Corrective Action Plans

Finding 2024-002: Significant Deficiency Activities Allowed or Unallowed and Allowable Cost/Cost Principle (Payroll) Responsible Official’s Response and Corrective Action Plan We concur with the finding related to deficiencies in our time tracking Process. Starting in the fourth quarter of fiscal year 2025, a time tracking system using Paychex Time & Attendance was implemented. This system is designed to accurately capture, and record employees’ hours worked by project/grant. Comprehensive training sessions have been conducted for all affected employees to ensure they are proficient in using the new time tracking system. Supervisors have received additional training on monitoring and verifying time entries. Planned Implementation Date of Corrective Action Plan October 2025 Person Responsible for Corrective Action Plan Natésha Johnson, Director of Finance and Administration Dr. Felecia Nave, President and Chief Executive Officer

Finding 2024-003 – Lack of Internal Controls over Expenditure Documentation (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: Natural Resources Conservation ServiceName of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land Management Criteria: Title 2 CFR §200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the awards in compliance with federal statutes, regulations, and the terms and conditions of the award. Additionally, 2 CFR §200.302(b)(3) requires entities to maintain records that adequately identify the source and application of funds, including supporting documentation for expenditures, and 2 CFR §200.430 requires documentation for compensation for personal services. Condition: During our review of expenditures charged to the federal programs, the entity was unable to provide invoice copies or other sufficient supporting documentation for certain expenditures tested. As a result, we could not verify the allowability, accuracy, and proper approval of these costs in accordance with federal requirements. In addition, records were unavailable for Personnel expenditures that were charged to grant awards, and no support or evidence of time per grant was available. Cause: Partnership for the Umpqua Rivers does not have effective internal controls in place to ensure that invoice documentation and other supporting records are retained, centrally filed, and readily available for audit and monitoring purposes. In addition, management did not perform ongoing monitoring to verify that required documentation was maintained prior to reimbursement or reporting. Effect or Potential Effect: because supporting documentation was not available, expenditures from detail documentation could not be substantiated. This increases the risk that the unallowable, unsupported, or inaccurate costs may be charged to the federal program and reported in the Schedule of Expenditures of Federal Awards (SEFA). Questioned Cost: Yes, $332,409 related to Personnel costs, equipment and other purchases that were not documented with detailed support. Context: During our audit, it was found that the Partnership for the Umpqua Rivers experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. No financial files for Accounts Payable, invoices, or reporting were available to the current financial staff. Not adequately retaining supporting documents and invoices to support the expenditures of the general ledger and requests for reimbursement for grants, the organization records may be insufficient for testing and review, for internal controls or meeting federal documentation and reporting requirements. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit.Recommendation: Partnership for the Umpqua Rivers should implement policies and procedures requiring invoice copies and supporting documentation to be maintained for all grant expenditures. Management should strengthen record retention practices, provide training to staff on documentation requirements, and implement periodic internal reviews to ensure compliance. District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: _____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: _________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

2024-004 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition As part of our audit procedures, we selected a sample of 40 payroll transactions for review. This process included examination of employee human resource files (such as signed W-4 and I-9 forms), management-approved pay rates, time sheets with supervisory sign-off, and corresponding payroll reports. We recalculated total hours per timesheet using the employees' pay rates and compared these figures to the relevant payroll reports. During our review, we observed that two employees received additional compensation ranging from $25 to $75 for undertaking extra responsibilities related to the administration of the CBS Food Program’s Summer Food Service Program by the former Chief Executive Officer. Management was unable to provide supporting documentation evidencing approval by the former Chief Executive Officer or confirmation from the Commonwealth of Pennsylvania, Department of Education, indicating that such additional compensation complied with the contractual agreement governing the Summer Food Service Program. Additionally, of the 40 payroll transactions sampled, we noted one employee’s required payroll change documentation (e.g., an approved payroll change form) was not present in their personnel file. Recommendation We recommend that management improve internal controls for payroll authorization by making sure every payroll change form and supplemental compensation approval is filled out, approved, and kept on file. Introducing a central electronic document management system will help securely store records, standardize documentation, and create clear audit trails for all payroll and personnel files. Management should also regularly review payroll records to confirm that all necessary paperwork, such as personnel forms, pay rate approvals, and backup for extra pay, is included. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions repeats the actions to be taken in response to finding 2024-003 and adds the following: Community Benefit Solutions will utilize ADP document management capabilities to maintain employee files including, but not limited to, Payroll Change Forms or other documentation related to modifications or supplements to employee pay. Community Benefit Solutions will ensure complete upload of all paper files to the appropriate employee profile within ADP to ensure documentation can be readily accessible by those with necessary authorization. Planned completion date for corrective action plan: June 30, 2025

Review and update Accounting Manual to align procedures with award requirements • Re-train employees on the proper timesheet procedures per the Accounting Manual • Perform monthly reconciliations of payroll allocations to grant budgets. • Require supervisory approval of timesheets prior to submission.

FINDING 2024-011 Finding Subject: Title I Grants to Local Education Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain time and effort documentation for all staff paid by federal grants for each six-month period from January 1-June 30 and July 1-December 31. In addition to the ongoing time and effort documentation for all staff paid by federal grants, the district will maintain wage and benefit distribution reports that reflect staff paid from federal grant funds. The school corporation will include supporting documentation for all accounts payable vouchers. Anticipated Completion Date: The school district began the practice above on January 1, 2024 and anticipate it will be completed by June 30, 2026.

F A 2024-002 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles InternalControllmpact: SignificantDeficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Depatment of Education Pass-Through Entity: Georgia Department of Education CFDA Numbers and Titles: 84.425 American Rescue Plan Elementary and Secondary School Emergency Relief Grant 84.425 - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth 84.425 - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425U210012 (Year:2021), S425W210011 (Year: 2021), 5425D2 1 001 2 (Year:202 I ) Questioned Costs: $8,763.69 Repeat ofPrior Year Finding: FA2023-002, F42022-002 I)escription: A review of expenditures charged to the Elementary and Secondary School Emergency ReliefFund program revealed that the School District's internal control procedures were not operating to ensure that expenditures were appropriately documented to support allowabiliqr. Corrective Action Plans: . Alljournal entries will be check by the independent CPA person to ensure that packets are complete and that each are fully approved by at least two of the following Superintendent, CFO and/or CPA and organized to FY folder as part of our monthly closing process . 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 3 1, 2025 Contact Person: Torrence H. Freeman IIl. CFO Telephone: 7 06-665-8571 Email: tfreeman@talbot.kl 2.ga.us

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Allowable Costs/Cost Principles, Activities Allowed or Unallowed Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education CFDA Numbers and Titles: 84.01 0 - Title I Grants to Local Educational Agencies FederalAwardNumber: S010A220010(Year:2023),S0104230010 (Year:2024) Questioned Costs: $9,307.29 Repeat ofPrior Year Finding: FA 2023-001, FA 2022-001 Description: The policies and procedures ofthe School District were insufficient to provide adequate intemal controls over expenditures as it related to the Title I Grants to Local Educational Agencies program. Corrective Action Plans: Payroll will reorganize how documentation is kept ofeach pay period to ensure it makes a: complete monthly folder . payroll will not process any timesheets that need signatures for approval. lf not able to get signed in time for currently pay period, it will be processed in the next one o CFO will review all salaries after they have been entered into PC Genesis to ensure that they are being processed correctly Contact Person: Torrence H. Freeman III, CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

Section III - Reportable Findings and Questioned Costs for Federal Awards Finding 2024-002 Noncompliance and material weakness in internal control over compliance with allowable costs/cost principles Management Response: 1. PARs were signed on a quarterly basis. We will transition to signing PARs biweekly to ensure timely acknowledgement. Person(s) Responsible: (COS) Rita Green, Department Managers

Recommendation: We recommend that the City review and update internal controls to ensure that supporting documentation for allowable time charges to grant programs is properly maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff has updated timekeeping for individuals charging partial time to the Housing Section 8 program to track actual hours spent rather than through budget allocation. Staff has in addition identified a method by which the City can produce supervisor approval documentation through the financial system’s electronic workflow. Names of the contact persons responsible for corrective action: Stephanie Meyer (Finance Director), Elizabeth Hause (Community Services Director) Planned completion date for corrective action plan: December 30, 2025

Views of Responsible Officials: CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. This FY 24 Program Audit immediately preceded the FY 25 Single Audit in fall 2025. Given this timing, the earliest possible implementation of corrective action is in FY 26. Beginning in FY 26, CIF implemented a system for documenting time and effort in a manner that complies with Federal requirements which involves timesheets that record actual time spent on a funding source and are accompanied by supervisorial approvals. This system has been formally documented in the FY 26 update to the CIF Financial Policy and includes annual training for staff responsible for managing payroll allocations and Federal reporting. Charges to Federal awards for salaries and wages are now based on records that accurately reflect the work performed. The records are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The records support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.

Mana Maoli has implemented a practical review and reconciliation step as part of payroll processing. This step compares approved timesheets to payroll register hours to help ensure that payroll allocations to federal programs are based on accurate records. This reconciliation is integrated into the existing payroll workflow to avoid added administrative burden. Management will conduct periodic reviews of payroll records and refine the process as needed to maintain reasonable assurance of accuracy, recognizing that the goal is continuous improvement. Anticipated completion date: December 31, 2026

The District Director of Student Services will monitor and make sure that all personnel who serve under federal programs have their time properly documented using semi-annual certification forms or other appropriate time and effort methods.

Planned corrective actions: Heritage implemented a new system, however Heritage continues to encounter mistakes on correctly completing the time & efforts due to the differences in length of faculty contracts. Heritage continues to work on the process to improve with further training. Name of Responsible Party: 1. Rachel Castijella, Grant Accountant 2. Terri Slack, Fiscal Agent 3. Ivan Banks, Interim Provost 4. Joanne Fernandez, Controller 5. Sagrario Armenta Jimenez, CFO 6. Dr. Christopher Gilmer, President Anticipated completion date: 6/30/2026

Planned corrective actions: Heritage implemented a new system, however Heritage continues to encounter mistakes on correctly completing the time & efforts due to the differences in length of faculty contracts. Heritage continues to work on the process to improve with further training. Name of Responsible Party: 1. Rachel Castijella, Grant Accountant 2. Terri Slack, Fiscal Agent 3. Ivan Banks, Interim Provost 4. Joanne Fernandez, Controller 5. Sagrario Armenta Jimenez, CFO 6. Dr. Christopher Gilmer, President Anticipated completion date: 6/30/2026

Planned Corrective Action: Heritage implemented a new system, however Heritage continues to encounter mistakes on correctly completing the time & efforts due to the differences in length of faculty contracts. Even though DOE noted that “this finding resolved and closed.”, Heritage continues to work on the process to improve with further training. Name of Responsible Party: 1. Rachel Castijella, Grant Accountant 2. Terri Slack, Fiscal Agent 3. Ivan Banks, Interim Provost 4. Joanne Fernandez, Controller 5. Sagrario Armenta Jimenez, CFO 6. Dr. Christopher Gilmer, President Anticipated Completion Date: 6/30/2026

Finding 2024-001: Grant Program: Department of Health and Human Services – National Institutes for Health Research and Development Cluster – Cancer Control – Assistance Listing #93.399 – Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. Montana Cancer Consortium (MCC) has updated the Financial Process Procedure to include language related to receipt management, allowable and disallowed grant expenses, and timing of payment requests. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators

09.744060 Basic Field Grant Grant Period: 1/1/2024 – 12/31/2024 Contract Number: 744060 U.S Department of Justice 16.575 Victims of Crime Act Grant Periods: 10/1/23-9/30/24 and 10/1/24 – 9/30/25 Contract Number: 4055104; 4055105 Supreme Court of Texas Basic Civil Legal Services Program Grant Period: 9/1/2023 – 8/31/2025 Contract Number: 26030 2024-003 Internal Controls and Compliance over Allowable Costs and Activities – Payroll (Material Weakness and Material Noncompliance) Recommendation: We recommend the Organization review its timekeeping policies and procedures and provide additional training to employees to ensure time sheets are retained for all payroll transactions to support the allocation of compensation. We also recommend the Organization review and refine its policies to reconcile the percentage of hours charged on the time sheets to the budget estimates used to bill Federal and State grantors. This should be done in conjunction with monthly or quarterly billings (or other determined regular interval), at fiscal year end, and at the end of the grant year (if different from the Organization’s fiscal year). Corrective Action: AVDA implemented a formal Timekeeping and Payroll Compliance Policy in June 2025. All employees funded by Federal or State grants are now required to complete bi-weekly electronic functional time sheets that identify time spent on tasks by budgeted grant(s). Supervisors must review and approve all time sheets prior to submission. The Director of Finance will reconcile budget estimates to actual hours monthly, and quarterly reviews will ensure accuracy in allocations. Training on grant timekeeping standards (2 CFR §200.430) was provided to all program directors and staff in July 2025. Responsible Parties: - Lisa Mikosh, Director of Finance - Marcello Gonzales, Bookkeeper - Maisha Colter, CEO (policy approval and oversight) Date Corrected: August 15, 2025

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