Corrective Action Plans

We are reinforcing our invoice verification procedures which include specific instructions on how to enter invoices including invoices without unique numbers so that the accounting system will flag and prevent any future duplicate payments. The accounts payable staff will also receive a refresher training.

Action taken: The district is hiring an additional account clerk (N: Tonn) and the deputy treasurer (R. Heimer) will begin working with the treasurer (C. Meher) so that the treasurer can focus more closely on reporting and more of the duties of the business manager. Review of the final cost reports is ongoing and the Comptroller's Office and/or Office of Grants Finance will be contacted once the internal audit is complete to make any necessary adjustments. This will be done by the treasurer, C. Meher. Anticipated completion date: will begin January 5, 2026 and continue throughout the school year

Finding 2025.004 – Period of Performance Federal Program Name: Continuum of Care Federal Assisted Listing Number:: 14.267 Recommendation We recommend that management implement additional controls and policies over period of performance. Staff who purchase items with grant funds should have additional training on period of performance requirements. Planned Corrective Action: TVCCA is strengthening its period of performance controls through the following actions: 1. Training – All employees with purchasing power will be trained on the deadlines of the grants they are responsible for. This training includes what the definition of obligation truly is, as well as allowable spend down period of their grants. Finance staff will also be trained on the timing and definitions of obligations. 2. Revised internal controls and workflow – Cutoff testing will be performed and added to the month close checklist on a quarterly basis to align with grant closing schedules. 3. Monitoring – Cutoff testing will be monitored on a quarterly basis in association with quarter ending checklist. Name of Contact Person: Max Logan, CFO, 860-425-6506, mlogan@tvcca.org Anticipated Completion Date: March 31, 2026

Duplicate Title I Draw Condition: 2 CFR 200.403 of the Uniform Guidance mandates that only necessary, and allowable costs be drawn down off of federal grants. During the audit, we found that the prior fiscal year's accrued payroll, which was drawn off of the grant In the previous fiscal year, was drawn off of the grant a second time in the current fiscal year, creating questioned costs of $53,509. We recommend that management implement procedures to ensure that all accruals charged to federal grants are properly reversed in the subsequent fiscal year to ensure that duplicate draws on those same expenses are not made. Corrective Action: The District understands what happened and will work on developing procedures to prevent such duplicate draws do not occur in the future. Contact Person Responsible for Corrective Action: Chanda Cleaves, Executive Director of Finance Completion Date: This issue will be corrected moving forward.

Reference Number: 2025-001 Description: Finding 2025-001 - Federal ALN 93.778 Medicaid Cluster Corrective Action Plan: The District will update the setup for Medicaid reporting in Skyward Qmlativ to back out expenditures coded to federal grants, specifically project numbers 341 and 347. Anticipated Corrective Action Plan Completion Date: Corrective action was implemented on July 23, 2025. The district has reviewed reports generated after this date and verified the accuracy of reporting. Contact Information: For additional information regarding this finding please contact Beth Sheridan, Assistant Superintendent of Finance and Operations, at 262-560-2119. Beth Sheridan Assistant Superintendent of Finance and Operations

Research and Development Cluster— Assistance Listing Nos. Various Recommendation: We recommend that the University review its procedures around review and approval of R&D expenditures to ensure that only valid expenditures are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University does have existing internal control processes over its federal grants. The principal investigators code, approve, and submit expenditures for payment. In addition, principal investigators receive periodic grant reports which include the detail of all transactions charged to their grants for review. The University will add an additional control step to review coding of research and development payment requests in the ERP system prior to payment. Names of the contact persons responsible for corrective action: Gerri Stepanek and Carole Kampf Planned completion date for corrective action plan: September 1, 2025

2025-003 Period of Performance (repeat of finding 2024-005) Corrective action planned: Beginning April 1, 2025, when the organization was made aware of this finding in last year’s audit, OMC took immediate corrective actions. The CFO/Designee will monitor expenses, and a separate prepaid schedule has been developed to track future period expenses. OMC’s current CFO/Designee has a basic understanding of GAAP. All coding will be reviewed and approved by an authorized, knowledgeable CFO/Designee. Anticipated completion date: Corrective Action taken on April 1, 2025. Contact person responsible for corrective action: Allen Boyd, Director of Fiscal Operations

Finding 2024-005 – Duplicate Reimbursement Request for Federal Award Expenditures (Material Weakness) Criteria: CFR §200.403 and related provisions, costs charged to federal awards must be accurate, allowable, and not charged or reimbursed more than once. Additionally, reimbursement requests must be supported by complete and accurate records to ensure compliance with federal requirements and prevent improper payments. Condition: During our testing of expenditures and reimbursement requests for the above-referenced federal program, we identified that certain expenditures were submitted for reimbursement twice across twoseparate fiscal years. While the underlying expenditures were incurred only once, and not paid twice by the entity, they were included in reimbursement requests in two different periods, resulting in The Town receiving duplicate reimbursements for the same costs Cause: The duplication likely occurred due to changes in financial staffing for The Town. Specifically: • Turnover in personnel resulted in a loss of institutional knowledge regarding prior reimbursement and submissions. • Inadequate review controls allowed previously reimbursed expenditures to be re-submitted in a subsequent period. • Initial reimbursement requests appear to have used an alternate methodology for reimbursement requests. Context: The Town administers multiple federal awards and is responsible for preparing and submitting reimbursement requests based on incurred allowable expenditures. During the audit period, The Town experienced staff turnover and changes in key financial and grant management roles. These changes affected the continuity of oversight and the tracking of cumulative expenditures and prior reimbursement requests. As a result, controls over the review and reconciliation of reimbursement submissions were not consistently applied, contributing to the resubmission of previously reimbursed expenditures in a subsequent year. Recommendation: We recommend that the entity: • Reconcile all reimbursement requests to the underlying expenditures and prior submissions to identify and quantify any additional duplication. • Re-pay any overpayments to the federal awarding agency in a timely manner. • Strengthen internal controls by: o Implementing a centralized tracking system for all reimbursement requests and cumulative expenditures. o Establishing a formal review and approval process to verify that costs have not been previously reimbursed. o Clearly document roles and responsibilities, especially during staffing transitions. • Provide training to staff involved in grant management to ensure compliance with federal requirements. Corrective Action Plan: The Town of Lakeview has taken significant organizational and procedural steps to strengthen its administration of federal awards and ensure future compliance with Uniform Guidance reporting requirements. Corrective actions implemented include: • The Town has hired a Finance Director with substantial experience in state and federal grant administration and financial reporting. The Finance Director is responsible for oversight of all federal financial reporting, including review of expenditures and preparation of disbursement requests. • The Town has hired a new Town Manager who has established improved financial oversight and accountability throughout the organization. The Town Manager will work closely with the Finance Director to monitor compliance with federal grant requirements and review expenditures and disbursement requests. • The Town Council has established a Citizen Finance Advisory Committee to provide independent oversight and review of the Town’s financial management practices. The committee will review financial reports, budget performance, and federal grant administration processes, providing recommendations to improve accountability and transparency. • The Town has developed and implemented formal policies and procedures governing the administration of federal awards including: o Identification and tracking of awards o Documentation of expenditures charged to federal programso Procedures for maintaining grant files o Reconciliation of grant expenditures to the general ledger o Annual preparation and supervisory review of the Schedule of Expenditures of Federal Awards • The Finance Director will prepare disbursement requests, and they will be reviewed and signed by Council members prior to submittal. A ll disbursement requests and associated expenditures will be maintained in an electronic file system. Hard copies of disbursement requests and expenditure documentation will also be maintained in a standardized fi le system. Planned Implementation Date: The corrective actions described above have been implemented. The Town will continue to monitor compliance throughout the fiscal year, and the revised procedures will be fully incorporated into the preparation of the next annual SEFA. Responsible Person: Town of Lakeview Mayor.

View of Responsible Officials and Corrective Action Plan We acknowledge the finding regarding the use of gift cards and bonus payments to contractors. During the Covid-19 pandemic, our staff and contractors were tasked with responding to urgent and overwhelming public health demands, particularly as the New Mexico Department of Health became overextended. To recognize the efforts and to ensure timely case reporting and investigations for tribal communities, gift cards and bonuses were used as a form of appreciation. Corrective Action Plan Moving forward, we will ensure full compliance with federal grant requirements. Specifically: 1. We will adhere strictly to the cost principles and allowability guidance outlined in federal regulations and the terms of each Notice of Award. 2. In instances where the allowability of an expense is unclear, we will proactively seek guidance and written approval from our Federal Grant Management Officer before incurring the cost. 3. We will provide refresher training to program and fiscal staff on allowable costs under federal awards to prevent recurrence of similar findings. These corrective actions will ensure future expenditures are fully compliant with federal guidelines. Corrective Action Plan Timeline As part of being a continued finding, AAIHB has already ceased the use of gift cards. Going forward we will also discontinue the use of bonuses for contractors. Within the next quarter, Finance and Program Leadership will review current grant guidance, the applicable Notice of Award, and other relevant federal requirements to ensure compliance. To prevent this issue for recurring, whenever there is uncertainty regarding the allowability of a cost, staff will consult Grants Management Officers prior to obligating or expending funds. Designation of Employee Position Responsible for Meeting Deadline Program Managers/Directors, Finance Officer, and Accounting Manager.

As noted above, we are working with consultants and our government partners to determine and define the requirements for each relevant program. We understand the recommendations offered and will review, and possibly revise, our policies and procedures, including supervisory review of documentation to support the allowability of costs charged to federal agreements. We will also review existing policies and procedures for preventing or detecting and correcting unallowable costs charged to federal agreements to ensure consistent application of those policies and procedures for all costs charged to federal agreements. The anticipated completion date is October 2026.

As noted above, we are working with consultants and our government partners to understand the requirements for each relevant program. We understand the recommendations offered and are exploring a comprehensive indirect cost allocation policy that would align with applicable requirements. The anticipated completion date is October 2026.

Finding Number: 2024-006 Finding Title: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting Program: 93.778 Grants to States for Medicaid Name of Contact Person Responsible for Corrective Action: LaRae Kuhfal, Fiscal Officer and Deb Sjostrom, Director. Corrective Action Planned: LaRae has taken over the report starting with quarter 4 of 2025 and is keeping all records used for the LCTS report. We plan to make sure that the quarterly reports are reviewed and approved by the director. Anticipated Completion Date: Completed as of quarter 4, 2025 and continuing.

The Government concurs with the auditor’s findings and recommendations. Management will conduct a comprehensive review of existing internal controls related to non-payroll expenditures. DHS will update policies and procedures to ensure all costs are properly documented and comply with federal allowable cost principles. DHS is committed to addressing the identified issues and maintaining ongoing compliance with federal regulations. DHS will conduct a thorough review of current internal controls and procedures related to non-payroll expenditures to identify gaps and areas for improvement. Policies will be updated to ensure all costs are properly documented and comply with federal allowable cost principles. Staff responsible for processing and approving expenditures will receive targeted training on documentation and compliance requirements. DHS will implement periodic internal audits to monitor adherence to updated procedures and promptly address any exceptions.

The Government concurs with the auditor’s findings and recommendations and finalizing a comprehensive corrective action plan to strengthen grant management and compliance through the Public Finance Management initiative including the development of a three-tier overarching Financial and Compliance policy and procedures framework. The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including fiscal and administrative requirements for expending and accounting for payroll expenditures. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.

VIDE will reinforce its procedures for tracking, compiling, and storing documentation related to grant expenditures. To achieve the necessary level of control precision, VIDE has successfully finalized the Standard Operating Procedure (SOP) governing the calculation, tracking, and record retention of indirect costs. Currently, the Third-Party Fiduciary Agent (TPFA) controls and executes this specific process on behalf of the Department. To ensure the newly finalized procedures are fully operationalized, VIDE is scheduling mandatory training. VIDE will coordinate directly with the TPFA to facilitate this training for all relevant VIDE staff. This will ensure that internal personnel are fully equipped to actively verify, compile, and securely store the required check payment details and detailed project expenditure reports. Building this internal capacity will strengthen VIDE's oversight of the TPFA's processes and prevent future documentation gaps.

VIDE will reinforce its procedures for tracking, compiling, and storing documentation related to grant expenditures. To achieve the necessary level of control precision, VIDE has successfully finalized the Standard Operating Procedure (SOP) governing the calculation, tracking, and record retention of indirect costs. Currently, the Third-Party Fiduciary Agent (TPFA) controls and executes this specific process on behalf of the Department. To ensure the newly finalized procedures are fully operationalized, VIDE is scheduling mandatory training. VIDE will coordinate directly with the TPFA to facilitate this training for all relevant VIDE staff. This will ensure that internal personnel are fully equipped to actively verify, compile, and securely store the required check payment details and detailed project expenditure reports. Building this internal capacity will strengthen VIDE's oversight of the TPFA's processes and prevent future documentation gaps.

VIDE will strengthen payroll and personnel action controls by requiring the Budget Team and Deputy Commissioner to review and approve all personnel actions before NOPA execution to validate pay rates. Furthermore, Payroll will establish a final review step to reconcile approved hours against both the payroll processing register and the final reimbursement invoice. Approved timesheets, Notices of Per Diem, and related payroll support will be centrally retained in SharePoint by pay period and attached to applicable invoices or general ledger journal entries. Program staff and supervisors will receive mandatory training on updated timesheet procedures and federal time and effort requirements. The Office of Fiscal and Administrative Services will also conduct monthly spot checks of SharePoint repositories and ERP logs to document compliance, identify control gaps, and ensure timely corrective action. Finalization of the formal SOPs and supporting controls is a top priority to achieve the necessary level of control precision and prevent repeat findings.

VIDE will reinforce its procedures for tracking, compiling, and storing documentation related to grant expenditures. To achieve the necessary level of control precision, VIDE has successfully finalized the Standard Operating Procedure (SOP) governing the calculation, tracking, and record retention of indirect costs. Currently, the Third-Party Fiduciary Agent (TPFA) controls and executes this specific process on behalf of the Department. To ensure the newly finalized procedures are fully operationalized, VIDE is scheduling mandatory training. VIDE will coordinate directly with the TPFA to facilitate this training for all relevant VIDE staff. This will ensure that internal personnel are fully equipped to actively verify, compile, and securely store the required check payment details and detailed project expenditure reports. Building this internal capacity will strengthen VIDE's oversight of the TPFA's processes and prevent future documentation gaps.

VIDE will strengthen payroll and personnel action controls by requiring the Budget Team and Deputy Commissioner to review and approve all personnel actions before NOPA execution to validate pay rates. Furthermore, Payroll will establish a final review step to reconcile approved hours against both the payroll processing register and the final reimbursement invoice. Approved timesheets, Notices of Per Diem, and related payroll support will be centrally retained in SharePoint by pay period and attached to applicable invoices or general ledger journal entries. Program staff and supervisors will receive mandatory training on updated timesheet procedures and federal time and effort requirements. The Office of Fiscal and Administrative Services will also conduct monthly spot checks of SharePoint repositories and ERP logs to document compliance, identify control gaps, and ensure timely corrective action. Finalization of the formal SOPs and supporting controls is a top priority to achieve the necessary level of control precision and prevent repeat findings.

DPNR recognizes the discrepancies identified between the employee pay rates reflected in the payroll registers and the Notices of Personnel Action (NOPAs) that were provided during the audit. Preliminary review indicates that the payroll system calculates employee compensation based on approved personnel actions maintained within the payroll system; however, it is possible that the NOPAs provided for audit testing did not reflect the most current approved personnel actions or subsequent amendments affecting employee compensation. Additionally, DPNR's procedures for maintaining and readily retrieving complete personnel and payroll support documentation were not sufficiently centralized to ensure that the most current supporting records were consistently available for audit review. DPNR will conduct a comprehensive internal review of the payroll transactions identified in the audit sample to determine the cause of the discrepancies between the payroll registers and the NOPAs provided during the audit. The review will include: • Verification of the official personnel actions maintained in the payroll system; • Review of any amended or revised NOPAs affecting employee compensation; • Reconciliation of payroll registers to approved personnel actions; • Verification that salaries and wages charged to Federal awards are properly supported and accurately reflected in official records; and • Identification and correction of any deficiencies in document retention or record management procedures.

The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including fiscal and administrative requirements for expending and accounting for payroll expenditures. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.

The Government concurs with the auditor’s findings and recommendations and finalizing a comprehensive corrective action plan to strengthen grant management and compliance through the Public Finance Management initiative including the development of a three-tier overarching Financial and Compliance policy and procedures framework. The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including allowable cost and cost principles. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.

OMB acknowledges the findings and notes that OMB does not calculate or determine fringe benefit amounts charged to payroll expenditures. However, OMB will coordinate with the Department of Finance to communicate the identified discrepancy and will work collaboratively to strengthen review procedures over payroll cost allocations charged to federal programs. In addition, OMB will reevaluate its existing oversight controls to ensure that payroll expenditures charged to federal awards are supported by appropriate documentation and reviewed for compliance with applicable federal requirements.

The Government will implement enhanced internal control procedures to ensure that payroll expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) are complete, accurate, and fully supported by transaction-level detail in accordance with 2 CFR 200.303, 2 CFR 200.403(g), and 2 CFR 200.430(i). Corrective actions will include the following: 1. Implementation of Monthly Payroll Reconciliations: The Government will establish a formal reconciliation process requiring monthly reconciliation of payroll expenditures recorded in the accounting system to detailed payroll records generated from the payroll system. o All variances will be identified, investigated, resolved, and documented. o Supporting documentation (e.g., payroll registers, timesheets, and cost allocation reports) will be retained and readily available for audit review. This aligns with enterprise expectations that reconciliation exceptions must be logged, investigated, and resolved with supporting evidence retained. 2. Development and Formalization of Standard Operating Procedures (SOPs): The Government will develop and/or enhance SOPs governing: o Payroll cost charging to federal awards o Documentation standards required to support payroll expenditures o Reconciliation procedures between payroll system and general ledger o SEFA preparation and validation procedures These SOPs will ensure consistency, completeness, and compliance with Uniform Guidance requirements. 3. Strengthening Documentation Controls: Payroll costs charged to federal awards will be supported by documentation that: o Accurately reflects the work performed o Reconciles to total compensation (100% effort) o Is incorporated into official records and retained in accordance with record retention policies Documentation reviews will be incorporated into routine processing and supervisory review controls. 4. Independent Review and Oversight: Reconciliations and payroll allocations to federal programs will be subject to supervisory or independent review to verify: o Accuracy and completeness o Proper allocation across funding sources o Consistency with grant terms and conditions Evidence of review and approval will be maintained. 5. SEFA Validation and Pre-Submission Review: Prior to finalizing the SEFA, the Government will implement a mandatory validation step requiring: o Reconciliation of SEFA totals to the general ledger o Verification that all amounts reported are supported by transaction-level payroll detail o Confirmation that all adjustments are documented and approved This aligns with established CAP practices requiring documented reconciliation outputs that demonstrate control effectiveness. 6. Training and Capacity Building: Relevant personnel will receive training on: o Federal cost principles under 2 CFR 200 o Payroll documentation and certification requirements o SEFA preparation and reconciliation expectations Training will ensure consistent application of policies and improve compliance. 7. Ongoing Monitoring and Compliance Reviews: The Government will implement periodic (quarterly) compliance reviews to: o Assess the effectiveness of payroll reconciliation controls o Ensure documentation requirements are consistently met o Identify and remediate any recurring issues timely These monitoring activities are consistent with prior CAP approaches that require periodic review of payroll documentation and reconciliation practices.

DPNR will: • Conduct a review of payroll transactions to identify any additional discrepancies between timesheets and payroll registers. • Implement a requirement for supervisory review and certification of employee timesheets prior to payroll processing. • Establish a reconciliation process requiring payroll staff to compare approved timesheets to payroll registers before final payroll approval. Grant Charge Authorization • Review personnel funding assignments to verify that salary charges are consistent with approved Notices of Personnel Action (NOPAs), grant budgets, and personnel authorizations. • Correct the employee's funding allocation to reflect the authorized grant funding source. • Establish a secondary review process to verify funding sources before payroll is posted to grant accounts. Payroll Adjustments • Review outstanding payroll adjustments and correction entries. • Process the identified correction and updated procedures to ensure adjustments are completed promptly upon discovery. • Establish tracking procedures to monitor payroll corrections through completion.