Corrective Action Plans

DJFS will begin to use project numbers to allow for an additional check of all amounts reported. DJFS is also going to provide federal grant information to the Auditor’s office as soon as they complete their final report in order to give the Auditor’s office adequate time to review the information with MUNIS and will afford the Auditor’s office more time to compile the SEFA and have a secondary review to avoid any computational or clerical errors.

Federal Agency: Various Federal Program: Research and Development Cluster Assistance Listing Number: Various Federal Award Numbers: Various Finding No.: 2025-002 Corrective Action Plan: To address the finding, the College will continue to implement a corrective action plan to strengthen internal controls over the application of indirect cost rates to federally funded awards. Although corrective actions were initiated following the prior year's finding, the College has identified opportunities to enhance the review and monitoring of indirect cost rate calculations to ensure consistent compliance with Uniform Guidance. Going forward, the accounting group, in collaboration with the Office of Sponsored Programs, will maintain the current federally negotiated indirect cost rates, apply approved rates to applicable awards, and perform periodic reviews to verify that the correct rates are consistently applied. Timeline for Implementation of Corrective Action Plan: The College will finalize written procedures governing the application and review of indirect cost rates, implement a documented review process for indirect cost calculations prior to posting, and provide guidance to employees responsible for grant accounting. These actions will be completed by September 30, 2026. Management will periodically monitor compliance to ensure indirect cost rates are applied accurately and in accordance with federal requirements.

Community Projects Funding / Congressionally Directed Funding – Assistance Listing No. 17.289. Recommendation: CLA recommends the Organization revise the indirect costs calculation process to review program-only costs, rather than entity-wide costs. Develop policies and procedures to incorporate appropriate internal controls over indirect cost calculations; ensure the performer of the internal control has the required knowledge & understanding of compliance requirements & accounting to catch errors during the review & approval process. There is no disagreement with this audit finding. Action taken in response to finding: In January 2026 we recevied an email from DOL outlining the correct way to allocate indirect costs. We made those adjustments to our indirect calculations and will adjust any previous overstated reimbursements. Name(s) of the contact person(s) responsible for corrective action: Tracey Hunter. Planned completion date for corrective action plan: May 2026

The City will implement a policy directing City staff that, if allowed, grant applications should include the option to charge indirect costs for the execution of the grant work. Upon grant application submissions, the department submitting the grant will coordinate with the Senior Finance Analyst to provide indirect cost rates and/or charges. As it relates to CDBG and HOME Program Grants, the Finance and Administration Department, in conjunction with the Community Development Director, will conduct a year-end review to ensure allowable indirect costs are appropriately charged. Personnel Responsible for Implementation: Meredith Elguira, Carol Molina, Ralston Turner Position of Responsible Personnel: Interim Community Development Director, Interim Finance and Administration Director, Senior Finance Analyst Expected Date of Implementation: April 30, 2026

Finding Number: 2025-002 Condition: DWIHN’s internal controls were not sufficiently designed and/or operating effectively to prevent the submission of unallowable costs for reimbursement under the federal award. Planned Corrective Action: Program and finance staff responsible for the approving and processing of FSR’s have been informed of the need to review FSR’s in greater detail before they are submitted, approved, and payment occurs. A more detailed review of the FSR’s and adherence to established policies and procedures will eliminate the risk of errors and omissions. Contact person responsible for corrective action: Vice President of Finance and Director of Grants and Community Engagement Anticipated Completion Date: August 7, 2025

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.

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

Home Investment Partnerships Program Assistance Listing No. 14.239 Recommendation: The City should review and enhance its internal controls and procedures to ensure that all required information is included in subawards at the time of issuance and maintained in subsequent modifications. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will undertake additional training for departments in FY 2026, to include providing departments with a grants responsibility checklist. Name(s) of the contact person(s) responsible for corrective action: Kevin Greenlief, Director of Finance. Planned completion date for corrective action plan: Q2, 2026.

Findings and Questioned Costs Relating to Federal Awards: Insufficient Controls Related to the Application of Indirect Cost Rates The Department will strengthen its administrative and management control processes to ensure accurate preparation and calculation for the Indirect Cost. The following corrective actions will be implemented: 1. Establish Internal Review Process: The Department will implement an excel report that includes all Grants to ensure adequate calculation and review. 2. Assign Reporting Responsibility: A designated staff member will be responsible for monitoring federal reporting requirements according to NICRA limitations. 3. Review and Approval Process: Management will implement an internal review and approval process prior to report submission to ensure accuracy and completeness.

Research and Development – Assistance Listing No. 11.000 Research and Development – Assistance Listing No. 11.617 Research and Development – Assistance Listing No. 12.000 Research and Development – Assistance Listing No. 20.000 Research and Development – Assistance Listing No. 20.109 Research and Development – Assistance Listing No. 43.000 Research and Development – Assistance Listing No. 43.001 Research and Development – Assistance Listing No. 43.002 Research and Development – Assistance Listing No. 43.008 Research and Development – Assistance Listing No. 43.012 Research and Development – Assistance Listing No. 47.083 Research and Development – Assistance Listing No. 81.000 Economic Development Cluster - Assistance Listing No. 11.307 Recommendation: We recommend OSU should notify the applicable sponsors and federal agencies regarding the calculated questioned costs and make any necessary repayments or adjustments. Further, OSU should develop and document a process to ensure the PES rates are developed and billed in accordance with OSU Policy, applicable federal regulations, and the requirements of OSU’s Federal Agreements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OSU will notify the applicable sponsors and federal agencies to resolve the questioned costs. OSU will also develop a process to ensure the correct PES rates are calculated and billed. Name(s) of the contact person(s) responsible for corrective action: Chris Kuwitzky, Senior Vice President for Administration & Finance and Chief Financial/Administrative Officer and Kenneth Sewell, Vice President for Research Planned completion date for corrective action plan: September 30, 2026

2025-004 Indirect Cost Rate Application on Federal Invoices We acknowledge BDO’s observation regarding the indirect cost rate applied to federal invoices during the period in which VOAWW transitioned from its approved NICRA rate to the de minimis rate. During this transition, VOAWW applied the NICRA rate of 17.2% while moving to the de minimis rate but did not complete the required true-up to 10% for a three-month period prior to the de minimis rate being increased to 15%. VOAWW has reviewed the circumstances that led to this error and determined that it occurred during an unusual and infrequent set of conditions. Transitions between indirect cost methodologies are rare and increases to the federal de minimis rate are also uncommon. As a result, this specific scenario is unlikely to recur. Nonetheless, VOAWW recognizes the importance of strengthening controls around indirect rate changes to ensure accurate application during any future transitions. To address this finding and strengthen controls over indirect cost rate application, VOAWW will implement the following corrective actions: • Formal Rate Transition Procedures – Before the end of FY26, the Finance Department will develop and document a standardized procedure for transitioning between indirect cost rates, including effective dates, interim rate requirements, required true-ups, and approval checkpoints to ensure accurate application during any future rate changes. • Centralized Indirect Rate Tracking – Before the end of FY26, the Finance Department will maintain a centralized indirect rate schedule that includes approval documentation, effective dates, and any required adjustments. This schedule will be referenced during invoice preparation and review to ensure consistent and accurate rate application across all federal awards. • Contract Kick-Off Meetings and Cross-Department Alignment – Before the end of FY26, Finance, Grants, and Contract Compliance will implement contract kick-off meetings for new awards and significant contract amendments to align on billing requirements, approved indirect cost rates, effective dates, and other critical compliance information and ensure consistent communication across departments. • Documentation of Important Communications – Before the end of FY26, VOAWW will implement guidance for documentation of important communications with funders that have a single audit impact. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

Finding No. 2025-008 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that State did not communicate the following award information required under 2 CFR 200.332: • Subrecipient’s unique entity identifier; • Federal Award Date; • Identification of whether the Federal award is for research and development; and • Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with 200.414). Corrective Action Plan DBEDT OPSD will strengthen internal controls over subaward identification and monitoring subrecipients to ensure that subrecipient monitoring requirements are met. The Program will communicate with the subrecipient to record their UEI. Program will supply the subrecipient with the date of the federal award, the indirect cost rate for the Federal award per CFR 200.414, and information on whether the award is for research and development. The Program will continue to supply subrecipient with Period of Performance Start and End Date, Budget Period Start and End Date, and the Assistance Listing number. Person Responsible Mary Alice Evans, Director of Office of Planning and Sustainable Development Anticipated Date of Completion April 1, 2026

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE U.S. Department of Justice 2025-001 Department of Justice Second Chance Act Community-based Reentry Program – Assistance Listing No. 16.812 Recommendation: We recommend that TASC follow its established procedures for segregation of duties over the calculation of indirect cost allocations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will follow established procedure to make sure that segregation of duties over the calculation of indirect cost allocations is properly documented. Management will review the procedure with all accounting staff. Name(s) of the contact person(s) responsible for corrective action: Roy Fesmire, CFO Planned completion date for corrective action plan: June 30, 2026

Starting in May 2024, the Alliance adapted its monthly Time and Effort Report that is reviewed by Kim Atkins, Executive Director, to be used for allocation of expenses other than payroll. This ensures a consistent, reviewed and authorized report is being used for expense allocation. This report is shared monthly with the Alliance’s funding agencies along with the submission of monthly vouchers for processing. During the year ended June 30, 2025, the Alliance has ensured that allocations were signed off on by Kim and has significantly reduced the amount of finance staff time required to process the allocation of administrative costs. The data from this monthly report is entered into NetSuite for allocation of administrative costs but subsequent review of the allocation program in NetSuite determined that the proper adjustment for adding new grants had not been built into the program. The Accounting Manager, Sarah Burgess, is currently working with NetSuite to fix this problem going forward. As of July 1, 2025 the Alliance is modifying all of its grants to adopt the 15% de minimis cost rate for all expenses other than personnel, direct program, and space costs.

Notice of Intent to Adopt the DeMinimis Cost Rate For Fiscal Year 2026-2027. The purpose of this document is to formally announce that the Bamberg County Office on Aging is taking the necessary administrative steps to adjust its indirect cost recovery method. Effective July 1, 2026 (Fiscal Year 2026-2027), the agency will elect to charge a de minimis rate (15%) for indirect costs. Please be advised that we are unable to adjust the current indirect cost rate within the Grant Management System (GMS) at this time (FY 25-26), as any modification would disrupt the financial reporting and accounting structures of the active fiscal year. The South Carolina Department of Transportation (SCDOT) has been formally notified that this change is technically non-viable for the current period; therefore, the implementation of the new rate will be deferred until the commencement of Fiscal Year 2026-2027 to ensure fiscal consistency and audit compliance.

Since the prior audit period, management has taken steps to establish procedures and internal controls to ensure consistent application, billing, and reporting of indirect cost rates across all federal awards. Such steps include defining and documenting roles and responsibilities for applicable staff members during each phase of the grants management lifecycle, as well as implementing procedures and tools to ensure compliance with subrecipient monitoring requirements. These steps involve multiple levels of review for accurate and consistent application of indirect cost rates. Finance will continue implementing the corrective actions necessary to achieve effective controls over compliance with indirect cost rate requirements. Policy and procedures on allowable and allocable costs will be drafted to clearly document how direct and indirect costs will be billed to federal awards. Training will be provided to relevant staff members to ensure accurate implementation and ongoing compliance. These actions will improve our ability to manage indirect costs effectively and ensure compliance with federal requirements. The anticipated completion date remains June 30, 2026.

IDC Error, Reference 2025-003 Audit Finding: For both programs, 50 expenditure transactions were selected for testing. Of these transactions, three that were unallowed under the MTDC definition for the program as stated in the Grant Award Notification were inappropriately charged indirect cost. These transactions totaled $364.32 (TRIO Program Cluster) and $242.87 (GEAR UP) and were charged indirect cost at a rate of 8% for a total indirect cost of $29.15 and $17.57, respectively. Our sample was not, and was not intended to be, statistically valid. Cause of the Finding: The University’s system for tracking costs requires manual review and adjustment, and this review was not completed on a timely basis. This resulted in the charging of inappropriate indirect costs not being corrected during the fiscal year. Effect of the Finding: Unallowable indirect costs were charged to the program and, as such, ED provided excess funding to the University. Corrective Action Plan: To address the errors identified in the IDC funds, the following corrective actions will be taken: 1. Immediate Review and Correction of Existing Data o The IDC errors had already been identified through the University’s monthly reconciliation process, and all corrections were completed by the end of each grant’s period of performance. o The University will continue to review existing processes and work with appropriate internal stakeholders to identify systematic improvements that reduce the need for manual review and adjustment. 2. System and Process Improvements o The University will evaluate its current approach for identifying and correcting unallowable IDC charges to ensure controls operate effectively throughout the year. As part of this review, procedures will be updated to clarify when IDC corrections under $50 per award will be completed, shifting required adjustments from the grant period of performance end date to the fiscal year end to promote consistency and timely resolution. 3. Training for Staff o Grants staff will receive refresher training on the allowability of costs under the Modified Total Direct Cost (MTDC) base, including proper identification of expenditures subject to indirect cost. o Training materials will be documented for reference and future onboarding. 4. Ongoing Monitoring o The University will continue its monthly grant award reconciliation procedures, including a review of MTDC IDC charges, to ensure any unallowable expenditures are identified and corrected promptly. 5. Timeline for Implementation o Updated procedures will be updated by Grant Office staff by February 28, 2026. o Staff training sessions: First session scheduled by February 28, 2026, with periodic refreshers as available. o Ongoing monitoring procedures will continue on a monthly basis. 6. Responsible Parties The Vice President for Finance & Operations and Assistant Vice President of Financial Operations will oversee the implementation of the corrective action plan. Responsible party contact information is located at uco.edu.

NACAA has received and reviewed the draft audit report for fiscal year 2025 conducted November 25, 2025. We have provided our auditors DeLeon & Stang with a Management Response to include with the audit. This document will outline NACAA’s course of corrective action for those findings. Finding 1: The Organization charged indirect costs to the major federal program in excess of the amount permitted under its approved NICRA for the fiscal year ended September 20, 2020. In addition, amounts reported on the annual Federal Financial Report (FFR) to the federal funder were incorrect, reporting the wrong base and charged amounts. The amounts reported on the FFR did not match the actual indirect cost base and charges for fiscal year 2025. Background As noted in the audit finding, NACAA’s NICRA has historically been based on a salary and fringe benefits allocation base. During fiscal year 2025, NACAA experienced significant turnover of longtenured employees, resulting in a substantial decrease in salaries and wages and, accordingly, a reduction in the approved indirect cost rate. As a result, indirect costs were overcharged to the federal program by $96,196. The annual Federal Financial Report (FFR) submitted on November 6, 2025, was based on internal year-end reports not NACAA’s audited final numbers. The information reported as the indirect cost rates and amounts were taken from the NICRA applications for the FY24 final and FY25 provisional negotiated rates. Remediation In order to address these findings, NACAA has contacted its EPA Project Officer and Grant Specialist to discuss appropriate corrective action. We explained that NACAA is having trouble paying its overhead expenses using the current negotiated indirect cost rate of 16.84% due to the substantial changes in our staff since the rate was negotiated. NACAA’s 2025 provisional indirect costs rate was calculated based on a SWF amount of $1,306,688. At year end because of staff changes, NACAA’s 2025 SWF amount is only $950,264, which makes our base for calculating indirect costs $356,424 less than when the rate was set. The indirect cost limit based on the old SWF was $220,046, while it’s $160,024 based on the new. NACAA’s indirect costs for 2025 were $256,919. After speaking with EPA, NACAA met with its auditors and accountant to discuss corrective action. It was recommended that some of NACAA’s overhead costs that have traditionally been added to the indirect cost pool (professional fees, rent, office insurance, etc.) be charged as direct costs using NACAA’s grant-related salaries and fringe benefits to allocate expenses between direct and indirect costs. To correct the other issue related to the Federal Financial Report (FFR) errors, NACAA will work with its accountant to complete the required FFRs and other grant reports to ensure that all figures being reported at correct. Reclassifying Indirect Charges to Direct Cost Categories NACAA has contacted the EPA Grants Management team to determine if our anticipated corrective course of action would be acceptable to EPA. We have received concurrence by email that the suggestion made by NACAA’s Auditors that pro-rating costs using salary as a basis for allocating overhead charges as direct costs is reasonable. This method should be used to allocate all expenses that are “traditionally” allocated as indirect costs. NACAA is currently drafting a request to re-budget its 2026 expenses, allocating many of the expenses traditionally part of the indirect cost pool as direct expenses, pro-rating costs using salary as a basis for allocating overhead charges as direct costs. NACAA’s Project Officer needs to approve that request so an amendment can be made for the current year of NACAA’s two-year cooperative agreement. Accountability Once NACAA’s re-budgeting request has been approved, NACAA’s Operations Manager and Accountant will be responsible for ensuring that expenses are correctly allocated every month using salary as a basis for allocating overhead charges as direct costs. Please see a description of NACAA’s Time and Attendance System and Method of Fringe Benefit allocation. These will be used to determine the percentage of expenses that will be allocated as direct costs: Salaries and Wages: Time & Attendance System: NACAA’s staff complete detailed timesheets on the 15th and last day of each month. Personnel Time Allocation Policy: Traditionally, activities of the NACAA headquarters office fall into three categories: federal grant-related activities; non-grant related activities; and indirect functions. Fringe benefits are allocated into these three categories based on the number of hours worked in each. Non-grant related activities are funded by the NACAA treasury. A very modest amount of time is allocated as Indirect Salaries, Wages and Fringes. Indirect salaries are included in NACAA’s indirect cost pool. Fringe Benefits: Fringe Benefits for NACAA’s staff members include employer-paid share of payroll taxes, health, life and disability insurance and a retirement plan. NACAA allocates fringe benefits based on a fringe benefit rate and distributes them based on salaries and wages.

Planned Corrective Action: We removed all unallowable costs from our indirect cost pool to ensure full compliance with applicable cost principles. We implemented an additional layer of review during the preparation of our 2025 indirect cost rate proposal to identify and exclude any unallowable charges. We added a dedicated step to our monthly close process to review all new charges and determine whether any should be classified as unallowable. Anticipated Completion Date 12/31/2025. Responsible Contact Person: Katherine Page, Director of Finance

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

Root Cause Analysis: The root cause of this finding was a misapplication of the approved indirect cost rate to the appropriate Modified Total Direct Cost (MTDC) base in connection with drawdown calculations. Although The EPI Center had an approved indirect cost rate and related policy in place, the operational procedures and system configurations necessary to consistently apply the methodology were still being refined and operationalized. The EPI Center notes that a formal, written Indirect Cost Rate Policy consistent with Uniform Guidance (2 CFR Part 200) was in place at the time of award. However, during the initial year of administering a federal award as fiscal agent, the procedures outlined in the policy were not fully operationalized. This resulted in a misapplication of the approved indirect cost rate. The overdraw resulted from applying the indirect cost rate to budgeted, rather than actual, direct expenditures. Management has since recalculated allowable indirect costs based on actual expenditures and has implemented enhanced controls to ensure accurate application of the MTDC base and compliance with federal requirements going forward. Response, with details: ☒Corrective Action Plan ☐Clarification Management acknowledges the misapplication of the approved indirect cost rate and has taken immediate steps to correct the calculation and ensure full alignment with federal requirements. Specifically, The EPI Center has recalculated indirect costs based on allowable expenditures within the Modified Total Direct Cost (MTDC) base and is actively engaging with the U.S. Department of Education to determine the appropriate resolution of the overdrawn amount. Management confirms that all underlying expenditures charged to the program were allowable, allocable, and supported by appropriate documentation, and no unallowable costs were identified. Corrective Actions Management has implemented the following corrective actions to address the issue and strengthen internal controls: 1. Training and Capacity Building (Completed - April 2026) Finance staff and senior leadership have completed targeted training on the application of indirect cost requirements under Uniform Guidance to reinforce compliance expectations. 2. Recalculation and Resolution of Overdraw (Implementation Initiated) The EPI Center has recalculated allowable indirect costs by applying the restricted 8 percent indirect cost rate for Teacher and School Leader Incentive Program (TSL) grants to actual expenditures incurred during the reporting period. The program officer has been informed of the miscalculation and resulting overdraw. The EPI Center will follow all applicable agency protocols upon receiving formal guidance from the U.S. Department of Education. Management is actively coordinating with the U.S. Department of Education to resolve the calculated overdraw and will comply with all agency guidance, including repayment of any amounts determined to be unallowable. Controls are now in place to ensure that all future drawdowns are calculated based on the approved indirect cost rate applied to the MTDC base and are subject to documented review prior to submission. 3. Standardized Indirect Cost Calculation Worksheets (Completed - April 2026) A standardized indirect cost calculation worksheet will be required and reviewed prior to approval of all drawdown requests. 4. Independent Oversight (Completed – June 2025) The EPI Center has engaged a third-party controller who will review and independently validate indirect cost calculations prior to submission, providing an added layer of oversight and control. Responsible Party: Finance and Compliance Manager, Third-party Controller, CEO Timeline for Completion: May 2026

2024-003 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA011008 and 2019 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness Management’s or Department’s Response: Imperial County Workforce Development Office (ICWDO) agrees with the finding. Views of Responsible Officials and Corrective Action Plan: The questions from finding 2021-008 relate to a formalization of the fiscal processes and protocols. ICWDO operates under WIOA guidelines and follows Imperial County’s fiscal policies. Internal policy will be formally updated to reflect compliance with WIOA regulations, as well as Imperial County policies. These policies will include formal controls and procedures to evaluate each subrecipient’s risk of noncompliance. Once the formal procedure is drafted, it will go through the ICWDO Policy Committee for comment and direction, and then finally reviewed and approved for implementation by the full Workforce Development Board. Additionally, for any future Memorandums of Understanding (MOUs) between this Imperial County department and any outside agency, there will be an additional step to include review by Imperial County Counsel to reflect that recital around the funding source will specify the following required information: • Federal Award Identification Number • Federal award date of award to recipient by the Federal agency • Name of Federal awarding agency • CFDA Number • Specific identification of whether the award is research and development ICWDO will develop internal policies for formalizing all subrecipient monitoring process. ICWDO operates under WIOA guidelines for monitoring; therefore a formal internal policy for future contracts will be developed and implemented using the usual review and approval procedures followed by the department. ICWDO will develop a formal internal documentation system, with appropriate checks and signatures, for the evaluation and assessment of each subrecipient’s risk of noncompliance. ICWDO will utilize this formal process to properly document the risk assessment of all subrecipients. ICWDO anticipates to implement the corrective action by December 31, 2025. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2025

Finding Reference: 2024-006 Finding Title: Indirect Cost Rate Pool, Noncompliance and Significant Deficiency CAP Contact Persons: • John Morris, Chief Financial Officer, Financial Affairs, (312) 322-6420 • Alan Ochab, Senior Director, Budget Management & Analysis, (312) 322-1519 Planned Corrective Actions: 1. Correction Adjustment: Management has communicated to its consultant, Maximus, its expectation that the final 2026 indirect cost rate report will incorporate an adjustment to remove the disallowed expense related to the unallowable tax penalty for all affected 2026 rates. Metra will not authorize submission of the final report to the Federal Transit Administration (FTA) until the Finance team confirms that the adjustment has been appropriately reflected and its impact fully evaluated. The adjustment, including relevant background information and its general impact on the rates, will be disclosed in the transmittal letter submitted to the FTA with the final report. 2. Independent Review Controls: Management will strengthen internal review controls by implementing a secondary review of the indirect cost rate data, including consulting with Internal Audit to improve review procedures. This review will verify that costs included in the indirect cost pool are allowable, reasonable, and adequately supported in accordance with 2 CFR Part 200, prior to submission to the Federal Transit Administration (FTA). Anticipated Completion Date: 09/30/2026

We have developed a communication procedure that any such project documents that are provided to the City of Vermilion Service Department or City Engineer reflecting revenue and/or expenditures related to work conducted in the City of Vermilion will be promptly provided to the Finance Office for any transaction recording required to have the dollars accurately reflected on our financial statements. This would include road work, water, waste water, storm water or other future project areas that may be included. Once received in the Finance Department, the funding status will be verified to determine if federally sourced. All federally sourced projects will be promptly recorded as revenue or expenses of the city as well as included on the SEFA for the year in question.

Finding Number: 2024-004 Anticipated Completion Date: March 31, 2026 Responsible Contact Person: Brad McCain, Chief Financial Officer Planned Corrective Action: Management has implemented procedures to verify vendor eligibility for federally funded programs in accordance with suspension and debarment requirements. These procedures include documenting SAM.gov verification or obtaining vendor certifications prior to payment for federally funded transactions and retaining evidence of verification. Finance and procurement staff will be trained on these requirements, and compliance will be monitored through periodic internal review.