Corrective Action Plans

Corrective Action Taken Management concurs with the finding. The Organization transferred $151,099.42 from its operating funds back into the SFSP program account prior to the financial statements being available to be issued, thereby restoring the unallowable charge. Additionally, to prevent recurrence, the Organization obtained competitive bids and received approval for a written payroll services contract before June 2025, in advance of the start of the camp season (i.e. the Organization’s operating period). This process was conducted in accordance with federal procurement requirements. Planned Ongoing Corrective Action: The Organization has strengthened its procurement and contract approval procedures to ensure all future contracts funded by the SFSP are subject to competitive bidding, documented in writing, and approved by the State agency prior to charging costs to the program. Responsible Official: Chaim Mendel Friedman, Camp Program Administrator, is responsible for overseeing corrective actions and ensuring compliance with procurement standards and cost allowability requirements. Completion Date of Corrective Actions: Corrective actions were completed prior to the date the financial statements were available to be issued, with continuing oversight in subsequent program years.

FINDING 2024-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-882-6426 clane@vincennes.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Clerks office will identify non- compliant activities to ensure that funds are being used appropriately and according to federal guidelines and principals. We will consult with the relevant personnel to ensure understanding of allowable and unallowable activities and identify areas that may need additional training. We will enhance our review and approval process and provide clear documentation requirements to our departments. Anticipated Completion Date: This corrective action plan will go into effect immediately.

Finding Number 2024-005: Activities Allowed or Unallowed, Allowable Costs/Cost Principles – Significant Deficiency in Internal Control Over Compliance and Noncompliance Corrective Action: To ensure compliance with GAAP and accurate reporting on the SEFA, Management will implement formal policies and procedures to accrue federal expenditures in the period in which costs are incurred. Grants Accounting will review payroll transactions and related fringe benefits at period-end to confirm proper accrual and recording. Management will also collaborate with the Payroll Service Provider to enhance accuracy and reduce errors in payroll allocations. These actions are intended to ensure federal expenditures are recorded in the correct fiscal year and prevent recurrence of prior year findings. Name of Responsible Individual(s): Jason Brenier, Judy Bokhari, and Luz Gonzales-Toscano Anticipated Completion Date: January 2025 – immediate term and December 2026 software implementation.

Management agrees with the finding. Management has downloaded 2 CFP Part 200 for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly. Contact Person: Renee LaFleur, Executive Director Anticipated Date of Completion: December 31, 2025

FA 2024-001 Improve Budgetary Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425U210012 (Year: 2021) Questioned Costs: $21,615 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed instances in which expenditures had not been properly approved by the pass- through entity. Corrective Action Plans: Going forward, the Sumter County Schools Program Director will review, sign, and date all purchase orders to signify that the Program Director has verified that the federal program costs have been written and approved in the consolidated application and/or the budget has been amended to include the costs and approved in the consolidated application and the costs are accurately reflected in the general ledger prior to payment. Estimated Completion Date: August 1, 2025 Contact Person: Jannie Carter, Finance Director Telephone: (229)931-8500 Email: janniecarter@sumterschools.org

We agree with the findings and recommendations. This was an isolated incident whereas the payment amount was mistakenly pulled from the wrong line on a contractor’s pay application. This overpayment was missed in the subject fiscal year as the program was still active. Once the overpayment was identified, the county sought reimbursement from the vendor for the overpayment and has since received the funds. The reimbursement will be included as program revenues in the next audit report. The County will reconcile contract values as each pay application is processed in lieu of awaiting program/project closeout in the future.

For payroll, procedures will be implemented to ensure that payroll costs allocated to federal grants are supported by actual time. For nonpayroll, procedures will be enhanced to ensure proper allocation of nonpayroll costs to federal grants. Allocations will be reviewed and monitored on a monthly and quarterly basis to prevent misallocation and ensure compliance with the Uniform Guidance. Personnel Responsible for Implementation: Executive Director Christy Zamani, and Beaulieu Accountancy Corporation Date of Implementation: August 5, 2025

To address this finding, AACC will adhere to the financial policies and procedures requiring all necessary itemized information be submitted to accounting with the proper signatures for review and approval. (Financial Policies and Procedures, page 26) Additionally, a tracking document will be utilized by the project manager outlining all expenditure reporting and invoices for each of the sub-award recipients. This document will be reviewed during the meeting with the accounting services department for reconciliation with the transactions reported in AACC’s accounting systems. (Financial Policies and Procedures, page 42).

To Address this finding, AACC will adhere to the financial policies and procedures requiring all necessary itemized information be submitted to accounting with the proper signatures for review and approval. (Financial Policies and Procedures, page 26) Additionally, a tracking document will be utilized by the project manager outlining all expenditure reporting and invoices for each of the sub-award recipients. This document will be reviewed during the meeting with the accounting services department for reconciliation with the transactions reported in AACC’s accounting systems. (Financial Policies and Procedures, page 42).

Significant improvements were made in 2024, and again this year’s findings highlight the need for stronger documentation of signed contracts, approved rate changes, and allocation support. To address this, we are further expanding use of the HR Solution’s (Rippling) workflow and document management tools to automate approvals and ensure a complete audit trail. In addition, our new global hub structure, with dedicated HR support functions, will provide greater oversight and consistency across entities. These measures will enhance compliance and reduce the risk of recurrence going forward.

U.S. Department of Housing and Urban Development – CFDA 14.228 Condition: The County charged payroll costs using an internal allocation method that included salaries, benefits, and supplies, rather than actual expenditures. This method was not supported by an approved cost allocation plan. Additionally, the hours charged were based on total grant administration time, not specific to the CDBG program. Recommendation: The County should ensure that all costs charged to federal programs are based on actual expenditures or an approved cost allocation plan. Documentation should be maintained to support all reported costs, and internal controls should be strengthened to prevent reliance on unsupported methodologies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The County will not be applying for any CDBG grants in the future unless there is adequate administrative cost allocation in the grant. The County will continue to make every effort to adequately close out CDBG grants and provide reports to the granting organization as staff and priorities allow. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins Planned completion date for corrective action plan: Completed and on-going

Federal program title - Local Assistance and Tribal Consistency Fund program (LATCF) CFDA 21.032 Recommendation: We recommend the County refine its understanding and interpretation of the standards and ensure that the County policies and procedures are consistent with that understanding and interpretation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The LATCF funds were reported on the SEFA under CFDA 21.032 by the CAO’s department because the funds were transferred from the CAO’s fund to the DOT fund, with the understanding it would be expended. However, DOT did not spend the funds within the same fiscal year in which they received the transfer due to a misunderstanding that the funds could not be used for prior year expense. As a result, the funds were recorded as unearned revenue in fiscal year 2023/24, and the related expenditures will be reported in the following fiscal year. Name(s) of the contact person(s) responsible for corrective action: Lisa McNeely Department of Transportation Business Manager & Christine Gaffney Auditor-Controller. Planned completion date for correcting action plan: Completed

Finding 2024-010 – Material Weakness – Allowable Costs/Cost Principles Condition The District supports time charged to federal awards via semi-annual certifications which are approved by the grant administrator or the building principal. In order for a cost to be supported at the time of final reimbursement, the semi-annual certifications should be approved by the grant administrator or the building principal. Title I Grants to Local Educational Agencies (ALN 84.010) The final reimbursement claim for the Title I Grants to Local Educational Agencies (Title I) program were due to Wisconsin Department of Public Instruction (DPI) on September 30, 2024; however, the final reimbursement claim for the Part A award was not submitted to DPI until November 18, 2024, and the CSI award was not submitted to DPI until October 1, 2024, due to an extension. Five of the 40 individuals sampled had their semi-annual certifications not approved timely and were approved after the due date of the final reimbursement claim, but before the date of the actual submission of the final reimbursement claim. An additional two individuals of the 40 sampled had their semi-annual certifications approved after the final reimbursement claims were submitted. Upon further review of all the spring semi-annual certifications for the Title I awards, there were an additional 50 individuals that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim but before the submission of the final reimbursement. Additionally, nine individuals had their semi-annual certifications approved after the final reimbursement date of the Part A award and another 59 individuals from Part A did not have their semi-annual certifications approved at all. Head Start Cluster (ALN 93.600) The final reimbursement claim for the program was submitted to the Federal agency on November 22, 2024. Four of the 40 individuals sampled had their semi-annual certifications approved by the Head Start administrator after the submission date of the final reimbursement claims. Upon further review of the all the spring semi-annual certifications, there was an additional individual that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim and another four individuals that did not have their semi-annual certifications approved at all. The samples were not statistically valid. Corrective Action Plan The Office of Finance agrees that it is important that certifications be completed in a timely manner and award reimbursements are submitted within the deadlines. The Office of Finance and the District as a whole is working on improving its internal controls system wide. We are committed to developing sound processes and procedures that are in full compliance with federal and state regulations. An example of a process improvement is to send out reminders on a regular schedule to school leaders and central office employees for programmatic compliance. These activities will be completed in advance of due dates going forward to ensure timely submission of grant claim reimbursements. Annual training for school leaders and central office staff is also part of the process improvement plan underway. Name(s) of Contact Person(s) Responsible for Corrective Action: Chief Financial Officer, State and Federal Programs Director, Comptroller, Grant Accounting Manager Anticipated Completion: 06.30.2026

Auditor's Recommendation: Strengthen policies and procedures to ensure proper authorization and documentation of payroll changes. Management Response: While ODI does not disagree with the audit finding, the Agency does clarify the context of the finding. ODI has a policy for setting, processing, and approving staff wage rates as follows: Sr. HR Manager or Payroll Assistant process new hires and sets them up in the timekeeping system (NOVAtime). Any salary changes are also processed by DHR (may also be processed by supervisor) on a change status form and approved by CEO. The auditors performed tests to determine if the CEO approved the change status form. As mentioned in the audit finding, of the audit sample of employees tested in the 16 pay periods from more than 250 pay periods, six employees did not have their change of status forms signed by the CEO. Audit requirements for federal awards require the auditors to assign a value to specific instances of noncompliance as “known questioned costs”. The known questioned costs for this finding are $14,112 and are comprised of the transactions the auditors tested for allocated wages of the six employees to specific grants. The auditors further calculate “likely questioned costs” by extrapolating the auditor’s sample across the entire population from which the sample is drawn and is $553,607. Is it important to note that the “known questioned costs” and the “likely questioned costs” are not calculations of errors or misstatement in the financial statements. All six employees' pay rates were processed correctly despite missing CEO signatures on the change status forms. Corrective Action: -Conduct comprehensive internal audit of all current staff to verify proper processing and CEO approval of change status forms -Implement dual-filing system: approved forms will be maintained in both personnel folders and financial accounting folders to verify that approved pay rates are used when charging labor costs to any grant. Responsible Personnel: Karen Dickson, Sr. Finance Director; Lisa Tucker, Sr. HR Manager Implementation Date: Immediate implementation

Auditor's Recommendation: Strengthen policies and procedures to ensure Suspension and Debarment Status verification for all vendors subject to verification under ODI's Procurement policy, prior to contract execution. Management Response: ODI acknowledges this finding without disagreement. Corrective Action: Implement mandatory suspension and debarment status verification for all new vendors before entering into any contractual agreements. Responsible Personnel: Karen Dickson, Sr. Finance Director Implementation Date: Immediate implementation

USAID Foreign Assistance for Programs Oversees – Assistance Listing No. 98.001 Recommendation: Management should review its existing control structure and ensure that there are adequate processes and controls to ensure only expenditures incurred during the period of performance are booked to Federal programs and that the correct program codes are charged, based on the underlying supporting documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Training on the Federal awards regulations to be provided to the country office. In addition, adjustments will be made to the review structure of expenditure to ensure full compliance. Follow up of the implementation status will be carried out by HQ finance. Name(s) of the contact person(s) responsible for corrective action: Florence Ruona Planned completion date for corrective action plan: September 30, 2025

The Project acknowledges the finding regarding the interproject payable. Management has developed the following corrective action plan: Repayment of Payable - The outstanding payable balance ot the related HUD project will be repaid in full by September 30, 2025. Documentation of repayment will be maintained and made available for audit verification. Elimination of Interproject Borrowing - Effective immediately, the Project has ceased the practice of borrowing funds from other HUD-assisted projects. Future interproject transactions will not be initiated unless expressly authorized by HUD. Polidy Development and Implementation - The Project will adopt a written policy governing cash management and interproject transactions by September 30, 2025. The policy will prohibit interproject loans without HUD approval and establish procedures for timely monitoring of accounts payable. Training and Oversight - Project staff responsible for financial reporting will receive training on HUD requirements and Uniform Guidance within 120 days. In addition, management will review monthly financial reports to ensure no interproject balances exist.

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 235GA32N1099 (Year: 2023) Questioned Costs: $7,388 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The following corrective actions will be implemented by the School District: 1. Implement Strengthened Pre-Approval and Documentation Procedures: a. All Child Nutrition purchases will require a completed purchase request form that clearly identifies the funding source, purpose, and allowability under federal guidelines. b. Documentation (invoices, quotes, purchase orders) must be attached and reviewed by the School Nutrition Director and CFO or designee before approval. 2. Enhance Segregation of Duties: a. The individual initiating a purchase or expenditure will not be the same person approving or reconciling it. b. Monthly expenditure reviews will be performed jointly by the Finance Department and School Nutrition leadership to ensure accuracy and compliance. 3. Establish an Internal Monitoring Checklist: a. The School Nutrition Department will implement a monthly internal monitoring checklist that includes documentation review, reconciliation of expenditures, and verification of procurement compliance. The CFO will meet with the Nutrition director monthly. 4. Update Written Polices and Procedures: a. The district's Financial Procedures Manual and the School Nutrition Operations Manual will be updated by December 2025 to reflect all new internal control steps and approval requirements specific to federal expenditures. Estimated Completion Date: June 30, 2026 Contact Person: Tiffany Crockett, Chief Financial Officer Telephone: 478-946-5521 Email: tiffany.crockett@wilkinson.k12.ga.us

Views of Responsible Officials: Management agrees and will implement improved documentation and review procedures. Estimate time of completion: February 10, 2025.

Finding 2024-03 Insufficient Documentation of Other Direct Expenses Condition: During testing of direct costs charged to the federal program, the Organization did not maintain sufficient documentation to fully support all expenditures claimed. In one instance, a receipt supporting a claimed expense was missing. In three additional cases, although the expenditures were generally supported, the documentation did not clearly reflect how the amounts allocated to the major federal program were determined. While these issues were isolated and the known and likely questioned costs were immaterial, the lack of complete documentation represents noncompliance with federal requirements for allowable costs. Corrective Actions Taken or Planned: The Organization will develop written guidelines specifying the required supporting documentation for each type of direct expense. Set up vendors in QuickBooks. We will hire and train Finance Manager to manage and track revenue and expenses, QuickBooks, grant reporting etc. All receipts and expenses will be scanned in and kept electronically. The Organization will provide training on documentation requirements, proper record submission, and compliance expectations.

Corrective Action Plan: Shiloh will expand its recurring processes around the disbursement of funds under its federal awards to ensure there is documentation that the associated expenses are allowable. Shiloh will also revisit its relationship with Spark Community Foundation who are currently engaged to perform the review and approval determination, including for Shiloh specific charges.

County department personnel changes have been implemented, which address this deficiency. Additional training from the Auditor’s Office and state grantors has occurred for newer staff in certain departments with large amounts of federal and state awards.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Corrective Action Plan: To mitigate the risk of error in payroll allocation and ensure compliance with allowable cost provisions, CFSC will enhance its payroll review process with the following corrective actions: 1. Enhanced Payroll Verification Process: a. CFSC will implement an additional cross‐checking step in the payroll entry process by requiring finance staff to a run a “Program Summary by Projects Lists” report in the timekeeping system (i.e., Clicktime) before submitting for payroll. b. This report will allow finance staff to verify that total hours worked per project per employee align with the grant allocation and employee timesheets before payroll is processed. 2. Regular Internal Audits & Compliance Checks: a. Finance will conduct quarterly internal payroll audits to identify any discrepancies in time tracking and grant allocations. Anticipated Completion Date: These corrective actions have been fully implemented as of FY25.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Corrective Action Plan: In response to the FY21 Corrective Action Plan, CFSC implemented a Subrecipient Monitoring Policy in June 2024 to ensure compliance with the Uniform Guidance for monitoring subrecipients of federal funding, including audit requirements and the verification of suspension and debarment status. To further strengthen compliance and ensure timely verification, CFSC will implement the following actions: 1. Mandatory Pre‐Award Verification Timing & Documentation: a. Suspension and debarment status must be verified on SAM.gov by the assigned Grant Specialist before the execution of any subaward agreements. b. The verification data and results will be documented by the assigned Grant Specialist and included in the Risk Assessment process prior to award issuance. c. Any subrecipients flagged as high risk due to past audit findings will undergo enhanced pre‐award due diligence before subaward execution to be carried out by the assigned Grant Specialist. 2. Grant Compliance Oversight & Approval: a. The Grants Manager (or designee) will review and approve all subrecipient compliance checks before final award execution. b. Any exceptions or delays in verification must be documented and approved by the CFAO & Deputy Director before proceeding. 3. Quarterly Compliance Audits: a. The Grants Manager (or designee) will conduct quarterly internal audits of subrecipient monitoring files to confirm that suspension & debarment verification was completed timely before subaward execution. b. The Grants Manager will be responsible for reporting any identified deficiencies to senior management and ensuring timely correction for policy reinforcement. Anticipated Completion Date: CFSC has implemented corrective actions regarding mandatory Pre‐award verification & documentation (action item 1) and grant compliance oversight & approval (item 2). CFSC has begun to implement the quarterly compliance audits (item 3) and will have this fully implemented by the end of FY25.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Corrective Action Plan: In response to the FY21 Corrective Action Plan, CFSC implemented a Subrecipient Monitoring Policy in June 2024 to ensure compliance with the Uniform Guidance for monitoring subrecipients of federal funding, including audit requirements and the verification of suspension and debarment status. To further strengthen compliance and ensure timely verification, CFSC will implement the following actions: 1. Mandatory Pre‐Award Verification Timing & Documentation: a. Suspension and debarment status must be verified on SAM.gov by the assigned Grant Specialist before the execution of any subaward agreements. b. The verification data and results will be documented by the assigned Grant Specialist and included in the Risk Assessment process prior to award issuance. c. Any subrecipients flagged as high risk due to past audit findings will undergo enhanced pre‐award due diligence before subaward execution to be carried out by the assigned Grant Specialist. 2. Grant Compliance Oversight & Approval: a. The Grants Manager (or designee) will review and approve all subrecipient compliance checks before final award execution. b. Any exceptions or delays in verification must be documented and approved by the CFAO & Deputy Director before proceeding. 3. Quarterly Compliance Audits: a. The Grants Manager (or designee) will conduct quarterly internal audits of subrecipient monitoring files to confirm that suspension & debarment verification was completed timely before subaward execution. b. The Grants Manager will be responsible for reporting any identified deficiencies to senior management and ensuring timely correction for policy reinforcement. Anticipated Completion Date: These corrective actions will be fully implemented by the end of FY25, with ongoing monitoring and enforcement thereafter.