Corrective Action Plans

Finding Number: 2025-002 Finding Name: Allowable Costs Finding Condition(s): During testing of allowable costs, we identified shared payroll and other costs charged to federal programs for which adequate support for the cost allocation methodology was not maintained. Specifically, allocation schedules and underlying documentation supporting how payroll allocation percentages were determined were incomplete or unavailable. As a result, we were unable to conclude that all sampled costs were allocated to the federal programs in proportion to the relative benefit received. Name of Contact Person(s): Mark Yates, Interim CFO, 312-479-5395 Corrective Action(s): Management will retain detailed allocation support and maintain its allocation methodology in accordance with applicable requirements. This documentation will be preserved to support the development and implementation of the management corrective action plan and to demonstrate consistency and compliance going forward. Anticipated Completion Date: May 31, 2026. Management agrees with the finding. The issue resulted from a system conversion and transition between payroll providers. Moving forward, management will ensure that appropriate documentation is consistently maintained and retained to support all payroll-related transactions.

Contacts: Brian Lutz, VP of Accounting; Rob Busteed, Director of Accounting Contact Phone Numbers: 479-967-5570 Ext. 2013; 479-725-5117 Audit Period Ending: June 30, 2025 2025-001: The Corporation failed to meet the 80% level of effort requirements as stipulated in the grant agreements. Management concurs with the finding. Arisa’s time-keeping application is designed to meet FLSA recordkeeping requirements. This system does not contain a solution to subdivide hours worked by project in a manner that would satisfy level of effort reporting. Arisa will require employees in positions that are partially or fully funded through a federal contract containing level of effort requirements to complete and submit a separate paper timesheet documenting time worked on the federal contract. In addition, subcontractors will be required to include a certification on their invoices that applicable level of effort requirements were met. Program Staff were alerted of the deficiencies in April 2026. Completion date: May 2026.

Management will formally document the CEO and CFO approval of all pay rate changes. Anticipated Completion Date: May 11, 2026

As required by the OMB Uniform Guidance, we have provided our response and corrective action plan addressing the finding in the Schedule of Findings and Questioned Costs for the year ended August 31, 2025. Finding 2025-001: Allowable Costs – Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Management’s Views – Management agrees with the finding. LAJH acknowledges that payroll reimbursement calculations submitted under the federal program were prepared using subsequent employee pay rates rather than the contemporaneous pay rates applicable during the grant performance period and that certain duplicative expenditures were included in error. Management recognizes that these errors resulted in overstated costs totaling $79,825. Corrective Action Plan – LAJH will implement enhanced internal control procedures over the preparation and review of payroll costs charged to federal awards. Specifically, management will require all payroll reimbursement calculations to be supported by contemporaneous payroll registers and employee pay rate documentation applicable to the period during which services were performed. Person Responsible for Corrective Action: Robin Ray, Corporate Controller Anticipated Completion Date: May 31, 2026

Recommendation: CT State Community College should strengthen internal controls to ensure that part-time and extension credit lecturer payroll and fringe benefits costs are based on actual time worked and are properly approved. Corrective Action Plan as Reported by the CT State Community College: CSCU is working to resolve the technical limitations that resulted in the relevant audit finding. Once resolved, reports will be generated and shared with the campuses to verify services provided. This will ensure that part-time and extension credit lecturer payroll is based on actual time worked that is properly approved and verified. Task Due Date Status Provide access to the template for the reporting requirements 1/8/2026 Completed Provide requirements for the report that would meet the needs of the audit requirement 1/12/2026 Review requirements and outline any questions / concerns with producing the requested report 1/20/2026 Regroup as a team to discuss next steps and review workplan for report implementation 1/21/2026 Completed Develop, test, and migrate report (detailed work plan to follow) 4/1/2026 Implement report for approval by each campus (Spring 2026 Semester) 5/1/2026 CT State Community College Anticipated Completion Date: May 1, 2026 CT State Community College Contact Person: Jennifer Person, Assistant Vice Chancellor of Human Resources and Labor Relations jennifer.person@ct.edu (860) 723-0258 Corrective Action Plan as Reported by the Office of Policy and Management: The Office of Policy and Management has no additional response beyond that offered by the CT State Community College. Office of Policy and Management Anticipated Completion Date: May 1, 2026 Office of Policy and Management Contact Person: Yvonne T. Addo, Chief Administrative Officer yvonne.addo@ct.gov (860) 418-6360

Management agrees with the finding. The Agency’s current approach was designed to balance compliance needs with limited resources. Management will assess feasible improvements to its documentation practices to enhance support for payroll allocations to federal awards while remaining mindful of funding and staffing constraints.

The District will ensure that a semi-annual certification is completed at least twice a year and signed by a knowledgeable supervisor or the employee, confirming those employees who worked solely on a single federal program or cost objective.

Views of Responsible Officials: All the Foundation's employees now complete an excel timesheet that is then submitted to their supervisor for review and approval. Payroll is processed only after all employee timesheets are approved and received by the Senior Accountant who processes payroll.

Allowable Costs/Cost Principles Finding Summary: During the testing performed, it was noted that the Organization transferred payroll costs between programs, however, no time and effort certification or equivalent documentation was updated to reflect the changes. Additionally, the transfer of payroll costs between grants was not properly reflected within the accounting system records by grant. Responsible Individuals: Andre Stringfellow, Chief Financial Officer Corrective Action Plan: Procedures were in progress towards the end of the current year. Staff will be trained to ensure future changes in payroll costs are updated timely within the system and documentation maintained. Staff will be trained to ensure future changes in payroll costs are updated timely within the system and documentation maintained. Anticipated Completion Date: August 2026

Blood Diseases and Resources Research (ALN 93.839) Recommendation: We recommend that the Organization reviews their calculations around payroll costs before drawdowns and that evidence of this review is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is in the process of implementing an upgraded grants payroll allocation costs software (Paas 2.0) that contains system controls that will detect payroll changes and automatically update, thus preventing such errors in the future. In addition to these automated software controls, management will implement review procedures in parallel as a secondary measure of control to detect and prevent such errors. Management anticipates the implementation and completion of the software project and related procedures in July 2026. Name of the contact person responsible for corrective action: Mahtab Khan Planned completion date for corrective action plan: July 2026

Continuum of Care Assistance Listing No. 14.267 Payroll Disbursements Recommendation: We recommend that LAHSA implement procedures to ensure that timesheet approval is documented timely. Explanation of disagreement with audit finding: There is no disagreement withthe audit finding. Action taken in response to finding: LAHSA has enhanced its internal controls over timesheet approvals to ensure timely documentation. Timesheet approval status reports are reviewed on a weekly basis during Chief level meetings to monitor compliance. Timesheets not approved within two days of the established deadline are escalated to the respective Chief and Deputy Chief for immediate follow-up. If timesheets remain unapproved after an additional two days, the matter is further escalated to the CEO, for prompt resolution. These procedures establish clear accountability and escalation protocols to ensure timely approval of timesheets Names of the contact persons responsible for corrective action: Gita O'Neill, Keshia Douglas, Christopher Williams, and Paul Rubenstein. Planned completion date for corrective action plan: Implemented

Management’s Views and Corrective Action Plan: Management’s Views: Management agrees with the finding. While the hours charged to the federal programs were reasonable and supported, the lack of timely supervisory approval represents a breakdown in the District’s established internal control procedures over payroll processing. Management acknowledges the importance of ensuring that all payroll charges to federal awards are properly reviewed and approved in accordance with District policy and federal requirements. Corrective Action: The District’s Human Resource Department will verify timecard approvals on Mondays. If Monday falls on a holiday, approvals will be verified on the Friday before. Human Resources will verify that each employee has approved his or her timecard for the prior week and that the employee’s Supervisor or Director has also approved the timecard. For timecards not approved by the employee, an email will be sent to the employee and the Supervisor or Director will be included. For timecards not approved by the Supervisor or Director, an email will be sent to the Supervisor or Director requesting approval, and the CEO will be included. Prior policy did not specify actions when timecards are not approved. Responsible Party: The District’s Human Resources Director and Department Directors Implementation Date: June 1, 2026 Monitoring Procedures: The Human Resources Director will maintain documentation of the weekly review process, including any follow-up communications. Compliance with the timecard approval policy will be periodically reviewed to ensure the control is operating effectively. Any recurring issues will be communicated to executive management for further action. Monitoring procedures were not included in prior policy.

Condition: Tests indicated that seven employees did not have propery time and effort documentation. Upon further examination, it was determined that the salary and wages for these employees were charged to a federal program when they should not have been. Recommendation: We recommend that the School District implement procedures to improve communication between the special education director and the director of business services. Furthermore, we recommend that the School District implement procedures that better monitor which employees are being paid out of which fund. Corrective Action Taken: Management has agreed with the recommendations and procedures have been implemented to ensure that better communication takes place.

Federal regulations, Title 2 U.S. Code of Federal Regulations §200.511 states, “At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in §200.516 Audit findings, a corrective action plan to address each audit finding included in the current year auditor's reports.” See Correction Action Plan for table/chart.

To prevent future occurrences, Genesee Health Plan has updated its payroll allocation procedures, and employees now track time directly through the payroll system.

2025-018 WIOA Cluster 17.258, 17.259, 17.278 Recommendation: We recommend the Department develop procedures and controls to ensure expenditures coded to the GDF from timesheets or manual adjustments do not exceed the 15% limit. Action taken in response to finding: In FY26, phase codes associated with federal grant activity will be further disaggregated and mapped in MMARS screen BQ87 (Federal Grant Phase Budget Status). This enhancement has improved the accuracy and clarity of budget-to-actual comparisons by providing a clearer breakout of expenditures by phase. It will also strengthen internal controls and facilitate better alignment between MMARS, Finance Data Mart, and federal reporting requirements. This new internal controls has been deployed on all FY26 grants and was not audited during this period. Name(s) of the contact person(s) responsible for corrective action: Finance: Sarah Shannon, Ken Luke Planned completion date for corrective action plan: Process is in place and completed on 12/31/2025 and practice is deployed for all new grants requiring break out amounts.

2025-017 WIOA Cluster 17.258, 17.259, 17.278 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to the program are based on actual time and effort and a combination code that is allowable under the program. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Action taken in response to finding: Ongoing training is provided for new staff to ensure they correctly enter combo codes that align with the activities performed. To strengthen oversight, a custom report has been developed to identify employees with missing combo codes each week, allowing Finance staff to proactively follow up and ensure proper time charging weekly. Finance will continue to enhance the custom report to ensure all paid TRCs are linked and properly monitor any missing combo codes in timesheets each pay period. Any new additional pay entered by Human Resource in the HR/CMS system, Human Resource will notify Finance to ensure a proper combo code or an appropriate account is assigned. Finance will collaborate with departments throughout the fiscal year to update labor distribution profiles, ensuring that employees are defaulted to the correct funding sources in accordance with approved labor distribution profiles for accurate and efficient time reporting. A custom report has been developed for managers and time approvers to validate that employee labor distribution profiles are regularly confirmed and updated in accordance with weekly time and effort. To further strengthen internal control preventive measures Finance will be monitoring variances between charged payroll data in relation to the labor distribution profiles to identify any large variances that need to be addressed. Name(s) of the contact person(s) responsible for corrective action: Finance: Anna Yong, Vina Yung, Sarah Shannon, Mai Giang, Stephanie Wong, HR/Payroll: Cheryl Stanton, Linda Stevens, DCS: David Manning, Beth Goguen Planned completion date for corrective action plan: 6/30/2026

2025-005 Employment Service Cluster - Assistance Listing No. 17.207, 17.801 Recommendation: The Department should update its procedures and controls and perform additional training over time and effort reporting to ensure that payroll costs charged to the program are based on actual time and effort and a combination code that is allowable under the program. The Department should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Action taken in response to finding: Ongoing training is provided for new staff to ensure they correctly enter combo codes that align with the activities performed. To strengthen oversight, a custom report has been developed to identify employees with missing combo codes each week, allowing Finance staff to proactively follow up and ensure proper time charging weekly. Finance will continue to enhance the custom report to ensure all paid TRCs are linked and properly monitor any missing combo codes in timesheets each pay period. Any new additional pay entered by Human Resource in the HR/CMS system, Human Resource will notify Finance to ensure a proper combo code or an appropriate account is assigned. Finance will collaborate with departments throughout the fiscal year to update labor distribution profiles, ensuring that employees are defaulted to the correct funding sources in accordance with approved labor distribution profiles for accurate and efficient time reporting. A custom report has been developed for managers and time approvers to validate that employee labor distribution profiles are regularly confirmed and updated in accordance with weekly time and effort. To further strengthen internal control preventive measures Finance will be monitoring variances between charged payroll data in relation to the labor distribution profiles to identify any large variances that need to be addressed. Name(s) of the contact person(s) responsible for corrective action: Finance: Anna Yong, Vina Yung, Sarah Shannon, Mai Giang, Stephanie Wong, HR/Payroll: Cheryl Stanton, Linda Stevens, DCS: David Manning, Beth Goguen Planned completion date for corrective action plan: 6/30/2026

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Aging Cluster – Special Programs for the Aging, Title III, Part B – Assistance Listing No. 93.044 Recommendation: We recommend that the Organization consider updating its cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities, and that are reflective on employees’ time and effort records. We also recommend that the Organization maintain contemporaneous documentation supporting all cost allocations. Lastly, the Organization could consider removing LSC from the general fund into its own fund, and using fringe benefit rate and indirect cost rate allocation methods to simplify its cost allocation process. Explanation of Disagreement With Audit Finding: Management partially agrees with this finding. First, 45 CFR Part 1635 codifies the timekeeping requirement. CLS keeps track of every case and time dedicated by staff in strict compliance with this requirement. Manual adjustments primarily result from planned internal reconciliations and reviews designed to ensure the accuracy of CLS allocations. These reconciliations are conducted on a monthly basis and form an integral part of the Organization’s internal control framework. Action Taken in Response to Finding: Additionally, with respect to the Native American grant transactions, CLS implemented the necessary correction to the referenced percentage effective beginning in 2026. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2027

FINDING 2025-014 Name of Responsible Individual: Assistant Vice President for Post Award Corrective Action: The University initiated the Effort Certification process to capture the full calendar year 2025 in April 2026. This represents a one-time extended certification period designed to include previously uncertified periods that had concluded, specifically the second half of FY25 (January–June 2025) and the first half of FY26 (July–December 2025). In May 2025, the non-accounting functions of Grants and Contracts Accounting at Howard University were transitioned to the Office of Research, Sponsored Programs Office. During this organizational transition, the University prioritized the completion and accuracy of all costing allocations to ensure payroll data was complete and reliable for effort certification purposes. This period was also utilized to identify and resolve any backlog of costing allocations and award charges and stabilize the Office of Research. Addressing these items ensured that effort reflected complete and accurate payroll activity, thereby enabling Principal Investigators to appropriately review and certify their effort. The Sponsored Programs Office (SPO) now leads post-award financial oversight and collaborates with Human Resources (HR) and Finance to ensure designated personnel are identified and granted system access to enter costing allocations and labor cost transfers in Workday. In addition, in response to the auditor’s recommendation to enhance internal controls and ensure timely monitoring of effort reporting, Howard University has implemented the following corrective actions: Hired Dedicated Departmental Support – Six College Research Administrators (CRAs) and an Associate Director of CRA’s were hired to support high-volume research colleges. The CRAs ensure timely and accurate labor cost transfers, effort certification, and costing allocation entries during award setup and throughout the award lifecycle. Enhanced Effort Reporting Process – SPO will lead improvements to the effort certification process, including: • Advance communication to PIs, CRAs, and Deans outlining certification deadlines • Clear guidance on when labor cost transfers may occur outside the certification cycle • Reinforcement that all effort changes must be reflected in the effort system to ensure alignment with payroll. • Training – Targeted training will be delivered to Principal Investigators, CRAs, and other research stakeholders to support consistent application of policies and procedures. Monitoring and Oversight – Monthly and quarterly reconciliation reports will be developed to track and validate timely and accurate payroll allocations for research personnel. Anticipated Completion Date: August 30, 2026

2025-002. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster: Special Education Grants to States: IDEA, Part B ALN: 84.027 Pass-through Entity Number: 0032-25-0875 Condition: One instance within the audit sample where the personnel activity report (PAR) supporting the allocation of payroll costs to the federal award was not maintained for an employee. The District did not have procedures in place to ensure signed PARs are obtained from departing employees before they leave employment, or have an immediate supervisor with knowledge of the employee’s work certify the PAR as an alternative. Planned Corrective Action: The District will change the procedures for obtaining signed personnel activity reports (PARs) from employees whose salaries are 100% charged to one federal grant program. The District will no longer utilize semi-annual PARs for employees who are 100% charged to one federal grant program; going forward, all employees whose wages and salaries are partially or fully allocated to one or multiple federal grant programs will be required to sign monthly personnel activity reports. Responsible Contact Person: Mr. Joseph C. Dragone Interim Assistant Superintendent for Finance and Operations 150 Park Avenue Amityville, NY 11701 Phone: (631) 565-6015 Email: jdragone@amityvilleufsd.org Anticipated Completion Date: June 30, 2026.

2025-002 Special Education Cluster – 84.027, 84.173 Recommendation: We recommend procedures be strengthened to ensure that time and effort certifications are completed in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District has begun reviewing and strengthening its internal procedures to ensure that required time and effort certifications for employees charged to the Special Education Cluster are completed accurately and in a timely manner. Going forward, the District will reinforce timelines for completion, provide reminders to responsible staff, and implement additional monitoring procedures to ensure certifications are collected, reviewed, and retained in accordance with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Special Education Department, in coordination with Business office. Planned completion date for corrective action plan: April 30, 2026

Corrective Action Plan – Material Weakness & Material Noncompliance (Single Audit) Entity Name: Froedtert ThedaCare Health (FTCH) Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Finding 2025-001 – Material Noncompliance (Major Federal Program) Federal Program U.S. Department of Health and Human Services – National Institutes of Health (NIH) – Cancer Control ALN: 93.399 Finding Description The audit identified material weakness and material noncompliance with federal program requirements related to payroll, fringe benefits and indirect costs. Specifically, FTCH did not comply with NIH Salary Cap requirements, which resulted in questioned costs that were quantitatively and qualitatively material. Cause of the Finding FTCH did not apply the NIH salary cap limitations correctly during the period under review. Corrective Action Planned • The Entity will take the following corrective actions to address the material noncompliance:  Performing a comprehensive review of all FTCH grants, both under consideration and currently active, to determine whether a salary cap limitation applies. Where applicable, management will confirm that the salary cap is being consistently and accurately applied in accordance with governing requirements. Any discrepancies identified have been or will be corrected in a timely manner.  Enhancing pre-award and pre-submission compliance controls through updates to grant review procedures and compliance checklists. These updates are designed to ensure that grants subject to salary cap limitations are clearly flagged and that salary calculations are reviewed and documented prior to submission and award acceptance.  Providing targeted training for staff involved in grant administration, budgeting, payroll processing, and financial reporting to ensure consistent understanding and application of salary cap requirements and related internal control procedures.  Conducting periodic internal monitoring reviews of salary charges to federal awards to assess ongoing compliance, validate the effectiveness of internal controls, and identify potential issues before they result in noncompliance. Results of these reviews will be documented, and corrective actions implemented as appropriate. Personnel Responsible: SVP Finance Anticipated Completion Date: May 31, 2026 Status of Corrective Action Corrective action has been initiated and will be completed within the stated timeframe. Management Certification Management certifies that the corrective actions described above are accurate, appropriate, and will be implemented as represented. ____________________ Matt Partridge SVP Finance April ___, 2026

Finding: 2025-028 - One of 10 employee timesheets tested did not support the charges billed to the Congressionally Mandated Projects (CMP) program. Questioned Costs: 2,273 Assistance Listing Number: 66.202 Assistance Listing Title: CMP Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department agrees with this finding. Corrective Action (corrective action planned): This finding has been corrected. The Division of Community and Regional Affairs (DCRA) and the Division of Administrative Services (DAS) have reviewed and updated timesheet processing functions in DCRA. DAS has provided information and training to DCRA timekeepers and management staff on timesheet entry, timekeeping procedures, and time entry and review processes in the accounting system. Both DCRA and DAS management will continue to monitor time entry and timesheet processing to ensure that time is entered accurately. Completion Date (list anticipated completion date): I The corrective action plan was fully implemented on January 31, 2026. Agency Contact (name of person responsible for corrective action): Nichole Tham, Division Operations Manager, Division of Community and Regional Affairs.

Single Audit Finding No. 2025-068 - For two out of 40 timesheets tested (five percent), the employees’ hours were inaccurately recorded in the State’s accounting system. Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): I The department agrees with this finding and recommendation. Corrective Action (corrective action planned): Department management will implement additional training for time collectors and payroll entry staff and strengthen the review process to ensure the accuracy of timesheet entry moving forward. Completion Date (list anticipated completion date): June 30, 2026 Agency Contact (name of person responsible for corrective action): Shanna Burns, Human Resources Consultant 5