Corrective Action Plans

Recommendation: The Center should develop policies and procedures to help ensure pay rates are consistent with supporting employee agreements or other management-approved documentation. Corrective Action Taken: 1. Immediate Review and Correction Upon identification of the finding, the Center conducted a comprehensive internal audit of pay rates for all employees hired from January 1, 2025, to the present. Any discrepancies identified during this review were promptly corrected to ensure alignment with approved documentation. 2. Staff Training Targeted training will be provided to all Human Resources and Payroll staff. This training will emphasize: The importance of accuracy in data entry and the use of self-review as a quality control tool; Accountability at both the individual and team levels for maintaining complete and accurate payroll data; and Proper preparation and retention of documentation supporting initial payroll entries and any subsequent changes. 3. Policy and Procedure Review The Center has performed a comprehensive review of its internal policies and procedures to: Ensure clear delineation of roles and responsibilities across hiring, onboarding, and payroll processes; and Provide detailed guidance on required documentation to support each step in these processes. 4. Double-Verification Process Management has reinforced a culture of shared accountability by implementing a doubleverification process. This includes: Requiring staff to review and confirm the accuracy of their own work prior to submission; and Requiring receiving staff to independently verify information and resolve any discrepancies before proceeding with further processing. 5. Continued Monitoring In addition to standard bi-weekly payroll reviews conducted by management, the Center will implement quarterly payroll system audits. These audits will verify that all payroll changes are accurate, properly documented, and supported by appropriate approvals.

Inadequate Supporting Documentation - Title 1 - OPI - The Montana Office of Public Instruction partially concurs with this finding. The prior audit was not completed in time for the Office to implement changes before the fiscal years reviewed in the current audit. More stringent criteria for cash requests from schools were put in place in late 2024, and these requirements have been followed since that time. Although there was considerable pushback from local education agencies, the Office remained firm on the information required. The Office audits cash requests quarterly against submitted budget documents, and any issues identified are addressed. The more stringent criteria are fully implemented, and no further corrective actions are needed beyond continuing the current process. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026

Noncompliant Direct and Indirect Cost Charges - ESSER - OPI - The Montana Office of Public Instruction partially concurs with this finding. Spreadsheets supporting items 0005169673 and 0005227738 were provided to the Legislative Audit Division on August 11, 2026. The Central Services Division spent direct time on the Elementary and Secondary School Emergency Relief (ESSER) reporting, and those hours were charged directly to that program. Administrative and management staff also spent time preparing reports for quarterly briefings, presentations to community partners, responses to school and community inquiries, and newsletter submissions. The Office charged those hours to the ESSER program as they were directly related to the required reporting. However, the Office concurs with the questioned indirect cost charges in addition to personal services. The Office has implemented a tracking mechanism to ensure appropriate time reporting. For fiscal year 2027, the Office has added a monthly review of each federal budget to confirm that time reported aligns with the expected and allocated time for each project. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026

Inadequate Payroll Certification Controls - R&D - UM - The University of Montana - Missoula will work with Information Technology to confirm that Personnel Activity Report reminder emails are sent on the correct schedule and to the appropriate individuals, including the Office of Sponsored Programs. The University will provide Personnel Activity Report certification training to the campus and will conduct targeted outreach for departments with outstanding records. After the current cleanup effort is completed, Grants and Contracts Officers will review outstanding Personnel Activity Reports quarterly and follow up as needed to promote timely certification. Responsible Party - Nicole Thompson, Director, Office of Sponsored Programs, University of Montana - Missoula Target Implementation Date - 2/28/2027

Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Allowable Costs, Payroll Disbursements - AB Recommendation: We recommend the Commission implement procedures to ensure payroll costs charged to the Housing Voucher Cluster are properly supported, accurately allocated, and reconciled to payroll records. Management should review and approve payroll allocations and investigate any variances to ensure compliance with 2 CFR 200.430. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. This error was caused by HCHC’s timekeeping and payroll system, ADP. The error resulted in overtime hours for certain employees being paid twice in one pay period. ADP has admitted to the error and reimbursed HCHC for the costs. In order to ensure that this type of error does not occur again, HCHC is taking a number of steps. Payroll and Overtime Reconciliation: Human Resources will print and review the overtime report for each payroll cycle and reconcile the overtime hours reflected on the report against the applicable employees’ payroll records/pay stubs. Any discrepancies identified during this review will be researched and addressed promptly. Time and Attendance System: The Commission is transitioning to a new time and attendance system that is better aligned with the Commission’s operational and payroll needs. The goal of this transition is to strengthen timekeeping controls, improve the accuracy of payroll information, and provide clearer documentation to support payroll processing and allocation. Employee Payroll Review and Reporting Procedures: The Commission is updating the Employee Handbook to provide employees with clear guidance on reviewing their pay and reporting potential payroll discrepancies. The updated guidance will outline the process employees should follow if they believe they have been overpaid, underpaid, or identify another discrepancy with their compensation. Name(s) of the contact person(s) responsible for corrective action: Ikea Smith, HR Manager and Bei Hua, CFO Planned completion date for corrective action plan: January 1, 2027.

Management will reconfigure the system to require after-the-fact entry of actual hours worked and to restrict advance entry and approval, reinforce supervisory review procedures to ensure timely and accurate approval of timecards, and provide training to employees and supervisors on federal timekeeping requirements under 2 CFR 200.430. These actions will strengthen internal controls and ensure payroll costs charged to federal awards accurately reflect work performed going forward.

Managementconcurswiththefindingandwillrequirestaffwhosepayrollischargedtotheprogramtocompletecontemporaneoustimeandeffortrecords,reviewed and approved by a supervisor before each payroll charge is submitted for reimbursement.

Significant deficiency in compliance and internal control over compliance relating to approval of timecards. View of Responsible Officials: Management accepts this finding. Approval of timecards by employees and supervisor is required based on agency policies. This issue was due to a supervisor not being available for approval and no delegate was assigned. Corrective Action: Management will require all approvers of payroll to assign delegates to approve timecards in their absence. Exceptions will be documented.

2025-001. 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 Special Education Preschool Grants: IDEA Preschool ALN: 84.173 Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District did not prepare this documentation, and therefore did not comply with Subpart E, 2 CFR §200.430. Planned Corrective Action: The District will adopt procedures that ensure that time performed will be used to support costs charged to the federal award, and comply with Subpart E, 2 CFR §200.430. Responsible Contact Person: Michael I. DeVito, Esq., Assistant Superintendent for Finance and Operations. Long Beach City School District 235 Lido Boulevard Lido Beach, New York 11561 mdevito@lbeach.org 516-897-2090 Anticipated Completion Date: June 30, 2026.

FA 2025-002 Strengthen Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Repeat of Prior Year Finding: Description: Activities Allowed or Unallowed Allowable Costs/Cost Principals Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education COVID-19 - 84.425U -American Rescue Plan Elementary and Secondary School Emergency Relief Fund S425U210012 (Year: 2024) $20,928.34 FA 2024-002, FA 2023-002, FA 2022-002 A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund Program revealed that the School District's internal control procedures were not operating to ensure that expenditures were appropriately documented to support allowability. Corrective Action Plans: • The CFO will ensure that every journal entry has all the supporting documentation that will show appropriate approval before entering into PCG and that the documentation explains clearly the purpose for journal entry. • Payroll will reorganize how documentation is kept of each pay period to ensure it makes a complete monthly folder. Payroll will not process any timesheets that need signatures for approval. If not able to get signed in time for current pay period, it will be processed in the next one. CFO will review all salaries after they have been entered into PC Genesis to ensure that they are being processed correctly. Estimated Completion Date: December 18, 2026 Contact Person: Torrence H. Freeman Ill, CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

FA 2025-001 Strengthen Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Repeat of Prior Year Finding: Description: Activities Allowed or Unallowed Allowable Costs/Cost Principals Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education 84.010 - Title I Grants to Local Educational Agencies S010A230010 (Year: 2024), S010A240010 (Year: 2025) $127,026.07 FA 2024-001, FA 2023-001, FA 2022-001 The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it related to the Title I Grants to Local Educational Agencies program. Corrective Action Plans: • The CFO will make sure that the voucher packets are properly prepared before the final steps. The packets must include approved requisition forms with school admin level approval, secondary approval from federal director if federal funds are used, and a completed purchase order signed by superintendent. • The CFO and Board Office Secretary will make sure that payments match the invoices. If there are any changes, those changes are documented correctly. • The CFO and payroll clerk will ensure all salary sheets are attached to contracts and are available for review. • The CFO will run a report to check additional payments against additional time sheets and will sign off on it. Estimated Completion Date: December 18, 2026 Contact Person: Torrence H. Freeman Ill, CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

Management concurs that documentation evidencing supervisory review and approval of employee timesheets was not consistently maintained during the FY2025 audit period. Supervisory review and approval did occur; however, documented evidence of that review was not consistently retained during the period following the federal executive stop-work order affecting the PRM grant, when the organization was operating with significantly reduced staffing and focused on maintaining essential operations. With the commencement of the ORR federal award, the organization implemented formal documented employee certification, supervisory review and approval procedures during October 2025. During that time, supervisors were required to review and approve employee timesheets electronically and documentation of those approvals retained as part of the organization’s payroll and grant compliance records. Anticipated Completion Date: October 2025. Responsible Contact Person: Michael Quan, Director of Finance & Operations.

Program: Public Housing Operating Fund AL Number: 14.850 Finding Number: 2025-002 Audit Finding (Copied & Pasted Directly from Auditor’s Report): Condition: During the audit we observed documentation showing employees recording a full 8 hour work day on time sheets while leaving work early. Management was instructed to cease tracking and compensate employees for full time anyway. Context: Employee(s) doing the following activities and still getting compensated for a full 8 hour work day; Employee(s) leaving their assigned worksite prior to the end of work day, employee(s) not calling off or leaving early for appointments without correctly calling off nor submitting the proper leave slips, employee(s) arriving late and leaving early daily. Cause: Management override and lack of monitoring/enforcement Criteria: According to 2 CFR 200.430 Compensation - personal services, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed Corrective Action to Be Taken: Reinstatement of accurate timekeeping with outlined policy and procedures including a discipline action plan for inaccurate payroll and leave slips submission. Strengthened controls and training; Support of management without overrides. Contact Responsible for Corrective Action: Gene Digennaro, Interim Executive Director PO Box 988 481 Neshannock Avenue New Castle, PA 16103 724-656-5100 ext. 204 gdigennaro@lawrencecountyha.com Tara Sheffler, Comptroller PO Box 988 481 Neshannock Avenue New Castle, PA 16103 724-656-5100 ext. 210 tsheffler@lawrencecountyha.com

BGCPR will provide additional training and guidance to Human Resources personnel to ensure consistent adherence to the internal procedures established. Contact Person: Yezaida Reyes Angel Morales Paul Rivera Team: Finance, Compliance and Human Resources Team Anticipated Completion Date: September 30, 2026

BGCPR will provide additional training and guidance to Human Resources personnel to ensure consistent adherence to the internal procedures established. Contact Person: Yezaida Reyes Angel Morales Paul Rivera Team: Finance, Compliance and Human Resources Team Anticipated Completion Date: September 30, 2026

Effective June 2025, the Organization hired a Director of Finance to strengthen financial management, enhance internal controls, and improve oversight of financial reporting and federal grant compliance. Management corrected the grant coding and updated the applicable expense codes to ensure transportation-related costs are charged to the appropriate account. Finance staff now verify grant coding before expenditures are posted and reimbursement requests are submitted. The Director of Finance performs monthly reviews of grant expenditures to identify and correct coding errors before reimbursement requests are finalized.

Description: During our testing of payments charged to the federal major program, we noted that employee timesheets lacked evidence of review and approval. Certain employees charged to the grant did not prepare timesheets and a separate tracking system was used. Federal regulations require that expenditures charged to Federal awards be properly reviewed, approved, and documented to ensure allowability and compliance with grant terms. Recommendation: Review the requirements of CFR 200.430 and ensure that current processes, whether digital or hard-copy driven, are consistent with the requirements of the Uniform Guidance. In addition, management should consider adding additional staff to its accounting and/or grants management team. Responsible Contact: Laura McQuay, Vice President & Chief Financial Officer Corrective Action Planned: The Organization has made significant progress in strengthening its timekeeping processes, as described in finding number 2025-002. This program ended in March 2025, and therefore management was unable to complete full remediation of the processes before completion of the grant. Anticipated Completion Date: December 31, 2027

Description: During our testing of payments charged to the federal major program, we noted that employee timesheets lacked evidence of review and approval. Federal regulations require that expenditures charged to Federal awards be properly reviewed, approved, and documented to ensure allowability and compliance with grant terms. Recommendation: Review the requirements of CFR 200.430 and ensure that current processes, whether digital or hard-copy driven, are consistent with the requirements of the Uniform Guidance. In addition, management should consider adding additional resources to its payroll approval process. Responsible Contact: Laura McQuay, Vice President & Chief Financial Officer Corrective Action Planned: Management: The Organization has made significant progress in strengthening its timekeeping processes over the past 18 months. In 2025, the agency transitioned approximately 800 weekly transitional workers from a paper-based timekeeping process to an electronic timekeeping system. In 2026, the agency implemented an upgraded workforce management system that provides enhanced scheduling, monitoring, and supervisory oversight capabilities. Management recognizes the importance of full compliance with timekeeping requirements. Given the size and complexity of the Organization's operations, including a large workforce distributed across multiple programs and locations, implementation of system and process changes requires substantial planning, training, and operational coordination. To support these efforts, the agency has dedicated additional resources and established clearly defined responsibilities to drive implementation and oversight. The agency continues to refine procedures, provide training, and leverage system capabilities to strengthen controls and ensure consistent compliance across the Organization. Anticipated Completion Date: December 31, 2027

2025-004 – Lack of Written Policies and Procedures Auditor Description of Condition and Effect. Although the Organization 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 Organization. As a result of this condition, the Organization did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Organization review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Organization has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Board of Directors before the end of fiscal year 2026. Responsible Person. Rob Rafson, Executive Director Anticipated Completion Date: December 2026

1. Explanation of Disagreement with Audit Finding: There is no disagreement with the finding. 2. Actions Planned in Response to Finding: Corrective actions are underway, including clarified expectations, additional training, and improved monitoring to prevent recurrence. Also, site-level recording and reporting templates have been implemented for the 2025-2026 school year and are in place at each recipient program. 3. Official Responsible for Ensuring CAP: The District’s Principal on Special Assignment who oversees the Title I program and the Business Services Director are the school officials responsible for carrying out the corrective action plan. 4. Planned Completion Date for CAP: The planned completion date for the CAP is June 30, 2026. 5. Plan to Monitor Completion of CAP: The Board of Education and administration will be monitoring this corrective action plan.

Management agrees with the finding that payroll costs charged to HUD-funded programs were based on estimated allocations and did not consistently reflect actual time and effort in accordance with 2 CFR §200.430 (Compensation—Personal Services) and applicable HUD program requirements. Management acknowledges the requirement that personnel costs charged to HUD awards (e.g., CDBG, HOME, CoC) must be supported by records that accurately reflect work performed on eligible program activities.

We agree with the auditor's comments. Prior to transferring financial responsibilities back to Essex County Public Schools Administration effective July 1, 2026, a process was put into place for all staff to have current and fully executed contracts stating their pay rate, FLSA status, expected length of contract (with number of workdays), and associated benefits. A process was also established to utilize an automated or manual timekeeping report to reflect all hours worked and approved by the supervisor prior to submission for payment. All records should be matched and retained to support payroll payments.

The School has now made personnel and policy changes, and established procedures regarding time certifications that provide assurance that charges are accurate, allowable, and properly allocated.

Finding Number: 2025-003 Name of Responsible Party: JaShawn Hill, Executive Director Corrective Action: Management acknowledges and agrees with the finding. This issue resulted from a reduction in force during which various employees’ final workday coincided with the end of a payroll period. While employees typically have around one week to submit their timesheets after the end of a pay period, the employees that were let go from the organization did not finalize their information before leaving. In the future, management will ensure that all timesheets are submitted on the final day of employment as a part of the last day procedures. Anticipated Completion Date: July 31, 2026

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. In May 2026, the Organization hired a subcontractor, Dapt to synchronize the employee hours worked on their time sheets and allocated into the cost centers/programs they worked on. The new timesheet will also reflect the employee and supervisor’s approval, as completed in ADP. Testing begins with the months of May and June 2026. 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: June 30, 2026.