Corrective Action Plans

Condition: The fiscal year 2025 schedule of federal expenditures of federal awards (SEFA) that was initially provided to the auditors included payroll and fringe expenses that were incorrectly coded to the grant. Planned Corrective Action: The Agency agrees with the recommendations above and will implement a process to ensure that a reconciliation of the listing of grant eligible employees to those employees that were being coded to the Special Education Cluster in the general ledger is performed. Contact person responsible for corrective action: Emily Herbert, Director of Business and Finance Anticipated Completion Date: June 30, 2026

Finding 2025-001: Head Start Cluster Semi-Annual Certification Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Number: 93.600 Award numbers: 05CH011882-04, 05CH011882-05 Award year ends: November 30, 2024 and November 30, 2025 Recommendation: The School District should provide training to educate all employees working in federal programs of the requirements for verifying program employee listings are complete under Uniform Guidance, and the School District should require proper time-and-effort documentation to be timely reviewed and approved by the appropriate program supervisor. Action Taken: The Business Manager will provide semi-annual certification templates to all program directors. The Business Manager and program directors will review staff listings together to ensure all necessary employees are listed. Training on the certification process will be provided to all directors of federally funded programs. All federally funded salaried employees are required to complete certifications twice each year. The first submission is due to the Business Manager by January 15, and the second is due by July 15. The Business Manager will verify and maintain all certification records. Responsible Person and Anticipated Completion Date: Business Manager, November 2025 If the Michigan Department of Education has questions regarding this plan, please call CJ Van Wieren at (231) 893-1005.

Improper Time & Effort Reporting Condition: 2 CFR 200.430 of the Uniform Guidance mandates that personnel compensation charged to federal awards must be based on records that accurately reflect the work performed. When an employee works on multiple cost objectives (e.g., multiple awards or activities), this often necessitates the use of personnel activity reports or similar timekeeping documents to accurately allocate salaries and wages. During the audit, we found that proper personnel activity reports were not being maintained for multiple cost objective employees charged to Title IV and to the Special Education Cluster. While we were able to support that the amounts charged to the grants were reasonable, through review of the employee's Outlook calendars, daily schedules, etc., the documentation required by federal guidance was not available. We recommend that management provide training to all multiple cost objective employees on how to properly document their time and then to Implement oversite procedures requiring that those personnel activity reports be submitted to management for review on a monthly basis. Corrective Action: The District has begun training all staff and grant Directors on the proper documentation required to properly support the time and effort employees spend on various grants. In addition, the Grant Director will begin reviewing this documentation on a periodic basis, to ensure complete compliance. Contact Person Responsible for Corrective Action: Chanda Cleaves, Executive Director of Finance Completion Date: This issue will be corrected moving forward.

Admin Offices 4301 S Cowan Rd Muncie, IN 47302 765-747-5222 office CORRECTIVE ACTION PLAN OF CURRENT AUDIT FINDINGS June 30, 2025 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Context: During testing of allowable activities and costs, it was observed that the School Corporation allocated payroll and benefit expenses to the school lunch fund for the employee overseeing the food service management company. Five payroll transactions totaling $5,476 were selected for testing. For each transaction tested, the School Corporation allocated 18% of the employee’s time to the school lunch fund. Although the employee completed an annual self-certification estimating time spent on food service duties, there was no detailed time and effort log to support actual hours worked. Additionally, no internal control existed to provide a documented secondary review of the self-certification for accuracy and completeness. Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: 765-747-5222 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will no longer charge any payroll and benefit expenses to the school lunch fund. Anticipated Completion Date: July 1, 2025.

2025-002 – Lack of Written Policies and Procedures. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Village. As a result of this condition, the Village did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Village review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Village has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Village Council before the end of fiscal year 2026. Responsible Person. Vicki Burrell, Village Clerk. Anticipated Completion Date: February 2026.

To safeguard from future errors and ensure data accuracy, Human Resources partnered with Enterprise Application Services department to develop an automated process that populates earnings codes and project account codes based on employee, job record and earnings code. This enhancement streamlines data entry by consolidating it into a single interface, reducing the risk of manual entry errors. Additionally, the HR Technology Manager has implemented a new monitoring report to track employees with multiple salary distribution accounts as a part of payroll process. The biweekly report will be automatically generated and sent via email to HR’s HRIS Consultants for review. The HRIS Consultants will analyze the report, resolve any discrepancies and escalate any issues to the HR Technology Manager or Lead Application Consultant as necessary. These processes will be routinely reviewed, with adjustments made as needed.

Develop and Implement Comprhensive Written Policies and Procedures. We will revise and formalize internal controls that address all major federal compliance area, Including: -Allowable/unallowable costs - Time and Effort reporting-Payroll allocations-Prior Approvals-Subrecipeint Monitoring -Grant Closeout. Going forward, we must be sure to follow the rules in OGAPP Manual 100.3, B2.4 Personnel Costs, which states that even though costs of overtime/bounsus are chargeable to federal grants, they are only allowable to the extent that the costs comply with certain guidelines. For bonuses, they are limited to 3% of an employee's gross wages (not including fringes) or $1,500, whichever is less. The Ohio Department of Health (ODH) program administrator must approve all bonuses and enter a comment in GMIS in the project comments section.

Condition: ALC has not implemented all policies and procedures required by 2 CFR Part 200, specifically for cash management, allowability of costs, procurement, compensation, and fringe benefits. Planned Corrective Action: The American Loggers Council will develop written policies and procedures to comply with 2 CFR Part 200, specifically for cash management, allowability of costs and procurement. Policies and procedures related to compensation and fringe benefits currently do not apply to the Organization because they do not have any employees. These policies and procedures will be reviewed and approved by the executive director and executive committee. Contact Person: Scott Dane Anticipated Date of Completion: December 2025

Corrective Action Planned: In July 2023, the Organization implemented ADP Work Force Now to systematically capture hours worked, the supervisor's approval and audit trail to reflect the work performed. Budget and Grants in conjunction with the program and Human Resources will implement a hindsight review of employee working hours with a certification by the employee and supervisor. Name(s) of Contact Person(s) Responsible for Corrective Action: Betsey Knapp, Director of Budgets and Contracts: Alvin Sinckler, Chief Financial Officer Anticipated Completion Date: November 15, 2025.

Finding Number: 2024-038 Audit Type: Single Audit Finding Title: Inadequate Documentation of HIDTA Personnel Costs Related Finding: 2024-026 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will implement timekeeping procedures and maintain documentation to support HIDTA personnel costs charged to the grant. 3. Anticipated Completion Date September 30, 2026 - plan in place 4. Management's Response Management concurs and will ensure compliance with federal documentation standards. 5. Status of Prior Year Finding This is a new finding.

Finding Number: 2024-039 Audit Type: Single Audit Finding Title: Inadequate Oversight of Davis-Bacon Compliance Related Finding: 2024-010 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will establish a monitoring process to verify contractor compliance with Davis-Bacon wage requirements, including certified payroll reviews. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will ensure oversight responsibilities are clearly assigned and documented. 5. Status of Prior Year Finding This is a new finding.

2024-1 Payroll Allocations Contact Person - Shannon MacKenzie, Director of Finance Description of Corrective Action - The School’s new Director of Finance will continue to work closely with the Deputy Head of School to ensure that payroll and other expenses are being charged correctly to our grant funding. We will ensure that the expenses for the grants are reviewed monthly and will make the correct adjustments on a timely basis to ensure that the grants are charged for the correct amounts based on the grant documents. The Director of Finance will also make sure that the time and efforts match the payrolls and that the changes in the payroll are updated on a timely basis. Completion Date - June 30, 2025 Root Cause - Turnover in the Director of Finance position

Views of Responsible Officials: We agree with the auditor’s findings and recommendations. Intacct allows for the automatic allocation of salaries to grants directly which provides us with much better records. ADP Workforce now will put all the appropriate approvals in place, both employee and supervisor. We are discussing the right method for project-specific timesheets, but think that biweekly forms for staff to fill out are the best route. Staff would check off grant-allowable activities that they engaged in and then note the hours allocated to those activities.

Corrective Action Plan: The Organization will implement a formalized process for the review and approval of payroll transactions, including the allocation of payroll costs to grants. We will do this by adding the proper software tools in place within our financial accounting software. This process will also involve establishing clear guidelines outlining the steps for reviewing and approving payroll transactions to ensure accuracy and compliance with grant requirements and financial processes. Designated personnel, the finance manager, will be assigned the specific responsibility of preparing payroll and the CEO will review the payroll report and sign off prior to payroll execution. This will be in the system of documented processes to track and document these approvals as well as written within the policies and procedures handbook. Anticipated Completion Date: November 30, 2025

Recommendation We recommend that the Organization consistently enforce its internal controls over payroll to ensure that timesheets are reviewed and approved by the appropriate supervisor and ensure that they agree to the payroll register. Repeat Finding Yes Action Taken The staff accountant does the payroll. We save a backup timecard report each payroll that we are paying from the approved by the employee's supervisor. We also have an internal worksheet that we use to document any changes that are made. Once the accountant is done with her review the controller will do the second review before we finish processing the payroll enforcing internal controls that are in place and being followed.

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Quincy, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: CBIZ CPAs P.C. 53 State Street, 17ᵗʰ Floor Boston, MA 02109 Audit period: July 1, 2023 through June 30, 2024 The finding from the June 30, 2024, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Financial Statement Finding Finding 2024-001: Certain Department Expenditures Exceeding Appropriated Amounts – General Fund – Significant Deficiency Condition: During 2024, it was noted that expenditures in the public safety and education functions exceeded the amounts appropriated by the City Council for the fiscal year. Criteria: Massachusetts general law prohibits the City from incurring liabilities in excess of appropriations in each department with certain specific exceptions, such as snow and ice removal costs, state and county charges, and debt service. Prudent budgetary control and monitoring are essential to ensure compliance with such requirements. Cause: The overspending of these appropriations occurred due to an inadequate internal control system to ensure timely budget amendments. Effect: Overspending appropriations in the General Fund constitutes noncompliance with state law and exposes the City to potential fiscal consequences, as the state may require the City to raise such deficits in the subsequent fiscal year. It may also indicate a weakness in the City's internal controls over budgetary compliance. Recommendation: We recommend that City management strengthen internal controls over budgetary compliance. Management should strengthen its’ procedures throughout the year to monitor budget-to-actual expenditures and ensure timely action, such as requesting formal budget amendments when actual expenditures approach or exceed authorized appropriations. Views of Responsible Officials: The Municipal Finance Office will be implementing procedures to ensure that the Municipal Finance Office and relevant department heads document reviews of budget to actual reports monthly throughout the year, with increased review intervals during June. The purpose of this increased monitoring is to ensure that potential budgetary appropriation deficits are identified in a timelier manner that will allow for any necessary budgetary amendments to be approved by the City Council. Finding 2024-002: Information Technology Controls in Financial Statements – Significant Deficiency Condition: During 2024, we noted the following deficiencies relating to information technology controls in the financial statement reporting process: • User Access Mirroring: When new users are provisioned in the accounting system, access rights are often “mirrored” from existing users without sufficient review of job responsibilities. This practice results in users receiving access to system functions beyond what is necessary for their roles and may compromise segregation of duties. • Privileged Access: A review of privileged user listings indicated access accounts with no exclusionary parameters. • Inadequate Controls Over System Upgrades: When implementing accounting system upgrades, controls over change management including testing, documentation, and approval, were not adequately designed or consistently applied. Instances were noted where upgrades were implemented without thorough pre-deployment testing and formal approval from finance or IT management. Criteria: Best practices and standards for internal control require: • Role-based access provisioning aligned with users’ responsibilities and effective segregation of duties. • The use of exclusionary parameters enhances the ability to monitor system access for unauthorized access. • Robust change management controls over system upgrades, including testing, documentation, and management approval, to ensure system integrity and minimize the risk of errors or unauthorized changes impacting financial reporting. Cause: These deficiencies appear to result from a lack of formalized policies and procedures for user access provisioning and for managing and documenting accounting system upgrades. Effect: The deficiencies increase the risk of: • Unauthorized access or inappropriate transactions due to excessive or incompatible user rights, undermining segregation of duties and accountability. • Errors, omissions, or unauthorized changes introduced during system upgrades, potentially affecting the integrity and accuracy of financial data and financial statement preparation. Recommendation: We recommend that City management: • Implement procedures to provision user access based on individual roles and responsibilities, with documented review and approval to ensure segregation of duties is maintained. This should be evidenced by written approval that is approved by Municipal Finance and Information Technology office. • Enhance the current process of implementing accounting system upgrades, including requirements for comprehensive pre-deployment testing, clear documentation, and explicit written approval from the Municipal Finance Office and the Information Technology office, prior to going “live” with the upgrade. • Periodically review system access and upgrade processes to ensure ongoing compliance with internal control standards. Views of Responsible Officials: The City will keep these recommendations in mind as it works to upgrade its already existing best practice IT control environment. Finding and Questioned Costs – Major Federal Program Audit Criteria or Specific Requirement: Uniform Guidance section 2 CFR § 200.430(g) requires non- Federal entities to maintain records that accurately reflect the work performed by employees whose salaries are charged, in whole or in part, to Federal awards. For employees working on a single Federal program, semi-annual certifications are required to document time and effort. Condition and Context: During testing of 40 payroll transactions for employees charged to the Special Education program, the City was unable to provide semi-annual certifications supporting that salaries and wages were properly allocated to the grant. Cause: The City did not have adequate procedures in place to ensure that required time and effort certifications were retained and readily available for payroll charged to Federal awards. Effect or Potential Effect: Failure to maintain required time and effort documentation resulted in the questioned costs documented below. Questioned costs are reported as follows: AL Number: 84.027 Name of Federal Program or Cluster: Special Education Cluster Questioned Costs: $2,572,675 Recommendation: We recommend the City establish and implement procedures to ensure that semiannual certifications are completed, maintained, and reviewed for all personnel whose salaries are charged to Federal awards. Views of Responsible Officials: This is a questioned cost due to the School Department not having completed certain administrative paperwork, required by grant regulations. We have implemented procedures during FY2025 to address this matter. The required paperwork will be retained on file going forward.

Grantee Response and Corrective Action Plan: AVLF concurs with the recommendation. The Organization will take the following corrective actions: 1. Remit corrected timesheets to the Agency for information purposes. 2. Revise the organization’s policy to include review and reconciliation of SER’s and timesheets prior to submission to the Agency. Responsible Parties: Jason Levister, Controller Date to be Completed: October 2025

The audit finding was reviewed with the new assistant superintendent that oversees grants to ensure certifications are completed going forward. The SAU senior leadership team reorganized and moved the grant management responsibiltiies to a member of the senior leadership team.

Management agrees with the finding and will work with the City of San Antonio to correct the issue, and develop review procedures to respond to the finding.

To address the identified deficiency, SAAMS will revise its payroll procedures to require that all payroll batch reports consistently include employee name, program charged, amounts charged to each program, hours, and pay rate. A standardized reporting format will be developed to ensure completeness and consistency of information. In addition, SAAMS will update its policies to clearly describe the review objectives and responsibilities of staff conducting payroll reviews. Training will be provided to relevant staff to ensure proper understanding and execution of the updated procedures. These measures will ensure payroll reviews are accurate, effective, and aligned with best practices. Completion Date: September 30, 2026 Responsible Person: Dr. Wei Ying Wong, CEO, SAAMS

Management will evaluate systems and processes to ensure time tracking procedures meet the standards outlined in the Uniform Guidance.

Recommendation: We recommend that the Organization implement a system of internal controls that clearly documents the time and effort that each individual employee spends on each grant per month. This can be done by requiring every employee that works on a federal grant to charge their time to a specific grant charge code regardless of position. We recommend the Organization adopt a written policy and implement a system of internal controls to review and true-up grant wages to actual to ensure accuracy, allowability, and proper allocation of federal and non-federal time. There is no disagreement with the audit finding. Action taken in response to finding: We have updated both our time reporting policy in Chapter 1 and added time allocation to the Allowable Costs section of Chapter 2 Financial Policies of our Fiscal Program Management Policy Manual. Copies of both additions are attached. We updated the staff of these changes at our April 16, 2025 Team Meeting, the agenda of the meetingis attached. We have also included payroll summaries and timesheets to show we are allocatingtime accurately. Name(s) of the contact person(s) responsible for corrective action: Tracey Hunter Planned completion date for corrective action plan: 4/16/2025

Program Name - Temporary Assistance for Needy Families (TANF); Services for Trafficking Victims; Violence Against Women Formula Grants CFDA Number- 93.558 16.320, 16.588 Finding Type - Significant Deficiency and Noncompliance Condition and Description - During our procedures, we noted, the Agency did not properly allocate its employees' leave hours for employees working on multiple activities. For 13 out of 20 samples selected for testing, Controls were not in place to ensure that leave time was proportionately distributed based on actual time worked on each activity. YWCA Response - The YWCA Victim Services acknowledges this finding and has implemented the following corrective action plan to ensure compliance. Corrective Action Plan - No employee leave hours are to be billed to the TANF grant. The cost of employee leave will be borne by non-governmental grants for all Victim Service staff. Time Frame for Correction - Corrective action was implemented in April 2025. Individuals Responsible- Marcy Dix, Director of Grant management with oversight from Jodi Breithart, CMA, MAcc, Vice President of Finance.

2024-006 - Failure to Maintain Standards for Documentation of Personnel Expenses Auditor Description of Condition and Effect: During our testing of Allowable Costs, for all 12 disbursements tested we noted that the hourly rate charged under the grant was higher than the actual hourly rate noted in personnel files. As a result of this condition, the Organization did not fully comply with the Uniform Guidance by not charging the proper hourly rate to the grant. Auditor Recommendation: We recommend that the Organization use actual rates per approved compensation records when charging costs to the grants. Corrective Action: Management has established procedures to enhance and improve the controls related to payroll charges under the grant to ensure that the proper pay rate is charged. Responsible Person: Michael Young & Dora Gonzales Anticipated Completion Date: December 2025

2024-002 – Allowable Costs/Cost Principles Corrective Action: ABHS has implemented a new accounting and payroll system which allows the organization to reconcile employee benefit expenditures monthly. These systems were implemented in March and April of 2025 and management expects this finding to be resolved in 2025. Person Responsible: Alethea Velasquez, Chief Financial Officer Estimated Completion Date: December 31, 2025