Corrective Action Plans

Company has, despite lack of prior approval, provided program audits to Agencies in prior audits. These audits were accepted by the GAO and Agencies without a requirement for a single audit. Unless otherwise advised directly by a subject Agency, we will continue to submit program audits as proof of compliance. We received guidance from the USDA and HUD that they do not require an audit, and the CDC funding is a contract, therefore not requiring an audit.

It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all employees to acknowledge in our County Handbook. We will strengthen this control and add this be updated yearly, so that all conflict can be disclosed. Creek County prides itself in moving toward complete transparency and holding each employee accountable to disclose all information needed to make a proper selection of purchases. Creek County Clerk’s Office will work with the District Attorney’s Office for proper language.

Item: 2025-002 Assistance Listing Number: 17.280 Program: WIOA Dislocated Worker National Reserve Demonstration Grants Federal Agency: U.S. Department of Labor Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: 23A60YP000003 Award Year: September 30, 2023 to September 30, 2026 Compliance Requirement: Subrecipeint Monitoring Criteria: A Pass-Through Entity (PTE) is required to monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: (a) reviewing financial and programmatic (performance and special reports) required by the PTE, (b) following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means, and (c) issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR 200.521. Condition: The Foundation did not complete the required subrecipient monitoring related to review of subrecipient Single Audits and financial statements. Specifically, we noted no evidence that the Foundation verified whether certain subrecipients met the Single Audit threshold under 2 CFR 200.501 or obtained the subrecipients’ Single Audit reporting packages from the Federal Audit Clearinghouse. Additionally, the Foundation did not obtain or document a review of the subrecipients’ audited financial statements (or other financial information) to inform the subrecipient risk assessment under 2 CFR 200.332(b). Name of Contact Person Steve Zylstra, President & CEO Phone Number: (602) 422-9447 Anticipated Completion Date: July 31, 2026 Views of Responsible Officials and Corrective Actions: For the current audit period, the Foundation has obtained the missing single audit reports and financial statements and is in the process of completing and documenting the required reviews, updating subrecipient risk ratings and performing any necessary follow-up or management decisions by April 30, 2026. Additionally, the Foundation will establish formal written procedures to comply with 2 CFR 200.332(b), (d), and (f), 2 CFR 200.501, and 2 CFR 200.521, including clear steps and timelines for verifying Single Audit applicability, obtaining and reviewing Single Audit reports, and issuing management decisions when applicable. Lastly, the Foundation will provide periodic training to finance and program staff on subrecipient monitoring requirements under the Uniform Guidance.

2025-001: Insufficient Controls Over Monitoring Federal Expenditures and SEFA Preparation (Significant Deficiency) The City concurs with the finding and will strengthen controls over monitoring federal expenditures and preparation of the Schedule of Expenditures of Federal Awards (SEFA). The Finance Department will implement centralized oversight of federal grant activity and maintain a grant tracking schedule to monitor cumulative federal expenditures by program, including reimbursements and receivables. Departments administering federal programs will be required to report grant expenditures to Finance, and periodic reconciliations will be performed between departmental records, reimbursement requests submitted to the pass-through agency, and amounts recorded in the general ledger. At year-end, the Finance Department will prepare the SEFA and perform a formal management review to ensure all federal expenditures are complete and accurately reported and evaluated against the Single Audit threshold in accordance with Uniform Guidance. Personnel involved in grant administration will receive training on applicable Uniform Guidance requirements to support compliance with federal reporting and monitoring requirements. Anticipated Completion Date: June 2026

Ignacio School District has already taken steps in changing the overall process of managing our Federal Award grants and overall year-end closing entries. The district will be working closely with our new auditors to ensure that Single Audits are completed annually moving forward. Our district has implemented scheduled monthly Requests For Funds and budget reviews for each grant to confirm that the grants are being spent according to their approved applications. The Superintendent and Finance Director meet to review the overall process to ensure grant compliance. This includes, but is not limited to assuring that the district charges a de minimis indirect cost rate and submitting End of Year reports to CDE. The district has assigned responsibility of Federal Grant oversight to new personnel. To assure a segregation of duties, there are three district office personnel involved in the management and oversight of the grants. The district has also been trained on proper closing entry procedures for all year-end closing entries and year-end Annual Financial Reporting of grants.

Corrective Action Planned: The auditee acknowledges that it did not have adequate procedures in place to identify all federal funding sources, track cumulative federal expenditures, and determine the applicability of Single Audit requirements.• Federal Funding Identification Procedures: Establish formal procedures to review all grant agreements, contracts, and funding documents to identify federal funding sources, including Assistance Listing (ALN) numbers and pass-through entity information. • Centralized Tracking of Federal Expenditures: Implement a tracking mechanism ( e.g., spreadsheet or accounting system enhancement) to record and monitor all federal expenditures by program throughout the fiscal year. • Periodic Monitoring of Single Audit Threshold: Perform quarterly reviews of cumulative federal expenditures to determine whether the dollar threshold (currently $1 million) for a Single Audit has been met. • SEFA Preparation and Review Controls: Develop a standardized process for preparing the Schedule of Expenditures of Federal Awards (SEFA), including a supervisory review to ensure completeness and accuracy prior to issuance. • Training and Awareness: Provide training to key personnel involved in financial reporting and grant management on Uniform Guidance requirements, including SEFA preparation and Single Audit thresholds. Anticipated Completion Date: September 30, 2026 Planned Monitoring and Follow-Up: Management will periodically review compliance with the new procedures and controls to ensure that all federal funding is properly identified, tracked, and reported, and that Single Audit requirements are evaluated timely.

2025-002 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D”) Sponsoring Agency: Various – All R&D awards with subrecipients from 1 campus Award Name: Various - All R&D awards with subrecipients from 1 campus Award Number: Various Assistance Listing Title: Various – All R&D awards with subrecipients from 1 campus Assistance Listing Number: Various - All R&D awards with subrecipients from 1 campus Award Year: 2024-2025 Pass-through entity: All pass-through awards for 1 campus with subrecipients The Sponsored Programs Office will implement a new process to ensure all Uniform Guidance reports for all subrecipients of federal funding are reviewed annually to ensure findings affecting our awards are appropriately addressed and that we issue a management decision to the extent applicable. The process will involve setting event reminders on all active subrecipients under federally funded projects to trigger review every 10-11 months regardless of any upcoming amendments. The targeted implementation date is August 1, 2026. For inquiries regarding this finding, please contact Patrick Woods at pjwoods@ucdavis.edu.

Federal Agency: U.S. Department of Health and Human Services State Department/Agency: Kansas Department of Health and Environment Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Award Number and Period: NU50CK000549 (7/1/2019 – 7/31/2027) & NU51CK000384 (8/1/2024 – 7/31/2029) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: Subawards issued by the Kansas Department of Health and Environment (Department) did not include all required subaward information and failed to obtain the Unique Identity ID for all subawards. The Department did not obtain the required audit information (Single Audit or another applicable audit) from its subrecipient during the audit period. Recommendation: We recommend that the Department develop a subaward template that includes all required federal award information and update its procedures and internal controls to ensure that all required federal award information is included in subawards at the time of issuance. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: A subaward template has been created and the ELC program director will ensure that all sub-recipient agreements contain the needed information prior to the start of the budget period. Name(s) of the contact person(s) responsible for corrective action: Sheri Tubach, Deputy State Epidemiologist Planned completion date for corrective action plan: March 9, 2026

The Town should review the restricted reserve requirements and establish a separate account to hold the funds.

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

Program: AL 84.010 – Title I Grants to Local Educational Agencies – Subrecipient Monitoring Corrective Action Plan: The Agency will strengthen both its fiscal monitoring and Single Audit tracking processes to ensure full compliance with 2 CFR §200.332 and §200.501. The Agency will update its fiscal monitoring procedures to ensure timely, well documented, and risk responsive reviews. Key actions include: • Updating the fiscal monitoring SOP to require complete documentation of all procedures performed, including use of the fiscal monitoring worksheet. • Implementing a monitoring calendar with automated reminders to ensure subrecipients are reviewed within the three year cycle and that higher risk entities receive additional attention. • Requiring supervisory review of all monitoring files to confirm completeness and adequacy. • Strengthening documentation standards so that all items reviewed and conclusions reached are clearly recorded. • Providing refresher training to staff on federal cost principles and monitoring expectations. • Introducing standardized naming conventions and consistent terminology aligned with 2 CFR Part 200 to ensure clarity, uniformity, and ease of review across all monitoring files. This includes consistent labeling of subprograms, transaction samples, supporting documentation, and references to applicable regulatory requirements. The Agency will reinforce its Single Audit tracking and verification procedures to ensure accurate identification and documentation of audit requirements. Key actions include: • Creating a standardized Single Audit tracking log capturing fiscal year end, total federal expenditures, audit requirement status, and follow up actions. • Revising SOPs to require documented verification when a subrecipient exceeds the $1,000,000 threshold but reports that no Single Audit is required. • Implementing system alerts to flag subrecipients approaching or exceeding the audit threshold. • Ensuring timely review and documentation of all submitted Single Audits, including any findings and resolutions. • Providing staff training on Single Audit requirements and updated procedures. These actions will strengthen internal controls, improve documentation, and ensure consistent compliance with federal subrecipient monitoring and audit requirements. Contact: Victoria Katzberg, Director of Grants Compliance Anticipated Completion Date: 6/30/2026

Name of Contact Person: Karen Gillis Corrective Action Plan: As mentioned in the corrective action plan for finding 2025-001, we have instructed our attorney’s office to develop language for the new Subaward Agreement outlining a new process for verifying single audit requirements and how we will follow up on any findings identified in audits associated with our subrecipients. Our process will identify the level of risk as well as a criterion for evaluating risk, a timeline for our request and review of audits and a correspondence schedule to include monitoring a subrecipient’s adherence to corrective action plans. In the end, BSFA will have a policy and process to annually assess subrecipient federal expenditures to determine single audit requirements, obtain and review subrecipient audit reports, including follow-up on any findings, document management decision and track corrective action until resolution. Proposed Completion Date: June 30, 2026

FINDING 2025-003 Finding Subject: Teacher and School Leader Incentive Grants – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Teacher and School Leader Incentive Grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

Finding #2025-002 (Late Submission to the Federal Audit Clearinghouse) Responsible Party: Sara Hudson & JCCS PC Anticipated Completion Date: Septemer 1, 2025 (Implemented) Corrective Action Planned: Snowy Mountain Development Corporation has engaged a new audit firm and strengthened management oversight of the audit process and related submission deadlines. Management now actively monitors audit progress, coordinates required deliverables, and tracks federal filing deadlines to ensure timely submission to the Federal Audit Clearinghouse. These procedures have been implemented for the fiscal year ending June 30, 2026. Management anticipates that future Single Audit reports will be completed and submitted in compliance with applicable federal requirements.

Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and formalize subrecipient monitoring procedures to ensure full compliance with Uniform Guidance requirements. Subrecipient agreement templates will be revised to require inclusion of the subrecipient’s Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) for all subawards, in accordance with 2 CFR §§25.300 and 200.332. MOHS has previously developed subrecipient risk assessment and monitoring tools for the Continuum of Care (CoC) program. These tools and procedures will be reviewed, updated as needed, and expanded to apply to all MOHS grants, including HOPWA. This includes documented risk assessments, monitoring plans, and verification that required Single Audit reports are obtained, reviewed, and retained when applicable. MOHS will maintain centralized subrecipient monitoring files containing executed agreements, audit reviews, monitoring documentation, and follow-up actions. Program and fiscal staff will receive training on updated subrecipient monitoring policies and documentation standards to ensure consistent implementation across all funding sources. MOHS will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, MOHS will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOHS will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. MOHS will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: September 30, 2026

Management agrees with the auditor’s finding 2025-01 Subrecipient Monitoring – Audit Verification. The following action will be taken to ensure that the Subrecipient complies with the single audit requirement: • The Finance Director, Kristie Howell, will correspond with the Subrecipient, Grassy Pond Water Company, to clearly state the single audit requirement and due dates. • Cherokee County will request written correspondence from the subrecipient, outlining their course of action and timeline to complete the single audit. • Cherokee County will follow-up with Grassy Pond Water Company on a bi-weekly basis until the 2024 single audit has been submitted, and monthly to ensure that the 2025 audit is being completed as well. • All correspondence will be documented.

State Agency: Office of Mental Health Program Name: Block Grants for Community Mental Health Services ALN #: 93.958 Single Audit Contact: April Wojtkiewicz Title: Director, Office of Community Budget & Financial Management Telephone: (518) 474-5968 E-mail Address: April.Wojtkiewicz@omh.ny.gov Audit Report Reference: 2025-009 Anticipated Completion Date: 3/31/2026 Corrective Action Planned: Office of Mental Health (OMH) updated policies and procedures regarding subrecipient monitoring in March 2025 and will continue to update the federal certification form annually to ensure that all required award identification information is included. Further, OMH initiated an expense report process to review award specific expense reports for the Mental Health Block grant in SFY2024-25. Additionally, while a formalized risk assessment was not conducted, one has been developed to assess subrecipient risk of noncompliance. This risk assessment will be used in conjunction with the review of award specific expense reports to determine those subrecipients that need additional monitoring. Applicable policies and procedures will be updated as appropriate upon completion. Lastly, OMH has adopted a tracking mechanism that will be used to track and review all subrecipient single audit submissions during the upcoming review cycle.

2025-003 Lack of Formal Subrecipient Monitoring Criteria: According to 2 CFR §200.332 (Requirements for Pass-Through Entities), a pass-through entity must monitor the activities of subrecipients as necessary to ensure that federal funds are used for authorized purposes and in compliance with applicable statutes, regulations, and terms and conditions of the Federal award. Required monitoring includes, but is not limited to, the following: a. Reviewing financial and programmatic reports; b. Performing risk assessments of subrecipients; c. Following up on deficiencies identified through audits or reviews; and d. Ensuring subrecipients have required audits under 2 CFR §200.501. Lack of documented subrecipient monitoring constitutes noncompliance with Uniform Guidance. Client Response: While the organization was in constant contact with subrecipients regarding the progress of their programming, those meetings were not transcribed. In the future, the organization will require mid year and year-end impact reports from each grant subrecipient. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444

2025-001 Audit Submissions the Federal Audit Clearinghouse - Significant Deficiency The audit was submitted on time this year, demonstrating that Opportunities, Inc. has addressed the system gaps that affected last year's submission. The corrective action established clear communication points during the audit process and ensured all timelines were followed. Opportunities, Inc. remains dedicated to upholding the highest standards of fiscal responsibility and regulatory compliance.

Finding 2024-012 - Single Audit Reporting Auditee's Response and Planned Corrective Action The Town will work with the accounting department, fee accountant, and audit fmn to file the required reports timely. Planned Implementation Date of Corrective Action: January 2026 Person Responsible for Corrective Action: Fred Costello, Town Supervisor

It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all employees to acknowledge in our County Handbook. We will strengthen this control and add this be updated yearly, so that all conflict can be disclosed. Creek County prides itself in moving toward complete transparency and holding each employee accountable to disclose all information needed to make a proper selection of purchases. Creek County Clerk’s Office will work with the District Attorney’s Office for proper language.

SUBRECIPIENT MONITORING ALN Number 93.558 Temporary Assistance for Needy Families (TANF) 93.489. 93.575. 93.596 Child Care Development Fund (CCDF) 93.568 Low Income Household Energy Assistance Program (LII-IEAP) 2024-039 Strengthen Controls over Subrecipient Monitoring to Ensure Compliance with Uniform Guidance Auditing Requirement . Federal Award No. All Current Active Grants Response : MDHS concurs that controls should be strengthened over subrecipient monitoring to ensure compliance with Uniform Guidance Auditing Requirements. Corrective Action Plan: 1. Strengthen Controls over Subrecipient Monitoring to ensure compliance with Uniform Guidance. A. The Office of Compliance. Division of Monitoring has made significant strides in strengthening controls over the subrecipient monitoring process ensuring compliance with Uniform Guidance Auditing Requirements. The Division continues to review and update the processes and procedures as necessary to ensure processes are adequate and effective. Staff are constantly notified/trained on updates to policies. procedures. and regulations to ensure continued compliance with monitoring the agency's subgrant agreements. B. Responsible Party: Laketha Gilmore. Director of Monitoring and Kameron Harris. Chief Compliance Officer C. Completion Date: The corrective action has been implemented and is ongoing.

TOFMHS concurs with the finding. The agency retained new auditors for the June 30,2024 fiscal year, subsequent to the due date for submission of the data collection reports. Corrective Action to be Taken: The Agency will take all reasonable measures to work with the new auditors to complete the audit process and submit the data collection report within the required time period. Responsible Person: Fiscal Officer/Program Director Completion Date: January 1, 2025

Finding Reference: 2024-004 Views of Responsible Officials and Planned Corrective Actions The Agency agrees with this finding and recommendation as presented. In some contexts, the Agency experienced significant turnover in the Finance department during the third quarter, and a new Finance Director was hired during the fourth quarter of fiscal year 2024. The turnover in fiscal staff hindered the accounting processes and oversight that included journal entry review and postings and account reconciliations promptly. As a corrective measure to ensure adhering to a closing schedule and maintaining timely account reconciliations, the Agency reevaluated the fiscal department’s needs and hired new staff, including a finance director, accounts payable, part-time fiscal support specialist, and contracted with a CPA to assist with the following scope of work:  Review all trial fund balance processes.  Prepare a closing schedule that includes reporting and data processing deadlines.  Reconcile all balance sheet accounts in the general ledger chart of accounts.  Timely prepare and file all financial reports required by each award.  Work with the independent auditor to implement an interim audit fieldwork schedule to reduce required work subsequent to fiscal year-end. Name of the contact person responsible for corrective action: Michael Young, President, (301) 274-4474. Planned completion date for corrective action plan: December 31, 2025

Views of Responsible Officials and Planned Corrective Actions We acknowledge the finding regarding the delayed submission of the FY 2024 Single Audit Report to the Federal Audit Clearinghouse, and we appreciate the opportunity to provide our explanation and corrective action plan. To address this finding and prevent future recurrence, the following corrective actions have been initiated: Hiring of CFO Replacement: A qualified replacement for the Chief Financial Officer has been identified and is currently in the final stages of the hiring and onboarding process. This individual will assume responsibility for financial oversight, including audit preparation and timely submission of compliance reports. Interim Oversight and Delegation: In the interim period, the duties previously overseen by the CFO have been temporarily assigned to the Controller and Chief Executive Officer, with close coordination with the Finance Committee of the Board. This ensures proper oversight and continuity of compliance functions during leadership transition. Revised Internal Calendar and Milestone Tracking: An internal compliance calendar is being updated to reflect all critical reporting deadlines, including those under Uniform Guidance. Key deliverables (e.g., SEFA preparation, audit milestones, report reviews) will be tracked and monitored monthly by management to ensure deadlines are met. Enhanced Communication with Auditors: Management will work closely with external auditors to formalize an earlier schedule for yearend fieldwork, allowing for earlier identification of issues and timely resolution to support ontime audit completion. We have determined that the year-end single audit must start no later than January 31of the end of the year. Internal Controls Improvement: Hillcrest is enhancing its internal control framework (aligned with COSO standards) by documenting audit preparation procedures and establishing written protocols for contingency planning in the event of future staff turnover. Hillcrest Children and Family Center is committed to strong financial management, regulatory compliance, and transparency in all its operations. We view this incident as an isolated disruption resulting from an unanticipated leadership transition and are taking proactive steps to strengthen our internal processes. We are confident that the corrective actions outlined above will ensure timely audit completion and reporting in future years. Name of the contact person responsible for corrective action: Carroll Parks, Chief Executive Officer Planned completion date for the corrective action plan: The corrective action plan is currently active and will be moving forward.