Corrective Action Plans

FINDING 2025-004 – Payroll Allocations Audit Finding Description: Audit procedures over expenditures revealed the following: For one (1) of forty (40) expenditure transactions tested, The Inner Voice, Inc. did not adequately track or review time and effort documentation for accuracy. For this selection, the time study used to allocate salary did not agree with the actual hours reported and paid. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Corrective Action Plan: Management will enhance policies and procedures related to time and effort reporting by strengthening review and approval processes for payroll allocations and providing additional staff training. These actions will improve consistency and reinforce internal controls over federal awards. Name of Contact Person Responsible for Corrective Action: Khurram Navaid, CFO/ Monika Mader, Exec. Manager Planned Completion Date: January 01, 2026

2025-001 Special Education Cluster - Assistance Listing Number 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 City will implement procedures to ensure time and effort certifications are completed in a timely manner for all payroll costs charged to federal awards in accordance with 2 CFR 200.430. The School Department will establish a standardized process requiring employees and supervisors to complete and approve certifications within a defined timeframe following the applicable payroll period. The School Department will maintain a tracking mechanism to monitor completion and will perform periodic reviews to ensure certifications are submitted timely and accurately to reflect the employee’s total activity. Departments will be notified of any missing or late certifications and required to submit documentation promptly. These procedures will strengthen internal controls and ensure compliance with federal documentation requirements. Name(s) of the contact person(s) responsible for corrective action: Brian Cisneros, Business Administrator Planned completion date for corrective action plan: Implemented immediately and effective for all current and future federal awards.

March 12, 2026 Federal Award Finding: U.S. Dept. Of Education Ellenville Central School District 28 Maple Avenue Ellenville, New York 12428 (845) 647-0115 Corrective Action Plan Pass-through - NYS Education Department Title I Grants to Local Education Agencies (ALN 84.010) Finding 2025-001 - Time and Effort Certifications Criteria - Under 2 CFR §200.430(i), charges to federal awards for salaries and wages must be supported by appropriate documentation that accurately reflects the work performed. Documentation must be signed by the employee or a responsible supervisory official having firsthand knowledge of the work performed by the employee. Condition - During testing of payroll expenditures charged to the Title I program, we noted one instance where the time and effort certification was not signed by the employee. The certification covered services charged to the Title I program during the fiscal year. Cause - The unsigned certification appears to be a result of oversight in the review and approval process for time and effort documentation. Effect - Without a signed certification, the School District cannot demonstrate full compliance with federal documentation requirements for payroll costs charged to the Title I program. This increases the risk that salary costs charged to the program may not be properly supported. Recommendation - We recommend the School District strengthen its review procedures to ensure all time and effort certifications are signed and properly retained prior to submission for payroll processing or federal reporting. Management Response - School District management concurs with the finding and will take corrective action. Corrective Action Plan - Management will review procedures in place over the time and effort certifications and ensure certifications are properly signed and retained prior to submission for payroll processing or federal reporting.

Condition: Of the 6 employees included in the payroll expenditures sample selected for testing, the University did not complete a full, executed review of the effort certifications within the time period outlined for one employee. Planned Corrective Action: A new control has been added to the effort certification process that occurs prior to the distribution of effort reports for certification. The Effort Certification Administrator reconciles a compiled listing of all federal grant effort by employee name from the general ledger to ensure that an effort report is subsequently generated for each qualifying employee who worked on a federal grant during the appropriate period. Contact person responsible for corrective action: Associate Controller Anticipated Completion Date: This new control was implemented for the Fall 2025 effort certification process in January 2026.

Management agrees with the finding. Management has already corrected by reducing the most recent drawdown from HRSA by the amount in question ($6,405). Management will also implement additional review procedures to prevent similar errors in the future.

Finding Reference Number: 2025-001 Federal Agency: U.S. Department of Health and Human Services Program Name: Aging Cluster Assistance Listing Number: 93.044/93.045/93.053 Responsible Official: Penny Crawford, Chief Executive Officer; Kelsey Swinderman, Financial Manager Views of Responsible Individuals: The Agency acknowledges the documentation deficiencies identified related to payroll and contract management. These issues were largely due to leadership transitions and changes in operational processes. The Agency has evaluated these gaps and is actively implementing corrective actions to strengthen internal controls and ensure compliance with Uniform Guidance requirements. Corrective Action Plan: Corrective actions currently in progress include: • Standardizing documentation requirements for all employee pay rates, including maintaining supporting documentation within personnel files • Implementing internal review procedures to ensure payroll changes align with Board-approved actions • Centralizing contract management and maintaining all executed service provider agreements in a secure, accessible location • Establishing documentation retention procedures to ensure all supporting records for federal award expenditures are complete and readily available for audit review The Agency is committed to fully resolving these issues and strengthening internal processes to ensure ongoing compliance and accountability. The Agency is implementing enhanced internal control procedures to ensure that all costs charged to federal awards are properly authorized, documented, and maintained in accordance with federal requirements. These improvements include the development of standardized processes for payroll documentation, contract management, and documentation retention. Internal review procedures are also being strengthened to ensure alignment between Board approvals and financial records. Anticipated Completion Date: June 30, 2026

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.