Corrective Action Plans

2025-003 ACTIVITES ALLOWED/ALLOWABLE COST PRINCIPLES Planned Corrective Action: This CMHSP will strengthen its grant financial management procedures. Finance staff will verify that all indirect cost calculations comply with the approved grant budget and the requirements of the federal award before indirect costs are charged to the grant. A grant expenditure tracking process will be established to monitor direct and indirect costs against the approved budget throughout the grant period. The Chief Financial Officer will review indirect cost calculations and budget-to-actual expenditures monthly to ensure expenditures remain within approved budget limitations and comply with applicable federal regulations and grant requirements. This CMHSP will create grant management policies and procedures, outside of the County of Lapeer’s grant management policy, to include documented reviews of indirect cost calculations, monthly budget monitoring, and supervisory approval of grant expenditures to ensure compliance with federal awards. Responsible Party: Emma McQuillan, Chief Financial Officer Anticipated Completion Date: 09/30/2026

View of Responsible Officials and Corrective Actions: We agree with the auditor's recommendation. Although the referenced invoices were reviewed by the CEO from the vendor for eligibility and reasonableness upon receipt of the automatic e-mailed invoice, there was no procedure to print and retain this documentation in the accounting files for Instacart invoices. Effective June 1, 2026, each month the Director of Finance will compare a checklist of all credit charges to the physical copies prior to filing and obtain any missing invoices as part of the monthly closing process.

Management acknowledge the improper treatment of the expenditure for the specific period. The expenditure in question was for a one-year marketing services agreement supporting activities under the FDA 503B award. The vendor required payment in advance as a condition of service delivery, and the cost was incurred for legitimate grant-related purposes within the approved scope of work and period of performance. The expenditure was fully documented, allocable to the award, reasonable in nature, and directly connected to approved programmatic objectives. Management acknowledges that the transaction involved payment for services extending across a future service period. Specifically, 2 CFR 200 does not prohibit recipients from entering into prepaid contractual arrangements for allowable services necessary to support award implementation, particularly where such arrangements reflect standard vendor business practices and operational necessity. Further, the organization’s actions must be evaluated in the context of significant federal payment administration changes that began in February 2025. Historically, the organization received advance funding under the award consistent with the cash management principles contemplated under 2 CFR 200.305. Beginning in 2025, however, the organization was required to operate under a reimbursement-based process requiring submission of supporting documentation prior to payment release. This materially altered the organization’s working capital position and limited its ability to independently finance operational expenditures for extended periods pending reimbursement. As a result, management was required to make operational decisions necessary to ensure continuity of approved grant activities while balancing vendor requirements, cash flow limitations, and evolving federal reimbursement practices. The organization did not receive excess federal cash, improperly retain federal funds, incur unallowable costs, or use award funds outside the approved project scope. The questioned transaction reflects a timing and payment structure issue rather than a violation of fundamental federal compliance requirements. Management also notes that 2 CFR 200.305 expressly contemplates advance payment methodologies and recognizes that reimbursement-only environments may create operational hardships for recipients lacking sufficient working capital. The organization’s actions were undertaken in good faith to maintain uninterrupted program operations under materially changed federal payment conditions. Importantly, the expenditure was allowable, the services supported approved award objectives, the costs were incurred during the award period, supporting documentation exists, no misuse or diversion of federal funds occurred, and no financial harm to the federal government resulted. Note also that going forward, PDA will record future services and subscriptions to prepaid and amortize based on the periods stipulated on the vendor invoices.

Identifying Number: 2025-001 Finding: Material Weakness in Internal Control and Material Noncompliance, Activities Allowed or Unallowed and Allowable Costs/Cost Principles Corrective Actions Taken or Planned: While the ARP ESSER Federal programs are no longer funded, there are other Federal programs that the District receives funding from. Therefore, the administrators in the District who apply and write the grants, specifically the Director of Learning & Instruction, Amabel Crawford, and the Director of Student Support Services, Jackie Janicke, will continue to participate, effective July 1, 2025, in all trainings from the Illinois State Board of Education regarding the programs they have applied for and will additionally confirm that the expenditures written into the grant are allowable under the federal guidelines for each program.

Management agrees with the finding and acknowledges that documentation supporting review, approval, and segregation of duties for certain nonpayroll transactions was not consistently maintained during the audit period. To address this finding, management has formalized procedures requiring documented approval of invoices and nonpayroll expenditures prior to payment. These procedures require a clear separation between the individual requesting or managing a transaction and the individual approving the invoice or payment. Management has also implemented standardized approval workflows to strengthen segregation of duties, enforce approval requirements, and maintain a complete audit trail. Management will incorporate these procedures into formal policies and standard operating procedures and will periodically monitor compliance to ensure controls are consistently applied across programs. Anticipated Implementation Date: Implemented and ongoing; formal policy incorporation expected by September 1, 2026 Contact Person Responsible for Corrective Action: Shahara Wright, Chief Operating Officer & General Counsel and Brook Abitz, Director of People and Operations

View of Responsible Officials and Corrective Action Plan WESST acknowledges this finding, remains committed to continuous improvement, and has already taken proactive, substantive corrective action. During the fiscal year under review, the organization experienced a leadership transition when a new Chief Executive Officer assumed responsibility following the departure of a CEO who had served for 33 years. At the same time, WESST faced significant and sudden changes in long-term funding sources, requiring prompt financial and operational adjustments. A significant finance department change occurred in October 2025. As noted in the Statement of Condition above, no exceptions were identified after that point. In connection with this change, WESST implemented key control processes, including: o All expenses will be reviewed for allowability, allocability, and reasonableness before being charged to the grant. o Payroll charges recorded in the general ledger will be reconciled to employee time records or approved allocation schedules each month. Variances will be investigated and corrected in a timely manner. o All changes to payroll allocations require documented justification and formal review and approval. o Monthly expense reviews will be performed by the: • Staff Accountant • Program Director • Accounting Controller o These reviews will support proper classification of direct and indirect costs and help prevent inconsistent treatment Corrective Action Plan Timeline Completed implementation in March of 2026. Designation of Employee Position Responsible for Meeting Deadline Chief Executive Officer

2025-005 Auditor’s Recommendation: UCM should develop and implement comprehensive written policies and procedures addressing allowability and documentation standards. Controls should ensure only actual costs are charged. Staff responsible for grant accounting should receive Uniform Guidance training. Corrective Action: UCM will develop and implement comprehensive written policies and procedures addressing cost eligibility, documentation standards, and the requirement that only actual costs are charged to Federal awards. The procedures will be designed to ensure costs charged to Federal awards are permitted under the award terms, properly supported, accurately recorded, and consistent with Uniform Guidance requirements. UCM will update its grant accounting procedures to require supporting documentation for all costs charged to Federal awards, including invoices, receipts, payroll records, allocation schedules, contracts, purchase approvals, proof of payment, and other relevant source documents. Estimated, unsupported, or budgeted amounts will not be charged to Federal awards unless specifically permitted by the award terms and adjusted to actual costs within the required reporting period. UCM will also implement a documented review process to confirm that Federal award expenditures are based on actual costs incurred. The review will include verification that the expense was incurred during the grant period, relates to the approved program, is supported by adequate documentation, is charged to the correct funding source, and agrees to the general ledger and supporting records. Evidence of review and approval will be retained with the grant files. Staff responsible for grant accounting, Federal award reporting, payroll allocation, accounts payable, and program budget oversight will receive Uniform Guidance training. Training will include cost eligibility, documentation standards, actual cost requirements, cost allocation, and grant expenditure review procedures. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Liya Tseye & Carmen Romero, Accountants Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Anticipated Completion Date: December 31, 2026

2025-003 Auditor’s Recommendation: UCM should develop and implement comprehensive written policies and procedures addressing time and effort, employee benefits, payroll allocations, and documentation standards. Staff responsible for grant accounting should receive Uniform Guidance training. Corrective Action: UCM is implementing Insperity, a new Human Resource and Payroll software system, to improve the accuracy and documentation of time allocation, payroll processing, and benefit allocation across programs and funding sources, including the Family Achievement Program federal award. UCM will configure Insperity and related procedures to support time allocation by program, grant, or cost objective, supervisor approval, payroll allocation reporting, and retention of supporting documentation. In addition, UCM will develop and implement written policies and procedures addressing time and effort reporting, employee benefit allocations, payroll allocation methodology, review and approval requirements, and documentation retention standards. These procedures will require that employee benefits charged to the federal award are based on actual benefit costs incurred, rather than budgeted or estimated amounts, unless otherwise permitted by the award terms and adjusted to actual costs within the required reporting period. UCM will establish a review process to ensure payroll and benefit costs charged to the federal award are accurate, allowable, based on actual costs incurred, properly supported, and consistent with Uniform Guidance requirements. Staff responsible for grant accounting, payroll processing, and federal award compliance will receive Uniform Guidance training. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Deborah Ewell, Director of Human Resources Laura D’Ambrogi, Grants Manager Anticipated Completion Date: September 30, 2026

VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the Activities Allowed or Unallowed// Allowable Costs/Cost Principles (ALN 10.553, 10.555, 10.559, 10.582, 84.010, 84.027, 84.425D, 84.425U. The PRDE recognizes that the recoup procedures established in the "Manual de Procedimiento de Nómina" are in place; however, the Department acknowledges that the detail of Accounts Receivable shows $3,756,580 corresponding to invoices generated during the audit year. The PRDE is working with the existing manuals, along with the new changes being implemented, to strengthen the recoup process for these overpayments. As such, the PRDE has implemented several procedures which have helped in this collection process. The PRDE is committed to strengthening its documentation practices and internal oversight mechanisms to ensure full compliance with 2 CFR § 200.403(g) and other applicable federal requirements. The PRDE further acknowledges that this is a repeat finding (prior year Finding 2024-005) and accepts the auditors’ recommendation to establish and implement formal procedures to obtain and review subrecipient audit reports in a timely manner, follow up on relevant audit findings, and maintain documentation of all monitoring activities performed IMPLEMENTATION DATE Fiscal Year 2025-2026 RESPONSIBLE PERSON Giovanni Siarez Deputy Director of Payroll Wilfredo Falcón Negrón Human Resources Area Director Office Time Attendance & Leave Evelyn E. Rodríguez Cardé Finance Director

VIEWS OF RESPONSIBLE OFFICIALS As a result of a Specific Conditions letter issued by the United States Department of Education (USDE), in March 2021 the Puerto Rico Department of Education (PRDE) signed a contract with a Third-Party Fiduciary Agent (“TPFA”) to oversee the administration of federal funds. As this was the first time the PRDE was required by the USDE to contract a TPFA, the PRDE received support and guidance from the USDE. The USDE reviewed and approved the key procurement terms of the RFP, including the stipulated fixed fee provision for payment of TPFA services and expenses. The following is the PRDE's response to Finding Reference Number 2025-003. Statement of Condition 1 — Reasonableness of the Average Hourly Rate The PRDE does not agree with the implication, in Statement of Condition 1, that the average hourly rate is unreasonable. As the contract stipulates a fixed monthly fee, the reasonableness of the hourly rate should be calculated over an extended performance period, as the hours worked during a particular month fluctuate depending upon the level of work required to be performed. In the sample of invoices examined for the twelve-month period beginning June 2024 and ending May 2025, the total invoice amounts over the twelve-month period, less related expenses and the 1.5% contribution fee to the Government of Puerto Rico, divided by the total hours worked, results in an average hourly rate of $407.83, which is slightly above the noted “reasonable” rate which was addressed over 5 years ago in the RFP. Adjusting for a cumulative inflation rate of 24.48% since 2020, the RFP range of rates would have been between $81 and $438, so the average hourly rate of $407.83 is within that range. However, it should be noted that the rates in the RFP were expected to be local billing rates and not rates of a global consulting firm providing TPFA services from a team of experienced international senior professionals. The range of rates noted in the invoice template, i.e., $195–$695, and highlighted in each TPFA monthly invoice, approximates rates of the US General Services Administration (GSA). The PRDE does not agree with the recommendation that contract terms with the vendor should be revised before the contract expires. As this was the first time the PRDE was required to contract the services of a TPFA, the PRDE received guidance from the USDE, which reviewed and approved the key procurement terms of the RFP, including the stipulated fixed fee provision for the payment of TPFA services and expenses. The fixed fees were a result of extensive negotiations between the PRDE and the selected vendor and, although the hours and expenses are disclosed in each monthly invoice, this is provided for informational purposes only and, as stated in each invoice, “is not to be used to calculate the Total Amount Due,” which in each month is the applicable fixed fee. In addition, the PRDE does not agree with the recommendation that the TPFA submit supporting evidence for the reimbursement of expenses because (i) the TPFA contract is a fixed fee that is inclusive of all professional service fees and expenses, (ii) the TPFA provides an explanation of major expenses incurred within each monthly invoice, and (iii) the monthly fixed fee invoice is not requesting any specific reimbursement for expenses incurred. Statement of Condition 2 — Allocability Between Federal and Non-Federal Funds The PRDE does not agree with the finding that there is no basis for the allocation of costs between Federal and non-Federal funds. The funding of TPFA invoices from various federal funds was a result of (i) reasonable discussions between the PRDE and the USDE, (ii) the USDE's authorization for the availability of federal funds to pay TPFA invoices, and (iii) the actual availability of both federal and state funds at the PRDE from which to pay TPFA invoices. Furthermore, the TPFA services are applicable to all federal funds under the TPFA's administration, and its work is not directly tied to any specific grant. The funding for TPFA services is divided between federal and state funds as agreed to between the PRDE and the USDE, and payment for those services is determined based upon the availability of both federal and state funds. TPFA services are conducted for the benefit of the entire PRDE organization and, as such, are overhead costs not directly tied to any specific program or purpose. In addition, funds used to pay TPFA invoices are sourced from grant administration accounts that are specifically designated for the payment of overhead costs. Auditor Comment on Management Response for Finding No. 2025-003 The 2 CFR 200.1 establishes that: “Indirect [facilities & administrative (F&A)] costs mean those costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of indirect (F&A) costs. Indirect (F&A) cost pools must be distributed to benefitted cost objectives on bases that will produce an equitable result in consideration of relative benefits derived.” This information was not provided for our evaluation. Also, we made reference to the Program Determination Email for ALNs. 84.938 and 84.425 dated September 18, 2024 (Audit Control Number 02-21-39634), received from Ms. Catherine Miers of the Office of Elementary and Secondary Education of the US Department of Education (USDE), in which they required that the PRDE provide documentation for the following corrective actions: “revised the contract terms to include a reconciliation of total hours and rates to adjust the payments made to the vendor before the contract expiration; requested that adequate supporting evidence from the vendors be presented for any expenses to be reimbursed by the PRDE; and develop an adequate review of the vendors invoice to properly identify the actual hours of services that benefited the Federal programs so a correct allocation of the costs incurred can be made within Federal programs and state funds”. IMPLEMENTATION DATE None RESPONSIBLE PERSON Jullymar Octtaviani Vega Sub-Secretary of Administration Edgar Delgado Serrano Interim Director of Federal Affairs Office

VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) accepts the finding identified by the auditors regarding the incorrect coding of five (5) reimbursement payments for equipment purchases in account E6170 (Donations and Contributions to Private Entities), rather than in the appropriate E5000-series accounts, and the omission of said assets from the institutional property register. The PRDE has initiated the necessary corrective actions to address this deficiency. Specifically, all assets included within the affected reimbursement transactions have been identified, and a detailed inventory is being prepared in which each asset is classified according to the capitalization criteria established in the Restart Program Fiscal Process Guide (unit cost equal to or greater than $500.00 and useful life greater than two (2) years). This inventory distinguishes between capitalizable equipment (E5000 series) and non-capitalizable equipment (E4414), in accordance with applicable regulatory requirements. Once finalized, the inventory file will be submitted to the PRDE’s Office of Property for review and mass upload into the institutional property register, ensuring that all assets acquired with Restart Program funds are properly recorded under PRDE ownership, in compliance with Section 102(h)(3) of the 2018 Hurricane Relief Act and the requirements of 2 CFR §200.302(b)(3)(4). IMPLEMENTATION DATE Fiscal Year 2026-2027 RESPONSIBLE PERSON Edgar Delgado Serrano Interim Director of Federal Affairs Office

VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the Activities Allowed or Unallowed / Allowable Costs/Cost Principles compliance requirement under the IDEA Special Education Cluster (Assistance Listing Nos. 84.027 and 84.173). The PRDE recognizes that certain deficiencies identified by the auditors relate to inconsistencies in supporting documentation, documentation retained in departmental systems, and the need to strengthen administrative controls over the documentation supporting disbursements for private educational and therapy services. The Department further acknowledges opportunities to improve the consistency of information maintained in supporting schedules, contract documentation, proposals, and other records used during the invoice review and payment process. The PRDE respectfully clarifies that, in several instances identified during the audit, the questioned conditions were attributable to documentation inconsistencies, system-generated reporting errors, or documentation that supports the transactions but was not maintained or presented in a standardized manner during the audit process. Specifically, the Department notes that adjustment reports recorded in the financial system agreed with the disbursement vouchers despite errors identified in certain Excel master schedules; that invoice validations performed by the Centers are based on the corresponding "Carta de Aprobación de Consulta de Ubicación," which establishes the approved services and applicable rates for each student; and that federal regulations authorize IDEA Part B (ALN 84.027) funds to be used for eligible children ages 3 through 21, including expenses otherwise allowable under the Preschool Grant (ALN 84.173), as permitted under 34 CFR §300.202(a). With respect to students identified as over 21 years of age, the PRDE conducted an individual review of the affected student records and determined that the population includes students who exited the program at age 21 as well as students for whom documentation exists supporting the continuation of services through individualized educational determinations, transition planning activities, or compensatory educational services. The Department recognizes, however, that documentation supporting these determinations was not maintained in a standardized manner that facilitated timely retrieval during the audit. The PRDE further acknowledges that improvements are needed to ensure that procurement documentation, contract amendments, proposals, invoice support, Excel master schedules, and student-level supporting documentation are complete, accurate, consistent, and readily available for audit and monitoring purposes. Accordingly, the Department accepts the auditors' recommendations and is committed to implementing corrective actions designed to strengthen internal controls, standardize documentation practices, improve supervisory review procedures, and enhance coordination among the responsible program and administrative units IMPLEMENTATION DATE Fiscal Year 2026-2027 RESPONSIBLE PERSON Enid Diaz Nieves Executive Director III Alayra Figueroa Gonzalez Associate Secretary for Special Education

Provide funder-led training sessions for management and staff, maintain current budget tracking incorporated federal program compliance into relevant staff performance evaluations, implement a dual-storage documentation methodology combining a shared drive and a document management system (DMS) and update the Finance Manual.

Provide all management staff with annual training on federal grant requirements, perform periodic internal reviews and a final year-end reconciliation, maintainall grant-related records on a shared organizational drive accessible to all responsible staff, provide formal onboarding and off boarding procedures for federal grant management, and update the Finance Manual .

Corrective Action Plan: Management acknowledges the finding relative to formal documentation for eligible project costs and will enhance review procedures for monthly WIFIA loans draws to have written contemporaneous evidence from the lender in addition to preliminary approval received for project transfers or changes (i.e. renaming of subprojects listed in the loan closing documents within the same scope approved in the loan). The project changes materialized due to a change in expected timing of Sewer Utility work included in joint projects with the City’s Department of Public Works. As a result, standalone projects were executed to complete the required work by the October 2025 deadline mandated in the Sewer Consent Decree. The changes were discussed with the lender upon notification from the Department of Public Works and included in WIFIA quarterly reporting while the formal project approvals are in process. The Utility’s Project Delivery Unit Director is responsible for ensuring that this corrective action is accomplished with an estimated timeline for completion by September 30, 2026. The WIFIA project scope is defined as: I. Water Line Replacement via the Joint Infrastructure (JIRR) Program; II. Sewer Line Replacement via the Joint Infrastructure Recovery Roads (JIRR) Program; III. Sewer System Evaluation and Rehabilitation Program (SSERP); and IV. Sewer Force Main Replacement and Improvement. The eligible activities include, restoration and replacement of damaged gravity sanitary sewer mains, manhole rehabilitation and repair, CIPP lining and point repairs, Water line replacement and repair, Roadway restoration and ADA curb ramp improvements associated with the utility work.

2025-005 Allowability – Interprogram Activity Public Housing Operating Fund ALN 14.850 Significant Deficiency in Internal Control Other matter required to be reported in accordance with Uniform Guidance Condition: The Authority maintains a material interprogram receivable balance in the asset management program (“AMP”), which is due from other programs of the Authority. This interprogram receivable increased by $373,091 from the September 30, 2024 balance of $433,981, for a total receivable balance of $807,072 as of September 30, 2025. Auditor Recommendations: We recommend that the Authority immediately discontinue using Public Housing Operating Fund resources to fund costs or cash shortfalls of other programs or component units. The Authority should prepare a detailed reconciliation of all interprogram receivable and payable balances by program and implement a repayment plan to restore the Public Housing Operating Fund. We further recommend that the Authority implement written cash management and interprogram accounting procedures to prevent future unauthorized advances. These procedures should include monthly reconciliation of all interprogram balances, supervisory review, and approval of interprogram activity. Management Response: Management acknowledges and accepts responsibility for the deficiencies in internal control over allowability and eligibility and are committed to implementing corrective actions that address missing documentation and lack of verifiable procurement procedures to ensure compliance. Reconcile intercompany balances • CHA is currently working with its fee accountant to complete this process Cease Additional Borrowing • Effective immediately, CHA will discontinue the practice of increasing interprogram borrowings from AMP 1 except where expressly authorized by HUD regulations. Implementing a Repayment Plan • CHA will implement a repayment plan to prioritize repayment from unrestricted or otherwise eligible funding sources in compliance with HUD requirements. Monthly Interprogram Reconciliation • Finance staff and fee accountant will reconcile all interprogram receivable and payable balances monthly. • Any new interprogram activity will be reviewed by the Executive Director and Fee Accountant to ensure allowability before recording. Strengthen Budget Monitoring • Management will perform monthly budget-to-actual reviews for every program to identify operating deficits before they require interprogram borrowing. • Programs experiencing budget shortfalls will implement corrective spending measures or identify alternative eligible funding sources. Improve Cash Flow Management • With the assistance of the fee accountant, CHA will prepare monthly cash flow projections for each program to monitor liquidity and prevent the use of restricted Public Housing Operating Funds for other programs. Implement Internal Control Procedures • Written procedures governing interprogram transactions will be incorporated into the Authority's financial policies. • All interprogram transactions will require documentation supporting the purpose, funding source, and regulatory allowability. Oversight by Fee Accountant • The Authority's Fee Accountant will review interprogram balances during monthly financial statement preparation and report unusual activity or growing receivable balances to management. Board Oversight • The Board of Commissioners will receive monthly financial reports that include interprogram receivable and payable balances to provide ongoing oversight of repayment progress and compliance. Monitoring • The Executive Director and Finance Department will monitor compliance with this corrective action plan monthly and adjust operating budgets as necessary to eliminate future interprogram borrowing. Name of Responsible Person(s): Jackie Otto, Executive Director, Sherdana Wade, Director of Operations, Michelle Guidry, Finance Director Projected Completion Date: Some of the corrective activities are underway. We anticipate full compliance ahead of the June 30, 2027 audited submission.

Corrective Action Plan Finding 2025-001 – Allowable Costs Requirement – Time and Effort Reporting for Salaries Corrective Action: Management concurs with the findings. Day One will formalize and implement written procedures governing the documentation, review, and reconciliation of personnel costs charged to federal awards. Employees whose compensation is charged, in whole or in part, to federal awards, will be required to complete after-the-fact timesheets that accurately reflect the work performed and the total activity for which they are compensated. The documentation will be reviewed and approved by the employee's supervisor. The Finance Director is responsible for reconciling payroll allocations charged to federal awards to the certified time and effort documentation on a regular basis and ensuring that any differences identified are reviewed and corrected in a timely manner. The Finance Director is responsible for supporting documentation for payroll allocations and reconciliations is maintained in accordance with Day One's record retention policies. Day One will update its written policies and procedures to reflect these requirements and has provided training to employees and supervisors responsible for completing, reviewing, and approving time and effort documentation. The Executive Director will periodically review compliance with these procedures as part of Day One’s internal control monitoring process. We will also do a final year-end review of time and effort allocations and certification. These corrective actions are intended to strengthen internal controls over payroll allocations and ensure that personnel costs charged to federal awards are adequately documented, properly allocated, and supported in accordance with 2 CFR Part 200. Responsible Official: • Anne Patterson, Executive Director – Oversight of implementation and ongoing compliance. Anticipated Completion Date: The corrective actions will be implemented and effective as of September 1, 2026. We have already implemented this process for FY2025. Once the process is complete, Day One will update, after-the-fact documentation and approval to date and will continue the process thereafter.

Finding – 2025-002 Allowable Costs and Cost Principles and Activities Allowed and Unallowed – Significant Deficiency in Internal Controls Over Compliance, Noncompliance Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Year(s): 2025 Federal Agency: US Department of Treasury Corrective Action: The Division will enhance controls and processes around the allocation of personnel-related costs, including retaining calculations and allocations of personnel costs that are charged to the grant. 1. Internal process to be continued throughout FY 2026. 2. The program directors will provide finance with a thorough written and grantor approved plan on all program staff that are to have time allocated to grant funded operations. Should any deviations of allocations of salary or staff occur from initial approved plan the program staff will provide written approval from the grantor to the finance department. 3. Billing staff for grant funded programs will provide all calculations via excel spreadsheets based on and ties to UKG Payroll data per payroll cycle. The calculations will be reviewed/approved electronically and saved/stored to the regional internal digital file storage system, as well as provided to the finance department for audit purposes. 4. Continued training of field staff and program directors to occur. Anticipated Completion Date: 10/01/2026 Responsible Contact Person: Kendall Phillips, Grants & Contracts Accountant

Finding Reference Number: 2025-03 View of Responsible Official and Planned Corrective Action Date: Corrective Action: The Finance Director has created additional cost centers for specific federal awards within the financial management system. FY26 YTD expenditures related to the specific grants will be reviewed and re-allocated. All future expenditures will be coded at the time costs are incurred. Name of Contact Person: Susan Phelps, Finance Director Projected Completion Date: September 30, 2026

Finding Reference Number: 2025-01 View of Responsible Official and Planned Corrective Action Date: Corrective Action: The Finance Director has created additional cost centers for specific federal awards within the financial management system. FY26 YTD expenditures related to the specific grants will be reviewed and re-allocated. All future expenditures for the specific grants will be coded at the time costs are incurred. Name of Contact Person: Susan Phelps, Finance Director Projected Completion Date: September 30, 2026

The Child and Family Services Agency (CFSA) concurs with the findings as stated. CFSA will review the intradistrict mandate with the Office of the Chief Technology Officer to gain greater clarity into their budgetary allocation of expenditure methodologies to subsidiary agencies, including CFSA, with a goal of providing the requested information to auditors during future audits. CFSA will initiate training for management staff to address appropriate practice for time keeping and approvals by September 30, 2026.

The Department of Health (DC Health) concurs with the finding. DC Health and OCFO will coordinate the development and implementation of a standard operating procedure to ensure that program administrators are implementing a secondary review of journal requests and OCFO accountants maintain a tracking record of all journal requests and properly review each request to ensure the expenditure is not duplicated via a journal entry.

The Office of the Deputy Mayor for Planning and Economic Development (DMPED) does not concur with the auditor’s finding regarding the allowability of subtenant improvement allowance per the CPF guidance. DMPED has sought express approval from the Federal awarding agency (U.S. Department of Treasury) regarding the use of funds. DMPED has evaluated its procedures to ensure only allowable expenses are charged to the program as required under 2 CFR Section 200.403. DMPED determined in FY25 that it needed to seek approval from the awarding Federal agency on allowable costs, which it completed in 2026.

Finding 2025-002: Agency: U.S. Department of Health and Human Services (CSBG) Program: Community Service Block Grant (AL No. 93.569) Significant Deficiency and Noncompliance over Eligibility Condition: During our testing of participant eligibility for the CSBG program, we noted the following exceptions out of a sample size of 40: (1) for one participant, the CSBG eligibility form was not signed by the case manager; and (2) for two participants, we were unable to obtain documentation to support proof of residence. Recommendation: We recommend that management strengthen internal controls over eligibility determination and documentation to ensure compliance with federal program requirements. Management should establish procedures to require complete and signed eligibility forms prior to approving or providing program benefits and consider implementing a standardized eligibility checklist to ensure all required supporting documentation (e.g., income verification, residency, other criteria) is obtained and retained. Auditee Response and Corrective Action Plan: UPOManagement acknowledges the audit finding and will ensure that staff follow established internal control activities to ensure compliance with CSBG participant eligibility. UPO will institute continuous training and increased monitoring of compliance by the internal Office of Performance Management regarding the review, retention, and documentation of eligibility determination evidence submitted by program participants. Anticipated Completion Date: September 30, 2026

Management Response and Corrective Action Plan Finding 2025-001 – Allowability Federal Agency: United States Department of Health and Human Services Program Name: Research and Development (R&D) Assistance Listing Number: 93.859 Responsible Individual: BIDMC – Jarod Kohr, Director, Research Finance or The Center - Roy Bourne, Director, Research Finance and Operations Contact Information: BIDMC - jkohr@bidmc.harvard.edu; 617-216-7479 The Center - rbourne2@joslin.harvard.edu; 617-309-5741 A review of Beth Israel Deaconess Medical Center’s (BIDMC) salary allocation process revealed 53 instances out of approximately 11,000 records of allocation in excess of NIH Salary Cap limits (0.04%). BIDMC acknowledges discovery of system limitations that will correct future instances. Accordingly, management has concluded that controls are operating as intended, but will be enhanced to limit human errors. Corrective Action Plan: - Management will implement a calculation control that will prevent the ability to save changes to salary allocation that exceeds the salary cap for the respective period. (Completed) - Management will implement a calculation control that will prevent the ability to reflect a percent salary higher than the percent effort for any salary cap controlled grant. (Completed) - Management will monitor monthly changes to effort/salary allocations in the Time and Effort system for calculated variances. (Ongoing) Expected Completion Date: October 1, 2026 Status of Completion: In process The Center’s management acknowledges that an invoice was incorrectly matched to a purchase order; however, this was not reflective of the overall control environment. The Center maintains established controls over purchase order invoice processing, including system-generated duplicate invoice detection, cost matching tolerances, and restrictions preventing matching to closed purchase orders. Transactions outside established parameters are automatically flagged for manual review. Management performed a targeted review of these transactions, noting expenditures were properly allocated with the exception of the item noted in this finding. Accordingly, management has concluded that controls are operating effectively overall, Accordingly, management has concluded that controls are operating effectively overall, while continuing to evaluate and enhance processes to further mitigate the risk of recurrence. Corrective Action Plan: - Management will reinforce matching requirements through targeted training and communication with Accounts Payable and Purchasing (Completed) - Periodic reconciliation reviews will be performed to identify and correct any misallocated costs as necessary (Completed) - The Center’s planned implementation of a new ERP system on October 1, 2026 will introduce enhanced automated matching controls, further reducing the likelihood of recurrence Expected Completion Date: October 1, 2026 Status of Completion: In process