Corrective Action Plans

Compliance Requirement: Other – Inaccurate reporting of the Schedule of Expenditures of Federal Awards Campus: Sacramento, Sonoma Recommendation: KPMG recommends the University implement a system of internal control that is designed and operating effectively to ensure the SEFA is complete and accurate. Corrective Action Plan: California State University, Sacramento The University concurs with the recommendation. The University will review and enhance its procedures and internal controls to ensure the SEFA is complete and accurate. Estimated Completion Date: July 2026 Contact person: California State University, Sacramento Tabitha Leeds Senior Director of Accounting Services (916) 278-4679 leeds@csus.edu Corrective Action Plan: Sonoma State University The University concurs with the recommendation. The University will review and enhance its procedures and internal controls to ensure the SEFA is complete and accurate. Estimated Completion Date: July 2026 Contact person: Sonoma State University David Crozier Associate Vice President, Financial Services (707) 664-3442 david.crozier@sonoma.edu

Condition: Controls were not in place to ensure that the schedule of expenditures of federal awards (SEFA) was complete and accurate. Planned Corrective Action: The Village has hired an outside contractor to assist with review of audit documents. Contact person responsible for corrective action: Penny Ray Anticipated Completion Date: 12/31/2025

Finding Reference: 2025-002 - Special Tests and Provisions — Accountability for USDA Foods— Questioned Costs: None Responsible Person: Todd Frease, CFO Actions & Timelines: 1. Valuation Policy (within 30 days from report issuance): Adopt an approved USDA valuation method (WBSCM price or rolling average) and document the policy. 2. Formal Inventory SOPs (within 60 days of report issuance): Issue written SOPs covering count preparation, reconciliation, and documentation retention per 7 CFR §250.19. 3. Training (within 60 days): Train finance and inventory staff on valuation requirements and new SOPs. 4. Annual Monitoring (ongoing): Review valuation application and inventory reconciliations annually and report results to leadership. Anticipated Completion Date: Initial policy and SOPs within 60 days of report issuance; ongoing monitoring thereafter.

Finding Number: 2025-002 Condition: Lakeland did not have adequate controls in place to ensure the SEFA was prepared to include appropriate expenditures for the Economic Development Cluster in the proper period. Planned Corrective Action: The College will establish the proper controls to ensure that the SEFA is prepared based on the timing of the underlying activity rather than payment dates. Contact person responsible for corrective action: David Cummins, Vice President for Administrative Services and College Treasurer Anticipated Completion Date: December 2025

Recommendation: We recommend management establish an informal procedure to reconcile grant funds received with funds expended on a regular basis. We also recommend management implement a formal procedure to reconcile the SEFA with the general ledger at year end. Corrective Action: The Comptroller will reconcile this report on a monthly basis making sure that all grants and other Federal / State expenditures are on the SEFA and that the two numbers reconcile with the general ledger. This will be kept in a notebook and the calendar kept in the Comptroller’s desk. The Comptroller will also create a folder in the business office folder on the server and input the current SEFA in this folder and show any discrepancies on a monthly basis and every time this report is run for drawdowns. This process will start immediately. The Comptroller will also make sure at year end that all items are on this report and they have been reconciled with the general ledger. This process will also be in the notebook and calendar within the desk of the Comptroller.

The Authority will consider implementing the recommendation. The Authority is actively working on rectifying the finding.

Management plans to develop proper written policies and procedures for internal control over compliance to ensure accuracy and completeness in the preparation of the schedule as required by Uniform Guidance.

While PCRI does have systems in place to adequately track federal expenditures, the preparation of the schedule of expenditures of federal awards was delayed in large part due to the deficiencies outlined in Finding 2024-001, which led to delays in accurately compiling the information required for the schedule of expenditures of federal awards. The transition of relevant accounting processes to the outsourced accounting firm will resolve this deficiency going forward. The timeline for full transition of relevant accounting processes to the outsourced accounting firm which started in January of 2025 was approximately twelve months due to the complexities of PCRI’s operations. PCRI has completed this transition as of December of 2025.

2024-001 – SEFA REPORTING Recommendation: We recommend that the Organization implement additional controls over financial reporting, including the SEFA, to ensure accuracy of financial data. Action Taken: • RVCDS will utilize a checklist, updated monthly by the Director of Finance, to track federal awards received. o The checklist will be reviewed quarterly by the Compliance Specialist and/or Director of Compliance. • The Director of Finance will complete a reconciliation between grant records and the general ledger quarterly to ensure all federal awards are captured. o Reconciliation reports will be reviewed by the Executive Director. o The Compliance Specialist and the Director of Compliance will review the reconciliation reports each quarter for accuracy. • A SEFA checklist will be created that includes assigned monthly, quarterly and year end responsibilities. The checklist will indicate each position’s assigned responsibilities and due dates for entries and compliance reviews. • The following staff will attend training on SEFA requirements under 2 CFR 200.510(b): o Executive Director o Director of Operations o Director of Finance o Director of Compliance o Compliance Specialist o Finance Clerks

Finding #2024-003: Internal Control Over Compliance and SEFA Reporting Contact Person Responsible: Jennifer Patrick, Project Manager Milk River Joint Board of Control Corrective Action Planned: 1. Develop SEFA preparation procedures, including grant identification, Assistance Listing Number verification, and reconciliation to the general ledger. 2. Establish a dual review process where the SEFA is reviewed and approved by a party independent of the preparer prior to submission to auditors. 3. Perform an annual reconciliation of SEFA totals to audited financial statements before audit fieldwork. Completion Date: This item was corrected during the 2024 audit process. A tracking spreadsheet has been implemented for 2025 to ensure proper identification, classification, and reporting moving forward. This control will remain in place as an ongoing activity for all federal funding to ensure continued compliance with reporting requirements. Disagreement with Finding: MRJBOC agrees with the finding; however, we would like to clarify that the reporting discrepancy was primarily the result of timing and classification factors. Specifically, certain funding initially received through the State of Montana was not identified as federal pass-through funding until after the SEFA was completed. Once it was determined that the funding required federal reporting under SEFA guidelines rather than state grant reporting, adjustments were necessary to properly reflect the award information. MRJBOC recognizes the importance of accurate grant identification and reporting and will implement the corrective actions outlined to strengthen internal controls, grant tracking procedures, and SEFA preparation processes moving forward. We have also taken steps to ensure a clear understanding of the findings and will continue to monitor and address them in future fiscal years. I certify this Corrective Action Plan has been prepared in accordance with 2 CFR §200.516 and addresses all audit findings for the year ended December 31, 2024.

Refugee and Entrant Assistance State Administered Programs – Assistance Listing No. 93.566 Recommendation: We recommend that the Department review and enhance its reporting procedures and internal controls to ensure that expenditures reported on the SEFA are accurate Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Department has made changes in the Office of Budget and Finance Leadership team and continues to do so at every level. The Department will review and enhance its reporting procedures and internal controls to ensure that expenditures reported on the SEFA are accurate. Currently, expenditures are recorded in the State’s Financial Management Information System (FMIS) with program cost accounting codes used to identify the funding source(s) for each activity. The system-generated report summarizes the information and includes the effective date of the activity. In turn, this same report is used to run the cost allocation to charge the exact costs to the funding source properly. Currently, information is manually inputted into multiple spreadsheets to prepare the federal reports and SEFA resulting in the possibility for errors. This significantly impedes the accuracy of the data being reported to federal grants and the provision of supporting documentation. As such, the Department will partner with external consultants to develop a better and more seamless recording structure for grant expenditures to the general ledger. This structure will require quarterly review by the Deputy Cost Allocation Revenue Management Director (CARM), the Cost Allocation Revenue Management Director, and the Deputy Chief Financial Officer. The Department will create a database and document repository to track the submission and reconciliation for federal grant reporting. The document repository will include the FMIS generated report and the cost allocation results table. Upon submission to the federal grant systems, the Deputy Director and or the Director of CARM will perform a thorough review of the material. These persons will insert their signature confirming the accuracy of the information reported to the General Accounting Division (GAD). Name(s) of the contact person(s) responsible for corrective action: Latanya Scott-Ward, Acting Director of Cost Allocation and Revenue Management, and Jessica Smith, Acting Chief Financial Officer. Planned completion date for corrective action plan: December 2025

Condition: The CDBG Cluster and Federal Transit Cluster expenditures on the schedule of expenditures of federal awards (SEFA) initially presented for audit were not complete and accurate. Planned Corrective Action: Due to turn-over and the loss of a long-term employee new processes were implemented to prepare reporting and documentation processes for the Federal Transit Cluster. Written Standard Operating Procedures have been generated and will be updated as necessary. Reporting and draw processes have been updated to include written signatures of approval for the documentation. The staff in transit and finance work closely together to ensure the completeness of records. City of Greeley will also be organizing a formalized grants team that will be dedicated to all grant activities including the SEFA and correcting the prior staffing insufficiencies. Contact person responsible for corrective action: Rebecca Romero, Grant Accountant Anticipated Completion Date: 03/01/2026

Finding Reference Number: 2024-004 Description of Finding: The Schedule of Expenditures of Federal Awards (SEFA) was not complete, and expenditures reported on the SEFA were revised during the single audit. Statement of Concurrence or Nonconcurrence: The SEFA required adjustments. Corrective Action: The Schedule of Expenditures of Federal Awards (SEFA) was not complete, and expenditures reported on the SEFA required revision during the single audit due to significant organizational transitions within the Finance Department during the audit period. Much of the team including senior staff was newly hired, resulting in limited historical knowledge of several complex, multi-year capital projects and grant activities. At the same time, the Town was implementing a new account structure and adapting to revised financial coding practices. These overlapping changes created temporary gaps in continuity, processing, and reconciliation workflows, which affected the Town’s ability to accurately reconcile grant activity to the general ledger and compile a complete and accurate SEFA prior to the start of the single audit. To address these issues and ensure accurate SEFA reporting going forward, the Town is implementing a comprehensive corrective action plan focused on stabilizing Finance staffing, improving reconciliation processes, and strengthening internal controls. Key actions include establishing consistent grant billing and reconciliation cycles; developing documented procedures for grant tracking, revenue recognition, and SEFA preparation; and improving financial coding accuracy under the new account structure. Ongoing staff training will reinforce institutional knowledge, and external support may be used as needed for complex reconciliations or project-specific cleanup. These measures will ensure the Town can prepare a complete and accurate SEFA on a timely basis and fully meet federal reporting requirements. Name of Contact Person: Aimee Beleu, Finance Director, (530) 872-6291, abeleu@townofparadise.com Projected Completion Date: 10/1/25

Finding 2024-225: Amounts reported as provided to subrecipients by financial services on the Schedule of Expenditures of Federal Assistance (SEFA) are not properly supported. Related to Prior Finding: 2023-208 Agency’s view: The agency agrees with this finding. Corrective Action Plan: For major grants, Financial Services staff will send a summary of transactions coded as subrecipient payments to the program manager to review prior to inclusion in the SEFA closing package. The review will be requested to be twofold: to ensure that everything that should be included as a subrecipient payment is and to ensure that nothing that should not be considered a subrecipient payment is included. This process helps to identify that we are reporting the accurate amount of expenditures for each subrecipient Anticipated Corrective Action Date: Completed 9/5/2025 Responsible for Corrective Action: Dena Darpli, Financial Manager dena.darpli@dhw.idaho.gov 208-334-4909

Management concurs with the finding. Procedures have been implemented to enhance year-end review of grant activity, including reconciliation of grant expenditures and receivables to the SEFA and general ledger prior to issuance. The Departments’ will continue to monitor these processes to ensure compliance with the Uniform Guidance reporting requirements. Anticipated Completion Date: October 31, 2025

Corrective Action: The Organization agrees with the finding and acknowledges the omission of the auditee’s prepared SEFA. The Organization will establish formal procedures to ensure SEFA preparation along with all federal funded contracts included in the SEFA as expenditures. Name of Contact Person: Leah Gaul, Director of Operations and Human Resources Proposed Completion Date: December 31, 2025

Views of responsible personnel and planned corrective actions: Management concurs with this finding. The College has implemented immediate corrective actions including development of a comprehensive grant tracking spreadsheet and establishment of regular meetings between program and finance staff. Additionally, effective immediately, all grant applications must be reviewed and approved by the Controller prior to submission to ensure proper identification of funding sources and compliance requirements. The College will also implement cutoff procedures to ensure federal expenditures are reported in the correct period based on when eligible costs are incurred. The Controller will review all G5 drawdowns near year-end to verify proper period reporting. Formal written procedures for SEFA preparation will be implemented by October 15, 2025. The Controller will maintain the master grant listing and review all grant agreements to determine federal funding sources. Beginning with fiscal year 2026 SEFA preparation, the CFO will perform an independent review for completeness and accuracy, including verification of proper period reporting for all federal expenditures.

Finding 2024-004 - Material Weakness in Internal Control over Compliance and Material Noncompliance (Qualified Opinion) - Inadequate Tracking of Expenditures and Retention of Documentation: Activities Allowed or Unallowed: Allowable Costs/Cost Principles and Reporting (A/B/L) for Assistance Listing Number 19.510 and 93.567 Criteria: The Code of Federal Regulations (CFR) Section 200.510(b) states in part, “The auditee must also prepare a schedule of federal expenditures for the period covered by the auditee’s consolidated financial statements which must include the total Federal awards expended as determined in accordance with 200.502.” Also, in accordance with CFR Section 200.302(b) - Financial Management, the auditees financial management system must provide 1) identification of all federal awards received and expended; 2) accurate, current, and complete disclosure of the financial results of each federal award or program; 3) records that identify adequately the source and application of funds for federally‐funded activities; 4) effective control over, and accountability for, all funds, property, and other assets; 5) comparison of expenditures with budget amounts for each Federal award; 6) written procedures to implement the requirements of section 200.305 and; 7) written procedures for determining the allowability of costs in accordance with Subpart E and the terms and conditions of the Federal award. Recipients of federal awards must submit accurate, complete and timely financial and performance reports. The Organization should have internal controls designed to ensure compliance with those provisions. The Organization should retain sufficient documentation such as invoice and allocation support for expenditures to retain documentation for audit purposes. Condition: During detail testing of expenditures, it was noted that the Organization did not maintain adequate documentation to support how certain costs were allocated to the federal program. Several transactions lacked sufficient detail, such as invoice or expense reimbursement form. Several expenditures selected for testing did not obtain sufficient approval by an individual at the Organization. There was one instance of employee compensation being processed at an approved pay rate and the Center could not provide any supporting documentation such as an offer letter, to substantiate the rate paid. It was noted that quarterly reports provided to the federal program were not reviewed by an individual at the Organization prior to submission to ensure accurate report of expenditures. 2 of the 8 monthly reports sampled were not submitted timely to the grantor. Cause: The Organization does not have an adequate system in place to ensure quarterly reports have sufficient supporting documentation, proper approval/review, and accurate reporting prior to submission. Responsibilities for expenditure tracking were not clearly assigned, and there was no formal review process in place. The Organization is not following their Document Retention Policy. Effect: The effect of this condition increases the possibility that quarterly financial reports are misstated or inaccurate and increase the risk of noncompliance with federal requirements. The effect of this condition also increases the risk that expenditures are unallowable per the grant, federal regulations, or cost principles due to the insufficient support of proper approval retained. Questioned costs: None Repeat Finding: Yes - 2023-003 Recommendation: Policies and procedures should be in place to ensure quarterly financial reports are properly supported, accurately reported, and adequately approved and reviewed. A formal review process should be established to ensure compliance. The Organization should follow the Document Retention Policy that was put in place and required by law and submit the required reporting documentation timely to the grantor to ensure compliance. Management Response: There is no disagreement with the audit finding. Management has taken steps to address these deficiencies in fiscal year 2025 including but not limited to: the implementation of a new accounting system that includes document retention and review/sign off logs, the engagement of a third-party CPA firm to provide client advisory and accounting services and the review and updating of accounting policies and procedures for best practices. Responsible Person for Corrective Action Plan: Marc Hall, Director of Operations Implementation Date for Corrective Action Plan: Fiscal year 2025

Views of responsible personnel and planned corrective actions: Management concurs with this finding. The Cooperative will implement the following corrective actions prior to December 31, 2025: • The CFO will document written procedures for SEFA preparation that specifically address proper period cutoff based on when costs are incurred versus when funds are received. • All current grant agreements will be reviewed to identify federal funding sources and ensure compliance with the single audit threshold. • The CFO will perform quarterly and annual reviews of federal expenditure reporting for completeness, accuracy, and proper period reporting. • Prior to year-end, the CFO will independently review all award documentation to the draft SEFA against all grant documentation to verify completeness and proper period reporting.

Finding Number: 2024-007 Finding Title: Reporting Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Colleen Robeck, Finance Director Corrective Action Planned: McLeod County recognizes the importance of internal controls over federal awards to be in compliance with federal statutes, regulations, and terms and conditions of the federal award. McLeod County has corrected the misstatements of contracts payments that should have been originally charged to the COVID-19 Coronavirus State and Local Fiscal Recovery Funds expenditures. Anticipated Completion Date: This issue will be resolved by December 31, 2025.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Pass-through: County of Sacramento Award Year: FY 2024 Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.Sl0(b) - Schedule of Expenditures of Federal Awards Grant Award Number: DHA-PRTS-NM-07-25-Al Finding Summary: During the audit procedures performed over the SEFA and expenditures reported for the Temporary Assistance for Needy Families program, we noted the Organization overstated expenditures by $138,217. The December 31, 2024 SEFA was corrected for this reporting error. Repeat Finding from Prior Years: No. Management's Response: The Organization acknowledges the reporting error identified during the audit procedures related to the SEFA. Upon notification of the discrepancy, the Organization promptly corrected the SEFA to reflect accurate expenditures. To prevent future occurrences, the Organization will strengthen internal review procedures for SEFA preparation, including cross-verification of reported expenditures with general ledger details. Name of Responsible Person: Projected Implementation Date: Bryan Wagner, CFO 09-05-2025

2024-007 - Significant Deficiency in Internal Control and Non-material Noncompliance - Schedule of Expenditures of Federal Award Awareness and Preparation WPHW understands this finding and will be implementing further steps to ensure full compliance with this finding. The follow process has been put in place to ensure compliance: 1) Director of Accounting and Grants Director will ensure they have appropriate training and work collaboratively to develop documentation process a. The Grant Director will update all grants as they are received, to ensure an accurate list of grants b. The Director of Accounting will update all the financial data for each grant 2) The Director of Accounting will be responsible for the review and submitting document to the auditing firm For FY25, the Director of Accounting and Grant Director will jointly build the document and review to ensure completeness and accuracy. Person(s) Responsible: Beth McLean, Director of Accounting Timing for Implementation: FY25-FY26

Finding 2024-001 – ReportingAssistance Listing No.: 93.391, COVID-19 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crisis Assistance Listing No.: 93.323, COVID-19 Epidemiology and Laboratory Capacity for InfectiousDiseasesManagement will distribute the updated SEFA reporting policy and procedure, outlining the required reporting requirements and timelines. A SEFA preparation checklist will be implemented to ensure that all submissions are accurate and complete. At the end of the year, Finance and Grants Management will collaborate to review all grant activities to ensure proper inclusion in the SEFA.Responsible Official: Annaliza Villamin, System Director of Accounting, Endeavor Health

Finding #2024-003 – Significant Deficiency and Other Noncompliance. Condition and context: During our testing of the Schedule of Expenditures of Federal Awards (SEFA) and the SESA, we noted that the expenditures were not reported in accordance with GAAP. An adjustment of $268,000 was recorded to properly state the expenditures. Recommendation: Implement policies and procedures to ensure that all expenditures have been properly recorded in accordance with GAAP in the SEFA and SESA. Corrective action plan: Management agrees with the finding. Beginning in fiscal year 2025, a detailed reconciliation process will be implemented to ensure that all expenditures are properly accrued and reported at the grant level in the SEFA and SESA, aligned with the appropriate reporting period, and the general ledger. Responsible officer: Gouri Kulkarni, Vice President of Finance. Estimated completion date: December 31, 2025.

Finding 2024-007 SEFA Reporting Issue: We lacked consistent grant-level financial reporting, which made preparation of the required Schedule of Expenditures of Federal Awards {SEFA) difficult and time-consuming. • What's been done: We have improved our accounting systems and can now produce regular internal financial reports by grant. All grant managers are given a monthly transaction listing for their grants to ensure transactions are posted to the correct grant. They are also given monthly financial statements for each grant to reconcile with their records. • Next steps: Financial reporting will be done on a timely basis, ideally no more than 5 days after the month closing so grant managers can reconcile their records. • Timeline: By early October, we hope to implement the monthly closing no more than 5 days after the month end. • Responsible party: Finance manager with oversight by President