Corrective Action Plans

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

April 30, 2026 Finding Number: 2025-001: Significant Deficiency in Internal Control / Immaterial Noncompliance – Activities Allowed/Allowable Costs Finding Condition: Allowable costs charged to the grant were coded to an incorrect functional expense within the grant. Planned Corrective Action: Although the allowable cost sampled was charged to the correct federal cost category, it was inadvertently charged to the incorrect internal functional account code. We have instituted more rigorous reviews of all elements of account coding during the invoice review process prior to posting invoices to the Accounts Payable ledger. We also note that the cost was reported to the correct cost category on quarterly reports. Responsible Contact Person: Shamar Herron (Executive Director) Sherron@mwse.org Anticipated Completion Date: Effective Immediately Respectfully, Shamar Herron

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

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.

Percentages used for allocations will be reviewed annually across all grants/programs and updated during the budget process. These allocations will be reviewed by the CFO. Implemented for the most part in FY2025 but discovered that we had not made corrections to the entire process of allocations, have tightened this up in FY2026.

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.

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

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