Corrective Action Plans

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

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.

Finding Number: 2024-005 Planned Corrective Action: The Special Projects Manager will ensure the County does not charge Indirect Costs in excess of the de minimis rate of 10 percent of modified total direct costs. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Philip Schaffer, Special Projects Manager

In response to the previous audit finding, CDPH submitted the required risk assessment as of January 2025, along with supporting documentation. Moving forward, CDPH will establish formal procedures to ensure that all required federal award information – such as the Assistance Listings Number, Title, and FAIN – is clearly identified in all agreements with subrecipients. Estimated Implementation Date: March 2026 Contact: • Melissa Relles • Assistant Deputy Director • Center for Preparedness and Response

Corrective Action Plan: Management is in the process of working with HHS to renew the Provisional Rate agreements. The anticipation is that the agreement will be completed by the end of 2025. Anticipated Completion Date: December 31, 2025

MATERIAL WEAKNESS Preparation of Schedule of Expenditures of Federal Awards Recommendation: We recommend the School implement internal controls over SEFA including a reconciliation and review process before submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action Planned/Taken : Management agrees with the finding and has created and filled the position of Manager of Grants Management. This staff member will be responsible for the oversight and management of all grants, including the SEFA. Additionally, the School has contracted with an outside firm that specializes in State Board of Accounts compliance, as well as Federal Award Compliance in line with Uniform Guidance. The firm will assist in the development of the required Internal Controls and Processes, with an estimated completion date is December 31, 2025.

FINDING 2024-003 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Subrecipient Monitoring Contact Person Responsible for Corrective Action: Gretchen Parker Contact Phone Number and Email Address: 765-648-6113 gparker@cityofanderson.com Views of Responsible Officials: "We concur with the finding." Description of Corrective Action Plan: The city has several individuals involved in the monitoring of activities related to the COVID 19 Coronavirus State and Local Fiscal Recovery federal award. The city has implemented procedures to ensure oversight and review of subrecipient reports is properly documented. Anticipated Completion Date: September 1, 2025

The staff has reviewed the Uniform Guidance requirements and has developed a standardized worksheet will be used for each reimbursement request, and all calculations will be reviewed by management prior to submission. All future correspondence with EDA regarding indirect costs will be documented in writing. Implementation of the worksheet has commenced.

Conservation and Rehabilitation of Natural Resources on Military Installations – Assistance Listing No. 12.005 Recommendation: CLA recommends additional internal scrutiny and controls surrounding applicable compliance requirements when there is a change in policies and procedures, such as the change in effective indirect cost rate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Ecostudies’ policy has always been to use the NICRA rate at the start of an agreement (or when we start working on the project) through the course of the agreement/task order’s performance period, even when a NICRA rate changes during the performance period. This policy was based on discussions with other non-profit organizations with federal awards. During the FY 2024 audit we raised this issue with CLA to receive clarification and guidance. Our understanding from that discussion was that CLA agreed that our policy was acceptable and appropriate. Our corrective action will be to work with each federal partner to ensure there is clear documentation of the direct and indirect costs in the agreement. Name(s) of the contact person(s) responsible for corrective action: Gary Slater Planned completion date for corrective action plan: 10/1/2025

Type of Finding: Significant deficiency in internal controls over the calculation of Modified Total Direct Costs puts CCS at risk of an overallocation indirect costs to federal programs. View of Responsible Officials: Management accepts this finding. Effective internal control over the calculation of Modified Total Direct Costs ensures that costs are allocated correctly to programs. Training of staff and increased review over allocations would likely have prevented this error. Corrective Action: CCS will be setting up a new form to calculate the Modified Indirect Cost Rate that each division will be required to use for all contract billings that are using the de minimis indirect cost method. The indirect costs charged to each contract will be reviewed semi-annually for accuracy and consistency.

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. As of July 1, 2025, the approved staff allocations are being uploaded into ADP in the anticipation of a direct link between ADP and the NetSuite general ledger so that personnel costs will be allocated automatically 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.

FINDING 2024-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Contact Person Responsible for Corrective Action: Debra Carnes Contact Phone Number and Email Address: 317.477.1105 Views of Responsible Officials: We concur with the audit finding and will enhance our internal controls and procedures for subrecipient monitoring. Specifically, we will: Corrective Action Plan for Finding 2024-001 l. Include the Assistance Listing Number (ALN) and Federal Award Identification Number (FAIN) in subaward agreements. 2. Verify that subrecipients have been audited as required. Implementation Timeline We will update our written internal controls by August 29, 2025, to reflect these enhancements. Current Status We have already verified that our subrecipient has been audited, and to the best of our knowledge, there are no findings related to ARPA funding. Sincerely, Debra A. Carnes Hancock Co. Auditor

Corrective Action Plan for Current Year Findings Grantee Name: Maine Community Action Association d/b/a Maine Community Action Partnership (MeCAP) Federal Program: AL 93.647 – Social Services Research and Demonstration Finding Reference: 2024-001 Type of Finding: Material Weakness in Internal Control Over Compliance and Material Noncompliance with Subrecipient Monitoring CFDA Number: 93.647 Award Numbers: 90XP0450-01-05 and 90EDA0019-01-00 Fiscal Year: 2024 Finding Summary: The auditor identified that subrecipient agreements under the 93.647 program did not include all elements required by 2 CFR §200.332(a), and that MeCAP lacked a documented procedure for obtaining and reviewing subrecipient audit reports. Corrective Action Plan: 1. Subaward Template Revision MeCAP will revise its standard subrecipient agreement template to include all Uniform Guidance–required elements as outlined in 2 CFR §200.332(a), including but not limited to: • Federal Award Identification (FAIN, ALN, federal agency name) • Period of performance and budget • Federal award project description • Indirect cost rate (including identification of the de minimis rate, if applicable) • FFATA reporting requirements • R&D identification (if applicable) • Contact information for the awarding official A revised template will be implemented and used for all active and future subawards beginning July 15, 2025. 2. Subrecipient Audit Review Procedures MeCAP will implement a formal policy and internal control procedure to: • Obtain and review the Single Audit reports of all subrecipients who expend $750,000 or more in federal awards annually; • Use the Federal Audit Clearinghouse and/or direct communication with the subrecipient to obtain the report; • Review audit findings for relevance to the MeCAP-administered program and assess any required follow-up or risk mitigation actions; 240 Bates Street | Lewiston, ME 04240 • Document this review in the subrecipient’s monitoring file. The procedure will be included in the Organizational Policies and Procedures Manual and communicated to all program and fiscal staff by August 15, 2025. 3. Training and Internal Communication Program and finance staff responsible for subrecipient oversight will participate in a training session covering: • Uniform Guidance subrecipient monitoring requirements • Changes to the subaward template • The audit review protocol Training will be conducted internally or through a third-party training provider by September 30, 2025. Person(s) Responsible: Executive Director, MeCAP Lawrence Rugg Contracted Fiscal Management, Fiscal Innovations Inc. Expected Completion Date: September 30, 2025

Federal Award Finding: 2024-002 Material Weakness in Internal Control and Noncompliance – Allowable Costs/Cost Principles: Indirect Costs Name of Individual Responsible for Corrective Action: Sara Kinjo-Hischer, Tribal Administrator Corrective Action: Skagway Traditional Council will work closely with the contract accountant to ensure that indirect costs charged to each grant are within the grant’s budget and are in accordance with the terms and conditions of each grant award and with Uniform Guidance. Planned Completion Date: September 30, 2025

This discrepancy resulted from a lack of understanding by the CFO in processing grant related funding. Grant policies have been updated, and personnel trained to direct and understand the role of independent accounting by funding sources through class codes. Anticipated completion date: 8/31/25. Responsible contact person: John Carroll, CFO

2024-001 Research and Development Cluster – Education Innovation and Research (formerly Investing in Innovation (i3) Fund – Validation Grants) Assistance Listing No. 84.411A Condition: For both subawards selected for testing, the identification of the contact information for the awarding agency was incorrect. The contact information was Education Analytics, Inc., the Organization’s grantor, but should have been Future Forward, Inc. Further, one of the two subawards selected for testing had information missing from the subaward including all requirements for the award to be used in accordance with Federal statutes, regulations and terms and conditions of the Federal award. We consider this condition to be an instance of noncompliance relating to the Subrecipient Monitoring compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: Future Forward will re-issue contracts/MOUs for its two subawards with the correct awarding agency listed (Future Forward instead of Education Analytics). In addition, Future Forward will include requirements for the award to be used in accordance with Federal statutes, regulations and terms and conditions of the Federal award in the revised contracts/MOUs. Responsible Person for Corrective Action Plan: Kate Bauer-Jones, Executive Director Implementation Date for Corrective Action Plan: May 15, 2025

Internal Control Over Compliance Recommendation: We recommend that the organization implement additional review process over the rate determination to ensure it is being calculated correctly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Daycare Director will review all parent fee calculations with signed approval, beginning upon enrollment of the student and, annually, for as long as they remain enrolled at AELC. Name(s) of the contact person(s) responsible for corrective action: Michelle James Planned completion date for corrective action plan: May 23, 2025 f the State has questions regarding this plan, please call Michelle James at (203) 744-4700.

Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Auditee’s Corrective Action Plan: The city’s legacy financial system did not collect data required for SEFA. Agencies had to provide most details manually and work between spreadsheets and multiple systems to input and track receipt grant awards and spend on personnel, supplies and services and sub-recipient awards related to grants. The steps to address this legacy finding have been phased and include the technology implementation, staff training and additional oversight. As noted, the City implemented Workday, an Enterprise Resource Planning (ERP) system, across workstreams so that Financial Accounting, Grants, Procurement, Supplier Accounts, Banking, Payroll and Human Resources are all in one system. As with any ERP, an ongoing process of evaluation and updates are needed to continuously align workflow and business processes. This approach has led to continued improvement over the years as the grants management module is fully implemented in Workday. Since implementation, additional enhancements have been adopted and utilized with a robust workflow process for grant approval, grant budget tracking, and invoice scheduling. In addition to the technology adoption, an increase in citywide grants training and oversight has been implemented. The progress is detailed below: • FY 23 represented the first year in the new system. To compile the SEFA, the City used a hybrid approach to leverage Workday and Agency provided data. o There were some data accuracy challenges from data entry errors. To address those data entry challenges the award modification business process was improved post-implementation to add a GMO review and approval step of award modifications. o As of May 2024, all award modifications now require centralized GMO review to verify data accuracy. o Additional process changes in FY 23 included implementation of the requirement as part of the FY 24 budget preparation process that grant worktags must be created and budgeted for during the City’s annual budget process. The grant worktag creation process includes approvals at the agency program and fiscal levels, as well as at the Department of Finance level. • In FY24 further Award Module enhancements were adopted to provide key new data points in Workday. o Each grant award now includes information: Federal Assistance Listing Number (fna CFDA#), Passthrough Agencies & Passthrough Identifier. o Additionally, in FY 24, GMO, in collaboration with BAPS launched the Grants Workstream Training sessions. These monthly citywide virtual live trainings are on a variety of grant management related topics, averaging 60 attendees per session. Attendees are city agency grant managers and city agency fiscal staff. • In FY 24 and FY 25 the topics covered included: o FY 24 Grant Work tag Preparation o FY 24 SEFA Preparation o Grant Accounting Best Practices and Workday Billing o Award Set-up Best Practice & Potential Pitfalls o Extra Features in Workday (including reporting and how to set up award tasks and deadlines) o Subrecipient Monitoring Best Practices o Cost-reimbursable grant invoicing in Workday o FY 25 SEFA preparation o FY 26 Grant Work tag Preparation o Grant Management Roles and Responsibilities o Specific training on the SEFA, including information on understanding the importance of the SEFA, what information is included and how to review SEFA data, was conducted. Citywide training sessions were held in FY 24 and FY 25 to ensure that the reporting is understood by city agencies, with special emphasis on subrecipient payments being reported properly. The training schedule is ongoing and continuous. • To improve SEFA reporting data, in FY 25 there is an emphasis on subrecipient set up and spending to ensure that functionality is refined to improve uniformity in subrecipient set up. GMO, in conjunction with BAPS, the Bureau of Procurement and city agencies will work to refine subrecipient set up, spending and monitoring, including improved reporting. o GMO has hosted three subrecipient monitoring and management–related trainings since December 2024. Additionally, to improve subrecipient managing and monitoring, GMO modified the award setup business process in Workday to include verification of subaward status before final award setup approval. In FY 25, GMO provided training on how to setup subawards accurately in Workday. As discussed above, these trainings will be ongoing. • Additionally, GMO and the BBMR will collaborate on a subaward dashboard to monitor subrecipient spending data in real time. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City Completion Date: FY26 3rd Quarter- • Design and complete a grants management dashboard within Workday • Ongoing and continuous - GMO will continue to conduct trainings on SEFA reporting and subrecipient management and reporting.

Corrective Action Plan: The identified conditions relate to the proper application and calculation of indirect cost rates for federal research grants. Further items relate to the assignment of the proper fringe rate for federal research grants. To mitigate future occurrences of possible incorrect rates applied to such contracts, the College has strengthened its internal controls and oversight by reviewing and reperforming calculations. Timeline for Implementation of Corrective Action Plan: These corrective actions were implemented by spring 2025.

Views of Responsible Officials: Federal grant requests and reporting is the function of three teams: Programs, Development and Finance. Prior to the hiring of the VP-Finance, the Associate Director, Grants Management and Compliance met with the Associate Director, Partnerships on a quarterly basis to discuss required program spend reimbursements and projected program cash needs prior to submitting the formal requests. With the onboarding of the new VP-Finance, internal review processes were changed to incorporate more robust segregation of duties, alignment with the internal cash management policies and procedures and formal review of drawdown requests prior to submission. The VP-Finance became a permanent employee in October 2024 and since then all submissions have obtained the appropriate approval prior to submission.

View of Responsible Officials and Corrective Action Plan We acknowledge the findings and appreciate the diligence of the audit team in identifying the discrepancies in our indirect cost calculations and reporting as outlined in the draft findings. The Veterans Integration Center (VIC) is committed to maintaining the highest standards of compliance with all federal regulations and grant requirements. Corrective Action Plan 1. Training and Guidelines: All relevant staff will undergo training to understand and implement the correct procedures for calculating indirect costs. Comprehensive guidelines will be developed and disseminated to ensure consistency across all calculations and reporting. 2. Completion of SF-425 Jointly: The COO, and VIC’s contracted Accountant will confirm the accurate Modified Total Direct Costs (MTDC) which is to be used in completing the SF-425, then prepare the GPD SF-425 jointly to ensure its accuracy. 3. Review and Approval Process: An additional layer of review and approval will be established for all indirect cost calculations before they are reported. This step will involve our Chief Executive Officer (CEO) to ensure accuracy and compliance. Corrective Action Plan Timeline • Staff Training and Guidelines Distribution: Completed by Q4 2025 • Completion of SF-425 Jointly: Starting Q3 2025 with SF-425 revision • Review and Approval Process: Effective immediately, with CEO, reviews starting Q3 2025 Designation of Employee Position Responsible for Meeting Deadline The Chief Operating Officer (COO) will be responsible for the oversight and successful implementation of the corrective action plan. The COO will coordinate with the contracted internal Accountant to ensure all actions are taken within the stipulated timelines and report directly to the Chief Executive Officer on the progress.

Effective August 2023; new sub-awards and pass thru grant agreements have elements specified in the respective agreement as required by Uniform Guidance, Part 200.332. In addition, Iowa Workforce Development is in the process of reaching out to grantees whose awards did not clearly state that the specified award is research and development, and that there will be no indirect costs assumed for reimbursement, as this was assumed given the nature of the projects as well as discussions that were had during the awarding process.

Effective late fiscal year 2024; new sub-awards and pass thru grant agreements utilize a cover sheet to ensure all required elements listed in 2 CFR 200.332 are clearly included in the subaward agreements.