Corrective Action Plans

During the FY2024 audit, Mana Maoli began implementing improvements to strengthen documentation practices for federal expenditures. These improvements include: Incorporating a centralized electronic system for retaining invoices, receipts, and other supporting documentation. Reinforcing existing approval procedures as part of the disbursement workflow. Providing targeted staff reminders and guidance on documentation expectations related to federal awards. Conducting periodic spot-checks of documentation to confirm consistency and identify any areas needing clarification. These steps are designed to strengthen controls using the organization’s existing capacity and tools. Mana Maoli will continue monitoring the process and making incremental refinements as needed. Anticipated completion date: June 30, 2026

Finding reference: 2024-004 - Inappropriate Allocation of Expenses The following steps were taken to bring the Borough into compliance. 1. Both the accounting specialist and the Borough Manger have implemented a tracking system to cross reference and monitor compliance of both payments and receipts of all grant funds. 2. Implemented June 2025.

CONDITION: During the calendar year 2024, the City did not utilize a formal general ledger system of accounting to track the financial activity (financial position and results of operations) for several ‘Funds’ held at the City. The activity of these funds is either 1) maintained in spreadsheet fashion similar to a checkbook used in personal finances, 2) recorded partially (expenses only with no revenue), or 3) not tracked at all. As these funds are not maintained using the City’s accounting software package, management does not have the ability to efficiently generate financial reports necessary to provide management with the proper fiscal oversight. This condition included the American Rescue Plan Act (ARPA) funding known as the Coronavirus State and Local Fiscal Recovery Fund. However, it should be noted that City personnel were able to prepare spreadsheets to document which expenditures were utilized to prepare the necessary quarterly reporting requirements to the Department of Treasury. This is a repeat finding (2023-002) from the prior year. CRITERIA: Prudent internal control procedures in the areas of general ledger management and financial reporting include maintaining a formal general ledger system of accounting to track the activity of all ‘Funds’ maintained by the City. In specific as it relates to federal programs, Section 2 CFR 200.403(g) of the Uniform Guidance requires that federal costs must be adequately documented which would include the maintaining of a formal general ledger system of accounting for all ‘Funds’ of the City. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City is continuing to assess the current workload and expertise of the City’s business office personnel in an effort to determine a feasible timeframe to continue the process of creating a formal general ledger system of accounting for all City ‘Funds’ that are not already entered into the software accounting system. The timeframe for completion of this review will occur during the first nine months of calendar year 2026 with the intention of having the City be in full compliance with Section 2 CFR 200.403(g) of the Uniform Guidance which requires federal costs to be adequately documented which would include the maintaining of a formal general ledger system of accounting for all ‘Funds’ of the City.

CONDITION: During the calendar year 2024, the City did not record the necessary adjustments to the various ‘Fund’ general ledgers of the City to properly reconcile the balance sheet accounts, such as cash, receivables, payables, and payroll-related liabilities to the underlying supporting documentation available at the City (which includes reconciliations of cash prepared independently by City personnel but do not agree to amounts reported in the various general ledgers). This included ‘Funds” containing significant federal funding such as the City’s Community Development Block Grant (CDBG) Program and American Rescue Plan Act (ARPA) funding known as the Coronavirus State and Local Fiscal Recovery Fund.CONDITION (Continued): As a result, the financial position and results of operations as shown throughout the calendar year were inaccurately stated. However, it should be noted that the Community Development Department of the City and other City personnel maintain separate financial reporting for these federal funds, independent of the aforementioned ‘Fund’ general ledgers sufficient to ascertain the revenues and expenditures of the federal programs. This is a repeat finding (2023-001) for the prior year. CRITERIA: Prudent internal control procedures in the areas of general ledger management and financial reporting include the reconciliation of all general ledger account balances to underlying supporting documentation monthly with independent oversight and approval as part of the process. In specific as it relates to federal programs, Section 2 CFR 200.403(g) of the Uniform Guidance requires that federal costs must be adequately documented which would include the applicable general ledgers of the City. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City is continuing their review of the recommended options as presented by the Audit Firm’s recommendation for feasibility considering current manpower, expertise, and budgetary constraints. In addition, the City plans to ensure that written procedures for all accounting functions are implemented, reviewed and updated as necessary with the objective of ensuring that all balance sheet account balances are supported by the underlying documentation available at the City. The timeframe for completion of this review will occur during the first nine months of calendar year 2026 with the intention of having the City be in full compliance with Section 2 CFR 200.403(g) of the Uniform Guidance which requires federal costs to be adequately documented which would include the applicable general ledgers of the City.

Finding Number: 2024-007 Finding Title: Allowable Costs/Cost Principles – Cost Allocation Plan Name of Contact Person Responsible for Corrective Action: Dillon Hayes, County Administrator Corrective Action Planned: The County has contracted with a new vendor to prepare its Cost Allocation Plan effective in 2025. Anticipated Completion Date: Completed August 2025

Finding 2024-243: The Division did not properly evaluate costs related to the Rehabilitation Services- Vocational Rehabilitation Grants to States and direct costs were incorrectly recorded as indirect costs for the grant. Related to Prior Finding: N/A Agency’s view: Agree 7.1 Corrective Action Plan: Establish and Document Clear Cost Classification Procedures: Develop written procedures defining and distinguishing between direct and indirect costs. 7.2 Strengthen Internal Controls Over Cost Allocation: Implement review and approval controls to verify proper cost classification before posting transactions to Luma or inclusion in the indirect cost pool. 7.3 Enhance Staff Training and Knowledge: Provide targeted training for fiscal staff to ensure understanding of allowable cost principles and consistent application of cost classification policies. 7.4 Ensure Documentation Retention and Review: Maintain complete documentation supporting all cost allocations, including approval records, cost pool calculations, and reconciliations. 7.5 Perform Regular Monitoring and Verification: Conduct periodic reviews of both direct and indirect cost transactions to confirm classification accuracy and identify any required adjustments. Anticipated Corrective Action Date: 04/01/2026 Responsible for Corrective Action: Eric Bjork, Fiscal Officer

Finding Number: 2024-041 Audit Type: Single Audit Finding Title: Unsupported FEMA Reimbursements Related Finding: 2024-031 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will implement a documentation checklist and assign a grants compliance officer to ensure all FEMA reimbursement requests are fully supported. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will ensure all FEMA-related expenditures are properly documented and retained. 5. Status of Prior Year Finding This is a new finding.

Finding Number: 2024-042 Audit Type: Single Audit Finding Title: Misallocation of Expenditures Across Federal Awards Related Finding: 2024-028 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will revise its grant accounting procedures to ensure expenditures are properly allocated to the correct federal awards. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will implement additional review steps during the grant reimbursement process. 5. Status of Prior Year Finding This is a new finding.

Finding Number: 2024-043 Audit Type: Single Audit Finding Title: Use of Unapproved Federal Funds to Satisfy Required Local Match Related Finding: 2024-022 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department2. 2. Planned Corrective Action The City will revise its grant accounting procedures to ensure only eligible local funds are used for matching requirements. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will coordinate with granting agencies to confirm match eligibility. 5. Status of Prior Year Finding This is a new finding.

Management Response: Feeding South Florida complied with LFPA contract provisions for food purchases by meeting and invoicing the required food purchase minimum. Freight was an allowable cost for the contract. Despite miscategorizing 5 freight invoices, Feeding South Florida complied with the LFPA contract for freight by meeting and invoicing the total amount allowable for freight. To ensure ongoing compliance, we established and implemented a comprehensive Standard Operating Procedure (SOP) for all contracts and grants, including the LFPA program, which has been consistently followed since LFPA Plus began. To strengthen oversight and enhance audit readiness, administrative responsibility for this contract has transitioned from the Grants Department to the Finance Department. This restructuring reinforces our compliance framework, improves operational support, and embeds stronger accountability measures across all organizational levels and throughout our region.

CVCA lost key accounting staff and experienced significant difficulty in locating and hiring competent replacements within the department. New fiscal staff were onboarded in October 2024. The new fiscal staff started to enforce the proper policies and procedures starting in November 2024 when prior finance staff was no longer involved managing CVCA books. All invoices and journal entries need proper backup attached for approval and processing.

1. Documentation Recovery — Completed (September 2025) ○ Contacted vendors to obtain duplicate invoices and receipts for all transactions with missing documentation. 2. Current Transaction Review — Completed (October 2025) ○ Conducted a comprehensive review of all pending and recent transactions. 3. Documentation Requirements Policy — Completed (September 2025) ○ Corrected identified gaps and implemented a Pending Documentation File system to track incomplete transactions. ○ Prepared expense memoranda describing goods/services, business purpose, and program benefit for any unrecoverable items. ○ Organized all recovered documentation into auditable files for review. ○ Establishes documentation standards for all expenditures. ○ Implements enhanced requirements for federal awards in compliance with 2 CFR §200.302 and § 200.303. ○ Requires submission of receipts/invoices within five (5) business days. ○ Aligns retention and compliance standards with federal and state regulations. ○ Defines clear consequences for non-compliance. 4. Strengthened Documentation Controls — Completed (October 2025) Purchases over $500 require prior written approval. ○ All receipts must be submitted within five (5) business days of the transaction. ○ Missing documentation triggers a 48-hour follow-up hold on spending authorizations. ○ Monthly certifications confirm all transactions are fully supported. 5. Enhanced Federal Award Documentation — Completed (October 2025) ○ Implemented a federal expenditure checklist requiring itemized receipts, program benefit descriptions, budget references, and authorizing signatures. ○ The Finance Director conducts monthly reviews of all federal expenditures. 6. Staff Training — Completed (October 2025) ○ Conducted mandatory training on documentation standards, federal compliance, and allowable costs under 2 CFR Part 200. ○ Training materials added to new employee orientation with annual refreshers scheduled. 7. Ongoing Monitoring — Ongoing ○ Monthly sample audits conducted by the Finance Director to verify compliance. ○ Quarterly reporting to the COO summarizing documentation metrics. ○ Annual compliance results presented to the Board Finance/Audit Committee.

Views of Responsible Officials and Planned Corrective Actions: Management agrees and recognizes the importance of consistent allocation methodologies. Corrective Action: Increase the Cost Allocation Plan defining allocation bases for shared expenses, supported by documentation and reviewed annually.

VIEWS OF RESPONSIBLE OFFICIALS Management agrees with the audit finding and has implemented a comprehensive corrective action plan to address payroll processing errors, strengthen internal controls, and ensure accurate and timely payments. As part of PRDE’s Fiscal Plan of 2020–2021, the Department launched the official integration project between the Time, Attendance, and Leave (TAL) system and the Payroll (RHUM) system. This integration ensures that payroll disbursements are made only after the employee’s attendance has been validated through the TAL system. Employees are required to record their attendance using biometric verification or have an authorized leave properly documented and approved by their supervisor before receiving payment. If attendance is not validated, the system automatically issues a notification and applies the necessary adjustment. This project, initiated in November 2020 with the collaboration of the Puerto Rico Fiscal Oversight and Management Board (FOMB), MS Consulting, the Department of the Treasury (Hacienda), the Financial Advisory Authority (AAFAF), and the Puerto Rico Innovation and Technology Service (PRITS), was fully integrated by February 2021. As a result, PRDE has significantly reduced overpayments, duplicate payments, and other payroll inconsistencies. To reinforce this effort, PRDE issued a new Time and Attendance Policy on December 7, 2021, later updated on April 11, 2022, which clearly defines employee responsibilities, authorized leaves, disciplinary procedures, and supervisor accountability. Under this policy, employees and supervisors are required to follow strict timekeeping procedures, and noncompliance triggers automatic system notifications and salary adjustments. The PRDE’s Time and Attendance staff continues to monitor and maintain compliance through: i. Ongoing training sessions for PRDE personnel; ii. System dashboards tracking attendance behaviors; iii. Issuance of notifications and payroll adjustments as required; and iv. Regular follow-up and evaluation activities. Additionally, PRDE’s Finance Office implemented a reconciliation process that integrates data from TAL, RHUM, and SIFDE, ensuring that payroll expenditures align with validated attendance records. The system now performs cross-checks before submission to the Treasury Department, preventing disbursements for unverified time. These combined measures—technological integration, policy enforcement, staff training, and reconciliation controls—have strengthened payroll accuracy, reduced the risk of overpayments, and improved financial accountability across the Department. IMPLEMENTATION DATE Done RESPONSIBLE PERSON Evelyn Rodríguez Cardé Finance Office Director Jullymar Octtaviani Vega Sub-Secretary of Administration

VIEWS OF RESPONSIBLE OFFICIALS The PRDE does not agree with the Recommendation to establish an allocation method for TPFA invoices because TPFA services are overhead costs paid from administrative funds and are not tied to any specific federal grant. In addition, the PRDE does not agree that contract terms should be revised before the contract expiration to require a reconciliation of total hours and rates because again, payments to the TPFA are overhead costs not directly tied to any specific program. Finally, 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 and (ii) the TPFA provides an explanation of major expenses incurred within each monthly invoice. Auditor Comment on Management Response for Finding No. 2024-004 As stated in CONDITION 2., “…on invoice 830311-2023-32 the amount of $1,978,791 (85% of total invoice amount) was charged to several programs of ALN 84.425, although the services described in the invoice were not related only to these programs; therefore, the cost objective is not chargeable in accordance with the relative benefit received.” Further, 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 María de los Angeles Lizardi Valdés Office of Federal Affairs Director

VIEWS OF RESPONSIBLE OFFICIALS The PRDE does not agree with the recommendation to revise the Restart Fiscal Process Guide to require private schools to submit a receiving report or equivalent documentation to substantiate equipment purchases prior to reimbursement. These transactions correspond to reimbursements, not direct purchases made by PRDE; therefore, verification is performed through proof of payment submitted by the schools. When auditors requested confirmation of receipt, PRDE obtained photographs of the equipment from the schools to provide additional verification that the items were in the school. In addition, the PRDE wants to clarify that where quotations were used instead of invoices, the private schools provided valid proof of payment that matched the quotations submitted. This evidence demonstrated that the purchases were completed and consistent with the approved documentation, meeting the requirements for allowable and verifiable costs under Federal regulations. The PRDE does not agree with the recommendation to change the accounting classification or to implement additional review procedures related to the use of account E6170, “Donations and Contributions to Private Entities.” The use of account E6170 is appropriate given the nature of the transaction, which reflects a reimbursement to a private school rather than a direct purchase by PRDE that would otherwise be recorded under account E5500. The PRDE acknowledges the deficiencies noted during the audit regarding the omission of reimbursed equipment purchases from the PRDE Property and Equipment Register. To address this, the PRDE has prepared a list of reimbursed equipment purchased by private schools under the Restart Program. This list will be provided to the personnel responsible for maintaining the register to ensure the inclusion of these items in the Property and Equipment Register, in compliance with the capitalization and accountability requirements established in the Restart Fiscal Process Guide. The corrective action is scheduled for implementation on or before the end of the current fiscal year. Auditor Comment on Management Response for Finding No. 2024-003 In relation to situation #2 comments, the PRDE didn’t have evidence of the receiving report, which is required for all other purchases of equipment for which the PRDE is the owner. Internal controls over property and equipment should be the same for all equipment for which the PRDE is the owner. In relation to situation #3, all equipment purchased and registered in this account was not included in the inventory of the PRDE, because the general ledger account used is not recognized for purchase of property and equipment, instead is a general ledger account for donations. Further, in accordance with the “Guia de Procesos Fiscales – Fondos Programa Restart”, it is established that all reimbursement of equipment should be recorded in accounts E5000 or E4414. This is because the system recognizes that an addition of equipment was made and must be capitalized. IMPLEMENTATION DATE In process. RESPONSIBLE PERSON María de los A. Lizardi Valdés Office of Federal Affairs Director Edgar Delgado Serrano Office of Federal Affairs Associate Director Hamir M. Mojica Mojica Program Coordinator

VIEWS OF RESPONSIBLE OFFICIALS The PRDE acknowledges the auditor’s finding. Management clarifies that all requested information was available and existed within the PRDE systems; however, it was not provided in a timely manner due to circumstances beyond the Department’s control, including competing deliverables required from the same operational areas. Regarding the disbursement vouchers referenced by the auditors, including the Excel Master and Adjustment Reports, the program area reviewed the documents and confirmed that they reconciled accurately. The timing differences were due to automatic and manual adjustments. All supporting information was available in PRDE’s databases, including SIFDE and MIPE, and has been included as part of this response for further reference. For the student billed for $34,000, all supporting documentation—such as the proposal, approval of payment, and related evidence—was and remains available in MIPE. As part of PRDE’s internal controls, all necessary documentation must be uploaded into the system before any transaction can proceed. It is also important to note that auditors were granted full access to both MIPE and SIFDE at the beginning of their audit procedures. In relation to Findings 4 and 5, documentation was available in MIPE. Management notes that certain contracts and proposals may have amendments, and it appears the auditors may have reviewed an incorrect version of the file. Similarly, for Finding 6, the area revalidated the information during the preparation of this response and confirmed that the documentation cited as missing was, in fact, available in the MIPE portal. Additionally, management evaluated the matter related to expense recognition. In accordance with federal regulations and to ensure compliance with IDEA requirements, PRDE is authorized to cover certain expenses of the Preschool Grant (84.173) using IDEA Part B (84.027) funds. As detailed in the prior Single Audit report: “IDEA Part B, Section 611 funds can be used for students ages 3 to 21. According to the description provided by OSEP, the Grants to States program assists states in meeting the excess costs of providing special education and related services to children with disabilities. States must serve all children with disabilities between the ages of 3 through 21, unless inconsistent with State law or court orders. Under 34 CFR § 300.202(a), the LEA must use IDEA Part B funds to pay the excess costs of providing special education and related services to children with disabilities.” Regarding the vouchers related to training services, PRDE does not concur with that portion of the finding, as the contract does not stipulate that the teachers must be an IDEA employee. This contract was previously evaluated as part of the auditors’ procedures. The PRDE accepts the auditors’ recommendations and will implement corrective actions to improve the timely submission of documentation and strengthen internal coordination among areas involved in responding to audit requests Auditor Comment on Management Response for Finding No. 2024-002 In response of the second paragraph, our Auditors held three (3) meetings with PRDE’s personnel and the amounts were not reconciled. For the third response, no justification exists in MIPE or SIFDE that the amount paid is reasonable and in accordance with the contract. In fact, if all costs disclosed in the contract were applied to that student, the amount is less than the $34,000 paid monthly. For the fourth response related to Conditions 4 and 5, our Auditors requested all information to be available. We held three (3) meetings, and the information did not reconcile and was not available for our evaluation. In addition, we understand and acknowledge that contracts have amendments; however, these amendments relate to increases in the total amount because an original contract is based on a certain quantity, and amendments are made as funds are received. The cost per student established in the contract or proposals remained unchanged in these amendments. The lack of verification between the supplier's cost as stated in the contract and the cost invoiced by the supplier is a significant problem because the supplier is billing for a cost that was not part of the original agreement or proposal. For the fifth through seven responses, the Uniform Guidance requires that financial management system record the expenditures in the program that benefited from the services; no in the program with more budget.. IMPLEMENTATION DATE None RESPONSIBLE PERSON Enid Díaz Executive Director Alayra Figueroa Associate Secretary of Special Education

Given the complexities of the compliance requirements of the State and Federal governments, this issue will remain a finding, but GWAAR Fiscal Staff will work towards ensuring that all opportunities to follow GAAP standards will be met and all costs will be properly posted.

Management disagrees with the following A) Management determined the expenditures charged to the 2021-#3 project MSOC Security Sustainment Costs, for camera, installation and project management were clearly related to the Investment justification which requested sustainment and upgrade to the existing MSOC the IJ states : “Investment provides maintenance and upgrades of software/hardware (I.e. servers/workstations), video surveillance management systems, operating systems, cameras systems, access control and communication systems for Plaquemines Port Harbor and Terminal District B) Management determined the questioned cost charged to the 2023-#3 project GIS for the cameras and the conference room were supported with the investment justification however management agrees the invoices for Survey totaling $95,900 should not have been changed to the grant. C) Management determined the expenditures charged to the 2023-#4 project Cybersecurity Network and IT: For Datto Backup, which is the name of the program, and cyber security training are valid expenses and align with the investment justification Management will ensure the following processes are added to the financial management policies and procedures over federal and state funds • The District will establish formal procedures requiring that all PSGP expenditures be cross-checked against the approved Investment Justification (IJ) and verified for compliance with the grant’s period of performance prior to payment. No disbursement of federal funds will occur unless documentation demonstrates that the expenditure directly aligns with the approved grant scope and timing. • This documentation will be required within the system in order to process payments to the vendor. • The District will consult with FEMA to assess the allowability of identified questioned costs. Management will follow FEMA’s guidance to resolve any discrepancies and ensure that all expenditures meet federal standards. • Mandatory training sessions are being scheduled for staff involved in grant administration and financial management. These sessions will cover Uniform Guidance requirements, documentation standards, and procedures for verifying expenditure eligibility under PSGP. These actions reflect the District’s commitment to regulatory compliance, fiscal responsibility, and continuous improvement in federal grant management practices.

Strengthen compliance efforts and mitigate risk, staff will consult a qualified third-party professional before executing any transaction that may be unallowable, ensuring adherence to funding. If unallowable expenses are identified, staff will quickly coordinate with the appropriate state agency to resolve issue.

Corrective Action Plan – Federal Funds Review and Processing Audit Finding Reference: Response to Finding 2024-002: Improvement Control Over Period of Performance for Federal Awards Name of Contact Person and Completion Date: Krystal De Gray, COO of Nashua School District 09-22-2025 Planned Corrective Action: The Nashua School District acknowledges the finding related to the control over the period of performance for federal awards (Finding 2024-002). In response, the district will develop and implement a formal internal procedure to ensure that all purchases funded by federal awards are both placed and received within the established period of performance. This procedure will include appropriate review, documentation, and oversight to maintain compliance with federal grant regulations. To further strengthen internal controls, the Nashua School District will implement a procedure limiting purchases to occur no later than 15 days prior to the grant’s end date. Additionally, all necessary services must be received and completed prior to the expiration of the grant period. Mario Andrade Krystal De Gray Superintendent Chief Operating Officer

2024-003 The City charged costs that were incurred prior to the beginning of the period of performance of the grant. Helen Tomic, Long Range Planning Manager December 31, 2025 The City will implement control procedure to prevent the charging of costs before the period of performance.

Corrective Action Plan Identifying Number: 2024-003 Finding: The Agency did not properly allocate indirect costs during the fiscal period in which the corresponding direct costs were incurred, resulting in an indirect cost rate exceeding the de minimis rate for a portion of the 2024 fiscal period. Corrective Actions Taken or Planned: The Agency concurs with the finding. To correct the cause and ensure compliance with Uniform Guidance requirements for indirect costs, the following actions will be implemented: 1. Establish Written Indirect Cost Procedures – Develop and document procedures to ensure indirect costs are consistently calculated at the approved de minimis rate per the federal grant award on total direct costs during the performance period. 2. Implement Pre-Posting Review – Require a supervisory review of indirect cost calculations before charges are recorded to the general ledger and before grant reimbursements are submitted. We have implemented new procedures to ensure that indirect costs are included in each invoice for reimbursement. 3. Staff Training – Provide training for grants and finance staff on indirect cost requirements, the proper application of the de minimis rate, and reconciliation processes in accordance with 2 CFR 200.414(f). 4. Quarterly Reconciliations – Implement quarterly reconciliations of indirect costs applied to grants to confirm rates are applied correctly and consistently throughout the fiscal year. 5. Continuity Controls – Assign responsibility for indirect cost oversight to both a primary and a backup staff member to ensure consistency during periods of management turnover. Contact Person Responsible for Corrective Action: Fred Timberlake, Vice President of Finance Isha Martin, Controller/Grant Finance Manager Anticipated Completion Date: • New procedures: June 15, 2025 • Written procedures in place: December 31, 2025 • Staff training completed: January 31, 2026 • Supervisory review and reconciliations implemented: Beginning with January 2026 close

Corrective Action Plan Identifying Number: 2024-001 Finding: Expenditure was identified for one invoice with a 2023 service period that was improperly recorded, and reimbursed, as an expenditure in 2024, indicating improper expense recognition in accordance with US GAAP. Corrective Actions Taken or Planned: The Agency concurs with the finding. To correct the cause and ensure compliance with 2 CFR 200.403(e), the following actions will be implemented: 1. Establish Written Cutoff Procedures – Formal written procedures will be developed for reviewing service dates and supporting documentation prior to posting expenditures in the general ledger. These procedures will specifically address Uniform Guidance period-of-performance requirements. 2. Implement Supervisory Review – All expenditures charged to federal awards will undergo supervisory review at period-end. The review will confirm that expenses are recorded in the proper performance period before submission for reimbursement. Effective June 2025, the Vice President of Finance and the Controller performed a retrospective review of 2024 expenses to confirm that they were allocated to the correct reporting period. This supervisory review has continued into the current reporting period with no exceptions noted. 3. Staff Training – Grants and finance staff will receive focused training on Uniform Guidance cost principles, proper expenditure cutoff, and documentation standards to ensure consistent application. Staff training will include review of the finding and leadership will highlight the importance of verifying the correct reporting period for each entry. 4. Continuity Controls – To address turnover risk, responsibility for cutoff procedures will be assigned to both a primary and a backup staff member to provide coverage and reduce errors caused by staff changes. 5. Ongoing Monitoring – The VP of Finance will review quarterly grant compliance checklists and provide updates to senior leadership and the Finance Committee. Contact Person Responsible for Corrective Action: Fred Timberlake, Vice President of Finance Isha Martin, Controller/Grant Finance Manager Anticipated Completion Date: • Management supervisory review procedures: June 15, 2025 • Written cutoff procedures in place: December 31, 2025 • Staff training completed: January 31, 2026

Audit Finding Reference: 2024-001 Description of Finding: The audit revealed that grant expenditures were incurred outside the authorized performance period, resulting in non-compliance with grant regulations and potential cost disallowance. Planned Corrective Action • Conduct a comprehensive assessment of existing procedures to identify gaps that led to noncompliance with grant regulations. • Ensure timely submission of grant applications. • Implement enhanced oversight and monitoring processes for all grant-related expenditures to ensure alignment with policy 2 CFR 200.1. • Maintain detailed documentation of all award dates and expenditures to provide a clear compliance record. • Ensure all documentation is easily accessible and systematically organized for audit purposes. • Ensure pre-award costs are allowable only to the extent they would have been allowable if incurred after the effective date and only with written approval from the Federal awarding agency (as per 2 CFR 200.458). • Establish a process for obtaining and documenting written approval for pre-award costs. • Provide comprehensive training on compliance with Uniform Grant Guidance to all relevant staff. • Review and update policies and procedures related to grant expenditures regularly to ensure they are current and compliant with federal regulations. • Assign accountability for monitoring and reporting compliance to specific roles within the organization. The Business Manager, Elizabeth Bouchard, will be responsible for implementing this plan beginning with the Fiscal Year 2026 grant cycle. As of September 2025, non-compliance issues have been identified and addressed, documentation has been maintained to track award dates, and training has been provided to designated roles within the District. In addition, procedures to maintain detailed documentation of all award dates and expenditures to ensure a clear compliance record have been shared with all District Administrators utilizing grant funds.