Corrective Action Plans

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.

The Institute has engaged an auditor to complete the December 31, 2022, 2023, 2024, and 2025 Single Audits concurrently, and will submit each reporting package and data collection form to the Federal Audit Clearinghouse as each audit is completed. Thereafter, the Institute will complete the audit and submit the reporting package within nine months after year end. Anticipated completion date: December 31, 2026. Responsible contact person: Kathy Walker, Executive Director.

D. Corrective Action Plans Finding Reference: 2024-001 Views of Responsible Officials and Planned Corrective Actions The organization agrees with this finding. The organization experienced turnover in its finance department in the third quarter of the 2024 fiscal year. The turnover in fiscal staff made it challenging to close out the 2024 fiscal year from a financial standpoint. As a corrective measure, the agency hired a new accounting firm at the end of the 4th quarter of the 2024 fiscal year. The new accounting firm was able to reconcile all bank statements for the 2024 fiscal year, fully automate the organization’s accounting system and create reliable financial statements and reports. The organization’s leadership in conjunction with the new accounting firm also instituted a process for reconciling income and expenses on a monthly basis and reviewing all financial data on a quarterly basis including the preparation and review of the organization’s profit and loss statements and balance sheets. Name of the contact person responsible for corrective action: Travis Hardmon, President, (202) 462- 3636 Corrective action completed as of: October 31, 2025. Auditor’s Note: The stated completion date for the corrective action plan is based on the Agency's representation. The implementation of these corrective actions has not been audited by the auditors and will be subject to review during the next audit period.

Planned Corrective Action: We understand the severity of the finding and will maintain a Schedule of Expenditure of Federal Awards to be updated at month-end close as well as documented timesheets for all staff included in the expenditures list. This will be accomplished by providing training for procurement, finance, and administrative staff on: . Recognizing when a transaction exceeds the threshold. . Collecting and organizing supporting documentation. Valley Health Associates shall conduct periodic audits to: . Review SEFA report. . ldentify gaps or missing documentation and correct them promptly. . Document findings and corrective actions.

Finding Reference: 2024-003 Views of Responsible Officials and Planned Corrective Actions Management acknowledges that the Single Audit reporting package (including the Data Collection Form) was not submitted to the Federal Audit Clearinghouse within the timeframe required by 2 CFR 200.501, due to delays in completing account reconciliations and finalizing the Schedule of Expenditures of Federal Awards. Management concurs with the finding and is implementing the following corrective actions: 1. Adopting a formal year-end closing and audit timeline that works backward from the required Single Audit submission deadline (the earlier of 30 days after receipt of the auditor's report or nine months after the end of the audit period), with interim deadlines for reconciliations, SEFA preparation, and audit fieldwork. 2. Engaging with the independent auditor earlier in the process to confirm fieldwork and reporting timelines and to identify potential delays before they affect the filing deadline. 3. Assigning management responsibility for monitoring progress against the closing timeline and escalating any anticipated delays to the Board in advance of the due date. Management is committed to submitting future Single Audit reporting packages within the required timeframe. Name of the contact person responsible for corrective action: Kristina Noell, Executive Director, (202) 897-5060 Planned completion date for corrective action plan: August 5, 2026. Auditor’s Note: The stated completion date for the corrective action plan is based on the ABID's representation. The implementation of these corrective actions has not been audited by the auditors and will be subject to review during the next audit period.

The County acknowledges the delay in submitting the Data Collection Form within the required timeframe. The delay was primarily attributable to unresolved financial data and reconciliation issues resulting from the September 2023 transition to the Workday ERP system. Additional time was necessary to resolve these issues and ensure accurate financial information was provided for the audit and subsequent filing. The County continues to strengthen reconciliation and year-end closing procedures and refine processes within Workday. With these improvements, the County anticipates the 2025 audit and related filings will be completed within the required timeframes.

Reference Numbers: 2024-001, 2023-001, and 2022-001 Federal Program: Direct - USDA Rural Utilities Service award; ALN 10.760, 'Water and Waste Disposal Systems for Rural Communities' (Single Audit / Uniform Guidance).Condition: The Great Northwest Wholesale Water Commission did not complete and submit its reporting package, including the SEFA and the single audit report, to the Federal Audit Clearinghouse within nine months of the fiscal year end. Criteria: Under 2 CFR §200.512, the audit must be completed, and the data collection form and reporting package must be submitted within 30 calendar days after receipt of the auditor's report, or nine months after the fiscal year end, whichever is earlier. Corrective Action Plan: Management acknowledges the finding and has implemented procedures to improve the timely completion and submission of the data collection form to the Federal Audit Clearinghouse. Management has engaged an audit firm to complete the December 31, 2022, 2023, and 2024 audits and will submit the reporting package to the Federal Audit Clearinghouse upon completion. Management will coordinate with the auditors throughout the audit process, monitor applicable reporting deadlines, and establish internal timelines to ensure the audit report and data collection form are submitted within the required time frame prescribed by 2 CFR 200.512(a). Personnel responsible for Corrective Action: Jerri Dearmont, Executive Director Anticipated Completion Date: August 18, 2026

Finding Number 2024-014 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) partially concurs with these findings. • OMES disagrees that they had sufficient and timely notice to make full corrective actions prior to this FY2024 audit for the following reasons: the FY2021 State auditor & Inspector (SAI) audit was released four days prior to the beginning of FY2024, the FY2022 SAI audit was released near the end of FY2025, and the FY2023 audit was released in FY2026; therefore, OMES could not take corrective action prior to the FY2024 audit began. At the beginning of FY2025, OMES began corrective measures as noted in SAI’s Condition and Context in this finding. • OMES acknowledges OMES subrecipient monitoring process lacked the strength and consistency to ensure subrecipients established and maintained effective internal control. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI as noted in SAI’s Condition and Context in this finding. Beginning with FY2025, OMES has taken the following measures:  Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience.  OMES ensured that the subrecipient agreement included all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) executed an updated Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies.  OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed.  OMES-GMO has in place a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements.  Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMESGMO conducted bi-weekly monitoring meetings with CFO and reviewed documentation provided by CFO to ensure all ERA projects were eligible under the ERA guidelines and that CFO exercised the proper oversight over their subrecipients and spending. Anticipated Completion Date Completed Responsible Contact Person Brandy Manek

Concur: · 8 instances where the Government was unable to obtain Quarterly Progress Reports. As a result of the audit finding and in accordance with grant requirement, a Governor's Authorized Representative (GAR) Memo is being implemented, requiring Subrecipients to submit Quarterly Progress Reports within 10 days of quarter end. All reports are reviewed and retained in a centralized location for documentation and audit compliance. · 8 instances where the Government was unable to obtain completion/inspection certificate. Project inspection/certification report(s) are now required for all payment request federal fund drawdowns. The reports must now be uploaded to the Enterprise Resource Planning System (ERP) and retained in centralized location for documentation and record keeping purposes. · 8 subrecipients with no supporting documentation that VITEMA verified that subrecipients expected to be audited as required by 2 CFR part 200, subpart F. The Program will annually notify subrecipients of their audit responsibilities, monitor compliance, obtain required audit reports, and maintain documentation in a centralized location for audit and recordkeeping purposes.

The Government concurs with the auditor’s findings and recommendations. Corrective action plan as follows: - Develop subrecipient monitoring policies (2 CFR 200.331–200.332) - Conduct risk assessments - Monitor financial and performance reports - Establish tracking system - Require follow-up on audit findings

To address this finding, OMB will strengthen its subrecipient monitoring controls and formalize procedures to ensure compliance with 2 CFR 200.303 and 2 CFR 200.332, including requirements related to identifying subawards, assessing subrecipient risk, documenting monitoring activities, following up on deficiencies, and maintaining evidence of supervisory review. OMB will also conduct periodic internal quality control reviews of subrecipient files to confirm that monitoring documentation is complete, timely, and consistent with federal requirements.

The Government concurs with the auditor’s findings and recommendations. DPNR’s subrecipient monitoring records and supporting documentation were maintained in multiple locations and were not consistently centralized in a manner that readily demonstrated compliance with Federal subrecipient monitoring requirements. In addition, DPNR did not maintain a comprehensive master listing of subrecipients that incorporated all information necessary to support risk assessments, monitoring activities, and audit requests. DPNR with the support of the federal agency’s consultant will implement a centralized electronic repository system to serve as the official recordkeeping location for all sub recipient supporting documentation. This repository will house all documents necessary to determine if a vendor is at high risk, if they are required to be audited and monitoring, including but not limited to: • A master listing of all subrecipients for each fiscal year; • Subaward agreements and any modifications; • Required subaward information pursuant to 2 CFR §200.331(a); • Subrecipient risk assessments and supporting documentation; • Financial and programmatic reports submitted by subrecipients; • Monitoring plans and monitoring reports; • Documentation of desk reviews and on-site monitoring, where applicable; • Audit reports, Single Audit reports, and management decisions; • Documentation of corrective actions and follow-up activities; and • Correspondence and any additional records necessary to demonstrate compliance with Federal requirements.

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.

Finding 2024-003 - Subrecipient Monitoring Contact Person Responsible for Corrective Action: Danny Yost Contact Phone Number: 812-285-6221 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County will obtain all subrecipient audit reports and formally document their review of each subrecipient's audit report. Anticipated Completion Date: October 2025

Finding Reference Number: 2024-002 Condition Found: The Organization expended more than $750,000 in federal awards during the fiscal years ended December 31, 2022 and December 31, 2023, but did not have Single Audits performed for those periods. Recommendation: The auditors recommend the Organization establish procedures to monitor annual federal award expenditures and ensure timely compliance with Single Audit requirements. Corrective Action Planned: Management acknowledges that the Organization did not comply with the Single Audit Act requirements for the fiscal years ended December 31, 2022, and December 31, 2023. This was due to a lack of awareness regarding the Single Audit threshold requirements. The Organization has taken the following corrective actions: 1. Quarterly Review of Federal Expenditures: Internal procedures have been implemented to review federal expenditures quarterly to determine whether the Single Audit threshold of $750,000 (increased to $1,000,000 for fiscal year 2025) has been met. 2. Designation of Compliance Officers: The Director of Accounting and the Director of Finance have been designated as responsible for monitoring compliance with 2 CFR §200.501 and ensuring auditors are engaged annually. 3. Compliance Calendar: A compliance calendar has been established to track key federal filing deadlines, including submission of the Data Collection Form and reporting package to the Federal Audit Clearinghouse. 4. Agency Notification: The Organization will contact the relevant federal awarding agencies to inform them of the missed audits for 2022 and 2023 and to seek guidance on any required remedial actions. Responsible Contact Person: Nikel Davis, Director of Accounting Anticipated Completion Date: October 15, 2025

FINDING 2024-003 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Subrecipient Monitoring Contact Person Responsible for Corrective Action: Gretchen Parker Contact Phone Number and Email Address: 765-648-6113 gparker@cityofanderson.com Views of Responsible Officials: "We concur with the finding." Description of Corrective Action Plan: The city has several individuals involved in the monitoring of activities related to the COVID 19 Coronavirus State and Local Fiscal Recovery federal award. The city has implemented procedures to ensure oversight and review of subrecipient reports is properly documented. Anticipated Completion Date: September 1, 2025