Corrective Action Plans

Finding Number: 2025-001 Anticipated Completion Date: March 14, 2025 Responsible Contact Person: Stephen Thomas, CEO Planned Corrective Action: TASC of Southeast Ohio has reviewed all personnel files to ensure that all approved rates are included in the files. Internal controls surrounding the documentation of approvals of timesheets and pay raises have been implemented.

2025-005 – Allowable Costs/Cost Principles: Lack of Time and Effort Report Certification and Lack of Timesheets Cluster: Not applicable Sponsoring Agency: United States Agency for International Development (USAID) Award Name: USAID Foreign Assistance for Programs Overseas Award Number: 7200AA19CA00018 Assistance Listing Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: ALN 98.001 Award Year: 2024-2025 Pass-through entity: Not applicable Compliance Requirement: Allowable Costs/Cost Principle The current process of annual effort certification is based on the federal fiscal year, with reports created in November and certification due on January 28. During testing, one out of forty reports was not certified. Monitoring of uncertified reports is performed year-round, monthly during the year and weekly during the certification period (mid-November through January). To address this, the campus will implement system and process improvements through the transition to a new effort reporting platform. The campus is currently in the process of changing effort reporting platforms, which will enhance monitoring and certification controls. The updated system will allow for more regular oversight from the PI as they will have access to a dashboard providing a year-round view of payroll expenditures on their projects, which is expected to improve oversight and timely certification. Implementation of the new effort reporting platform is expected to go live in September 2026. During field testing 14 hourly employee timesheets selected were not available. Timesheets are held at the department level, and due to the termination of USAID funding, administrative positions responsible for retrieving these timesheets were no longer available. Due to the unique circumstances surrounding the termination of the USAID awards, the central office was unable to retrieve reports as a result of the loss of departmental administrative staff. To address this, effective immediately the central office will request the archiving and accessibility of documents upon receiving termination notices. All other archiving will follow the University’s record retention policies as outlined in University policy. For inquiries regarding this finding, please contact Mario Reina-Guerra at mreinaguerra@ucdavis.edu.

Finding 2025-002: Significant Deficiency in Internal Control over Compliance – Allowable Costs Corrective Action Plan: With the implementation of the new UKG Payroll system in January 2026, the timesheet process now systematically reflects the ability for individuals to track time spent on individual grants when completing their timesheet. Name of Person Responsible for the Corrective Action Plan: Francene LaPoint, Chief Financial Officer and Brandon Wheatly, University Controller Anticipated Completion Date: January 30, 2026

Finding 2025-003, Timesheet - Timekeeping (Assistance Listing 16.575 and 93.958) Persons Responsible: Irene Math, Chief Financial Officer; Shannon Van loon, Chief Operating Officer Comment: Per 2 CFR § 200.430 requires that the distribution of salary and wages charged to federal awards be based on actual employee activity as reflected in personal activity reports (timesheets), prepared after-the-fact, that include the total activity for which employees were compensated. Response: In January 2025, WJCS implemented an automated time and attendance system for staff to track time which integrates with the payroll and financial systems to ensure appropriate allocations to Federal awards. Prior to implementation of the new system weekly manual timesheets were used to track staff time and attendance on Federal contracts. However, these manual timesheets were not integrated into a standard agency-wide payroll processing system. The new system enhancements to payroll tracking will allow WJCS to completely and accurately allocate payroll costs to grants with fewer mechanical steps which increase the risk of miscalculations. Management will continue to monitor the automated timekeeping system through periodic supervisory reviews and payroll-to-grant allocation reconciliations to ensure ongoing compliance with 2 CFR §200.430. Estimated Completion Date: The agency-wide time and attendance system was implemented in January 2025.

The Department of Environmental Services respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency Performance Partnership Grants – Assistance Listing No. 66.605 Disposition of Audit Finding: The Department of Environmental Services agrees with the audit finding. Corrective Action: According to (g),(vii),(B) Significant changes in the related work activity (as defined by the recipient's or subrecipient's written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; Many DES staff will work on multiple grants, and effort between grants may change from week to week. Reviewing the effort compared to amounts charged to a Federal grant for a single pay period may not be an accurate reflection of what the DES employees work over the life of that grant award. Reconciliations between payroll and effort occur over the life of the grant to ensure that all charges applied are reasonable and support the overall goal of the project on the longer term. To support this effort, budget staff will perform more periodic reviews of effort as compared to funding to identify situations where the difference between payroll and effort recorded are not on track to support the overall charges to a federal award. Anticipated Completion Date: Processed started July 1, 2025 and will ongoing. Simon Li will be responsible for corrective action: • Simon Li at 803-898-3443

The South Carolina Department of Environmental Services (SCDES) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency 2025-017 Drinking Water – Assistance Listing No. 66.468 Disposition of Audit Finding: The SCDES concurs with the audit finding. Corrective Action: According to (g),(vii),(B) Significant changes in the related work activity (as defined by the recipient's or subrecipient's written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; Many DES staff will work on multiple grants, and effort between grants may change from week to week. Reviewing the effort compared to amounts charged to a Federal grant for a single pay period may not be an accurate reflection of what the DES employees work over the life of that grant award. Reconciliations between payroll and effort occur over the life of the grant to ensure that all charges applied are reasonable and support the overall goal of the project on the longer term. To support this effort, budget staff will perform more periodic reviews of effort as compared to funding to identify situations where the difference between payroll and effort recorded are not on track to support the overall charges to a federal award. Anticipated Completion Date: Will have to be ongoing Budget and Program staff will be responsible for the corrective action plan. Simon Li 803-898-3443

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency has added additional quality control measures within the approval process, is hiring an additional staff member who will be responsible for auditing personnel actions and personnel files, and has implemented monthly audits in addition to the current standard of annual audits. Anticipated Completion Date: 6/30/2026 Name of the contact person responsible for corrective action: Robert Faulk at 803-299-4337

Significant Deficiencies 2024-001. 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. Current Status: The District has not implemented revised procedures to document after-the-fact personnel activity records for salaries and wages charged to federal awards, as required by 2 C.F.R. § 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.

Allowable Costs/Activities Allowed or Unallowed Federal Financial Assistance Listing 15.042 Indian School Equalization Significant Deficiency in Internal Control over Compliance and Immaterial Instances of Noncompliance Findings Summary: During the course of the engagement, Eide Bailly LLP identified an expenditure where payroll benefits were not paid in accordance with the employment letter. Responsible Individuals: Trevor Gourneau, Superintendent Corrective Action Plan: The School will review internal controls surrounding allowable costs and activities to exsure they are adequate to identify unallowable expenditures. Anticipated Completion Date: June 30, 2026

Management concurs with Finding 2025 - 4 and acknowledges that controls over the review and approval of timecards for federally funded staff were not consistently applied. In response, we will reinforce timekeeping expectations, clarify roles, and ensure that policies and procedures are aligned with 2 CFR § 200.430. We will conduct targeted training for supervisors to reinforce expectations. Central office monitoring will now include quarterly internal audit reviews and follow-up, creating a continuous feedback loop that supports compliance. These enhancements reflect management’s commitment to ensuring that payroll charges to federal programs are accurate, well supported, and reliably documented going forward.

CFDA NUMBER 84.010A – Title I Grants to Local Educational Agencies US Department of Education – 2025 Passed Through Arizona State Department of Education Project Number: 25FT1TTI-510414-01A Finding: Unallowable Personnel Costs Charged to Federal Grant Description of Finding During the fiscal year, the school received reimbursement through a federal grant for services performed by an Instructional Assistant. It was subsequently identified that for a portion of this period the employee was temporarily reassigned to perform substitute teacher duties. Substitute teaching services are not an allowable activity under the federal grant for this position. As a result, a portion of payroll costs were inadvertently charged to the federal program. Corrective Action Taken The school conducted a review of payroll records and staff assignments to determine the time period during which the Instructional Assistant performed substitute duties. The payroll costs associated with that period have been identified and were removed from the federal grant and reclassified to an appropriate non-federal funding source. If applicable, the school will reimburse the federal program for any disallowed costs. Documentation supporting the adjustment and calculations will be maintained for audit and monitoring purposes. Steps to Prevent Recurrence To prevent similar issues in the future and ensure compliance with federal grant requirements, the following procedures will be implemented: School administration will notify the HR and finance office whenever federally funded staff are reassigned to duties outside the scope of the grant. The Payroll and HR administrators will review payroll allocations and staff assignments prior to submitting federal reimbursement requests.Time and effort documentation will be maintained for federally funded personnel to ensure that activities performed align with allowable grant requirements. Administrative and finance staff will be reminded of federal grant compliance expectations related to allowable personnel costs and documentation. Monitoring Process The payroll administrator will conduct periodic internal reviews of payroll allocations and federal reimbursement requests to confirm that personnel costs charged to federal programs align with documented duties and allowable activities. Any discrepancies identified will be corrected prior to submitting reimbursement requests. Responsible Parties School Administration and Payroll Administrator Implementation Date These procedures are effective immediately and will apply to all future federal grant reimbursement requests

CFDA NUMBER 84.010A – Title I Grants to Local Educational Agencies US Department of Education – 2025 Passed Through Arizona State Department of Education Project Number: 25FT1TTI-510397-01A Finding: Unallowable Personnel Costs Charged to Federal Grant Description of Finding During the fiscal year, the school received reimbursement through a federal grant for services performed by an Instructional Assistant. It was subsequently identified that for a portion of this period the employee was temporarily reassigned to perform substitute teacher duties. Substitute teaching services are not an allowable activity under the federal grant for this position. As a result, a portion of payroll costs were inadvertently charged to the federal program. Corrective Action Taken The school conducted a review of payroll records and staff assignments to determine the time period during which the Instructional Assistant performed substitute duties. The payroll costs associated with that period have been identified and were removed from the federal grant and reclassified to an appropriate non-federal funding source. If applicable, the school will reimburse the federal program for any disallowed costs. Documentation supporting the adjustment and calculations will be maintained for audit and monitoring purposes. Steps to Prevent Recurrence To prevent similar issues in the future and ensure compliance with federal grant requirements, the following procedures will be implemented: School administration will notify the HR and finance office whenever federally funded staff are reassigned to duties outside the scope of the grant. The Payroll and HR administrators will review payroll allocations and staff assignments prior to submitting federal reimbursement requests. Time and effort documentation will be maintained for federally funded personnel to ensure that activities performed align with allowable grant requirements. Administrative and finance staff will be reminded of federal grant compliance expectations related to allowable personnel costs and documentation. Monitoring Process The payroll administrator will conduct periodic internal reviews of payroll allocations and federal reimbursement requests to confirm that personnel costs charged to federal programs align with documented duties and allowable activities. Any discrepancies identified will be corrected prior to submitting reimbursement requests. Responsible Parties School Administration and Payroll Administrator Implementation Date These procedures are effective immediately and will apply to all future federal grant reimbursement requests

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