Corrective Action Plans

In order to avoid this situation happening in the future, instruction will be provided to all personnel emphasizing that every purchase should be made through a purchase order. This will ensure that we follow the BGCPR formal procedure and ensure better internal control is being followed. In addition, we will emphasize that no shipment should be received if such purchase is not in accordance with the specification disclosed in the purchase order. Contact Person: Purchase and procurement personnel Carlos Rivera Paul Barreras Amarilis Rodríguez (PACNA’s Project Manager) Team: Finance Team Anticipated Completion Date: September 30, 2026

BGCPR will provide additional training and guidance to Human Resources personnel to ensure consistent adherence to the internal procedures established. Contact Person: Yezaida Reyes Angel Morales Paul Rivera Team: Finance, Compliance and Human Resources Team Anticipated Completion Date: September 30, 2026

BGCPR will provide additional training and guidance to Human Resources personnel to ensure consistent adherence to the internal procedures established. Contact Person: Yezaida Reyes Angel Morales Paul Rivera Team: Finance, Compliance and Human Resources Team Anticipated Completion Date: September 30, 2026

2025-002 a. Name of Contact Person Responsible for Corrective Action: LaKenya Thomas– Executive Director of Finance & Business Affairs b. Corrective Action Planned: We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability and to ensure compliance with all state and federal grant requirements. c. Anticipated Completion Date: Immediately.

#2025-003 - Accounts Payable Cut-Off/ Period of Performance Corrective Action Planned: Certain grants - particularly at the Center for Adult College Success - were prepaid by the funder in order to disburse funds quickly, with grant conditions permitting continued work beyond the nominal completion date. TalentFirst closed these grants out in the accounting records before the full period of performance had concluded, resulting in expenses recorded in the wrong period. Management has implemented a contract timeline document that tracks each grant and contract's actual period of performance and governs when a grant is closed out in the accounting records - grants are no longer closed out until the full period of performance has concluded. Management is also moving away from structuring large prepaid contracts, in part to ease the cash flow pressure that structure creates. Anticipated Completion Date: Already implemented. Responsible Party: Finance Manager, with oversight by the President.

Description: During our testing of payments charged to the federal major program, we noted that employee timesheets lacked evidence of review and approval. Certain employees charged to the grant did not prepare timesheets and a separate tracking system was used. Federal regulations require that expenditures charged to Federal awards be properly reviewed, approved, and documented to ensure allowability and compliance with grant terms. Recommendation: Review the requirements of CFR 200.430 and ensure that current processes, whether digital or hard-copy driven, are consistent with the requirements of the Uniform Guidance. In addition, management should consider adding additional staff to its accounting and/or grants management team. Responsible Contact: Laura McQuay, Vice President & Chief Financial Officer Corrective Action Planned: The Organization has made significant progress in strengthening its timekeeping processes, as described in finding number 2025-002. This program ended in March 2025, and therefore management was unable to complete full remediation of the processes before completion of the grant. Anticipated Completion Date: December 31, 2027

Description: During our testing of payments charged to the federal major program, we noted that employee timesheets lacked evidence of review and approval. Federal regulations require that expenditures charged to Federal awards be properly reviewed, approved, and documented to ensure allowability and compliance with grant terms. Recommendation: Review the requirements of CFR 200.430 and ensure that current processes, whether digital or hard-copy driven, are consistent with the requirements of the Uniform Guidance. In addition, management should consider adding additional resources to its payroll approval process. Responsible Contact: Laura McQuay, Vice President & Chief Financial Officer Corrective Action Planned: Management: The Organization has made significant progress in strengthening its timekeeping processes over the past 18 months. In 2025, the agency transitioned approximately 800 weekly transitional workers from a paper-based timekeeping process to an electronic timekeeping system. In 2026, the agency implemented an upgraded workforce management system that provides enhanced scheduling, monitoring, and supervisory oversight capabilities. Management recognizes the importance of full compliance with timekeeping requirements. Given the size and complexity of the Organization's operations, including a large workforce distributed across multiple programs and locations, implementation of system and process changes requires substantial planning, training, and operational coordination. To support these efforts, the agency has dedicated additional resources and established clearly defined responsibilities to drive implementation and oversight. The agency continues to refine procedures, provide training, and leverage system capabilities to strengthen controls and ensure consistent compliance across the Organization. Anticipated Completion Date: December 31, 2027

The organization will develop a process of checks and balances to ensure that supporting documentation is provided and attached to justify the draw down requests. A reconciliation of expenditures recorded on the books and submitted request for reimbursement. All excess funds will be returned to the funding source. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date:

A designated Finance staff member with knowledge of the Uniform Guidance requirements will be responsible for overseeing SEFA preparation for each fiscal year-end. A grant-by-grant SEFA reconciliation will be completed prior to yearend close, with particular attention to period-end cutoff. The SEFA will be independently reviewed by the Finance Director and compared to grant expenditure reports before the audit commences. Management will engage its external accountants earlier in the year-end close process.

Finding Number: 2025-001 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Corrective Action Plan In March 2026, following the recognition of the issue, APS immediately conducted a comprehensive review of all payroll related charges, and promptly corrected the accounting records and updated the SEFA to remove all duplicated costs. In response to this finding, APS implemented additional policies, procedures, and controls to strengthen oversight of payroll processing and grant expenditure reporting. Specifically, APS established a documented review process to identify and investigate duplicate payroll postings prior to and following the upload of payroll data to the general ledger and grant accounting records. In addition, APS enhanced its system change management procedures to ensure that future modifications or upgrades to payroll and grants management systems include validation testing of key controls before implementation. APS will continue to review payroll charges and grant expenditures regularly and maintain documentation of all review and reconciliation activities to ensure costs charged to federal awards are accurate, allowable, properly supported, and recorded only once. APS implemented the corrective action plan on April 30, 2026. Management's contact responsible for the implementation of the Corrective Action Plan: Name: Jane Hopkins Gould Position: Chief Financial & Operating Officer Telephone number: 301-209-3276

Corrective Action Plan: Management is in the process of working with HHS to renew the Provisional Rate agreements. The anticipation is that the agreement will be completed by the end of 2026. Anticipated Completion Date: December 31, 2026

Period of Performance California Department of Social Services CDSS agrees with this finding. State operations costs incurred from July through September 2024 were incorrectly charged to FFY 2025 when the federal drawdown was processed in October, rather than being charged to FFY 2024. The issue identified in the audit period has been corrected in the ACF-696 report submitted on April 30, 2026. Upon identifying the error, CDSS provided additional training to staff and added a second level of supervisory review to ensure the appropriate federal fiscal year is applied when processing drawdowns that cross both the state and federal fiscal years. These corrective actions are intended to prevent similar misclassifications and strengthen compliance with federal reporting requirements. Estimated Implementation Date: July 2026 Contact: - Rosali Bautista, Chief, Accounting and Reporting Bureau, Accounting and Fiscal Systems Branch, Finance and Accounting Division

Period of Performance California Department of Public Health The California Department of Public Health (CDPH) agrees with this finding. CDPH is reviewing and updating existing processes and training materials to ensure expenditures are charged to the appropriate federal award and within the applicable period of performance. CDPH will coordinate with relevant staff in the Financial Management Division to strengthen grant monitoring during the award closeout process and will continue to review expenditures on an ongoing basis to prevent the misclassification of post-award costs. Estimated Implementation Date: June 2027 Contact: - Louise Karsten, Emergency Funding Coordination Branch Manager, Center for Preparedness and Response

Period of Performance Employment Development Department Employment Development Department (EDD) agrees that it did not have documented procedures or formal ongoing monitoring activities to adequately ensure that payroll charges to Federal awards fell within the authorized award dates before costs were charged to the grant. As a result, payroll costs were incurred outside of the approved period of performance and were not prevented or detected in a timely manner. EDD’s Unemployment Insurance Branch (UIB) established the procedures to be overseen by the UIB Budget Unit to ensure proper controls are in place moving forward and costs are appropriately charged to current and future grants. See artifacts titled ‘Project-Activity Code Establishment Procedure for DUA Revised 7.6.26’ and ‘UIAN DUA Template for Code Release Instructions’. To address the 25 instances where payroll hours were charged to a grant after the approved period of performance end date of May 22, 2025, the Department identified and removed those expenditures from the federal grant and reallocated them to an appropriate state funding source via ledger adjustments. Adjustments were processed during the month end closing process for May and June. As a result, all expenditures outside of the grant’s period of performance have been identified and appropriately removed from the federal grant. Estimated Implementation Date: Currently implemented Contact: - Diane Underwood, Division Chief, Unemployment Insurance Branch

Planned Corrective Action: Management agrees with the finding regarding unallowable items that included human resources services claimed under professional development supplies and food costs claimed under instructional supplies. To address this deficiency, management has implemented the following corrective actions: • Ensure all allowable expenses are reviewed by the Senior Vice President prior to voucher submission under the grant terms and conditions • Establish a formal process to ensure all expenses are coded accurately These enhancements have been implemented and will be applied to strengthen internal controls. Contact person responsible for corrective action: Mary Ann Mahon-Huels, President & CEO Anticipated Completion Date: July 31, 2026

The Partnership will implement controls to ensure that program costs are not incurred or charged to federal awards until formal award and budget approval has been received. This will include a required verification step within the finance function prior to cost authorization, documented evidence of approval dates, and staff training on allowability and timing requirements. Existing procedures will be updated to prevent premature charging of expenditures and to ensure ongoing compliance with Uniform Guidance.

Finding 2025-003 a. Name of Contact Person Responsible for Corrective Action: Jeff Jones, Business Manager b. Corrective Action Planned: Additional Training has been provided during professional development sessions to keep in the forefront the importance of preventing conflicts of interest as well as possible nepotism as defined by Miss. Code Ann. § 25-1-53 and Miss. Code Ann. § 25-4-105(1). New hires are required to disclose possible conflicts of interest during the application process. Department heads making recommendations for hire are required to disclose if they are related to the person they are recommending for hire. c. Anticipated Completion Date: Training was provided in February, 2026, after disclosures were added to the employment applications in the human resource software asking the applicant to disclose if they are aware if they are related to anyone currently working in the district. As soon as the violation was identified, the Office of Child Nutrition at the Mississippi Department of Education was notified

Management agrees with the finding that subrecipient monitoring procedures were insufficient to ensure subrecipient audit reports are obtained and reviewed. Monitoring procedures were not in place to ensure adequate documentation was obtained regarding the use of payment advances. The Pandemic Recovery Office has communicated with the Executive Office of Housing on the best practices to be employed to ensure that effective subrecipient monitoring takes place. To that end the Executive Office of Housing has implemented policies and procedures to: • Ensure the timely review of subrecipient audit reports and the issuance of management decisions in accordance with the Uniform Guidance. In particular, the Executive of Housing (EOH) now requires that subrecipients submit their Single Audit Report or financial audit report when submitting for annual funding. At that time, these reports are reviewed by EOH, and action is taken as needed regarding management decisions. • Develop and implement internal controls to ensure that adequate documentation of monitoring procedures and support for subrecipient expenditures is obtained. EOH executes periodic site visits of subrecipients at which time expenditures are reviewed and documentation for said expenditures is obtained (i.e., invoices, demonstration of services performed, etc.). • Strengthen and improve subrecipient monitoring procedures to ensure compliance with the terms and conditions of the grant award. PRO will communicate to EOH the need to provide the proper reconciliation documentation for payment advances made to subrecipients and acquire supporting documentation for reimbursement of subrecipient expenditures. • Enhance controls to ensure all award identifying information required by 2 CFR §200.332(b)(1) is accurately included in the subaward. PRO will reiterate to EOH the need for subrecipients to have an accurate Unique Entity Identification (UEI) number, issued by SAM.gov, to receive funding under the State Fiscal Recovery Fund and/or the Emergency Rental Assistance programs. Further, EOH will review all subawards to ensure that every subaward includes the Federal Award Identification Number, Assistance Listing Number, and program title. Anticipated Completion Date: September 30, 2026 Contact Persons: Paul Dion, Director, Pandemic Recovery Office, Department of Administration paul.l.dion@doa.ri.gov Brianna Ruggiero, Chief of Staff, Pandemic Recovery Office, Department of Administration brianna.ruggiero@doa.ri.gov

Corrective Action: What we've already been doing to correct the issue LifeWire has strengthened oversight within Services by consolidating the Services and Rapid Rehousing programs under a single Director, creating clearer accountability for expenditure documentation. The expanded multi-tier approval workflow (Advocate → Manager → Director → Finance) now includes a documentation completeness check at each stage, requiring that underlying support for all charges be attached and verified before a transaction advances toward payment. LifeWire has updated its policies and procedures to explicitly require that underlying documentation supporting the nature and amount of each expenditure be retained at the time the charge is generated from the program services department, consistent with 2 CFR §200.403(g). This will include clear guidance on what constitutes sufficient documentation (e.g., invoices, receipts, lease agreements, or other source documents) and the requirement that payment confirmation alone is not sufficient. What else we are putting in place LifeWire has implemented training for all Services staff on federal documentation standards, reinforcing that charges to federal programs must be supported by documentation that evidences both the nature and the amount of the expense. The Services Director is responsible for delivering and maintaining this training on an ongoing basis. All staff will be required to formally acknowledge completion of the training and their understanding of the updated requirements. Responsible Staff: Olivia Montgomery •Advocates and program staff (generating and attaching underlying documentation at pointof charge) •Services Managers (first level review for documentation completeness) •Services Director (program oversight and secondary review) •Executive Director (internal audit oversight; reviews Director of Services approvals andmonitors compliance) •Finance Director / Finance Department (final documentation review, approval, and paymentoversight) Anticipated Completion Date: Policy and procedure updates and staff training will be completed, with full implementation and demonstrated compliance expected by Q3 2026.

Management concurs with the finding. During the audit period, the Organization maintained payroll records, compensation documentation, and payroll allocation schedules; however, it did not maintain personnel activity reports, periodic certifications, or other after-the-fact documentation sufficient to support compensation costs charged to the Community Development Financial Institutions Program in accordance with 2 CFR § 200.430. The Organization's methodology relied on management-established allocation percentages based on employee responsibilities and anticipated level of effort supporting CDFI Fund activities. While management believes the costs charged to the award were incurred in support of eligible program activities, the Organization recognizes that documentation supporting the allocation methodology did not meet the standards required under Uniform Guidance. Planned Corrective Action: Beginning July 1, 2026, the Organization will implement formal time and effort reporting procedures for all personnel whose compensation is charged, in whole or in part, to federal awards. Specifically, the Organization will: 1.The CFO will establish a cost allocation plan which includes a methodology to support salary, wage, and fringe benefit charges, and other applicable costs, to the federal award and to support allocation among cost objectives. 2. The CFO will implement a documented process for personnel activity reporting and/or periodic certifications (or other equivalent documentation) that reasonably reflects actual work performed and supports the allocation of compensation costs to eligible activities. 3. CFO will reconfigure the current workforce management system to ensure projects, departments, and contextual details are logged at the source. 4. The COO will review existing timesheet submission and review policy to ensure compliance with federal requirements. The policy will require supervisory review and approval of personnel activity documentation/ certifications consistent with the payroll cadence and retain documentation in the grant file and/or payroll file. The CFO will review and enforce compliance with timesheet submission requirements. 5. The CFO will implement a dynamic allocations module within Sage Intacct to facilitate automated allocation of time and fringe benefits to federal and other programs. 6. The CFO will ensure that the systems established perform periodic reconciliation and after-thefact review of payroll and fringe benefit allocations. The CFO will make timely adjustments when actual activity differs from budget estimates or planned allocations. 7. The CFO, COO, and other personnel working on federal programs will receive training on the documentation standards in 2 CFR § 200.430 and allowability factors in 2 CFR § 200.403. 8. The CFO and COO will provide training to program and finance personnel on the documentation standards. in 2 CFR § 200.430 and allowability factors in 2 CFR § 200.403. 9. The CFO will, as part of the monthly close process, review compensation charged to federal awards to ensure all costs are appropriate and supported prior to requesting reimbursement. Management believes these actions will strengthen internal controls over compensation costs charged to federal awards and ensure compliance with Uniform Guidance requirements going forward. Responsible Official: Julia Gazizova, Chief Financial Officer Anticipated Completion Date: September 30, 2026.

The Foundation, through its outsourced bookkeeping firm, acknowledges the audit observation regarding the duplicate reimbursement of lender expenditures. Management believes this was an isolated administrative error rather than the result of a deficiency in the Foundation's internal control environment. The Foundation maintains controls designed to ensure that expenditures charged to federal awards are reviewed for allowability, properly supported, and approved before submission for reimbursement. In this instance, a subsequent reimbursement from the lender was not identified through the Foundation's normal monitoring process. Management contacted the grantor and resolved the matter by applying other allowable expenditures to the federal award, thereby eliminating any duplicate recovery of federal funds. To further strengthen existing controls, the Foundation has enhanced its procedures to specifically track expenditures submitted for reimbursement under federal programs and monitor any subsequent refunds, credits, rebates, or reimbursements received from vendors or other third parties related to those expenditures. In addition, management will document a post-submission review process to identify vendor credits or recoveries received after reimbursement requests have been submitted and determine whether any adjustment to future reimbursement requests or repayment to the granting agency is required.

The Airport has incorporated the addition of electronic approvals for Airport Improvement Plan invoices within its existing procurement policy.

2025-003 – Allowable Costs Corrective Action: Implement a process to ensure that unallowable costs are not charged to the grants. Person Responsible: Executive Director, Seth Kirshenberg Estimated corrective action completion date: Fiscal year 2026\

The Society of American Foresters has enhanced their exis􀆟ng expense recogni􀆟on controls for event-related invoices by reques􀆟ng more detailed vendor invoices that clearly iden􀆟fy the event and applicable service period, implemen􀆟ng addi􀆟onal review for vendors with recurring or overlapping billing arrangements, and reinforcing current invoice review procedures to ensure that the period of benefit is adequately documented, par􀆟cularly for transac􀆟ons occurring near year-end. These enhancements are intended to further strengthen the Society’s already effec􀆟ve control environment and support consistent and accurate recogni􀆟on of event expenses in accordance with federal requirements and GAAP.

Finding 2025-003: Lack of Authorization for Expenses - The Organization is currently updating their approval process and including an additional approval form. This form will require accounts payable staff to verify that the expense has appropriate signatures before any federal grants are charged.