rate agreement in place for 28.50%, the CDC did not adjust the NOA to reflect the update. Going forward, when there are any approved changes to the NOA, BWHI will ensure that those changes are reflected in an updated NOA. In addition, in 2025, the new accounting team is charging indirect costs as a percentage of direct expenses incurred during the period of draw down. Each drawdown will be prepared and then reviewed by a separate employee before submission. Preparation and review are time stamped and documented in the CDC payment system. Personnel Services: In July 2026, we formalized our review process for all payroll transactions. Each payroll is reviewed for completeness and reasonableness and is reconciled on each payroll run before posting to the general ledger. We are currently working on our employee training that will require employees to document their weekly time and charge hours to grants using actual timesheets. Those timesheets will be reviewed and approved by their manager before the payroll run. This process will be in place effective in December 2026. Name(s) and title(s) of contact person(s) responsible for corrective action Kim Cockerham, Sr. Director of Finance and Accounting Desarae Kirtz, Sr. Director HR (personnel services)

Pohnpei has agreed to the findings and is committed to implementing the recommendations. Ongoing Director of Treasury and Administration Sihna N. Lawrence sihna.lawrence@pohnpeidota.fm

Pohnpei has agreed to the findings and is committed to implementing the recommendations. Ongoing Director of Treasury and Administration Sihna N. Lawrence sihna.lawrence@pohnpeidota.fm

Pohnpei has agreed to the findings and is committed to implementing the recommendations. Ongoing Director of Treasury and Administration Sihna N. Lawrence sihna.lawrence@pohnpeidota.fm

2024-006 Significant Deficiency in Internal Control and Compliance over Major Programs Management Response: As of August 2026, KCR has begun reconciling the bank account statements each month. As part of the reconciliation process, the finance team is reviewing all outstanding checks/payments and following up with vendors to confirm if the check/payment needs to be voided and resubmitted. KCR is also paying special attention to any check/payment that is being expensed to a federal program, ensuring that only checks/payments that have been negotiated with the bank are refunded by federal awards. Staff responsible: CFO Irmgard Davis irmgardd@kcr.org.

Finding 2024-006 – Deficiencies in Disbursement Procedures and Documentation Retention Contact Person: Gary Kloosterman, Village Manager Planned Corrective Action: The Village will implement formal procedures for disbursement review, approval, and documentation. Staff will be trained on federal documentation and record retention requirements. Anticipated Completion Date: March 31, 2026

Management agrees with the finding. Management has downloaded 2 CFR Part 200 for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly.

AUDIT FINDINGS 2024-001: In one of 25 selections for testwork over period of performance, expenditures related to contract labor were submitted for reimbursement to the Federal Emergency Management Agency (FEMA) that were outside of the project period. Further, the review performed over expenditures was not completed appropriately to identify this error, this is an instance of the District’s internal control not operating as designed. Name of Contact Person: Daria Heimerman, Director of Financial Reporting, dtheimerman@evergreenhealthcare.org Corrective Action Planned: Assess process and controls for improvements to identify expenditures incurred outside of the designated project period. Anticipated Completion Date: August 2025 Statement of Concurrence or Nonconcurrence: Management concurs with audit finding 2024-001.

Finding 2024-005: Allowable Costs/Cost Principles Lack of proper review of underlying lease agreement for invoices Corrective Action Plan The lease agreement referenced in this finding originated in 2014 and involved copier equipment that had previously been returned. The matter has been fully resolved with the copier provider, which refunded the applicable amount, and those funds were subsequently returned to the Office of Head Start in accordance with the instructions provided. The program also contacted OHS, followed the guidance received, and submitted all supporting documentation for review. Within the next 30 days, the program will strengthen its invoice review process by requiring verification of lease agreements and supporting documentation prior to payment approval and by ensuring all historical and current lease-related records are retained in a centralized location. To ensure long-term compliance, the program will implement strengthened internal controls within 60 days, including dual review of all leases-related invoices, periodic reconciliation of active lease agreements, and annual verification of contract status. Ongoing monitoring will be conducted by the Finance Officer and Head Start Director, who will provide quarterly updates on compliance and documentation accuracy. Responsible Personnel: Cynthia Cooper – Chief Finance Officer: Oversight, review, and compliance monitoring Sharon Jordan - Head Start Director: Accountability and reporting Estimated Date of Completion: December 2026

Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding. LYRIC will implement the following corrective actions: (1) document the start and end period of grant and performance for each future federal award in a centrally accessible grant file, and require Finance staff to reference these dates during all expense coding and reimbursement processing; (2) add a pre-submission checklist step requiring staff to confirm that all expenditure dates fall within the approved period of performance before any draw request is finalized; (3) assign supervisory review responsibility to the Finance or Grants Manager to provide a secondary check on period eligibility before submission; (4) work with HUD to assess the questioned costs and take appropriate corrective action to substitute other legitimate expenses as necessary; and (5) train finance and program staff on period of performance rules and the requirement that only costs incurred within the approved grant period may be charged to a federal award. Responsible Official and Position: Ana Rubio, Director of Finance, and Laura Chavez, Contracts Manager Expected Implementation Date: July 1, 2026

Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and treats accurate reimbursement of federal funds as a serious obligation. LYRIC will implement the following corrective actions: (1) create and maintain a detailed reimbursement tracking log recording each submitted draw by expense date, vendor, amount, and draw number, to be updated at the time of every submission; (2) require a second staff member to perform an independent review of each reimbursement request against the tracking log and general ledger prior to submission, specifically to identify potential duplicate charges or wrong coding of expenses; (3) work with HUD to address the $54,799 in duplicated amount to offset other legitimate expenses; and (4) explore whether LYRIC's accounting system can be configured to flag expenditures already coded to a prior reimbursement request, adding a system-level check to the manual review process. Responsible Official and Position: Ana Rubio, Director of Finance, and Laura Chavez, Contracts Manager Expected Implementation Date: July 1, 2026

Audit Finding Reference: 2024-003 Improve Internal Controls and Documentation over Vendor Transactions Planned Corrective Action: Management agrees with recommendation to strengthen internal controls by ensuring all expenditures charged to federal programs are properly documented and approved prior to payment and periodically review vendor payment processes to verify compliance with documentation and approval procedures. Management expects these recommendations to be fully implemented by the start of the next fiscal year. Planned Implementation Date of Corrective Action: July 1, 2026 Person Responsible for Corrective Action: School Superintendent, School Business Office and City Grants Management

Reference Number: 2024-007 Finding Title: Reimbursable Expenditures Assistance Listing Number/Program: 20.205 – Highway Planning and Construction Agency / Pass-Through: U.S. Department of Transportation, passed through the California Department of Transportation Compliance Requirement: Allowable Costs and Activities Management's Response Management concurs with the finding and acknowledges that improvements are necessary to strengthen StanCOG's internal controls over grant expenditure documentation, review, and reimbursement processes. The condition identified resulted from deficiencies in historical grant expenditure documentation and review procedures. During the period under audit, StanCOG did not have sufficiently documented processes in place to ensure that all costs charged to federal awards were supported by adequate documentation demonstrating the nature, amount, timing, allowability, and allocability of the expenditure prior to reimbursement submission. The unsupported expenditure identified during testing relates to a reimbursement claimed under the Highway Planning and Construction program. Management recognizes the importance of maintaining complete supporting documentation for all federal award expenditures and will work with the appropriate parties, including the grantor as necessary, to evaluate and resolve the questioned cost in accordance with applicable federal requirements. Since the period under audit, StanCOG has undergone significant changes within its Finance Department and has recently hired new management focused on strengthening financial controls, improving grant compliance practices, and rebuilding sustainable financial processes. Management is currently reviewing existing grant accounting and reimbursement procedures and is implementing enhanced controls to ensure federal expenditures are properly supported and reviewed prior to reimbursement requests. Management is implementing, or plans to implement, the following corrective actions: • Establish standardized grant expenditure review procedures requiring supporting documentation before costs are charged to federal awards or submitted for reimbursement. • Develop documentation requirements for grant-related expenditures, including invoices, contracts, payroll documentation, time records, and other supporting records necessary to demonstrate allowability and allocability. • Implement documented supervisory review procedures to verify that expenditures charged to federal programs are appropriate, supported, and comply with applicable federal requirements. • Improve coordination between Finance and program/project staff to ensure required supporting documentation is collected and retained timely. • Establish consistent grant file organization and retention procedures to ensure documentation supporting federal expenditures is readily available for monitoring and audit purposes. • Provide guidance and training to staff involved in grant administration, project management, and expenditure processing regarding federal cost principles and documentation requirements. • Review the questioned cost identified in the audit and coordinate with the appropriate grantor representatives regarding resolution, as necessary. Management recognizes the importance of strong grant management practices and maintaining adequate documentation to support the use of federal funds. StanCOG is committed to strengthening its internal control environment, improving grant expenditure review procedures, and ensuring that future reimbursement requests are supported by complete and appropriate documentation in accordance with federal requirements.

Management has enhanced controls over FEMA grant compliance by strengthening the formal review process to verify that costs claimed are eligible, adequately supported, and consistent with FEMA program requirements prior to submission, including the removal of any duplicates.

Planned Corrective Action: All purchase orders will be approved by an Administrator and the Business Administrator. The current software allows for and audit path of approval, changes will be made to include the above practice in accordance with City and School District policy. Name of Contact Person: Dawn Cilley, Business Administrator dcilley@laconiaschools.org Anticipated completion date: September 30, 2026 Example of Planned Corrective Action: School ERP Pro software will be adjusted for an approval path including an Administrator and The Business Administrator.

The Coalition will develop and formally adopt a written Cost Allocation Plan (“CAP”) to support the allocation of shared and indirect costs among funding sources and programs. The CAP will clearly define allocation methodologies, identify appropriate allocation bases, and ensure that costs are allocated consistently and in proportion to the relative benefit received by each program. Management will review the CAP annually and update it as necessary to reflect operational or funding changes. The CAP will be formally approved and retained as supporting documentation for allocated costs.

Management has updated its policies and procedures to require a formal annual review and update of the cost allocation plan. This review will occur in conjunction with the finalization and Board approval of the organization’s annual operating budget, ensuring that the CAP aligns with the most current program structure, funding sources, and cost allocation methodologies. As part of this process, management will: • Evaluate the reasonableness and appropriateness of allocation methodologies; • Ensure consistency in application across all programs and funding streams; and • Document and approve any necessary revisions to the cost allocation plan prior to implementation. Management believes this corrective action will ensure that the CAP remains current, appropriately reflects organizational activities, and complies with applicable Federal requirements. Ongoing adherence to this process will strengthen internal controls over cost allocation and financial reporting.