Corrective Action Plans

Finding 2025-001: Significant Deficiency in Internal Control over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Corrective Actions Taken and Planned: Washington Alliance for Better Schools is reimbursing the passthrough agency for the identified questioned costs, at their direction, and has adjusted the financial statements and schedule of expenditures of federal awards as of and for the year ended August 31, 2025, accordingly. In addition, to prevent future errors, as part of the grant invoicing process, management will implement a formal reconciliation of amounts billed to federal programs to supporting documents for reimbursable costs incurred. Anticipated Completion Date: August 31, 2026 Contact Person: Emily Yim President and CEO 206-393-4918 emilyy@wabsalliance.org

Creek County will work with all offices making sure that a proper invoice is attached on all purchase orders. Educating Offices that there is a difference in a quote verses an invoice. The County Clerk will make sure that there are multiple eyes on the purchase orders to ensure that this is caught before payment is issued.

The Town will implement written procedures requiring the development and maintenance of project‑specific budgets for all federal awards, including FEMA emergency response and recovery projects. Project budgets will be prepared in accordance with approved scopes of work and used to monitor expenditures throughout the life of the award. The Town will provide training to applicable staff on federal grant budgeting requirements and designate responsibility for budget preparation and monitoring.

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Aging Cluster – Special Programs for the Aging, Title III, Part B – Assistance Listing No. 93.044 Recommendation: We recommend that the Organization consider updating its cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities, and that are reflective on employees’ time and effort records. We also recommend that the Organization maintain contemporaneous documentation supporting all cost allocations. Lastly, the Organization could consider removing LSC from the general fund into its own fund, and using fringe benefit rate and indirect cost rate allocation methods to simplify its cost allocation process. Explanation of Disagreement With Audit Finding: Management partially agrees with this finding. First, 45 CFR Part 1635 codifies the timekeeping requirement. CLS keeps track of every case and time dedicated by staff in strict compliance with this requirement. Manual adjustments primarily result from planned internal reconciliations and reviews designed to ensure the accuracy of CLS allocations. These reconciliations are conducted on a monthly basis and form an integral part of the Organization’s internal control framework. Action Taken in Response to Finding: Additionally, with respect to the Native American grant transactions, CLS implemented the necessary correction to the referenced percentage effective beginning in 2026. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2027

In response to the Auditor’s recommendations and as corrective action, the staff responsible or department will locate and document all required reports that were filed in accordance with the grant agreement requirements, including reconciliations with the Municipality’s official accounting subsidiary ledgers. Furthermore, the Municipality will design, document, establish, and provide the necessary training, along with written guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds. In addition, the Municipality will implement periodic reviews and monitoring mechanisms to ensure ongoing compliance with reporting requirements and the accuracy of financial information related to federal funds.

We agree with the finding and we will be reviewing and implementing the recommendations accordingly. We are committed to ensuring no duplication of costs across reporting periods and compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan will be implemented by June 30, 2026.

We agree with the finding and will review and implement the recommendations accordingly. We are committed to ensuring proper application of indirect costs, avoiding duplication of costs across reporting periods, and maintaining compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan will be implemented by June 30, 2026.

2025-00I Condition: The center did not maintain adequate documentation to support compliance with Federal requirements related to allowable costs, period of performance, and procurement standards. Auditor's Recommendation: We recommend The Center review and revise its documentation policies and procedures to ensure that compliance is met with regards to federal awards. Management response: Management agrees with the finding and has collaborated with grant personnel to implement standardized personnel activity reporting and cost allocation documentation for all federal grants. The Center will strengthen controls to ensure that only allowable costs incurred within the approved grant period are charged to federal awards. In addition, procurement procedures have been revised to ensure compliance with 2 CFR §§ 200.317-200.327. Corrective actions have been implemented or are in progress and apply to all federal awards moving forward beginning in FY2026.

Signing of invoices have been added to our procedures when submitting invoices for payment. The required staff were notified of this addition to the procedures.

Federal Program: U.S. Department of Homeland Security - FEMA Assistance Listing Number: 97.036 - Disaster Grants - Public Assistance Passthrough Entity - Arkansas Department of Emergency Management Program Year: 2025 Management concurs with the finding. Corrective Action Planned: 1. Process Improvement: Management has updated its internal grant reimbursement request process. All future reimbursement requests now require a "Duplicate Payment Verification" step, where the preparer must reconcile the current request against the cumulative total of previous requests to ensure no individual transaction is billed twice. 2. Enhanced Oversight: A secondary review by Julie Haney will now explicitly include a cross-reference of payroll periods to the general ledger to confirm the uniqueness of each request. Anticipated Completion Date: The repayment will be initiated by 05/01/2026, and the updated reconciliation procedures have been implemented as of 03/31/2026. Responsible Official: Julie Haney CFO

Finding: 2025-030 - A review of 17 FY 25 Disaster Grants payments found that 15 payments - (88 percent) lacked adequate supporting documentation. Questioned Costs: Indeterminate Assistance Listing Number: 97.036 Assistance Listing Title: Disaster Grants COVID- 19 Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): DMVA concurs with the finding Corrective Action (corrective action planned to ensure compliance with federal regulations and effective management of federal awards, the Finance Office, in conjunction with the Homeland Security Director, will develop and implement written procedures that provide a clear framework for managing federal awards and ensure compliance with federal regulations. DMVA will: • Clearly outline federal requirements under 2 CFR 200.327, 2 CFR 200.403(g), and Homeland Security Acquisition Regulation Class Deviation 15-01. • Specify the documentation required to support reimbursement requests, including expectations related to discrepancies and follow-up actions. • Outline the procedures for Homeland Security for reviewing and certifying work completed by contractors, where applicable, prior to reimbursement to subrecipients. Completion Date (list anticipated completion date): October 31, 2026 Agency Contact (name of person responsible for corrective action): Bryan Fisher

Finding No. 2025-071 - Deficiencies were identified in the Office of Children’s Services FY25 foster care base rate setting methodology. Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): DFCS disagrees with this finding. DFCS evaluated two foster care base rate proposals using the established Hornsby Zeller Methodology. The first option applied the traditional methodology and the second followed the same structure but incorporated Urban West regional expenditure data, which includes Alaska and eleven other western states as well as Hawaii. This change was implemented because Urban West data more accurately reflects Alaska’s high cost of living environment, whereas reliance on national averages has historically produced rates below Alaska’s true cost of care. Both options were reviewed with departmental legal counsel, who were involved in the original settlement, division leadership and the Commissioner’s Office. DFCS advanced the second option, resulting in an approximate 3000 increase to foster care base rate stipends effective July 1,2025. DFCS disagrees with the conclusion that the cost-of-living (inflation) factor should be adjusted to include inflation from 2016 forward. When the 2018 Foster Care Base Rates were established, inflation up to that point was already incorporated into the rate calculation. The current rate-setting process correctly used the 2018 rates as the baseline, which already accounted for prior inflation. Adding inflation from 2016 again would result in double-counting. DFCS disagrees with the conclusion that the rate-setting process did not follow the Hornsby Zeller methodology. The methodology was followed in full. As part of the rate analysis, DFCS applied the national average cost-of-living factor as outlined; however, the resulting amount did not adequately meet the needs of the children under the care and responsibility of the Department. DFCS is fiduciarily required to ensure that rates are sufficient to meet the actual needs of children in out-of-home care, and the national average input did not satisfy that obligation. To ensure the methodology produced accurate and appropriate results, DFCS utilized the Urban West index, an allowable and geographically relevant data source under the methodology. This adjustment did not change the methodology itself it refined the underlying input to better reflect Alaska’s actual cost of living and support the intended purpose of the rate-setting process. Corrective Action (corrective action planned): DFCS will continue to consult with legal counsel regarding any future methodology changes and will follow all guidance provided. Completion Date (list anticipated completion date): DFCS considers this matter resolved. Agency Contact (name of person responsible for corrective action): Nancy Miller, Finance Officer

Title II, Part A-Supporting Effective Instruction Stat Grants – Assistance Listing No. 84.367 Special Education Cluster (IDEA programs) – Assistance Listing No. 84.027, 84.173 Title I-A-Grants to Local Educational Agencies – Assistance Listing No. 84.010 Recommendation: The District should design and implement controls to ensure semi-annual time and effort certification are obtained and reviewed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To address the material weakness related to untimely and incomplete approval of Time and Effort certifications, MPS implemented process improvements to strengthen internal controls, increase accountability, and ensure certifications are completed prior to reimbursement submissions. MPS performed the following with respect to enhancing the internal controls surrounding this process: Prior to Collection • Adjusted certification timelines to allow adequate review and approval, • Established centralized email account to improve communication reliability, • Reassigned responsibility to the ESEA Manager for stronger oversight, • Beginning FY26, implemented a monthly grant report to monitor expenditures and detect and correct errors in a timely manner, • Communicated certification timelines to district leadership in advance of the collection window. During Collection • Sent daily communications and district-wide reminders, • Monitored completion through daily reporting, • Provided real-time technical support. Post Collection Window • Continued system-generated reminders, • Conducted targeted outreach via email, phone, and virtual meetings, as appropriate, • Launched a formal escalation process through supervisory channels when needed as described in our communications outlined above. These actions are supported by documented procedures and enhanced oversight to ensure timely completion of certifications and compliance with federal cost requirements. Name(s) of the contact person(s) responsible for corrective action: State and Federal Program Director, ESEA Coordination and Compliance Manager Planned completion date for corrective action plan: Completed as of December 2025.

Management’s Response and Corrective Action Plan: Management acknowledges the finding and agrees with the recommendation. Once notified of the stipend rate issue, management immediately corrected the allocation and ensured the unallowable portion was funded with non-Federal resources. To prevent future occurrences, SoFIA Management has reinforced controls by (1) requiring a compliance review of stipend rates before charging costs to the AmeriCorps award, (2) updating written procedures to reflect stipend limits, and (3) providing further training to program and finance staff. These measures will ensure that only allowable stipend costs are charged to the Federal program going forward. We are committed to maintaining strong fiscal controls and ensuring full compliance with all federal grant requirements. Contact and Completion Date: Cresha Reid, 954-484-7117, creid@thesofia.org, is the primary contact, and the Chief Executive Officer at the South Florida Institute on Aging. The corrective action will be resolved before the end of the next fiscal year-end of June 30, 2026.

Period of Performance – Assistance Listing No. 93.958 Recommendation: Management should review and revise its process for allocating costs to federal grants to include additional layers of review and so that costs for which some or all are from outside of the period of performance, may be appropriately excluded from the federal grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will revise cost allocation procedures to add program and finance review steps to ensure that only costs incurred within the applicable period of performance are charged to federal grants. Costs identified as outside the allowable period will be excluded or reclassified. Updated procedures will be communicated to relevant staff and monitored for compliance. Name(s) of the contact person(s) responsible for corrective action: George Pepe Planned completion date for corrective action plan: 6/30/2026

United Way will ensure all disbursements related to major program are allowable.

Corrective Action Plan Finding No. 2025-004 Condition – The District submitted an expenditure report for $19,165,569 for the quarter ending March 31, 2025, which included amounts that were properly obligated but not yet expended as of the report date. The District reported $14,638,097 in ESSER funds on the Schedule of Expenditures of Federal Awards (SEFA), resulting in an unsupported difference of $4,527,472. Plan – The District will implement additional review processes to ensure material errors are detected and corrected. The District requested all ESSER obligated funds as of March 2025 as directed by the state. Anticipated Date of Completion: 03.06.26 Name of Contact Person: Delfaye Jason, Chief School Business Official

2025-006 – Allowable Costs/Cost Principles Corrective action plan: Contractors have been tasked with training and implementation during fiscal year 2026. Revised accounting staff structure will provide better on-going implementation and monitoring compliance. Personnel responsible for corrective action: Heather King, Interim Chief Operating Officer Estimated corrective action completion date: March 2026

2025-06 Allowability of Rental Assistance Payment- Unallowable Program Expenditure Federal Agency- US Department of Housing and Urban Development Continuum of Care Program -Assistance Listing# 14.267 Hennepin County Contract HS00001366 Year ended June 30, 2025 Material Weakness in Internal Control over Compliance, Noncompliance Other Matter Recommendation - Agate Housing and Services, Inc. strengthen internal controls to ensure all expenditures charged to the Continuum of Care Program are allowable and comply with applicable federal and program requirements. Corrective action - Agate Housing and Services, Inc agrees with the finding and is in the process of strengthening its controls over its review of program expenditures prior to submitting requests for reimbursement. An additional layer of review/approval by the Director of Contracts and the Chief Operating Officer prior to submission has been implemented. Name of contact person(s) responsible for corrective action - Elizabeth Macha rt, Director of Housing Programs and Sara Wenzel, Associate Director Time Limited Housing Completion date - Management implemented the additional layer of review/approval beginning January 2026.

Allowable Costs / Period of Performance The University acknowledges the finding related to expenditures recorded outside the approved period of performance and the missing supporting documentation for one transaction. We recognize that all federally funded costs must be both allowable and incurred within the designated performance period, and that proper documentation must be retained for audit purposes. Corrective Actions 1. Improved Period-of-Performance Verification: The University has strengthened its review procedures to ensure all expenses are confirmed as occurring within the applicable grant period before being charged to the award. Both grants management and accounting staff now verify dates prior to posting. 2. Enhanced Documentation Requirements: A shared electronic repository is being used to ensure all supporting documents are uploaded and retained before any expenditure is approved. Transactions submitted without documentation are now automatically rejected. 3. Staff Training: Relevant staff have received targeted training on allowable-cost rules, documentation standards, and period-of-performance requirements under Uniform Guidance. 4. Ongoing Monitoring: Periodic internal reviews will be conducted to verify continued compliance and ensure that all costs charged to federal awards are timely, appropriate, and fully supported, and charged within the required time periods. The University believes these actions address the issues noted and will strengthen internal controls over federal expenditures moving forward.

iLearn Schools, Inc. notes that the excess reimbursement of $85,425 was identified, properly recorded as a grant advance liability, and not recognized as revenue or expense in the current year. Going forward, all reimbursement requests will be based on actual allowable direct costs incurred. Management will establish written procedures for indirect cost recovery, implement a formal review and reconciliation process prior to submission, and provide staff training on Uniform Guidance requirements. These corrective actions will be in place for the fiscal year ending June 30, 2026. Responsible Official: Mr. Coban, Chief Financial Officer

FINDING 2025-005 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure allowable costs are documented and that receive board approval for all pay rates moving forward. However, we disagree with the finding on the allowable costs pertaining to the Financial Consulting Claims. We wrote them into the grant, and the grant was approved. There was also no Business Manager or Chief Financial Officer in place during the pandemic, resulting in the need for the consulting firm. Anticipated Completion Date: We anticipate that this correction will be in place by July 2026.

FINDING 2025-003 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure that the Form 9 and all underlying expenditures are properly documented. Anticipated Completion Date: We anticipate that this correction will be in place by July 2027

FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure that the Form 9 and all underlying expenditures are properly documented. Anticipated Completion Date: We anticipate that this correction will be in place by July 2027

SWN will develop additional review procedures over contracts to ensure proper adjustments are proposed to allocate expenses between proper periods. Procedure for approval of the Finance Committee by May 21, 2026. This procedure may include implementation of official listing of SWN's written contracts and vendor contracts. Additionally, the Organization plans to work with vendors to align contracts with the fiscal reporting period.