Corrective Action Plans

The Alabama Law Enforcement Agency has corrected the program coding within the State's financial system to ensure that each grant is associated with the appropriate Assistance Listing (CFDA) number. To strengthen internal controls and reduce the risk of similar errors in the future, grant setup and coding information will be subject to review by multiple individuals prior to implementation. Additionally, annual reviews will be conducted to verify that grant information recorded in the financial system is consistent with the applicable Notice of Award and other grant documentation. These measures are intended to enhance the accuracy of federal program reporting and ensure expenditures are properly attributed to the correct funding source.

Management Response: Management acknowledges Finding 2025-005 and agrees that the deficiency in accounting for expenses covered under the resource sharing agreement constitutes a material weakness in internal control over financial reporting and compliance. Misclassification of individual expense categories by $70,223 affected the accuracy of category-level reporting and increased the risk of budget overages or noncompliance where federal awards and resource sharing agreements contain line-item spending limitations or require accurate reporting by cost category. Although the error did not necessarily affect total expenditures, incorrect classification can impair oversight, distort budget-to-actual monitoring, and reduce the reliability of information used for internal and external reporting. Management determined that the root causes included insufficiently detailed written guidance for coding transactions under the resource sharing agreement, inconsistent use of account mappings between the general ledger and agreement budget categories, and inadequate review of category-level coding before expenditures were finalized and reported. Existing procedures addressed expense processing generally, but they did not provide enough direction on how shared-service or agreement-covered costs should be classified into the proper expense categories for budget monitoring and reporting. To address this material weakness, management is implementing a corrective action plan focused on improving category-level classification and reporting for expenses covered under the resource sharing agreement. The plan includes four key actions: revising written accounting procedures to define category descriptions, coding rules, and decision standards; creating a standardized crosswalk between general ledger accounts and agreement budget categories; requiring supervisory review of category coding before final reporting; and implementing periodic budget-to-actual monitoring to identify unusual balances, potential overages, and coding trends that may indicate misclassification. Under the revised process, each expense charged under the resource sharing agreement will be recorded using the approved chart-of-accounts mapping and supported by documentation sufficient to identify the nature of the cost, the applicable budget category, and the reason the selected classification is appropriate. If a transaction involves a cost type that does not clearly align to an established category, accounting personnel will be required to elevate the transaction for review before posting or reporting. Any manual reclassification entries affecting agreement categories will require documented justification and supervisory approval. In addition, management will compare recorded expenditures to budgeted amounts by category on a recurring basis so that unusual fluctuations, coding anomalies, or category overages can be investigated and corrected before financial or grant reporting is finalized. Management will also provide targeted training to accounting, finance, and grants personnel responsible for recording or reviewing resource sharing agreement activity. Training will address the relationship between GAAP-based accounting records, agreement-specific budget categories, and federal compliance expectations for accurate, current, and complete financial reporting and comparison of expenditures to budget amounts. Management will supplement this training with periodic reviews of classification trends and exception items so that recurring coding issues can be identified and corrected through additional guidance, process changes, or retraining as needed. Management believes these corrective actions directly address the auditors’ recommendation to review current policies and procedures for compliance with GAAP and federal regulations. Responsibility for implementation will rest primarily with the Finance Director, in coordination with accounting and grants personnel involved in resource sharing agreement reporting. Management expects the enhanced coding guidance, account crosswalk, review controls, and category-level monitoring procedures to improve the accuracy of expense classification, strengthen budget oversight, and reduce the risk of misstatements or noncompliance related to resource sharing agreement expenditures in future periods. Corrective Action Plan Summary Corrective Action Responsible Staff/Role Target Completion Date Evidence of Completion Revise and adopt written accounting procedures for expenses covered under the resource sharing agreement, including category definitions, coding rules, and documentation standards for classification decisions. Finance Director; Accounting Manager June 30, 2026 Approved procedures; updated accounting manual; staff distribution records. Develop and implement a standardized crosswalk between general ledger accounts and resource sharing agreement budget categories, including guidance for common transaction types and reclassification scenarios. Accounting Manager; Finance Director July 15, 2026 Approved account crosswalk; coding reference guide; sample mapped transactions. Require documented supervisory review of category coding for resource sharing agreement transactions before final reporting, including review of manual reclasses and higher-risk expense categories. Finance Director Effective immediately Reviewer signoff on category reports; approved reclassification support; supervisory review documentation. Provide targeted training to accounting, finance, and grants personnel on category-level expense classification, use of the crosswalk, and reporting requirements under the resource sharing agreement Compliance Officer; Finance Director August 31, 2026 Training materials; attendance logs; completed acknowledgements or knowledge checks. and applicable federal regulations. Perform monthly budget-to-actual category reviews for resource sharing agreement expenditures to identify unusual balances, potential overages, and coding anomalies requiring investigation or correction. Accounting Manager; Finance Director Monthly, beginning July 31, 2026 Monthly budget-to-actual reports; exception logs; documented follow-up and corrections. Perform quarterly monitoring of a sample of resource sharing agreement transactions to verify correct category coding, consistency with the approved crosswalk, and compliance with agreement and federal reporting requirements. Compliance Officer; Finance Director Quarterly, beginning September 30, 2026 Quarterly monitoring reports; sample testing documentation; corrective action follow-up records

Finding: 2025-002 Reportable finding considered a material weakness-Expenses incurred outside of the period of performance Effect: The organization claimed and was reimbursed for unallowable costs under 2 CFR 200.458. Failure to maintain effective controls over cost allowability increases the risk of noncompliance questioned costs, and potential repayment of federal funds. Questioned costs: Known questioned costs of $403,805 were identified by reviewing each transaction prior to the date and for the month after the award began to ensure there are no likely questioned costs. Recommendation for the organization from the auditor: • Formalize and implement written policies and procedures governing identification, approval, and accounting for pre-award costs. • Require documented written approval from the federal awarding agency prior to charging any pre-award costs to federal awards. • Provide training to program and finance personnel on Uniform Guidance cost allowability requirements, including 2 CFR 200.458 and 2 CFR 200.403. • Implement supervisory review controls to ensure costs charged to federal awards are incurred within the approval period of performance or have documented prior approval. Corrective Action Plan for Pre-award costs Management acknowledges the audit finding that pre-award costs were charged to multiple federal awards for expenses incurred before the approved period of performance beginning October 1, 2024. The costs were incurred without the required written prior approval from the Maryland Department of Labor (MD DOL), the pass-through entity. As a result, unallowable costs were reimbursed and later removed from the Schedule of Expenditures of Federal Awards (SEFA). Management determined that the issue resulted from insufficient internal controls, the absence of formal written procedures for pre-award costs, and gaps in staff understanding of Uniform Guidance requirements. To address these root causes, the organization adopted a formal written policy governing the identification, approval, documentation, and accounting of pre-award costs. The policy requires written prior approval from MD DOL before any pre-award costs may be incurred or charged to a federal award and establishes documentation, retention, and accounting standards to support compliance with 2 CFR 200.458 and 2 CFR 200.403. Third, the organization also implemented a mandatory written approval workflow requiring program and grants staff to prepare and submit a formal request to MD DOL whenever pre-award costs are anticipated. No costs may be incurred until written approval is received. Approval documentation must be retained in both the official grant file and the accounting system. This workflow is now part of the grant start-up process for all federal awards. Fourth, the organization strengthened supervisory review controls to ensure that all costs charged to federal awards fall within the approved period of performance or have documented prior approval. These controls include a pre-posting cost allowability checklist, supervisory review and approval of all federal charges, and accounting system alerts that flag costs incurred outside the period of performance. Additionally, the Compliance Officer will conduct quarterly internal compliance reviews to verify adherence to federal requirements and internal policies. Finally, the organization implemented preventive measures to ensure long-term compliance. These include maintaining a centralized grant calendar with period-of-performance dates, requiring dual review of costs charged during the first 90 days of new awards, and conducting semi-annual internal audits of federal expenditures. Any discrepancies identified will be reported to senior leadership within five business days. Management is committed to ensuring full compliance with Uniform Guidance and MD DOL requirements. All corrective actions described above have been implemented or will be fully implemented by July 31, 2026. The organization believes these actions sufficiently address the audit findings and significantly strengthen internal controls over federal award management. Corrective Action Plan Summary Corrective Action Responsible Staff/Role Target Completion Date Evidence of Completion Develop and implement formal Pre-award Cost Policy Finance Director June 1, 2026 Final approved policy; distribution email; policy posted to shared drive Establish mandatory written prior approval workflow Finance Director June 30, 2026 Completed approval request template; sample approval documentation; updated grant file checklist Conduct Uniform Guidance training Compliance Officer July 31, 2026 Training materials; attendance logs; post-training assessments Implement supervisory review controls Finance Director June 30, 2026 Completed checklists; system screenshots; supervisor sign-offs Perform quarterly internal compliance reviews Compliance Officer Quarterly, ongoing Quarterly review reports; corrective action memos (if applicable) Maintain centralized grant calendar Director of Performance and Compliance June 30, 2026 Updated grant calendar; access logs or distribution email Conduct semi-annual internal audits Compliance Officer Semi-annual, ongoing Internal audit reports; follow-up documentation Dual review of early-period charges Finance Director; Grants Manager July 1, 2026 Dual-review sign-off forms; documented approvals

Audit Finding Reference: 2025-003 Improve Controls over Period of Performance Planned Corrective Action: The District has strengthened its grant management and closeout procedures to ensure that all expenditures charged to federal awards are incurred, processed, and paid within the applicable period of performance. Specifically, the District will: 1. Implement a formal grant closeout checklist that includes a review of all open purchase orders, encumbrances, unpaid invoices, and outstanding obligations prior to submission of final expenditure reports. 2. Require reconciliation of grant expenditures between the Grants Office, Special Education Department, and Business Office before final grant reports are submitted. 3. Establish periodic reviews of open encumbrances throughout the year to identify outstanding obligations and ensure timely processing of invoices. 4. Designate backup personnel and document grant management procedures to ensure continuity during staffing transitions or vacancies. 5. Require supervisory review and approval of all grant closeout documentation to verify that all allowable expenditures have been recorded and reported appropriately. 6. Provide training to personnel responsible for grant administration and financial reporting regarding federal period-of-performance requirements and grant closeout procedures. Planned Implementation Date of Corrective Action: The revised grant monitoring and closeout procedures have been implemented for all active federal grants and will be fully incoiporated into the District's grant management process beginning with the current fiscal year. Person Responsible for Corrective Action: Grants Manager Signature Derek Pinto, Assistant Superintendent of Finance

Findings (2025-001, 2025-002, 2025-003) Finding: Advance Funds- In accordance with 45 CFR 75.305(b)(1) [refer to “Prepaid Rent” above]. Of the 24 cash advances received, one advance was held for six working days, which is in excess of “immediate cash needs” as outlined in the Uniform Guidance and the policy historically observed by the Organization of 72 working hours. Auditor Recommendation: Advance Funds- We recommend that management design and implement formal, written internal control procedures to ensure compliance with cash management requirements. Specifically, management should implement a supervisory review to ensure federal funds are limited to minimum amounts needed for immediate cash requirements as indicated in the Uniform Guidance. Corrective Action: Advance Funds- Internal controls have been updated and there is an additional level for reviewing requests. The Executive Director is provided a list of all funds available after each draw down and the amounts drawn down are matched to the GL and GFR. This responsibility will be transferred to the Deputy Director once the new Fiscal Manager is in place. There is a schedule for the date the funds are allowed to be requested that fall within the 72-hour window posted in the Finance office and the Executive Director is notified before any requests are processed. The current Finance officer is meeting every 2 weeks for training with NDRN and policies, Uniform Guidance, MIP processes, and federal grants are reviewed in these meetings. Timeline: Advance Funds- TA with NDRN: Every 2 weeks starting April 22, 2026. Fiscal Manager: Posting for the position will be up by end of June 2026. 72-Hour Listing: Created and posted 6/1/26 Finding: Payroll Expenses- During our testing of allowable costs, 2 of the 20 time sheets selected did not contain approval signatures. Auditor Recommendation: Payroll Expenses- We recommend that management update its internal control policies to establish formal backup/interim approval authorities. When primary supervisors are out of the office on vacation or leave, a designated alternative official must be authorized to review and approve timesheets timely to ensure the continuity of internal controls. Corrective Action: Payroll Expenses- Payroll review: Payroll packets are reviewed during and after the payroll process to ensure all timesheets are approved and signed off by both the Executive Director and Board of Directors when appropriate. Executive Director’s timesheets and authorizations are presented to the Board of Directors when signing checks for review and approval. Procedures have been updated to include a secondary review of the timesheets at the end of each payroll cycle. Timeline: Payroll Expenses- Payroll review: After every payroll beginning 4/23/26 Finding: Prepaid Rent- As of September 30, 2025, a total of 14 months of rent payments were recognized in the general ledger and had been drawn from the PAIMI program. Total questioned costs related to these prepaid transactions, prepaid at year end, totaled $3,855.80. Auditor Recommendation: Prepaid Rent- We recommend that management design and implement formal, written internal control procedures to ensure compliance with cash management requirements. Specifically, management should implement a supervisory review of all general ledger disbursements against grant draws to ensure federal funds are limited to minimum amounts needed for immediate cash requirements. Corrective Action: Prepaid Rent- We received permission and were encouraged by our federal funders to pre-pay rent. We will not be pre-paying rent going forward. The Executive Director meets weekly with both PADD and PAIMI program managers to review processes. Timeline: Prepaid Rent- PADD and PAIMI program manager meetings: ongoing since before audit. Finding: Program Income- Our testing of allowable costs under the PADD grant identified two specific transactions where expenditures were fully reimbursed by federal funds despite being offset by program income and/or being erroneously drawn. Because these transactions relate to the same journal entry recognized in the general ledger, these are considered isolated instances. Auditor Recommendation: Program Income- We recommend that management design and implement formal, written internal control procedures to identify, track, and account for all program income generated by PADD grant activities within the general ledger. Corrective Action: Program Income- We received confirmation from the federal partners that we should spend the $16,165 legal fees from 2023, in April 2026. Those funds were not drawn down during PPE 4/30/26 and 5/15/26. Timeline: Program Income- $9104 was used to cover the PADD draw down for 4/30/26. No additional funds were drawn down. The remaining $7061 was used to cover part of the funds requested for 5/15/26. Additional funds were requested during the 5/15/26 draw down to cover remaining expenses. Nevada Disability and Law Center 2820 W Charleston Blvd, Suite 11 Las Vegas, NV 89102 EIN: 88-0327392 Jessica Crain, Deputy Director (Jessica@ndalc.org) (702) 257-8150 ext. 7122 phone (702) 257-8170 fax

2025-006 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirement (Significant Deficiency) Contact Name – Robert Mooney Position – Chief Financial Officer Phone Number – rmooney@corusinternational.org Estimated date of completion – September 30, 2026 Corrective Action Plan – Corus management concurs with this finding. In early 2025 Corus’ USAID funded project in Haiti was terminated and we were required to close down the project within two months. At that time, the security situation in Haiti was volatile and our Haiti employees were unable to regularly access the office and none of our US-based employees were permitted to travel to Haiti to assist with the project close out. As part of the close-out, Corus employed the services of a local courier company (none of the US-based courier companies were operating in Haiti at that time due to the security issues) to ship all physical supporting documentation to our offices in the US. Unfortunately, those documents were never received and despite several follow ups with the courier company, we were unable to locate the documents. The key learning was that we need to ensure that going forward all physical accounting related supporting documentation is digitized in a timely manner. This requirement was already a part of our document management policies and procedures. However, we were not regularly tracking compliance. It is important to note that the new Finance & Accounting solutions will enforce staff to digitally capture supporting documentation at the point of transaction entry, thereby transitioning us to a digital first organization.

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

Findings #2025-001 and #2025-005 – Material Weakness. Applicable federal programs: U. S. Department of Health and Human Services, 93.566, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Passed through Texas Office for Refugees: 10/01/24 – 09/30/25, FFY2025-27946V-ASA RSS, 10/01/24 – 09/30/25, FFY2025-27946V-AUSAA-RSS, 10/01/24 – 09/30/25, FFY2025-27946V-CMA, 10/01/24 – 09/30/25, FFY2025-27946V-RSS, Passed through United States Conference of Catholic Bishops: 10/01/24 – 09/30/25, 25RSI13A, Passed through U. S. Committee for Refugees: 10/01/24 – 09/30/25, RHP-2025-YMCA-Houston TX-03, 93.567, Refugee and Entrant Assistance Voluntary Agency Programs, Passed through U. S. Committee for Refugees and Immigrants: 10/01/24 – 09/30/25, 2502VARVMG, 10/01/23 – 09/30/24, 2402VARVMG, 93.676, Unaccompanied Alien Children Program, Passed through U. S. Committee for Refugees and Immigrants: 01/01/25 – 12/31/25, 90ZU0630-02. Condition and context: During the planning phase of the audit, management disclosed that amounts reported as employee withholdings on Form 941 had been intentionally manipulated by the former payroll director resulting over reporting withholdings to the Internal Revenue Service. Management did not have a formal reconciliation process in place to compare Form 941 to the payroll register and general ledger, nor was there a periodic reconciliation of the payroll register to the general ledger. The absence of these independent reconciliation controls allowed the misstatement to occur and not be detected in a timely manner. In our testing of 110 payroll transactions, we identified the following exceptions: Refugee and Entrant Assistance State/Replacement Designee Administered Programs (ALN 93.566) – 1 out of 40 payroll transactions tested utilized the incorrect pay rate. Unaccompanied Alien Children Program (ALN 93.676) – 1 out of 40 payroll transactions tested utilized the incorrect pay rate. Refugee and Entrant Assistance State/Replacement Designee Administered Programs (ALN 93.566) – 1 out of 40 payroll transactions tested was incorrectly charged to the program. Additionally, in testing the reconciliation of payroll expense recorded in the payroll register to the amount recorded in the general ledger system, an error of $349,000 was identified. The error was related to credit card charges erroneously being recorded to payroll expense. Recommendation: Policies and procedures should be designed and implemented to prepare a formal reconciliation of Form 941 to the payroll register and the general ledger and a reconciliation between the payroll register and the general ledger. Additionally, procedures should be strengthened over the review of pay rates utilized in the payroll system and the allocation of payroll to cost centers and government programs. Planned corrective action: Management acknowledges the deficiency identified in the execution and precision of payroll reconciliation processes. During the audit planning phase, management disclosed that a former payroll director intentionally manipulated employee withholding amounts reported on Form 941 in prior periods. While reconciliation procedures between the payroll register, general ledger, and Form 941 filings were in place, they were not performed with sufficient precision and consistency to detect the misstatement in a timely manner. Additionally, audit testing identified isolated instances of incorrect payrates and program allocations, as well as a misclassification of approximately $349,000 related to credit card return charges recorded to accrued payroll; management has confirmed this item represents a classification error and not an issue impacting payroll processing or employee compensation. In response, management has refined reconciliation procedures to require more detailed comparison across systems, established clearer expectations for investigation and resolution of variances, and enhanced documentation standards to evidence the level of review performed. Management has also strengthened oversight of payroll activity, including review of payrates and allocation of payroll costs to programs, and will continue to monitor these controls to ensure they are operating with an appropriate level of precision and consistency. In May 2026, an interim leadership structure was established in response to the departure of the Chief Financial Officer. During this interim period management is assessing departmental functions and organizational structure to better align responsibilities and further strengthen internal controls in the areas noted above. Responsible officer: Lauren Rome, VP of Financial Operations/Interim CFO. Estimated completion date: June 15, 2026.

Views of Responsible Officials and Planned Corrective Action Management agreed with the findings and indicated that corrective actions were implemented in January 2026 to ensure employee time is properly tracked and allocated by program, including updated timesheet procedures and enhanced supervisory review.

Views of Responsible Officials and Planned Corrective Action Management agreed with the findings and indicated that corrective actions were implemented in January 2026 to ensure employee time is properly tracked and allocated by program, including updated timesheet procedures and enhanced supervisory review.

Finding 2025-001 Fiscal year in which the finding occurred: 2025 Pass-Through Entity, if pass-through or Federal Grantor Agency, if direct: U.S. Department of Labor Contact person responsible for the corrective action: Michael Brey Description of Audit Finding: An effective internal control system was not designed or implemented at the Organization related to payroll and incentives/subscriptions to ensure compliance with requirements related to the grant agreements and Allowable Costs/Cost Principles compliance requirements. Corrective Action to be Taken: Beginning in April 2026, the organization has changed the process to record payroll to be charged to the grant. A spreadsheet has been created to track each payroll register and the amounts paid to each employee assigned to the grant. This data will be tracked throughout the year and checked against the payroll amount allowed per the grant budget. If any adjustments are required, that will happen in June and December. The payroll spreadsheet will be reviewed by a second employee to validate the spreadsheet is correct. Beginning in February 2026 the organization has corrected the subscription pricing to $1,500 per eligible shop. Additionally, the organization identified that certain shop incentives were being overcharged to the grant due to sales tax being added to the tool kit. The organization has adjusted the composition on the tool kit to reduce the amount including sales tax to be under the $8,500 allowable limit. Any excess incentive awarded in 2026 will not be submitted to the DOL for reimbursement from the grant. The tracking file for shop incentive awards is reviewed by the Controller. Correcting adjustments will be made to the grantor financial reports in 2026 to correct the overcharged payroll costs and incentives/subscription costs identified in 2025 and to properly reflect the cumulative grant expenditures in accordance with Allowable Costs/Cost Principles compliance requirements. Grantor financial reports will be reviewed by a second employee. Anticipated completion date: New process in place effective 4/1/26.

Agency personnel will ensure costs that are charged to federal awards were incurred during the applicable period of performance and recorded in the correct period.

Finding 2025-003-Allowable Costs/Cost Principles and Activities Allowed and Unallowed - Significant Deficiency in Internal Controls over Compliance and Non-Compliance Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Year(s): 2025 Federal Agency: Department of Treasury Pass-Through Agencies: State of Oregon and Multnomah County Responsible Party: Jeanne Stromberg, Major- Divisional Finance Secretary- Cascade Division 916-501-6374 RESPONSE: Management will implement a review and approval of the billing submissions to prevent duplicate submission of expenses and perform a review of billing submissions by the senior accountant monthly to prevent duplicate submission of costs. Effective Date: November 2026

The City has taken steps to strengthen internal controls over the CDBG program. The City will additionally implement formalized procedures requiring, centralized project files containing procurement documentation, cost support, and project eligibility records, document procurement procedures consistent with Uniform Guidance requirements, including cost/price analysis and justification for contractor selection, collection and review of Davis-Bacon documentation, including wage determinations and certified payrolls, when applicable, verification that required permits are obtained prior to construction and retention of inspection and completion documentation, and secondary review by City staff to ensure all required documentation is complete prior to project closeout. Additionally, the City will provide training to staff involved in CDBG program administration. Responsible Persons: Community Development Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27

As required by the OMB Uniform Guidance, we have provided our response and corrective action plan addressing the finding in the Schedule of Findings and Questioned Costs for the year ended August 31, 2025. Finding 2025-001: Allowable Costs – Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Management’s Views – Management agrees with the finding. LAJH acknowledges that payroll reimbursement calculations submitted under the federal program were prepared using subsequent employee pay rates rather than the contemporaneous pay rates applicable during the grant performance period and that certain duplicative expenditures were included in error. Management recognizes that these errors resulted in overstated costs totaling $79,825. Corrective Action Plan – LAJH will implement enhanced internal control procedures over the preparation and review of payroll costs charged to federal awards. Specifically, management will require all payroll reimbursement calculations to be supported by contemporaneous payroll registers and employee pay rate documentation applicable to the period during which services were performed. Person Responsible for Corrective Action: Robin Ray, Corporate Controller Anticipated Completion Date: May 31, 2026

Contact Persons Responsible: Primary – Anthonia Ibe, CFO In Absence (Alternative): – Jesus Infante, CAO Management acknowledges this finding and has developed a corrective action plan to strengthen the underlying control, assign clear ownership, and ensure timely implementation. The Agency is developing a time-tracking and documentation system to capture the actual time spent by allocable staff on federal programs, ensuring that charges to federal awards reflect the actual work performed in compliance with 2 CFR Part 200.403. Concurrently, HR is implementing a standardized pay rate approval and documentation process to ensure all approved salaries are formally recorded and retained by the human resources department. As an interim measure, manual time attestation will be in place by August 31, 2026, while the longer-term system is finalized. The CFO and CAO will work jointly to implement and monitor corrective actions in cross-functional areas, including timekeeping, payroll documentation, record retention, lease tracking, IT access controls, vendor onboarding, procurement documentation, and personnel training. This shared structure is intended to ensure that policy revisions are supported by clear workflows, staff training, documentation standards, and periodic compliance review. By October 31, 2026, the Agency will complete communication and training related to payroll approval controls.

The BGCNEO accounting staff will closely review expenditures to ensure costs were incurred within the applicable grant period, regardless of when the expenditure was paid.

Recommendation: The Department of Social Services should strengthen internal controls to ensure that only eligible recipients receive Money Follows the Person Rebalancing Demonstration services in accordance with federal laws, award terms and conditions, and the Money Follows the Person Operational Protocol. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees in part with this finding. Condition #1: DSS agrees that participation end dates were not updated timely due to cross-system manual entry limitations. Reconciliation procedures and supervisory oversight will be strengthened. Condition #2: DSS agrees that participation suspensions were not consistently reflected across systems due to timing delays. Monitoring and real-time reconciliation controls will be enhanced. Condition #3: DSS agrees approved costs exceeded institutional thresholds in limited cases. Variances were clinically justified, reviewed, and authorized. DSS will strengthen documentation and internal protocols to ensure clearer policy alignment. Condition #4: DSS agrees that the documentation was incomplete in one instance. Internal review standards will be reinforced to ensure comparative cost analyses are consistently documented. Please note, the Department will not be returning the questioned costs associated with this finding. According to federal regulations, recoveries based on eligibility errors can only be pursued when identified by programs operating under Centers for Medicare and Medicaid Services’ (CMS) Payment Error Rate Measurement program, per section 1903(u) of the Social Security Act and regulations at Title 42 CFR Part 431, Subpart Q. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Christine Weston, Program Division Director (860) 424-5012

Recommendation: The Department of Developmental Services should strengthen internal controls to ensure it obtains the required signatures for the individual plan for all Money Follows the Person Rebalancing Demonstration recipients. The Department of Social Services should conduct an audit of the medical provider in accordance with Section 17b-99 of the Connecticut General Statutes to ensure integrity of the Money Follows the Person Rebalancing Demonstration program. Corrective Action Plan as Reported by the Department of Developmental Services: DDS agrees with the finding. The errors were attributed to current manual processes and case management oversight regarding documenting signatures when individual plan (IP) meetings are held remotely rather than in-person. Most of the deficiencies (5 of 6) were isolated to one case manager. The MFP division is small with 3-4 case managers, causing a higher error rate when extrapolated against the sample size. The missing support service records have been forwarded to the Department of Administrative Services for research. There are plans to improve the individual plan process to enhance internal controls through automation. In the interim, case managers and case manager supervisors will be reminded of the IP signature requirements. Department of Developmental Services Anticipated Completion Date: June 30, 2026 Department of Developmental Services Contact Person: Krista Ostaszeski, Health Management Administrator (860) 418-6066 Wayne Siedel, Director of Service Development and Support (860) 418-6041 Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with this finding and the response provided by the Department of Developmental Services. Additional research is needed to determine whether the missing documentation was the provider's responsibility or was due to a billing issue. The Department of Developmental Services is coordinating with the Department of Administrative Services to research this further. Department of Social Services Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Christine Weston, Program Division Director (860) 424-5012

Recommendation: The Department of Social Services should conduct an audit of the medical provider in accordance with Section 17b-99 of the Connecticut General Statutes to ensure integrity of the Money Follows the Person Rebalancing Demonstration program. The Department of Social Services should recoup any improper payments issued to medical providers and refund the corresponding federal reimbursements to the Centers for Medicare and Medicaid Services. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with the finding. The improper payment has been recouped and the DSS Audit Division will open an audit of the provider. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Cathie Bussolotta, Director of Internal Audit (860) 424-5548

Recommendation: The Department of Transportation should strengthen internal controls over consultant payments for extra work. Corrective Action Plan as Reported by the Department of Transportation: The CTDOT Transit Design Unit has immediately put in-place a corrective action plan, which will be completed by January 30, 2026. As part of this action plan, when signing off on invoices in the future, the Project Manager will ensure the date of the invoice refers to the correct payment mechanism or extra work letter in accordance with our established policies. This will strengthen internal controls and reviews over payments for all fee letters to ensure it follows established policies and only pay for properly authorized extra work. In addition to internal actions, the consultant project team will be counseled for submitting an invoice that does not follow CTDOT policies. Anticipated Completion Date: January 30, 2026 Department of Transportation Contact Person: Jonathan Kang, Transportation Supervising Engineer Jonathan.Kang@ct.gov, (860) 594-2754

Finding 2025-003 Duplicate expenditures charged to same grant Recommendation: We recommend the District establish and maintain proper review procedures for expenditures charged to grants prior to submission for reimbursement. Management’s View: The District will strengthen internal controls over payroll expenditures charged to federal grants by implementing a standard operating procedure that will be conducted by the Payroll Specialist of verifying payroll distribution reports, funding codes, and supporting documentation prior to submission for payment. Before each payroll is finalized, the payroll specialist will run a payroll report that will be generated and sorted by employee to verify that no duplicate charges have been applied to the same grant within the same payroll period. This review will ensure that all costs charged to federal grants during the pay period are accurate, allowable, properly coded, and not duplicated. No payroll adjustments will be keyed until timesheets have been verified against previously submitted timesheets and that they are reviewed to confirm that prior entries have not already been charged to the same grant. Additionally, a secondary review by the accountant will be conducted prior to finalizing grant-related payrolls. Effective March 1, 2026, the Payroll Accountant and Chief Financial Officer will review grant-related payroll transactions to ensure accuracy, proper funding allocation, and compliance with applicable federal requirements. Effective Date: March 1, 2026 Contact Person: Sylvia Garza, Chief Financial Officer, Edcouch-Elsa Independent School District

Community Development Block Grants Cluster Entitlements/Special Purpose – Assistance Listing No. 14.218 Recommendation: It is recommended the County modify its procedure to include: • Improve reconciliation procedures to verify hours per pay period recorded in quarterly spreadsheet agrees to hours recorded in the KRONOS system. • Record grant wages using the pay rate at the beginning of the quarter if recorded on a quarterly basis or use pay rates for each pay period if recorded on a pay period basis. Explanation of disagreement with audit finding: Management concurs with the auditor’s recommendations. Action taken in response to finding: • Document the audit process in a formalized SOP and cross train all reviewers from SRGA Admin, Budget, and Fiscal. • Create a checklist to accompany each personnel draw to ensure that after rates are verified that SRGA Admin certify that no RPAs or pay adjustments were approved during the pay periods reported and if there were, a second pay rate is entered for that draw and hours are split according to accurate rates/dates. • Document the cure process in the SOP to ensure that any errors found after the fact will be corrected with HUD to remain compliant and to ensure that no funds drawn in error are retained. • Include a date verification process prior to submission of the draw to ensure that staff did not duplicate any dates. This verification will be an audit of the Time Tracking Review completed by Admin staff. Ongoing training and coaching will be administered should duplicate entries be found on final draw reports. • Audit of all personnel draws for both allocations of CDBG-DR grants will be completed using the new SOP and verification tools before the end of FY2026. Name of the contact person responsible for corrective action: Nicole Turner, Director Planned completion date for corrective action plan: The above action plan will be implemented immediately; an audit of all personnel draws will be conducted using new process and checklists by the end of FY2026.

Criteria: The Uniform Guidance requires the City to establish and maintain effective internal control over compliance for federal awards, including controls to reasonably ensure that costs charged to federal programs are allowable, properly supported, and comply with applicable federal requirements and the terms and conditions of the award. Under 2 CFR 200.403, costs charged to a federal award must be allowable, including that they be adequately documented and not be included as a cost or used to meet cost-sharing requirements of any other federally financed program in the current or a prior period. Condition: The City did not have adequately designed and implemented review controls over certain material project costs included in reimbursement requests submitted to the pass through agency. Our testing identified that the city submitted the same eligible project cost for reimbursement under two different federal grant awards, of which one was denied for reimbursement Cause: The City lacked sufficiently designed or effectively operating controls over the preparation, review, and approval of reimbursement requests for federal awards. In particular, the City's controls did not include an effective reconciliation of expenditure detail by invoice, pay application, or other unique transaction identifier across open grant awards before submission of reimbursement requests. Effect: The absence of effective review controls over material project costs increases the risk that ineligible, unsupported, or incorrectly costs could be included in reimbursement requests without timely detection and correction. The duplicate submission was not reimbursed from both federal awards and therefore does not require repayment or adjustment of reimbursement requests. This deficiency is considered a material weakness in internal control over compliance for the Department of Transportation program. Recommendation: We recommend that the City design and implement formal, documented review procedures over material project costs included in reimbursement requests. These procedures should include defined review responsibilities, documentation of the review performed, review of other federal funding reimbursement request, and supervisory oversight to ensure that all high-dollar or complex transactions are reviewed for eligibility, accuracy, and adequate supporting documentation before submission.Management Response: Management acknowledges the finding and will continue to review and controls to ensure all costs included in reimbursement requests are allowable.

2025-002. Allowable Costs/Cost Principles – (Excess Reimbursement Due to Inaccurate Final Expenditure Reporting) United States of Department of Education, Passed Through New York State, Department of Education: COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D Pass-through Entity Number: 5891-21-1490 COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief ALN: 84.425U Pass-through Entity Number: 5880-21-1490 COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief ALN: 84.425U Pass-through Entity Number: 5884-21-1490 Condition: The District submitted Form FS-10F final expenditure reports that included amounts for open encumbrances that were not fully expended after the final reports’ submission; the cumulative expenditures in the District’s accounting records for two of the Education Stabilization Fund (ESF) grants (CRRSA ESSER II, pass-through entity number 5891-21-1490, and ARP ESSER III, pass-through entity number 5880-21-1490) were less than the amounts claimed by the District on the FS-10Fs. The FS-10F for a third ESF grant (ARP SLR Learning Loss, pass-through entity number 5884-21-1490) included a duplicated amount for purchased services that was the result of a duplicated journal entry in the District’s accounting records. As a result, the expenditures reported on the FS-10F final expenditure reports exceeded the actual expenditures incurred and recorded by the District, and the District received reimbursements from the pass-through entity, New York State Education Department (NYSED) for expenditures it did not incur. Recommendation: The District should strengthen its internal controls over grant reporting and reimbursement processes to ensure that expenditures reported on the FS-10F final expenditure reports are accurate, allowable, and fully supported by the accounting records. Journal entries affecting federal grants expenditures The District should perform a comprehensive reconciliation of the FS-10F to the general ledger prior to submission, and again after the grant period ends to confirm all reported amounts were ultimately expended, and establish a formal process to review and clear outstanding encumbrances included in grant reports, ensuring any amounts not realized as expenditures are removed or adjusted. Additionally, the District should develop procedures to identify and track subsequent adjustments, including reclassifications of unallowable costs, and ensure that such changes are timely communicated and corrected with the New York State Education Department, and to require documented supervisory review and approval of all final expenditure reports and their subsequent reconciliations with supporting documentation and final accounting records. Planned Corrective Action: The District will strengthen internal controls over grant reporting to ensure that all expenditures reported on Form FS-10F are accurate, fully expended, and supported by the general ledger. Prior to submission, the District will perform a detailed reconciliation between the FS-10F and accounting records, verifying that only actual expenditures—not open encumbrances—are reported. A post-period reconciliation will also be conducted to confirm that all reported amounts were ultimately realized as expenditures. The District will establish a process to identify and track subsequent adjustments, including reclassifications or corrections, and will promptly communicate any necessary amendments to the New York State Education Department (NYSED). Starting from the next grant final cost submission, effective May 1, 2026, a structured review and approval process will be enforced: the Administrative Assistant responsible for grants will serve as the first-level reviewer during FS-10F preparation, and the Financial Officer will serve as the second-level reviewer prior to final submission. All final reports will require documented supervisory approval and supporting documentation, including actual invoices and purchase order amounts, to ensure accuracy and compliance. Responsible Contact Person: Mr. Idowu K. Ogundipe, CPA Assistant Superintendent for Business Freeport Union Free School District 235 North Ocean Avenue Freeport, New York 11520 Tel: (516) 867-5212 Email: iogundipe@freeportschools.org Anticipated Completion Date: May 1, 2026