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

Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding. LYRIC will take the following corrective actions: (1) immediately correct the indirect cost rate applied to the HUD award and all future grant budgets to ensure it does not exceed the 10% rate; (2) work with HUD to address the $48,814 overcharge and determine the appropriate remedy, including offsetting other legitimate expenses against the overdrawn amount as necessary; (3) document the organization's elected indirect cost rate and methodology in each grant's budget file and award documentation; (4) evaluate whether to pursue a new NICRA through the cognizant federal agency if a rate above 10% is needed to accurately recover indirect costs with future grants; and (5) provide specific and targeted training to concerned staff on indirect cost rate rules, MTDC calculation, and Uniform Guidance compliance. Responsible Official and Position: Ana Rubio, Director of Finance, and Laura Chavez, Contracts Manager Expected Implementation Date: July 1, 2026

1. Person Responsible: County Auditor-Controller 2. Corrective Action Plan: The County agrees with the finding and recommendation. The County has drafted policy and procedures for subrecipients. In addition, the County has drafted a subrecipient agreement template to identify subrecipients based on criteria in § 200.332. The County will provide a comprehensive training to program managers to implement the monitoring program and subrecipient agreement template. In addition, the County will include direction to project managers to review current awards to identify existing subrecipients that were not provided a subrecipient agreement with all of the required elements from CFR § 200.332. 3. Anticipated Implementation date: June 30, 2027

The School District will review the Uniform Guidance requirements and ensure all expenditures are accurately reported on the School District’s Schedule of Expenditures of Federal Awards.

Finding Number 2024-094 Subject Heading (Financial) or AL no. and program name (Federal) 97.036 – Disaster Grants – Public Assistance Planned Corrective Action To address this finding, OEM will strengthen its review procedures for the SEFA by implementing a documented review process to verify the accuracy and completeness of information provided by ABS. OEM will coordinate with ABS to obtain and retain sufficient supporting documentation for amounts reported on the SEFA and will work with ABS to resolve any discrepancies identified during the review process. In addition, OEM will ensure staff responsible for reviewing the SEFA receive additional guidance and training on SEFA reporting requirements. These actions are intended to improve the accuracy and reliability of future SEFA reporting and strengthen compliance with applicable federal requirements. Anticipated Completion Date SFY26 Reporting Period Responsible Contact Person Brianna Thomas

Finding Number 2024-025 Subject Heading (Financial) or AL no. and program name (Federal) 93.658 – Foster Care Planned Corrective Action Oklahoma Human Services (OKDHS) concurs with the recommendation. OKDHS has been working to centralize and strengthen its contract and subrecipient monitoring processes to improve consistency in the identification, documentation, risk assessment, and monitoring of subrecipient relationships across the agency. As part of this effort, OKDHS is updating its procedures and standardized documentation to better ensure that subawards include required federal award information, program responsibilities and deliverables are sufficiently defined, required documentation is obtained and retained, and subrecipient risk assessments and monitoring activities are completed and documented consistently. OKDHS will implement updated, centralized contract and subrecipient monitoring procedures, including standardized tools and documentation requirements designed to address the conditions identified in the finding. The updated process will clarify responsibilities for documenting subrecipient risk assessments, required federal award information, contractual requirements, deliverables, and ongoing monitoring activities. Anticipated Completion Date 9/30/2026 Responsible Contact Person Kayla Urtz

Finding Number 2024-016 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; #84.425U) Planned Corrective Action The agency acknowledges that certain ESSER II and ARP ESSER III claims were approved without adequate review of supporting documentation by authorized claims reviewers. To address this finding, the agency has strengthened its claims review procedures and internal controls related to reimbursement processing. Additional training will be provided for all claims reviewers regarding: • allowable use of funds requirements, • supporting documentation standards, • verification of invoice documentation, • program coding requirements, and • review and approval expectations for federal claims. The agency will also implement enhanced supervisory review and monitoring procedures to help ensure claims are consistently reviewed in accordance with federal requirements prior to approval. The agency acknowledges that allocation notices were not consistently generated and provided to certain LEAs in accordance with the requirements of 2 CFR § 200.332(a)(1). Additionally, one allocation notice did not contain all required elements, including the Federal Award Identification Number (FAIN) and Federal award date. Although the audit confirmed that allocation amounts and approved budgets within the grants management system were accurate, the agency recognizes the need to strengthen procedures related to issuance and documentation of subrecipient award notifications. To address this finding, the agency will revise and strengthen internal procedures to ensure all required allocation notices are generated, maintained, and distributed timely and consistently to subrecipients. The agency will also coordinate with our third party vendor to implement additional quality control measures and staff training to ensure all required federal award information, including the FAIN and Federal award date, is included in future allocation notices in accordance with 2 CFR § 200.332 requirements. Anticipated Completion Date Sept-26 Responsible Contact Person Tammy Smith

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.

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