Corrective Action Plans

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

Finding Number: 2024-005 Anticipated Completion Date: March 31, 2026 Responsible Contact Person: Brad McCain, Chief Financial Officer Planned Corrective Action: Management is strengthening controls over tracking, documenting, and reconciling federal grant expenditures to ensure compliance with period of performance requirements. Actions include implementing improved grant-level tracking within the financial system, reconciling general ledger activity to reimbursement invoices and the SEFA on a routine basis, and retaining documentation to support the allowability and timing of costs charged to federal programs. Management will also formalize procedures for payroll reallocations across programs to ensure traceability and compliance with grant requirements. Documentation will be required to be attached to all journal transactions demonstrating the linkage between the underlying payroll records to the correct grant programs.

Finding Number: 2024-003 Anticipated Completion Date: March 31, 2026 Responsible Contact Person: Brad McCain, Chief Financial Officer Planned Corrective Action: Management has reviewed and revised its reimbursement and reconciliation procedures for federal grants to prevent duplicate submission of costs. Enhanced controls include standardized invoice preparation checklists, segregation of duties between invoice preparation and review, and reconciliation of reimbursement requests to payroll registers and the general ledger prior to submission. Management will also provide targeted training to staff involved in grant billing and reimbursement processes. In coordination with the City of Columbus, the YMCA is updating and resubmitting a final report and invoice reflecting the removal of duplicated expenses and the inclusion of allowable actual expenses that had not previously been invoiced.

U.S. Department of Health and Human Services Department of Human Services respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 - June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Human Services Low-Income Home Energy Assistance Program – Assistance Listing No. 93.568 Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Explanation of disagreement with audit finding: No disagreement. Action taken in response to finding: The Department has made changes in the Office of Budget and Finance Leadership team and continues to do so at every level. The Department will review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Currently, expenditures are recorded in the State’s Financial Management Information System (FMIS) with program cost accounting codes used to identify the funding source(s) for each activity. The system-generated report summarizes the information and includes the effective date of the activity. In turn, this same report is used to run the cost allocation to properly charge the exact costs to the funding source. Currently information is manually inputted into multiple spreadsheets to prepare the federal reports resulting in the possibility for errors. This significantly impedes the accuracy of the data being reported to federal grants and the provision of supporting documentation. As such, the Department will partner with external consultants to develop a better and more seamless recording structure for grant expenditures to the general ledger. This structure will require quarterly review by the Deputy Cost Allocation Revenue Management Director (CARM), the Cost Allocation Revenue Management Director, and the Deputy Chief Financial Officer. The Department will create a database and document repository to track the submission and reconciliation for federal grant reporting. The document repository will include the FMIS generated report and the cost allocation results table. Upon submission to the federal grant

U.S. Department of Education (USDE) Maryland State Department of Education respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023-June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. Finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Maryland State Department of Education 2024-023 Special Education Cluster– Assistance Listing No. 84.027, 84.173 Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MSDE will review and enhance its Standard Operating Procedures (SOPs) and internal controls to ensure that it charges expenditures (including accounts payable and payroll) to Federal programs that are incurred within an award’s allowable period of performance. Name(s) of the contact person(s) responsible for corrective action: Neeta Gandhi Executive Director Office of Program Fiscal Operations and Local Strategic Finance Jenna Meinl Director Office of Procurement and Contract Management Planned completion date for corrective action plan: June 30, 2025 If the USDE has questions regarding this plan, please call Patricia Ramallosa at 410- 767-0103. Page 2 Approval of Response to the CLA Findings and Recommendations: Document Version Approval Date Approved by Signature 1.0 Mar 29, 2025 Neeta Gandhi, Executive Director-Office of Program Fiscal Operations & Local Strategic Finance Mar 29, 2025 Jenna Meinl, Director-Office of Procurement and Contract Management Mar 29, 2025 Donna Gunning, Assistant Superintendent of Financial Policy, Planning, Operations & Strategy Mar 29, 2025 Shawn Rushing, Assistant Superintendent of Administration Mar 29, 2025 Krishnanda Tallur, Deputy Superintendent of Finance and Operations

Higher Education Institutional Aid – Assistance Listing No. 84.031 Condition: The Institution did not adjust the employee’s payroll costs to reflect the reported effort. We noted that the actual time and effort charged to the grant did not agree to the time and effort report. Recommendation: We recommend that the Institution strengthen its internal controls to ensure expenditures are reviewed and adjusted for, if necessary, in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As a corrective action, Coppin State will complete the implementation of the following: 1. Award PI will provide training regarding proper submission of Time and Effort Reports. 2. Award PI will review distribution of time and percentage. 3. Award PI will review compensation and fringe benefits. 4. Award PI will approve Time and Effort Reports and route to the Payroll Office. 5. Award PI with the support of the Controller will obtain the appropriate role in Workday that allows for the review and confirmation of approved payroll allocations and adjustments.

Higher Education Institutional Aid – Assistance Listing No. 84.031 Condition: Time and Effort documentation were not being documented and reviewed timely. Recommendation: We recommend that the Institution strengthen its internal controls to ensure that Time and Effort are documented, expenditures are reviewed and adjusted for, if necessary, in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In June 2024, we successfully implemented a new ERP system designed to automate the documentation of Time and Effort. This system streamlines the process by capturing and organizing data more efficiently, reducing manual effort and enhancing accuracy. As part of the implementation, we have established a process for regular reviews and adjustments of expenditures, ensuring ongoing compliance with regulatory requirements and maintaining the integrity of financial records. We are providing comprehensive training for relevant staff members, focusing on how to utilize the new system effectively. This training will ensure that documentation is completed in a timely, accurate, and consistent manner, minimizing the risk of errors and improving overall operational efficiency. Moving forward, we will continue to monitor the system's performance and provide ongoing support to ensure its success. Name(s) of the contact person(s) responsible for corrective action: Miliani Sinclair Planned completion date for corrective action plan: April 2025

1. The Maryland Military Department respectfully submits the following corrective action plan for the year ended June 30, 2024.Projects – Assistance Listing No. 12.401 (1) Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award's allowable period of performance. (2) Explanation of disagreement with audit finding: There is no disagreement with the audit finding. (3) Action taken in response to finding: The Department will carefully exam and allocate expenses to the fiscal year in which they are incurred, ensuring proper period assignment when expenses span multiple fiscal years. This will confirm accurate costs charged to the programs. 2. Audit period: July 1, 2023-June 30, 2024 3. The findings from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. 4. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS: a. Finding 2024-011: National Guard Military Operations and Maintenance (O&M

Review current policies regarding employee travel and expense reimbursements and adjust, if needed, to be aligned with award requirements • Implement a pre-approval process for all employee travel and expense reimbursements charged to federal programs. • Require detailed documentation (receipts, agendas, purpose statements) to demonstrate direct program benefit. • Provide staff training on allowable costs and documentation standards.

FA-2024-003 Strengthen Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: AL Numbers and Title: Federal Award Number: Questioned Costs: Activities Allowed or Unallowed Allowable Cost/Cost Principles Significant Deficiency Nonmaterial Noncompliance U.S. Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program 245GA324N1199 (Year: 2024), 225GA324N1099 (Year:2024) $2,641.33 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating to ensure that expenditures were appropriately reviewed, approved, and documented. Corrective Action Plan: A bookkeeper has been hired for the School Nutrition Program. Bookkeeper keeps alphabetical organized files for each vendor to monitor and track revenue and expenditures. The bookkeeper prepares voucher packets for payments and credits for each vendor on a monthly basis. The bookkeeper signs the voucher package for accuracy. The Nutrition Director signs the voucher package for accuracy. Records are maintained under lock and key for a period of five years. Estimated Completion Date: July 1, 2025 Contact Person: Danny Durham, Director of School Nutrition Telephone:478-994-2031 Email: danny.durham@mcschools.org Title: Director of Financial Services

FA 2024-002 Strengthen Controls over Journal Entries Compliance Requirement: Activities Allowed or Unallowed Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program COVID-19-10.555 – National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: Unknown Description: The policies and procedures of the School District were insufficient to ensure that journal entries made for the Child Nutrition Cluster were properly documented. Corrective Action Plan: All journal entries transferring cash from the School Nutrition Fund to the General fund will be done on a more frequent basis and include the detail of amounts used to arrive at the amount of the transfer. Estimated Completion Date: October 17, 2025 Contact Person: Danny Durham, Director of School Nutrition Telephone: 478-994-2031 Email: danny.durham@mcschools.org

FINDING 2024-015 Finding Subject: COVID-19 - Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles 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 maintain documentation of all payroll and stipend amounts to ensure allowability and compliance with grant agreements. All stipend and other payroll payments will be approved by the School Board. The school corporation will include supporting documentation for all accounts payable vouchers Anticipated Completion Date: The school district began the practice above on January 1, 2024, and anticipate it will be completed by June 30, 2026.

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.

FINDING 2024-011 Finding Subject: Title I Grants to Local Education Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles 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 maintain time and effort documentation for all staff paid by federal grants for each six-month period from January 1-June 30 and July 1-December 31. In addition to the ongoing time and effort documentation for all staff paid by federal grants, the district will maintain wage and benefit distribution reports that reflect staff paid from federal grant funds. The school corporation will include supporting documentation for all accounts payable vouchers. Anticipated Completion Date: The school district began the practice above on January 1, 2024 and anticipate it will be completed by June 30, 2026.

FINDING 2024-008 Finding Subject: Special Education Cluster (IDEA) – Earmarking and Level of Effort Contact Person Responsible for Corrective Action: Susie Swango, Director of Special Education Contact Phone Number and Email Address: swangos@nlcs.k12.in.us (812) 277-3220 ext. 16243 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Earmarking- The Non-Public Proportionate Share of expenditures The school district will document all non-public proportionate share expenditures to ensure that Earmarking compliance requirements are consistently met. Time and Effort Logs are kept for employees to document the proportionate share time paid for with Federal Special Education Grant Funds. Level of Effort – Maintenance of Effort- The school corporation will properly document all Special Education expenditures from accounts payable vouchers to payroll and fringe benefits. This documentation will ensure that we can calculate and substantiate our maintenance of effort required amounts. Anticipated Completion Date: June 30, 2026

FINDING 2024-006 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Susie Swango, Director of Special Education Contact Phone Number and Email Address: swangos@nlcs.k12.in.us (812) 277-3220 ext. 16243 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All payments and expenditures corporation wide, including those made with Federal Special Education Funds, will be properly documented. Accounts payable vouchers will be primarily entered by the Deputy Treasurer/Accounts Payable Specialist and reviewed by the Treasurer/Director of Business. Purchase requests will be submitted by the Director of Special Education thereby authorizing that the purchase is an allowable cost from the designated fund. Documentation will be provided to identify specific staff members included in payroll and fringe benefit payments from Federal Special Education funds. Anticipated Completion Date: June 30, 2026

FINDING 2024-003 Finding Subject: CHILD NUTRITION CLUSTER - ACTIVITIES ALLOWED OR UNALLOWED, ALLOWABLE COSTS / COST PRINCIPLES Contact Person Responsible for Corrective Action: BONNIE SANDERS, Director of Food Services Contact Phone Number and Email Address: Sandersb@nlcs.k12.in.us (812) 277-3220 ext. 48014 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All payments and expenditures coming out of the Food Service Fund (Fund 800) will be documented and accompanied by supporting additional documents detailing the reason and application of the funding. All payments will be accompanied by vouchers signed by 2 parties (the requestor and their supervisor), as well as an invoice and, if applicable, quote for merchandise or services. In addition, the Accounts Payable staff will also review these documents prior to signature by the Supervisor. Student meal account reimbursements will also be handled in this way, ensuring the appropriate account, Prepaid Food Account (Fund 8400), is the account these funds will be withdrawn from. Stipend requests will be in writing and approved by the Business Director and the School Board prior to being processed by payroll. This will be documented in writing along with any payment documentation. Anticipated Completion Date: Immediately (December 1, 2025)

F A 2024-002 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles InternalControllmpact: SignificantDeficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Depatment of Education Pass-Through Entity: Georgia Department of Education CFDA Numbers and Titles: 84.425 American Rescue Plan Elementary and Secondary School Emergency Relief Grant 84.425 - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth 84.425 - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425U210012 (Year:2021), S425W210011 (Year: 2021), 5425D2 1 001 2 (Year:202 I ) Questioned Costs: $8,763.69 Repeat ofPrior Year Finding: FA2023-002, F42022-002 I)escription: A review of expenditures charged to the Elementary and Secondary School Emergency ReliefFund program revealed that the School District's internal control procedures were not operating to ensure that expenditures were appropriately documented to support allowabiliqr. Corrective Action Plans: . Alljournal entries will be check by the independent CPA person to ensure that packets are complete and that each are fully approved by at least two of the following Superintendent, CFO and/or CPA and organized to FY folder as part of our monthly closing process . CFO will review all salaries after they have been entered into PC Genesis to ensure that they are being processed correctly Estimated Completion Date: December 3 1, 2025 Contact Person: Torrence H. Freeman IIl. CFO Telephone: 7 06-665-8571 Email: tfreeman@talbot.kl 2.ga.us

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Allowable Costs/Cost Principles, Activities Allowed or Unallowed Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education CFDA Numbers and Titles: 84.01 0 - Title I Grants to Local Educational Agencies FederalAwardNumber: S010A220010(Year:2023),S0104230010 (Year:2024) Questioned Costs: $9,307.29 Repeat ofPrior Year Finding: FA 2023-001, FA 2022-001 Description: The policies and procedures ofthe School District were insufficient to provide adequate intemal controls over expenditures as it related to the Title I Grants to Local Educational Agencies program. Corrective Action Plans: Payroll will reorganize how documentation is kept ofeach pay period to ensure it makes a: complete monthly folder . payroll will not process any timesheets that need signatures for approval. lf not able to get signed in time for currently pay period, it will be processed in the next one o CFO will review all salaries after they have been entered into PC Genesis to ensure that they are being processed correctly Contact Person: Torrence H. Freeman III, CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

Along with hiring the above consultants, VFC also hired a new Finance, Grants and Administration Manager. This person is now ensuring that all expenditures have receipts and are properly approved by the Interim Executive Director. In addition, revised policies and procedures for both supporting and approval documentation will be included in the updated accounting policies and procedures manual. The expected completion date is December 31, 2025.

We agree with the recommendation and it was implemented effective 7/1/2025.