Corrective Action Plans

Program: AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – Adoption Assistance; AL 93.767 – Children’s Health Insurance Program; AL 93.778 – Grants to States for Medicaid – Allowable Cost/Cost Principles Corrective Action Plan: DHHS has begun strengthening processes and procedures to ensure entries are complete and accurate and in compliance with Federal regulations. Contact: Patrick Werner Anticipated Completion Date: June 30, 2026

The Organization has transitioned from QuickBooks to Sage Intacct accounting software, which now requires digital attachments for all transactions to ensure proper documentation. The Organization continues to review and improve processes and procedures as we grow as an organization. We will reinforce adherence to the Organization's policies.

2025-001-Activities Allowed or Unallowed and Allowable Costs/Cost Principles - Beneficiary Payments Federal Agencies: U.S. Department of State/ Bureau of Population and Refugees and Migration Program Titles and ALN Numbers: 1. ALN #19.510: U.S. Refugee Admissions Program Federal Grant Numbers: 1. SPRMCO23CA0361- FY24 MRA Capacity Development Funds 2. SPRMCO24CA0356- FY2023-25 Year 3 Reception and Placement Program - Affiliate MRA DA+Admin 3. SPRMCO24CA0357- FY2023-25 Year 3 Reception and Placement Program - Affiliate ERMA DA+Admin Contact Person: Rick Estridge, Controller, rick.estridge@rescue.org, (443)890-0915 Corrective Action: IRC’s management has taken several steps to stop fraudulent activities, prevent new fraud and improve IRC’s ability to detect future fraud. a. Upon identifying potentially unauthorized and fraudulent fund requests, all program office access to the USIO bank portal was immediately suspended. USIO debit card loads were centralized, and this process remains in place. b. Nine staff potentially involved in those activities were placed on leave during the investigation; five were eventually terminated. Following investigations, the IRC has made significant changes in leadership in structure in Northern California. By the end of June 2026, new Finance, Operations, and Program Delivery leadership will be in place, and the office will be broken down into two smaller offices, each with its own Executive Director. c. Working visits and in-person training on fraud prevention have been and will continue to be delivered to reinforce IRC’s compliance standards in all offices engaged in direct client payments. Additionally, network wide training are being provided focused on on compliance, CFR and fraud prevention for all staff. New policies on pre-paid cards and gift cards have also been issued. d. A Financial Analyst position was created under the RAI Head of Finance to focus on compliance. The analyst performs quarterly sample-based spot checks across all U.S. network offices, randomly selecting transactions for end-to-end review, including USIO payments. An automated tool also flags potential non-compliance issues such as irregular p-card payments and gift card purchases – vulnerabilities that could be exploited in NorCal-like situations. The RAI Head of Finance then compiles quarterly compliance reports for office leadership, highlighting areas for improvement. Anticipated Completion Date: June 30, 2026

FINDING 2025-001 Finding Subject: Twenty-First Century Community Learning Centers – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: April Boone and Levi Yowell Contact Phone Number and Email Address: 765-249-2515; april.boone@clinton.k12.in.us; levi.yowell@clinton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Per written directive from our Superintendent, Mr. Yowell on November 14, 2025, the following steps are being implemented to provide better oversight over the Twenty-First Century Program. 1. Multiple signatures are now required on all payroll, including the CCE Principal, Site Coordinator, CCSC Treasurer, and Superintendent 2. Immediately discontinuing the unallowable expenses as shared by the SBOA auditors 3. Required approval for all purchases from Site Coordinator, CCE Principal, CCSC Treasurer, and Superintendent. On December 15, 2025, the School Board will be reviewing and considering the approval of a District Financial Authority Oversight Resolution. This resolution will better define who has financial oversight and authority for all spending within the corporation. Anticipated Completion Date: November 14, 2025 and December 15, 2025 (Note: Provide the projected date of completion of major tasks for the planned corrective actions described above.)

FINDING 2025-003 Finding subject: COVID-19 Educational Stabilization Fund – Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131 millerje@maconaquah.k12.in.us Views of Responsible Officials: We concur with the finding According to our Classified Handbook, we only have a starting wage stated for employees. This handbook is in place for the 2025-2026 and 2026-2027 school years. We will take action to update the handbook for the 2026-2027 school year to include a starting and ending wage for the classified positions listed within the Classified Employee Handbook. This action will need to be voted on by the School Board. Anticipated Completion Date: August 2026

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Allowable Costs/Costs Principles Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131; millerje@maconaquah.k12.in.us Views of Responsible Officials: We concur with the findings Response Comments: According to our Classified Handbook, we only have a starting wage stated for employees. This handbook is in place for the 2025-2026 and 2026-2027 school years. We will take action to update the handbook for the 2026-2027 school year to include a starting and ending wage for the classified positions listed within the Classified Employee Handbook. This will need to voted on by the School Board before we can put into practice. Anticipated Completion Date: August 2026

FINDING 2025-004 Finding Subject: Special Education - Earmarking Contact Person Responsible for Corrective Action: Phyllis Ritenour Contact Phone Number and Email Address: 317-205-3332 x 77218 pritenour@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Business Services will work with the Special Education team and IDOE to ensure that waivers are filed in a timely manner for any proportionate share funding not spent by nonpublic schools. Anticipated Completion Date: June 30, 2026 INDIANA STATE

FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA)- Earmarking Summary of Finding: The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2023-2024, the Cooperative operated the special education programs and spent the federal money on behalf of all of its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 22611-021-PN01, 22611-021-ARP, 22619-021- ARP, 23611-021-PN01, and 23619-021-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 22611-021-PN01, 22611-021-ARP, 22619-021-ARP, 23611-021-PN01, and 23619-021-PN01 grant awards. Contact Person(s) Responsible for Corrective Action/Contact Phone Number and Email Address: Lissa Stranahan Michelle Cronk Phone: 765-771-6013 Phone: 765-746-1602 Email: lstranahan@lsc.k12.in.us Email: cronkm@wl.k12.in.us View of Responsible Officials: West Lafayette Community School Corporation concurs with the audit finding for Earmarking. The GLASS Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The methodology used by the Cooperative to monitor non-public proportionate share expenditures was based upon a percentage for each school corporation that comprises the Cooperative rather than basing the expenditures off of the grant award for each non-public school within the geographical boundaries of the school corporations. While all proportionate share funds were expended, it was problematic in determining if the minimum amount per the grant awards was expended and properly reported prior to July 1, 2024. Description of Corrective Action Plan: The former Director of GLASS retired June 30, 2023. Upon hire on July 1, 2023, the new director immediately implemented measures to correct the previous methodology used at GLASS. Non-public proportionate share funds are identified and reported based upon the grant award for each school corporation. The expenditures are based upon the geographical location of the non-public school and the corresponding public school corporation, not based upon the “home” school corporation of the student. This process was implemented and descriptions were included on the ledgers to identify non-public school proportionate share for grants that were initiated during the FY 2024-2025 school year. Anticipated Completion Date: The corrective action was already put into place on July 1, 2023 and implemented with FY 2024-2025. The audit finding reflects the previous grant cycle for 2022 grants and 2023 grants, which is prior to this action taken.

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

Recommendation: We recommend that the Department identify the reason for the exclusion of the credit in its query. Additionally, the Department should consider reviewing the query to the general ledger as part of the final review before submitting the reimbursement request. Explanation of disagreement with audit finding: The Department recognizes the audit finding and its responsibility to comply with 2 CFR §200.403(f). Action planned in response to finding: Corrective action will be taken. The Department revised the policies and procedures for cash disbursements within the Administrative Services Division. Effective immediately, upon running the monthly query of federal expenditures for the cash reimbursement for federal grants, the Federal Financial Analyst will submit the query to the Budget Director and the Accountant/Auditor. A reconciliation to the General Ledger will be completed by them prior to the Federal Financial Analyst requesting the cash reimbursement. Name(s) of the contact person(s) responsible for corrective action: Paul Varela, CFO Planned completion date for corrective action plan: July 31, 2026

Condition: The City applied the same expenses to pass-through and direct funded awards, which resulted in reported quarterly reports and SEFA expenditures including approximately $2.7 million of expenditures that were being double counted. Planned Corrective Action: The City will ensure that all future expenses under this program are in compliance and under ARPA guidelines. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2026

Responsible Person(s): Fernanda Crandol, Chief Financial Officer Corrective Action Planned: DARS’ Finance Division will develop agency-specific payroll policies and procedures governing all critical payroll processes, including payroll reconciliations and payroll certifications. Additionally, the Finance Division will ensure that payroll reconciliations are completed each pay period so that payroll transactions are accurate, complete, and properly reviewed. Estimated Completion Date: 5/31/2026

U.S. DEPARTMENT OF EDUCATION 2025-002 Special Education Cluster Grants – ALN’s 84.027 & 84.173 Recommendation: We recommend procedures be implemented to ensure that charges to the grant program are incurred within the period of performance included in the grant award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have reviewed the finding and have since implemented controls to ensure that expenditures are charged to a grant only after final approval has been issued in the grant portal. Name(s) of the contact person(s) responsible for corrective action: Aisha Oppong, Executive Director of Business and Support Services Planned completion date for corrective action plan: January 12, 2026.

FINDING 2025-001 Finding Subject: Summary of Finding: Earmarking for Non-Public proportionate share was improperly calculated based on budgeted percentage. Contact Person Responsible for Corrective Action: Quinnlyn Van Rys Contact Phone Number and Email Address: (219) 850-1914 - qvanrys@pces.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hours are calculated, a percentage based on total hours worked for each member school will be used to allocate the provider/employee time for each member school. This documentation will be attached to each reimbursement request. Anticipated Completion Date: This finding was corrected in January, 2024.

2025-003. Payroll and Disbursement (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster: Special Education Grants to States: IDEA Part B ALN: 84.027 Education Stabilization Funds COVID 19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U Condition: As required under Subpart E, 2 CFR §200.403 through §200.405 and §200.430, and Subpart D, 2 CFR §200.302, which require a financial management system to provide effective control over accountability for federal funds, and to identify the source and application of funds. During the year, we noted that the District recorded journal entries transferring payroll and disbursement related expenditures from the General Fund to the Special Aid Fund under the Special Education Cluster and Education Stabilization Funds grant codes. These journal entries lacked adequate supporting documentation to demonstrate approvals and if the costs were allowable and allocable to the applicable federal awards. Consequently, we were unable to obtain sufficient appropriate audit evidence to conclude whether the journalized transactions were properly charged to the federal programs in order to comply with Subpart E, 2 CFR §200.403 through §200.405 and §200.430, and Subpart D, 2 CFR §200.302. Planned Corrective Action: The District will implement procedures to ensure that all payroll and disbursement transactions charged to federal awards through journal entries are properly supported. This will include maintaining original time and effort documentation for payroll, as well as invoices and supporting records for disbursements. Additionally, the District will establish a review and approval process for journal entries transferring expenditures between funds to verify that amounts are allowable, reasonable, and allocable to the appropriate federal awards. Staff will be trained on federal documentation requirements under 2 CFR §200.430 and §200.302 to prevent recurrence and ensure that all financial records support compliance with federal guidelines. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Jean Mingot Assistant Superintendent for Business Southampton Union Free School District 70 Leland Lane Southampton, New York 11968-5089

The Department agrees with the recommendation. The Center for Accounting (CFA) and the Office of Transportation Safety (OTS) have coordinated to implement updated reviews and controls. This implementation involves reviewing current processes to ensure supporting documentation is vetted and grant compliance is verified prior to payment. It also includes assessing the need for increased monitoring to ensure initial program reviews are complete and accurate. This remediation effort was finalized on June 30, 2025, following the September 2024 transaction in question. Additionally, the Department plans to review the remediation plan with all relevant staff again this season. This will ensure that all supporting documentation is thoroughly vetted and that expenditures comply with the applicable award period of performance.

The Colorado Department of Transportation (CDOT) agrees with the recommendation. The Center for Accounting (CFA) and the Office of Transportation Safety (OTS) have coordinated on its implementation. The Department has assessed and updated training for staff responsible for reviewing and approving invoices for Highway Safety Cluster grants, with a specific focus on the period of performance. This training plan will be revisited and reviewed with all staff involved by April 2026.

The Department of Local Affairs (Department) agrees with the recommendation to strengthen internal controls over the financial management of federal Coronavirus Capital Projects Fund grant expenditures and the accuracy and completeness of the Exhibit K1, Schedule of Federal Assistance. The Department will develop a corrective action plan that includes enhanced procedures for the performance of year-end estimates/accruals. The Department will create and implement staff training for staff that are responsible for preparing and reviewing the estimates/accruals, the Exhibit K1, grant transactions and enhancements.

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Katie Elliott Contact Phone Number and Email Address: katieelliott@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: While the School Corporation completed the required Time and Effort logs, a time study was not completed and documented to justify the allocation of costs related to the compensation and fringe benefits of the food service director. The School Corporation Food Service Director is now documenting the hours spent each day completing food service activities. Anticipated Completion Date: This Corrective Action Plan will be put in effect January 2026.

FINDING 2025-005 Finding Subject: Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Audit Findings: Significant Deficiency, Other Matter Contact Person Responsible for Corrective Action: Chrystal Street Contact Phone Number and Email Address: cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district has implemented procedures requiring written documentation whenever federally funded materials, equipment, or property are reassigned, repurposed, or disposed of due to project changes. This documentation includes the reason for the change, approval by district administration, the new use or location of the materials, and verification that the use remains allowable under the grant. These records will be maintained with grant documentation and reviewed as part of internal control procedures to ensure compliance moving forward. Anticipated Completion Date: January 2026

Corrective Action Plan: While Elkhorn Slough Foundation performs SAM.gov suspension and debarment checks for all contracted vendors, documentation evidencing these checks was not consistently maintained. The Foundation will implement enhanced documentation and record‑retention procedures to ensure verification records are retained in compliance with the Foundation’s Procurement Policy and 2 CFR § 180.995. Contact Person: Mark Silberstein, Executive Director and Administrative Director with review by outside CPA. Contact: 831‐728‐5939 Anticipated Completion: June 30, 2026

2025-017 ALLOWABLE COSTS/COST PRINCIPLES DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.659 DOHS maintains a multi-layered review process for P-card payments. While documentation for the two specific transactions totaling $26 was unavailable at the time of the audit, these transactions were processed through the same automated financial system that enforces budgetary limits and eligibility checks for all validated cases. Due to current system configurations, P-card transactions must be processed even when documentation is missing. According to the internal controls, any transaction not properly reconciled is marked “Admin Not Reconciled”. This designation indicates the DOHS is aware of the missing documentation, which, according to policy, becomes the cardholder’s responsibility. The Office of Shared Administration (OSA) P-card Division provides reconciliation dates and notifies coordinators of any unreconciled transactions. If a cardholder loses a receipt, they are permitted to submit a lost receipt memo detailing the purchase, accompanied by a supervisor’s signature. The P-card Division has recently begun working closely with the DOHS’s internal purchasing card audit section within the OSA Office of Accountability and Management Reporting (OAMR) to mitigate reconciliation errors. OAMR reviews transactions for accuracy and completeness. Through this coordinated effort, missing documentation or errors are investigated and brought to management’s attention. DOHS will continue to issue monthly notifications to staff emphasizing that all P-card expenditures must be reconciled with proper documentation within one week of the cycle end date. Reconciliations must be electronically reviewed and approved by a supervisor to verify the allowability of costs. To mitigate noncompliance, the P-card Division will work with OAMR to monitor repeated occurrences. Persistent failure to provide documentation or obtain approval may result in the temporary suspension of purchasing privileges. These measures ensure that documentation is maintained, reviewed, and readily available for future audits.

2025-016 ALLOWABLE COSTS/COST PRINCIPLES DEPARTMENT OF HEALTH & HUMAN SERVICES (DOHHS) Assistance Listing Number: 93.658 DOHHS maintains a multi-layered review process for P-card payments. While documentation for the two specific transactions totaling $50 was unavailable at the time of the audit, these transactions were processed through the same automated financial system that enforces budgetary limits and eligibility checks for all validated cases. Due to current system configurations, P-card transactions must be processed even when documentation is missing. According to the internal controls, any transaction not properly reconciled is marked “Admin Not Reconciled”. This designation indicates the DOHHS is aware of the missing documentation, which, according to policy, becomes the cardholder’s responsibility. The Office of Shared Administration (OSA) P-card Division provides reconciliation dates and notifies coordinators of any unreconciled transactions. If a cardholder loses a receipt, they are permitted to submit a lost receipt memo detailing the purchase, accompanied by a supervisor’s signature. The P-card Division has recently begun working closely with the DOHHS’s internal purchasing card audit section within the OSA Office of Accountability and Management Reporting (OAMR) to mitigate reconciliation errors. OAMR reviews transactions for accuracy and completeness. Through this coordinated effort, missing documentation or errors are investigated and brought to management’s attention. DOHHS will continue to issue monthly notifications to staff emphasizing that all P-card expenditures must be reconciled with proper documentation within one week of the cycle end date. Reconciliations must be electronically reviewed and approved by a supervisor to verify the allowability of costs. To mitigate noncompliance, the P-card Division will work with OAMR to monitor repeated occurrences. Persistent failure to provide documentation or obtain approval may result in the temporary suspension of purchasing privileges. These measures ensure that documentation is maintained, reviewed, and readily available for future audits.

2025-015 ALLOWABLE COSTS/COST PRINCIPLES, ELIGIBILITY DEPARTMENT OF HEALTH & HUMAN SERVICES (DOHHS) Assistance Listing Number: 93.658 DOHHS’s corrective action plan from the prior audit indicated that a system change was made during FY 2025 to prevent future payments to psychiatric facilities from being charged to the Foster Care program. This change did go into effect on September 19, 2024. However, this provider was an anomaly. The facility was a Residential Treatment Facility which was Title IV-E eligible until they received Psychiatric Residential Treatment Facility (PRTF) status in August of 2024, however, they did not provide DOHHS documentation until February 2025. Immediate action was taken by a call ticket to the Technical Call Center to ensure that the PRTF was not continuing to show as IV-E eligible. The staff from the Division of Regulatory Management will continue, as part of their annual licensing review will ensure wvPATH provider records are updated to reflect timely licensing status as well as ensuring that child specific agreements do not lapse. The previously stated Corrective Action Plan remains in place and will continue.

The entity has implemented new procedures for the preparation and review of reimbursement requests.