Corrective Action Plans

Finding 2025-003 Name of Responsible Individual: Angelo Chrisomalis, Sr. Director Grants and Contracts Corrective Action: Due to a change that occurred after the reporting period appropriately reallocating one employee’s effort to the federal funding source, the certification was not displayed on the effort report. The employee has certified that this effort was charged appropriately to this award. We are reviewing our policies and procedures to ensure redistribution of labor is performed within a timely manner. We have moved to an annual effort reporting process aligned to the federal regulations and are implementing the Cayuse Effort Reporting module that will more effectively track and report effort. The system will be implemented during our next effort reporting cycle. Anticipated Completion Date: March 1, 2026

We have a multi-pronged action plan. We will clarify and review our accounting policies and procedures regarding payroll allocations with staff; We will create a more thorough documentation process of the basis for each allocation; We will review the assumptions used for allocations during the year and update them (as needed); We will include regular monitoring and review of payroll allocations.

Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Context: We noted that for 13 of the 40 payroll samples selected, the School Corporation did not have employees fill out semi-annual certifications to support the percentage of their payroll charged to the Title I grants. Contact Person Responsible for Corrective Action: Nathaniel Day Contact Phone Number: 317-462-4434 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will continue the plan instituted in the 2021-23 Audit. This finding was identified after the first period of the 2023-25 audit and was corrected at that time moving forward.

The district will implement procedures to ensure that all Child Nutrition employees paid 100% from Child Nutrition funds complete a semi-annual time certification as required by the Arkansas Department of Education Child Nutrition Unit

The Siloam Springs School District was instructed to submit a time certification for all employees paid from the nonprofit food service account to Arkansas Department of Education, Division of Elementary and Secondary Education, Nutrition Services by January 16, 2026. The District received a letter from the Arkansas Department of Education, Nutrition Services dated January 9, 2026 informing the District’s corrective action submitted was accepted and therefore, the review was officially closed

Joanna Trimble, Child Nutrition Director

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Subrecipient Monitoring Corrective Action Plan: DNR will enhance subrecipient monitoring procedures to specifically include documented reviews of subrecipient procurement policies and procurement files to ensure compliance with applicable federal requirements and the subrecipient’s own written policies. DNR will revise subaward templates and procedures to ensure that all required federal award information and applicable terms and conditions, including closeout requirements, are consistently included in subaward agreements at the time of issuance. DNR will develop and implement formal written procedures for subrecipient Single Audit monitoring. DHHS will continue to improve subrecipient monitoring where necessary. NDCS will revise its policy to include a requirement for verifying subrecipient qualifications for federal funds. Additionally, NDCS will notify all subrecipients that proper payroll and benefit documentation must be submitted to ensure accurate cost allocation. NDCS will ensure that all required subaward documentation is provided to each subrecipient. This documentation will include: a. The subrecipient’s Unique Entity Identifier (UEI) b. Federal Award Identification Number (FAIN) c. Federal Award Date d. Federal award project description e. The name of the Federal agency, pass-through entity, and contact information for the awarding official of the pass-through entity f. Assistance Listings title and number g. A requirement that the subrecipient permit the pass-through entity and auditors to access the subrecipient’s records and financial statements h. Appropriate terms and conditions concerning closeout NDCS will incorporate these requirements into its subaward process to ensure compliance with federal regulations. Contact: Erv Portis, Shelby Mikulak, Heather Arnold, Jenise Trautman Anticipated Completion Date: June 30, 2026

Reference # and title: 2025-001 Untimely Completion of Time Certifications Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Agriculture; passed through Louisiana Department of Education Child Nutrition Cluster: School Breakfast Program 10.553 2025 National Lunch Program 10.555 2025 Condition found: Federal regulations require that salaries and wages charged to federal programs be supported by time and effort documentation that accurately reflects the work performed and is completed in a timely manner, in accordance with 2 CFR §200.430. In testing a sample of Child Nutrition payroll, it was noted for all eleven employees tested, the Child Nutrition Program did not complete required time certifications in a timely manner. Several certifications were completed after an extensive amount of time, resulting in noncompliance with federal documentation requirements. Corrective action planned: The School Board has changed when the time certifications are completed to comply with the federal requirements. The School Board will implement written procedures to address the issue. Management will review and monitor the process to ensure compliance with the new procedures.

Reference # and title: 2025-004 Internal Control over Allowable Costs Federal program and specific federal award identification: AL # Grant Year FEDERAL GRANTOR/ PASS-THROUGH GRANTOR/PROGRAM NAME Passed through Louisiana Department of Education Child Nutrition Cluster: School Breakfast Program 10.553 2025 National School Lunch Program 10.555 2025 Summer Food Program 10.559 2025 Criteria or specific requirement: 2 CFR section 200.430(g) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on a Federal award and a non-Federal award. Condition found: No time certification was completed by Child Nutrition Supervisor for six months of the year. The Child Nutrition Supervisor retired in December 2024. Corrective action plan: Make a list of all employees who are paid by two budgets and require them to complete and sign time and effort sheets monthly. Person responsible for corrective action: Supervisors Anticipated completion date: Time and effort reports are to be reviewed monthly by supervisor and time and effort reports are to be kept on file by individual supervisors beginning school year 2025-2026.

Finding #: 2025-004 Allowable Activities and Cost - Payroll (Significant Deficiency, Other Noncompliance) Corrective Action Plan: Please describe below how the situation in the finding will be corrected. What action(s) will be done (refer to finding recommendation and agency response): Newly imposed supervisory review of the bi-weekly payroll correction process will ensure that miscoded employees are detected. Discrepancies will be addressed immediately. Who will act (name and title): Division Finance Directors, Program Grant Administrators, and Federal Grants Director. When will action(s) be completed (effective dates, timelines, etc.): The Department is working on remediation of this finding and anticipates completion before June 30, 2026.

Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airport Programs; We recommend that the City implement a reporting system that requires all employees paid with federal funds to complete itemized, signed timesheets detailing the specific hours worked on each grant or project on a daily or weekly basis. These timesheets must be reviewed and approved by a supervisor with firsthand knowledge of the work performed.; Management's Response: The City of Red Bluff has used a log of time spent on the grant including date, description of activity, and time worked on the grant. The logs failed to account for non-grant related time as required by 2 CFR 200.430(g)(1)(iv).; Responsible Individual: Leanna Pearson, Assistant Finance Director; Corrective Action Plan: The City will set up separate tracking within the job category in the City’s payroll timekeeping software for grants. The employee will split the time in the timekeeping software and add notes describing the activities and grants worked on.; Anticipated Completion Date: 3-4-2026.

Finding number 2025-004 Planned Corrective Action All required semi-annual certifications and or time and effor documentation will be completed and retained. Anticipated completion date 6/30/26 Responsible Contact Person Treasurer, Denise Ketchum

Corrective Actions: • Reinforce expectations through additional training and support for employees and supervisors on the proper preparation and monthly submission of PAR forms. • Strengthen internal review procedures by assigning responsibility for confirming PARs are completed accurately, submitted on time, and signed by both the employee and the supervising administrator. • Ensure PAR documentation is consistently forwarded to Fiscal Services for timely review and any necessary adjustments so payroll charges align with the actual percentages of time worked on Title I activities. Responsible Department/Person: • Educational Services (Federal Programs/Title I) - Program Oversight • Human Resources/Payroll- Payroll Coding Support (as applicable) • Fiscal Services - Compliance Review and Adjustments • Primary Contacts: Siddhant Bhatta (Executive Director of Fiscal Services); Alma Quijas (Fiscal Compliance Manager) Anticipated Completion Date: March 31, 2026

Responsible Person(s): Dale Batten, Deputy Commissioner Rehabilitative Services; Rob Perrine, Information Security Officer Corrective Action Planned: The DARS Information Security Office and the System/Data Owner will continue to remediate the audit findings noted in the IAD audit report on the case management system. In addition, the ISO and System/Data Owner will continue to meet quarterly with Internal Audit to review remediation progress, address implementation challenges, and ensure corrective actions are completed in a timely manner. Estimated Completion Date: 9/30/2026

Responsible Person(s): Clara Harris, Chief Financial Officer/Fiscal Officer Corrective Action Planned: Review 2 CFR 200 § 200.430; send to all Program Area Directors to distribute to their staff. February 28, 2026, CFO/Fiscal Officer to disburse. Develop payroll cost allocation policy and plan for federally funded employees in accordance with federal guidance. Include method of allocation and how it is documented. Also develop monthly reconciliation to do reviews of payroll by March 9, 2026, and present for review. The Grant Manager, Finance Manager and Human Resource Manager (team) will create and review with CFO, CPO and Internal Auditor. Develop written procedures: March 16, 2026, team will write procedures to present to CFO, CPO and Internal Auditor for approval. Training to be held by March 31, 2026 for all program areas via in-person training or team meetings. Coding descriptions will be sent out to all program areas to ensure information of coding on system time sheeting is easily accessed by the employee. Implement plan: Time sheeting will commence in the system on April 10, 2026. Test the implementation: Review results with management. Audit reports to ensure compliance set forth in policy and procedures. May 1- 31, 2026, team reports findings to CFO, CPO and Internal Auditor. Estimated Completion Date: 5/31/2026

2025-003. Payroll and Disbursement (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 Education Stabilization Funds COVID 19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U Condition: As required under Subpart E, 2 CFR §200.403 through §200.405 and §200.430, and Subpart D, 2 CFR §200.302, which require a financial management system to provide effective control over accountability for federal funds, and to identify the source and application of funds. During the year, we noted that the District recorded journal entries transferring payroll and disbursement related expenditures from the General Fund to the Special Aid Fund under the Special Education Cluster and Education Stabilization Funds grant codes. These journal entries lacked adequate supporting documentation to demonstrate approvals and if the costs were allowable and allocable to the applicable federal awards. Consequently, we were unable to obtain sufficient appropriate audit evidence to conclude whether the journalized transactions were properly charged to the federal programs in order to comply with Subpart E, 2 CFR §200.403 through §200.405 and §200.430, and Subpart D, 2 CFR §200.302. Planned Corrective Action: The District will implement procedures to ensure that all payroll and disbursement transactions charged to federal awards through journal entries are properly supported. This will include maintaining original time and effort documentation for payroll, as well as invoices and supporting records for disbursements. Additionally, the District will establish a review and approval process for journal entries transferring expenditures between funds to verify that amounts are allowable, reasonable, and allocable to the appropriate federal awards. Staff will be trained on federal documentation requirements under 2 CFR §200.430 and §200.302 to prevent recurrence and ensure that all financial records support compliance with federal guidelines. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Jean Mingot Assistant Superintendent for Business Southampton Union Free School District 70 Leland Lane Southampton, New York 11968-5089

2025-002. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds COVID 19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U Condition: Subpart I, 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 employees work on more than one Federal award, or a Federal award and non-Federal award. The preparation of payroll verification forms, or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, it was noted that in one instance, the District’s payroll verification form was not reviewed or signed by either the supervisor or employee that was chargedto the grant in order to comply with Subpart I, 2 CFR §200.430. Planned Corrective Action: The District acknowledges the finding and will thoroughly review and maintain the payroll verification forms to ensure each employee’s salary, or other forms of compensation, are properly approved and signed off by the employer and employee. Anticipated Completion Date: June 30, 2026

2025-001. 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 Condition: Subpart I, 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 employees work on more than one Federal award, or a Federal award and non-Federal award. The preparation of payroll verification forms, or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, it was noted that in some instances, the District’s payroll verification forms did not accurately reflect the actual allocation that was charged to the grant in order to comply with Subpart I, 2 CFR §200.430. Planned Corrective Action: The District acknowledges the finding and will thoroughly review and maintain the payroll verification forms to ensure each employee’s salary, or other forms of compensation, charged to the grant corresponds to the federal program to which the employees’ earnings were allocated, based on time and effort, in compliance with Subpart I, 2 CFR §200.430. Anticipated Completion Date: June 30, 2026

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Katie Elliott Contact Phone Number and Email Address: katieelliott@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: While the School Corporation completed the required Time and Effort logs, a time study was not completed and documented to justify the allocation of costs related to the compensation and fringe benefits of the food service director. The School Corporation Food Service Director is now documenting the hours spent each day completing food service activities. Anticipated Completion Date: This Corrective Action Plan will be put in effect January 2026.

Corrective Actions Taken or Planned: Management concurs with the auditor’s assessment that this was a control oversight and a breakdown in the internal control system for payroll documentation, rather than intentional noncompliance. As part of our federal grant closeout efforts, we have taken the following steps to address the deficiency: •After-the-Fact Certifications: As of this response, WETA has obtained ten after-the-factemployee certifications confirming that the payroll allocations for FY 2025 accurately reflectthe effort performed. These certifications are on file and available for review. •Managerial Oversight Confirmation: The Director of Production Operations has provided writtenconfirmation that monthly allocation decisions were discussed with project managers andreflected in payroll actions, though these reviews were not formally documented at the time. •Policy Review and Update: Management is currently reviewing and updating internal policiesto ensure that documentation procedures align with operational practices. These updates willrequire contemporaneous certification and documentation of payroll allocations for any futurefederal or restricted awards. •Training and Controls: We are developing additional training to reinforce documentationexpectations and strengthen internal controls among finance and operational staff. Completion Date: January 31, 2026 Contact Person: Dorian Davis Title: Corporate Controller Phone Number: (703) 998-2216

The agency has verified and concurs with the finding as the payroll expense was inadvertently posted to the incorrect Chartfield. The agency failed to complete the requested journal entry, which was a communication failure within the ASD division. The ASD division has corrected this issue with added communication levels to ensure that more than one person received communication between ASD and agency divisions. The ASD division has implemented better communication lines between the ASD division and the agency divisions which will resolve this issue. With more than one person receiving the information and additional training on ensuring that all reconciling items are addressed timely the agency general ledger will remain clean and in balance with allowable expended posted to the correct Chatfield’s.

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring timesheets and payroll registers to be reviewed and approved, with such review and approval clearly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective January 1, 2026, the process for timesheet review has been updated. Previously, preliminary timesheets were reviewed and approved before payroll was entered into the system. Now, all final timesheets will be reviewed, approved, and cross-referenced with payroll registers to ensure consistency. Any identified errors will be documented and promptly resolved. Name(s) of the contact person(s) responsible for corrective action: Kendra Jones Planned completion date for corrective action plan: January 1, 2026

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring timesheets to be reviewed and approved, with such review and approval clearly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Previously, preliminary timesheets were reviewed and approved before payroll entry, but a signature was not required. The timesheet review process has been updated, effective January 1, 2026. Now, both preliminary and final timesheets require the following steps: 1. Review 2. Approval 3. Signature 4. Conversion to PDF (to prevent alteration). Name(s) of the contact person(s) responsible for corrective action: Kendra Jones, Executive Director Planned completion date for corrective action plan: January 1, 2026

Views of Responsible Officials: Management acknowledges the findings related to Payroll Allocation, and Training & Compliance, as outlined in the recent audit report. We appreciate the recommendations provided and are committed to implementing corrective actions to strengthen compliance, improve payroll allocation accuracy, and enhance staff knowledge of grant management requirements.

FA 2025-001 Strengthen Controls over Employee Compensation Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Allowable Costs/Cost Principles Significant Deficiency Nonmaterial Noncompliance U.S. Department of Education Georgia Department of Education 84.027 - Special Education Cluster Grant to States 84.173 - Special Education Cluster Preschool Grants H027A230073 (Year: 2024), H027A240073 (Year: 2025), H173A240081 (Year: 2025) $1,283 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Special Education Cluster. Corrective Action Plans: The District concurs with the finding and is committed to strengthening internal controls. While the identified discrepancies were isolated, we recognize the need for enhanced reconciliation during personnel transitions. The Human Resources and Finance departments will enhance our review process. This pre-payroll validation step will ensure that all salary adjustments and position changes align with Board authorized pay documentation prior to disbursement. Estimated Completion Date: 3/31/2026 Contact Person: Julie Wiley, Chief Financial Officer Telephone: 229-316-1878 Email: juliewiley@lowndes.k12.ga.us