Corrective Action Plans

Finding Number: 2025-011 ALN Number(s) and Program Title(s): 21.029 – Coronavirus Capital Project Funds Views of Responsible Officials and Planned Corrective Action: Administrative costs charged to CPF were program-related and remained within the statutory administrative cap. ASBO acknowledges, however, that documentation supporting the internal methodology used to allocate administrative costs across multiple broadband funding streams was not sufficiently formalized during the period reviewed. The identified variance of $22,516 reflects an administrative reconciliation issue rather than an unallowable expenditure, and the variance amount was reduced from a subsequent administrative cost drawdown. Moving forward, the team will more formalize its administrative cost allocation methodology to include a narrative explanation to support allocation percentages, as well as authorizing signatures. Anticipated Completion Date: June 30, 2026 Contact Person: Name: Glen Howie Title: State Broadband Director Agency: Arkansas State Broadband Office Address: 1 Commerce Way City, State, Zip: Little Rock, AR 72202 Phone Number: 501-683-6000 Email Address: broadband@arkansas.gov

The District will implement time and effort documentation for employees paid with federal funds. The District has already implemented allocation process on the Child Nutrition invoices in FY26.

Recommendation: The Department of Social Services should strengthen internal controls to ensure that it allocates costs to the appropriate federal award in accordance with federal regulations. The Department of Social Services should return federal reimbursements for unallowable costs that it claimed to Children’s Health Insurance Program federal awards. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with this finding. The Department will review internal controls to identify possible corrective actions. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Nelida Maldonado, Fiscal Administrative Manager 2 (860) 424-5461

Condition: Expenditures for the Child and Adult Care Food Program were incorrectly reported as expenditures to other nutrition programs. Recommendation: The auditors recommend that the School properly identify and report nutrition program expenditures by program. Contact Name: Anastacia Europa Ruiz, Chief Operating Officer Corrective Action Planned: The School Management will identify nutrition program expenditures by each separately funded program and report such expenditures by each separately funded program. Anticipated Completion Date: June 30, 2026

Condition: For FAL 10.185, all 40 vendor disbursements tested lacked evidence of supervisory approval, as the payment request forms were not signed by the designated approver prior to payment. For FAL 10.558, 27 of thirty-two vendor disbursements tested lacked documented supervisory approval prior to payment. Finally for FAL 84.010A, two of the ten vendor disbursements tested lacked documented supervisory approval prior to payment. In each noted instance, payments were processed without evidence that the School performed and documented a review in accordance with established internal control procedures. Recommendation: The auditors recommend that the School enforce existing policies requiring documented supervisory approval prior to processing payments and implement monitoring procedures to ensure approval documentation is completed and retained. In addition, the School should strengthen pre-payment review procedures to ensure expenditures are evaluated for allowability, necessity, reasonableness, and proper allocation in accordance with 2 CFR Part 200 and applicable program requirements. Training should be provided to personnel responsible for processing and approving federal program expenditures to reinforce compliance responsibilities. Contact Name: Anastacia Europa Ruiz, Chief Operating Officer Corrective Action Planned: The School Management will require documented supervisory approval, including signature and date, on all payment request forms prior to processing vendor disbursements charged to federal programs. Accounts payable staff will not release payments without evidence of required authorization. Written disbursement procedures will be reviewed and the applicable staff will be retrained within 90 days. The School will perform monthly oversight of disbursement activity and quarterly sample reviews to ensure ongoing compliance. Anticipated Completion Date: June 30, 2026

Congressionally Directed Spending – 93.493 Recommendation: We recommend that the University reviews its procedures around review and approval of 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 identified expenditures were removed from the award and appropriately reclassified in September 2025. In response to this finding, the University of Maine at Augusta (UMA) has increased the frequency of general ledger review for its federal awards from monthly to twice monthly. This review process includes a direct cross-reference between transactions and the approved award budget. This enhanced oversight allows for timely identification and correction of discrepancies. The UMA Finance Department has several initiatives underway which will mitigate the risk of similar mispostings in the future, including the implementation of a formal training program for staff as a preventative control. A monthly reconciliation and transaction level review process which will be completed with principal investigators is also being developed. These additional procedures are expected to be in place by May 2026 and will support a consistent and strong awareness of federal compliance requirements, award administration and University of Maine System policies and procedures. Name(s) of the contact person(s) responsible for corrective action: Mark Mantey, Assistant Director of Finance, University of Maine at Augusta Planned completion date for corrective action plan: May 2026 If the United States Department of Education or other agency has questions regarding this plan, please call Darla Reynolds at 207-262-7743 or darlab@maine.edu.

The Office of Resilience respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Housing and Urban Development 2025-036 Community Development Block Grant – Assistance Listing No. 14.228 Disposition of Audit Finding: The Office of Resilience does not agree this item rises to the level of a finding and could be sufficiently addressed with a recommendation. SCOR acknowledges this process could be improved and will act to better support this transaction going forward. Corrective Action: To provide additional support and clarification on the use of cost allocation percentages, SCOR Finance will create a memo to file each time the cost allocation changes. The current methodology is based on headcount and is subject to change frequently. At the beginning of each quarter, SCOR Finance will recalculate the cost allocation percentage based on agency headcount on the last day of the previous quarter. The quarterly updated allocation percentages will be the basis of allocating agency wide shared costs. A copy of the memo will be attached to the SCEIS payable document as support. Anticipated Completion Date: Immediately. SCOR Finance will go back to the beginning of FY26, recalculate the cost allocation percentages, create the memo to file and post correcting journal entries as needed. Names of the contact persons responsible for corrective action: • Andrew DeRienzo - CFO at 803-422-0092 • Sarah Reynolds – Accounting Manager at 803-896-0038 • Tiffany Frye -Budget Manager at 803-896-6704

Westminster College Corrective Action Plan (CAP) Federal Program: Economic Adjustment Assistance Program, Assistance Listing Number 11.307 Finding 2025-001: Questioned Costs – Allowable Costs/Costs Principles (material weakness) Name of Contact Person: Gerald J. Ganz, Jr., Vice President, CFO Specific Corrective Action: To prevent recurrence, the College is implementing the following measures: 1. Enhanced Funding Source Review Procedures: The College will develop and enforce a standardized review process requiring staff to verify and document the original funding source for any expenditure prior to charging it to a federal award. This process will include mandatory cross-checking between project accounting records, bond expenditures logs, and grant reimbursement requests. 2. Strengthened Internal Controls Over Capital Project Accounting: The College will implement additional controls within the accounting system to ensure expenditures tied to capital projects are flagged and reviews for potential dual funding before being charged to any federal program. 3. Training and Guidance for Staff: All personnel involved in grant management, accounting, and capital project administration will receive updated training on Cost Principles under 2 CFR 200.400-200.406, with emphasis on allocability, reasonableness, and the proper handling of applicable credits. 4. Ongoing Monitoring and Review: Quarterly internal compliance reviews will be conducted to confirm adherence to the new procedures, and corrective measures will be taken immediately if discrepancies are identified. The College is committed to ensuring full compliance with federal regulations and strengthening internal controls to safeguard all funding sources. We appreciate the opportunity to improve our processes and will implement the recommended procedures to ensure the integrity of future federal program expenditures. Anticipated Completion Date: June 30, 2026

We have a multi-pronged action plan. We will clarify and review our accounting policies and procedures regarding payroll allocations with staff; We will create a more thorough documentation process of the basis for each allocation; We will review the assumptions used for allocations during the year and update them (as needed); We will include regular monitoring and review of payroll allocations.

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

Program: AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.090 – Guardianship Assistance; 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: A new Business Unit mapping process has been implemented that will ensure that all Business Units are correctly accounted for. In addition, procedures were updated and sent to applicable staff to ensure payroll is correctly recorded. Contact: Patrick Werner Anticipated Completion Date: Complete

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

Planned Corrective Action: After review, it was determined that the wrong indirect rate was applied to a project. The overcharged amount was $1,461.69. The prime of this project was an industry sponsor and a CRADA was necessary for this work to be completed. It is the belief of the current OSRI management that the error accurred due to confusion that the funds came from an industry sponsor and not a federal agency. To correct this error, management will issue a payment of $1,461.69 to the sponsor. Planned Implementation Date of Corrective Action: Three inquiries were made by CBIZ on 1/5/26 regarding indirects charged by OSRI. On 1/6/26 OSRI management responded clearing up two of the three inquiries showing that the total indirects charged based on direct numbers were correct and that an adjustment had been made during the fiscal year in question to correct prior short falls. After a thorough review of the third inquiry, OSRI management on 1/8/26 reached out to the industry sponsor to inform them of our error and payment reimbursement was initiated. On 1/16/26 the industry sponsor confirmed receipt and cashed check for reimbursement.

Recommendation: We recommend that the Department develop and implement a written policy for leave allocation consistent with federal regulations. Also, we recommend that the Department provides training to ensure employees understand and comply with the written policy. Explanation of disagreement with audit finding: The Department recognizes the audit finding and its responsibility to comply with 2 CFR §200.405(d). Action taken in response to finding: Corrective action was taken. The Department revised the procedures and will no longer charge any type of leave activity to a grant, effective July 1, 2025, and for the foreseeable future. An email was sent out by the CFO on June 26, 2025 advising all Department employees about this change. The Federal Aid Cost Tracking System (FACTS) has also been changed to block access to all grants for any leave time reporting code entries. If a system is developed in the future to enable the allocation of leave consistent will the federal regulations, training will be provided for all employees. Name(s) of the contact person(s) responsible for corrective action: Paul Varela, CFO Planned completion date for corrective action plan: July 31, 2026

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

Allowable Costs/Cost Principles Recommendation: Update and revise the cost allocation plan annually to reflect actual program usage including the board of directors approval. Implement a time and effort reporting system for all shared staff and provide training to ensure compliance with federal requirements. This should include proper review and approval of all costs, explicitly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Management will establish and implement formal procedures to ensure the proper allocation of allowable costs across all grant components. These procedures will include appropriate oversight mechanisms to verify accuracy, compliance with grant requirements, and consistent application of cost-allocation methodologies. Names of the contact persons responsible for corrective action: Robert Loiseau, Finance Director and Gary Beaulieu, Executive Director

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will document the allocation methods used for employees and expenses.

FINDING 2025-003 Finding Subject: Teacher and School Leader Incentive Grants – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Teacher and School Leader Incentive Grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

Finding Reference: 2025-001 – Activities Allowed or Unallowed Costs/Cost Principles — Food Distribution Cluster (TEFAP/CCC/CSFP) — Questioned Costs: 188,459 Responsible Person: Todd Frease, CFO Planned Actions & Timelines: 1. Allocation Methodology Correction (by 30 days from report issuance): We will redesign our administrative cost allocation model to remove the CCC double-counting and ensure each program’s share is based on documented, reasonable measures of benefit, consistent with 2 CFR §200.405. The revised workbook will include locked formulas and version control. 2. Secondary Review Control (effective next monthly close): We will implement a two-step review: preparer signs off on the allocation workbook, and an independent reviewer validates sources, bases, and formula ranges before posting entries or submitting claims. Evidence of review will be retained in monthly share drive by indicating approval through email. Anticipated Completion Date: Within 60 days of report issuance

This finding was identified and addressed during the prior fiscal year audit and the current year findings are instances identified from prior to the identification of the finding in the prior year. Going forward the Organization will document the review and approval of the payroll allocated and charged to the federal award. of the payroll allocated and charged to the federal award.

The District will reconcile the Human Resources spreadsheet to the Grant Information to the payroll information entered into Skyward. Currently underway checking personnel by personnel, initiating needed updates and changes.

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

1. Document formal allocation methodologies for shared non-personnel costs using rational and supportable bases such as square footage, FTEs, usage, or other proportional benefit measures depending on the cost. 2. Review and approve methodologies by management and update them when operational realities change. 3. Maintain allocation schedules and supporting documentation for audit and grant compliance purposes. 4. Incorporate the methodology into policy and periodic review procedures.

Finding Number: 2024-006 Finding Title: Financial Policies and Procedures Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Financial Management and Standards of Financial Management Systems (2 CFR §200.302(b)); Allowable Costs (2 CFR §200.403-405); Procurement (2 CFR §200.317-327); Cash Management (2 CFR §200.305); Travel Costs (2 CFR §200.475) Note: Organization has existing Conflict of Interest policy in compliance with 2 CFR §200.318(c)(1). Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization will establish formalized accounting policies and procedures that adhere to the requirements of the Uniform Guidance. Corrective Action Plan: Corrective Action #1: Comprehensive Policy Manual Development • Action: Engage consultant or work with Contract Accountant to develop comprehensive written financial policies and procedures manual addressing all Uniform Guidance requirements, including: (a) Allowable costs (2 CFR §200.403-405); (b) Procurement (2 CFR §200.317-327); (c) Cash management (2 CFR §200.305); (d) Travel costs (2 CFR §200.475); (e) Time and effort documentation; (f) Equipment management; (g) Subrecipient monitoring; (h) Financial reporting; and (i) Record retention. Ensure policies address financial management system requirements under 2 CFR §200.302. Tailor policies to Organization's all-volunteer structure. [Note: Organization already has Conflict of Interest policy complying with 2 CFR §200.318(c)(1).] • Responsible Person/Title: Board Treasurer with Contract Accountant • Anticipated Completion Date: April 30, 2026 Corrective Action #2: Board Approval and Adoption • Action: Present draft policies to full Board of Directors for review and input. Board will formally adopt policies by resolution. Document approval in Board meeting minutes. • Responsible Person/Title: Board President • Anticipated Completion Date: May 31, 2026 Corrective Action #3: Dissemination and Training • Action: Distribute approved policies to all Board members and Contract Accountant. Conduct training session for Board members and Contract Accountant on new policies and procedures. Board members and Contract Accountant will sign acknowledgment of receipt and understanding. Make policies readily accessible (e.g., shared drive, Board portal). • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026 Corrective Action #4: Implementation Tools and Support • Action: Develop templates, forms, and tools to support policy implementation. Create workflow diagrams and checklists for common transactions. Establish Board Treasurer as primary resource for policy implementation questions. • Responsible Person/Title: Board Treasurer and Contract Accountant • Anticipated Completion Date: July 31, 2026 Corrective Action #5: Annual Policy Review Process • Action: Schedule annual review of policies to ensure continued Uniform Guidance compliance. Update policies as needed for regulatory or organizational changes. Submit material policy changes to full Board for approval. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: Annually, beginning June 2027 Corrective Action #6: Governance Structure Assessment • Action: Board will evaluate establishing Audit Committee or combined Finance/Audit Committee to provide enhanced oversight of financial management, internal controls, and federal compliance. If Board size prohibits separate committee, designate at least two Board members with specific oversight responsibilities. • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026