Corrective Action Plans

Audit Finding Reference: 2024-006 Improve Documentation and Controls over Allowable Costs Planned Corrective Action: The Town will implement and enforce procedures to ensure all employees whose salaries or wages are charged to federal grants maintain and retain appropriate time and effort documentation, including timesheets for hourly staff and semi-annual certifications for salaried staff, in compliance with Uniform Guidance. Management has made staff aware of the Time and Effort reporting requirements associated with Federal grants and will work with grant managers and finance department staff to ensure this requirement is implemented during Fiscal 2026; on or about March 18th.

Management acknowledges the importance of ensuring that payroll costs charged to the program are consistent between the payroll system and the employee’s timesheet. The City continues to monitor its internal control process to ensure thorough review procedures are being followed. Timesheets are reviewed, bi-weekly, by payroll and adjusted to reflect actual hours as they relate to a specific activity. The City was able to hire a permanent accountant hiring who will provide additional oversight of these processes ensuring that hours worked are both reported correctly on the timesheets and are following the funding allocations that are approved by the grant.

Management acknowledges the importance of ensuring that payroll costs charged to the program are consistent between the payroll system and the employee’s timesheet. The City continues to monitor its internal control process to ensure thorough review procedures are being followed. Timesheets are reviewed, bi-weekly, by payroll and adjusted to reflect actual hours as they relate to a specific activity. The City was able to hire a permanent accountant hiring who will provide additional oversight of these processes ensuring that hours worked are both reported correctly on the timesheets and are following the funding allocations that are approved by the grant.

Finding 2024-003 Material Weakness in Internal Control over Compliance Name of responsible official: Evan Howard – Business Manager Corrective action: The municipality is in the process of reviewing roles, responsibilities, and job descriptions to ensure appropriate segregation of duties and proper internal controls, in accordance with the Corrective Action Plan. The plan has not yet been formally adopted. Anticipated completion date: June 30,2026

2024-004 – Allowable Costs/Cost Principles – Internal Control over Payroll Expenditures City’s Corrective Action Plan: The City accepts the finding, which resulted from the implementation of a new ERP system for position control, benefits, and payroll that began in 2024 and was completed in 2025. To address the identified conditions, the City will strengthen internal controls over federal payroll allocations by implementing documented reconciliation and review procedures, regularly validating system configuration and allocation files, and establishing processes to identify and correct duplicate or unusual benefit postings. The finding appears to be based on salary charges from two staff members whose time was charged to ESG-related accounts that were not part of their original salary allocation setup. Charging time to accounts outside of original salary allocations is not atypical across City departments and is a common practice when staff responsibilities or work assignments cross funding sources. Executive-time was designed to allow this flexibility so that time charged accurately reflects how staff time is spent. In this instance, the two staff members performed ESG-related activities, and time was charged accordingly to reflect actual work performed. Cross-department internal controls for federal payroll expenditure processing and reporting will be updated, with revisions expected to be completed and tested by 2027. Responsible Person: Payroll & Department(s) Administering Grants Expected Implementation Date: Fiscal Year 2026

Management will implement procedures to ensure payroll costs charged to federal awards are supported by after-the-fact documentation of actual time worked, in compliance with 2 CFR §200.430(i). Employees whose time is allocated to multiple programs will be required to complete time and effort reporting. Payroll processing will include documented review and approval by separate individuals to strengthen internal controls and ensure accurate allocation of personnel costs.

Recommendation We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts. Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on August 8, 2025 - over two years after the end of the June 30, 2023 fiscal year audit), the College did not have the opportunity to review and begin a timely process of addressing a majority of the audit findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the June 30, 2023 audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Corrective Action Taken / Planned: Policy and Procedure Development The institution will revise or develop written policies and procedures to ensure compliance with 2 CFR §200.430. The revised procedures will include: • Detailed requirements for supporting documentation for payroll costs. • Clear guidance on time and effort reporting. • Procedures for periodic payroll reconciliation between payroll records and grant charges. Staff Training Training will be provided for payroll, grants accounting, and department personnel involved in charging payroll costs to federal awards to ensure understanding and compliance with the new procedures. Payroll Reconciliation A process will be established to reconcile payroll charges to the grant with actual payroll records at least quarterly, with reviews and approvals documented. Effort Certification Employees whose salaries are charged to federal grants will be required to complete effort certifications, which will be reviewed and retained per federal guidelines. Monitoring and Review Grant accounting and payroll offices will implement an annual review process to ensure continued compliance and address any gaps or errors identified. Due Date of Completion: August 31, 2025 Responsible Part(ies) Vice President for Business and Finance (or appropriate official), Dean of Business and Finance, Restricted Funds Manager, Payroll Manager

Corrective Action Plan Year Ended September 30, 2024 Finding 2024-001 AL Numbers: 97.036 Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Correction Action: We will identify and quantify the total amount of the labor cost overstatement. We will report our results to the granting agency and work with them to resolve the questioned costs by May 31, 2026. To prevent recurrence, management will revise our review control of project applications to reconcile the calculation file to invoice support to verify accuracy. Contacts: Stephen Almonte, VP of Finance and Corporate Controller Salmonte3@brownhealth.org Mark Adelman, Director Public Policy and Federal Advocacy Madelman@brownhealth.org Planned Completion Date: May 31, 2026

2024-005: Coronavirus State and Local Recovery Funds - Assistance Listing Number 21.027; Pass-through from State of Geogia Office of the Governor and Dekalb County; Grant Period: Year Ended December 31, 2024 Planned Corrective Action Description of Corrective Action: 1. BBBSMA Accounting will set up a monthly validation process that is signed off by the CFO that the grant payroll allocation is reconciled to the time sheets for each grant billing. Overall Completion Target Date: [03/31/2026] How Effectiveness Will Be Monitored: 1. Monthly validation of grant payroll to timesheets should be signed off by 20th workday after every month and scanned into the accounting grant file on the system. Responsible Person: CFO/VP Finance and CEO in lieu of CFO.

FA 2024-001 Improve Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Activities Allowed or Unallowed Allowable Costs/Cost Principles Reporting Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund S425D210012 (Year: 2021), S425U210012 (Year: 2021) $819,799.49 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: The Hancock County School District has updated the policies and procedures to ensure that these coding errors do not occur in the future. The updates included but are not limited to: The District has corrected the coding in the general ledger for FY 26 and has implemented additional coding cross-checks to ensure alignment with the approved Con App. The function/object coding has been corrected in the FY 26 budget crosswalk, and coding protocols have been reinforced. Personnel coding has been corrected, and a verification procedure is now in place at the point of hiring and funding assignment. The Federal Program department will meet with the Finance Department to review funding codes prior to submission. Estimated Completion Date: June 30, 2026 Contact Person: Matthias Jones, Finance Director Telephone: 706-444-5775 ext. 125 Email: mjones@hancock.k12.ga.us

2024-002 Payroll Costs Contact Person – Erin Metcalf, Finance Director Description of Corrective Action – Training has been provided and currently the payroll allocations are matched to weekly payroll reports from outside payroll company. Allocations of vacation and sick time are done according to actual payroll reports and entered into accounting software based on true numbers instead of tracked on a spreadsheet. Completion Date – June 30, 2025 Root Cause – Outdated procedures in place.

Management will implement a revised methodology for allocating payroll costs to Federal awards whereby all employees will record their time spent on Federal awards on their biweekly time cards.

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

The department will adopt written policies with the Uniform Guidance for federally funded grant programs accepted by the department.

U.S. Department of the Treasury Department of Housing and Community Development respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023-June 30, 2024 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 PROGRAMS AUDITS Department of Housing and Community Development 2024-014 COVID-19 – Emergency Rental Assistance Program – Assistance Listing No. 21.023 Recommendation: We recommend that the Department review and enhance supervisor review and approval to ensure that program requirements are consistently performed. Documentation to support compliance with the requirements should be maintained and readily available for review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The subrecipient who administered the assistance for three (3) of the four (4) affected records has fully expended ERA 2 funds. DHCD will review the subrecipient’s internal approvals process and tenant notification process to determine where improvements can be made and issue recommended recordkeeping changes for the subrecipient to implement for future federal subawards. DHCD will review and make necessary changes to program policy guides as necessary to strengthen case file recordkeeping requirements and ensure that case file reviews for direct financial assistance programs include a review of notifications to clients. In prior desk monitoring and file audits, the relevant subrecipient files always included a notification of assistance to the tenant. Name(s) of the contact person(s) responsible for corrective action: Danielle Meister Planned completion date for corrective action plan: April 30, 2025 2024-015 COVID-19 – Homeowner Assistance Fund – Assistance Listing No. 21.026 Recommendation: The Department should reevaluate current process, implement proper controls, and perform additional training over time and effort reporting. The Department should not seek federal reimbursement unless they can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Monthly reporting to Senior Management of any exceptions to the federal timesheet process will be required to ensure that all federal timesheets are completed and received in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Wade Simmons Planned completion date for corrective action plan: April 30, 2025 If the U.S. Department of the Treasury has questions regarding this plan, please call Crystal Quinzani at (301) 429-7840.

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.