Corrective Action Plans

MATERIAL WEAKNESS Preparation of Schedule of Expenditures of Federal Awards Recommendation: We recommend the School implement internal controls over SEFA including a reconciliation and review process before submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action Planned/Taken : Management agrees with the finding and has created and filled the position of Manager of Grants Management. This staff member will be responsible for the oversight and management of all grants, including the SEFA. Additionally, the School has contracted with an outside firm that specializes in State Board of Accounts compliance, as well as Federal Award Compliance in line with Uniform Guidance. The firm will assist in the development of the required Internal Controls and Processes, with an estimated completion date is December 31, 2025.

Corrective Action Plan (Unaudited): The corrective actions described under Finding 2024-003 will directly address this compliance issue. Key measures include: 1) Adoption of centralized grant management policies and procedures by the end of 2025. 2) Quarterly reconciliations and independent review of SEFA reporting. 3) Annual training for Finance and department grant managers on SEFA compliance. 4) Continued use of the grant management team to enhance communication and oversight. Contact Person: Jamie Robichaud, Economy Director Anticipated Completion Date: January 1, 2026

Management will continue strengthen its processes and internal control to ensure that report of expenditures is reviewed by Finance prior to submission and only includes expenditures incurred in the period. Purchase orders will no longer be included in any submissions. Management will amend its procurement policy to ensure the policy includes the required regulations as outlined in the Code of Federal Regulations in relation to Federal Awards and that all relevant documentation will be retained.

In September 2025, Management has implemented the following corrective action item to eliminate the 2024-001 finding: 1. Management has redesigned our schedule of federal awards template to align with the format presented in the Single Audit report, thus eliminating reliance on summation formulas. 2. Management has implemented an additional review of the draft Single Audit report to be performed by the Controller. This is followed by the final review from the CFO before the report submission. Staff have reviewed the applicable Uniform Guidance (2 CFR 200.510b) to ensure full comprehension of reporting requirements. All corrective action items have been implemented and followed for the preparation of the schedule of federal expenditures. Contact Person Responsible for Corrective Action: Blaine Hoovis, Chief Financial Officer Email: BHoovis@ifaw.org Phone: 1 508 744 2134

Corrective action plan: The Finance Department will begin close out work on the year under audit as soon as the year ends, so that all accounts including expenditures will be accurately adjusted before the SEFA is prepared. Finance will verify all Assistance Listing Numbers on the SEFA. Once the SEFA is prepared, it will be independently reviewed by a contracted CPA before submitting the SEFA to the auditor. Personnel responsible for corrective action: Lisa Donham (Finance Manager) and contracted CPA consultant. Estimated corrective action completion date: March 31, 2026

Finding 2024-003 – Preparation of Schedule of Expenditures of Federal Awards (SEFA) (Material Weakness) (Repeat Finding) Corrective Action Plan Strengthening Internal Controls • Implement a formal SEFA preparation checklist aligned with the Uniform Guidance. • Require dual-level review (Finance Manager and Executive Director) of all SEFA schedules before submission to external auditors. • Establish reconciliation procedures that tie SEFA expenditures to the general ledger, grant agreements, and drawdown records. Year-End Closing Procedures • Revise year-end close calendar to include specific SEFA preparation deadlines and review steps. • Require supporting documentation (trial balance reports, grant reconciliations, and expenditure detail by funding source) to be retained and cross-referenced to the SEFA. Training • Provide targeted training to finance and grants staff on SEFA preparation, Uniform Guidance requirements, and OMB Compliance Supplement updates. • Require annual refresher training for staff responsible for grant accounting and reporting. Responsible Parties • Finance Director (Primary) • Executive Director (Oversight and Resources) Anticipated Completion Date Full implementation by June 30, 2025 (in time for fiscal year 2024-2025 reporting cycle).

Management agrees with this finding. Parkview Services will implement a formal SEFA preparation checklist by December 31st, 2025 that requires Finance Director to review federal loan agreements, program-specific compliance supplements, and prior year SEFAs to ensure all applicable programs are reported. The checklist will include a step to verify whether any federal loans with ongoing compliance requirements, including EIDL, must be included even if no new funds were expended during the audit period. The Finance Director will find and take trainings and seek out updates on federal reporting requirements, including any programspecific guidance for all federal awards held by the organization. Finance Director will monitor and idetntify of continuing compliance requirements for loans, as well as the treatment of federal loans in the SEFA. Before finalizing the SEFA each year, the Finance Director will perform a documented review of the draft against the checklist and supporting loan documentation. The Executive Director will provide a secondary review to confirm completeness before submission to the auditors. This dual review process will begin with the preparation of the 2025 SEFA.

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.

Management will ensure Federal expenditures are obligated during proper period and reported appropriately.

2024-001- SEFA REPORTING Recommendat ion : We recommend that the Council implement controls over financial reporting, including the SEFA, to ensure accuracy of financial data . Action Taken: Once the Fiscal Officer has compiled the financial reports and they have been reviewed by Matheny & Company AC, Senior Manager, the Fiscal Officer will send them to the Executive Director for final review and approval.

Finding Number: 2024-001 Condition: The expenditures were reported for the Capital Magnet Fund throughout the award period from the year ended June 30, 2019 to the year ended June 30, 2024 on the schedule of expenditures of federal awards (SEFA) but did not accurately report the amount of administrative expenditures incurred during the performance period, and, therefore, the SEFA was not complete and accurate for the year ended June 30, 2019 to the year ended June 30, 2024. Planned Corrective Action: Management has implemented procedures and controls to ensure reports are reviewed prior to submission and distributed funds are reported properly and in the correct period. Contact person responsible for corrective action: Lindsey Dehring, Vice President of Financial Planning & Analysis Anticipated Completion Date: July 31, 2025

Finding 2024-002 – Significant Deficiency Award No.: Assistance List (AL) No. 15.555 and No. 15.704 Federal Grantor: U.S. Department of the Interior, Bureau of Reclamation. AL No. 15.074 Passed-through the Del Puerto Water District Compliance Requirement: Other compliance requirements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was not complete, and expenditures reported on the SEFA were revised during the single audit. Criteria2 CFR Part 200, Subpart F (Uniform Guidance) Section 200.502 states, “The auditee should prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee’s financial statements.” Internal controls over preparation of the SEFA should be in place to ensure accrual basis expenses incurred under each federal program are properly reported as expenses on the SEFA and are properly reported as revenue in the financial statements prior to the start of the single audit. Cause: SEFA was not fully reconciled and finalized until after the single audit began. Effect: Expenses were omitted from the SEFA that should have been included and other expenses were included on the SEFA that were not eligible. The SEFA had to be revised for multiple grants over the course of the audit. This delayed the audit testing and major program determination process and could have resulted in the wrong programs being tested as major programs and the single audit not complying with the Uniform Guidance. Context: The District’s Finance Department was not informed of grant amendments that changed the amount of federal funding available. The expenses reported on the SEFA were revised during the single audit as follows. • AL No. 15.555 San Joaquin River Restoration Program Poso Canal Bridge Replacement: The District estimated additional reimbursable costs of $30,335 existed for the Poso Canal Bridge Replacement grant under a potential new $990,000 grant amendment that was to be signed by the USBR in 2025. The amendment was not approved for the Poso Canal Bridge Replacement but the District included the additional reimbursable expenses on the SEFA. The expenses on the SEFA had to be reduced to reflect the eligible federal grant maximum reimbursable expenses under the approved grant agreement at year-end. • AL No. 15.704 Small Surface Water and Groundwater Storage Projects Orestimba Creek Recharge and Recovery Expansion: An additional grant amendment was identified during the single audit that authorized an additional $1,262,928 of federal funding. The District had eligible expenses during the period of performance to fully claim the additional funding, but did not include the expenses on the SEFA. Recommendation: We recommend additional review procedures be implemented to ensure the SEFA is complete and accurate when the single audit begins, which includes working with program managers to identify each grant awarded, obtain current executed grant agreements and amendments, reconciling all expenses incurred under each federal awards down to the invoice, payroll check and lowest level of any other costs claimed, cutting-off each expense at year-end and claiming the reconciled qualifying expenses within 45 days after quarter end. At year-end, programs should be reviewed for cost adjustments, extensions, and other changes that should be reflected on the SEFA when reconciling expenses for the SEFA. Separate general ledger program codes should be used for each grant on the SEFA that summarizes expenses down to the individual invoice level that should be provided to the auditor for the single audit. If overclaimed amounts are identified, the grantor and/or pass-through agency should be contacted to determine whether to return the funds or apply the overclaimed amounts to future claims. Views of Responsible Officials and Planned Corrective Actions: Prepare a summary of grant expenses to reconcile to claims with performance periods included. Staff has prepared an expense summary for Orestimba Creek Recharge and Recovery project and will be updated moving forward. A similar file will be created for each grant received. Estimated Completion Date of Corrective Action: File started for Orestimba Creek.

Description: The SEFA schedule included unallowable costs. Planned Corrective ActionL CGS will revise its SEFA preparation procedures to ensure that only allowable and properly reimbursable expenditures on federal awards are reported. Additional training will be scheduled for those responsible staff members to ensure that this error does not happen in the future. Anticipated Completion Date: October 1, 2025 Responsible Person: Keith Peregonov, VP for Finance, Human Resources and Operations

Condition: The schedule of expenditures of federal awards (the "SEFA") was not accurate. Planned Corrective Action: To improve accuracy and completeness of the SEFA, the City will enhance its master grant tracking spreadsheet to ensure all grant expenses are calculated correctly and consistently. In addition, quarterly reviews will be conducted in partnership with departments to confirm that all federal awards are current and accurately captured. These improvements, along with the updated required quarterly report and request for reimbursement procedures, will allow the City to compile a complete and accurate SEFA. Contact person responsible for corrective action: Grant Accountant and Accounting Manager Anticipated Completion Date: 7/31/2025

Starting during Fiscal Year 2024, the County Finance Department has been preparing and analyzing quarterly draft Single Audit expenditures and other trial balance amounts with participation from grant fiscal staff throughout the County to improve the reporting of expenditures at year-end. There are also a variety of other initiatives to improve financial reporting and other grant-related processes. An interorganizational Grants Workgroup has been started to have periodic meetings to work on root causes that affect the accounting of grant expenditures. For example, this work group is addressing topics such as expenditure reconciliations, timely recording of grant receivables and revenues throughout the fiscal year to facilitate expenditure analysis at year-end, timely recording of County match and the identification of County match-funded versus grantor-funded (Single Audit reportable) expenditures, and the development of accounting-system reports. County Finance management (Merrie Allen and Ajay Gajjar) will continue to work with the Grants Workgroup and develop improvements that will improve the reporting of grant expenditures.

Condition: The fiscal year 2024 schedule of expenditures of federal awards (SEFA) that was initially provided to the auditors was incorrect because it included expenditures related to fiscal years 2023 and 2025. Planned Corrective Action: The City of Fort Collins has determined that two separate and identifiable root causes led to the inclusion of expenditures from fiscal years 2023 and 2025 in the initial fiscal year 2024 SEFA. 1. Improper Accrual of Prepayments: A small number of transactions involving partial prepayments were not properly accrued in accordance with accounting standards. To address this issue, the City will implement a formal review process whereby all reimbursement requests are reviewed by the Grant Accountant prior to submission. This review will include a targeted examination of expenditure listings to identify and ensure appropriate treatment of any transactions requiring accrual as prepayments. 2. Inconsistencies Between Reimbursement Packets and the General Ledger: For the Highway Planning and Construction Cluster, the SEFA preparation process previously relied on reimbursement request packets compiled by departmental staff. In some cases, these packets did not accurately reflect the timing of expenditures recorded in the general ledger. To enhance accuracy, the City will implement a reconciliation procedure requiring the Grant Accountant to cross-reference reimbursement packet data with the general ledger during SEFA preparation. This step will help ensure that all expenditures are properly reported in the appropriate fiscal year. The City is confident that these corrective actions will strengthen internal controls over SEFA preparation and prevent recurrence of similar issues in future reporting periods. Contact person responsible for corrective action: Trevor Nash, Accounting Manager Anticipated Completion Date: 12/31/2025

View of Responsible Officials and Corrective Action Plan: The corrective Action Plan will be carried out in the 2025 Fiscal Year and information will be given to the auditors when requested for the next audit. The Coalition will ensure that all information needed for the SEFA is kept and entered accurately (this process has already begun). When the fiscal year closes out, the Coalition will provide the auditors with a test SEFA to confirm that the information we are collecting throughout the year and are asserting are the correct numbers for our federal grants, is indeed the correct information. Corrective Action Plan Timeline: Completed by December 19, 2025 (Final copy of the SEFA will not be given to the auditors until requested for the Audit).Designation Of Employee Position Responsible For Meeting Deadline: Executive Director will oversee this project and work directly with NMCEH finance staff work closely with the auditors to make sure that the information saved and shared is correct.

The Department of Behavioral Health (DBH) Office of the Chief Financial Officer (OCFO) concurs with this finding. Condition #1 - All FFRs and corresponding programmatic and financial reports will be reviewed by the Accountant, the Accounting Officer, the Agency Fiscal Officer, the Budget staff, and the Grants Program Manager prior to submission to the Federal government. OCFO will utilize a grants matrix that will reflect the respective grants due dates to ensure timely filing of FFRs. The matrix will be reviewed to ensure compliance monthly with each Accountant during the monthly analysis and review process. Condition #2 -DBH will save the SOR tracking sheet that is used to calculate the earmarked amounts for administrative and data costs for the Federal programmatic reports. This will be retained in a central location. Condition #3 - Prior to the submission of the SEFA, the grant expenditures will be reviewed with the Accounting Officer, the AFO, and the Grants program manager for a detailed review of the SEFA to confirm expenditures are correctly categorized by fund and grant, reconciles to the financial system and reflects the amount expended for sub-recipients. Contact: FFR (SF-425) and SEFA: Barbara S. Roberson, Accounting Officer, Human Support Services Cluster PPR Reporting: Sharon Hunt, State Opioid Treatment Authority, DBH Estimated Completion Date: September 2025 See Corrective Action Plan for chart/table

2024-003: Material Weakness and Noncompliance – Preparation of Schedule of Expenditures of Federal Awards (SEFA) Statement of Condition/Criteria: The Code of Federal Regulations requires a non-federal entity to prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section 200.502(a) and must reconcile amounts reported in the SEFA to the amounts reported in the auditee’s financial statements. Planned Corrective Action: County management will develop a closing process to ensure all federal expenditures are identified, recorded, and reconciled on the SEFA.

2024-001 - Material Weakness and Noncompliance, Completeness and Accuracy of Schedule of Expenditures of Federal and State Awards (Repeat Finding 2023-001) Audit Finding: There were several adjustments to the basic financial statements, Schedule of Expenditure of Federal Awards (SEFA) and Schedule of Expenditures of State Awards (SESA) as originally provided by the Town. The SEFA and SESA balances are required to be reconciled to the basic financial statements prepared in accordance with generally accepted accounting principles in the United States (US GAAP). The Town has failed to adequately perform such reconciliation and as a result of procedures performed by RSM a number of adjustments to expenditures reported on the SEFA and SESA as well as to intergovernmental Revenues reported on the basic financial statements had to be performed. Corrective Action Taken: The Town Finance Department has placed an emphasis on educational meetings with the Board of Education within the area of receiving grants. These issues have resulted from the continual problem of employee turnover of personnel working within the areas of responsibility of grants accounting. All positions in the BOE Finance Department have now been filled, and the Director of Finance at the BOE has implemented monthly reconciliation procedures. From the Town side, the reconciliations between the GAAP financial statements and amounts reported on the SEFA and SESA will be overseen by the Town Comptroller. The Deputy Comptroller and BOE Director of Finance meet regularly to discuss updates and issues and will reconcile the June 30, 2025 reports in the first quarter of FY2026. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

The Office of Financial Management and Budget (OFMB) has collaborated with County departments and agencies that administer grants to ensure staff are informed of and participate in relevant training opportunities related to State and Federal grants. In addition, OFMB continues to monitor grant activity through established agenda review and grant reconciliation processes to identify and address potential errors or omissions and will provide guidance as needed.

Corrective Action Plan Year Ended September 30, 2024 Findings Related to Federal Awards 2024-001 SEFA Control Deficiency Federal Agency: U.S. Department of Treasury Program Titles and Assistance Listing Numbers (ALN): Community Development Financial Institutions Program (ALN 21.033) Federal Grant Numbers: 22ERP061418 Contact Person: Steven Kaczynski, Controller; skaczynski@newjerseycommunitycapital.org; 732-640-2061 Corrective Action: As noted by our auditor, the submitted expenditures were allowable under the grant. The condition exists such that these expenditures were included within the current period SEFA report because that is when they were determined to be applicable, rather than the period when they were actually incurred (the prior period SEFA report). Going forward, management will ensure to report expenditures in the period they were incurred rather than the period they were applied. Anticipated Completion Date: September 30, 2025

Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. ODI agrees with the auditors’ recommendation. Consistent with response to finding 2024-001, we have reviewed the design and implementation of internal controls procedures around accounting for grants and contracts. This has resulted in revision of our new funding form including identifying federal and nonfederal designations in subcontracts from states, and determination of conditions to ensure compliance with U.S. GAAP. Responsible staff member, Laurie Larson-Lewis, Finance Manager, completion date 5/31/2025.

Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Auditee’s Corrective Action Plan: The city’s legacy financial system did not collect data required for SEFA. Agencies had to provide most details manually and work between spreadsheets and multiple systems to input and track receipt grant awards and spend on personnel, supplies and services and sub-recipient awards related to grants. The steps to address this legacy finding have been phased and include the technology implementation, staff training and additional oversight. As noted, the City implemented Workday, an Enterprise Resource Planning (ERP) system, across workstreams so that Financial Accounting, Grants, Procurement, Supplier Accounts, Banking, Payroll and Human Resources are all in one system. As with any ERP, an ongoing process of evaluation and updates are needed to continuously align workflow and business processes. This approach has led to continued improvement over the years as the grants management module is fully implemented in Workday. Since implementation, additional enhancements have been adopted and utilized with a robust workflow process for grant approval, grant budget tracking, and invoice scheduling. In addition to the technology adoption, an increase in citywide grants training and oversight has been implemented. The progress is detailed below: • FY 23 represented the first year in the new system. To compile the SEFA, the City used a hybrid approach to leverage Workday and Agency provided data. o There were some data accuracy challenges from data entry errors. To address those data entry challenges the award modification business process was improved post-implementation to add a GMO review and approval step of award modifications. o As of May 2024, all award modifications now require centralized GMO review to verify data accuracy. o Additional process changes in FY 23 included implementation of the requirement as part of the FY 24 budget preparation process that grant worktags must be created and budgeted for during the City’s annual budget process. The grant worktag creation process includes approvals at the agency program and fiscal levels, as well as at the Department of Finance level. • In FY24 further Award Module enhancements were adopted to provide key new data points in Workday. o Each grant award now includes information: Federal Assistance Listing Number (fna CFDA#), Passthrough Agencies & Passthrough Identifier. o Additionally, in FY 24, GMO, in collaboration with BAPS launched the Grants Workstream Training sessions. These monthly citywide virtual live trainings are on a variety of grant management related topics, averaging 60 attendees per session. Attendees are city agency grant managers and city agency fiscal staff. • In FY 24 and FY 25 the topics covered included: o FY 24 Grant Work tag Preparation o FY 24 SEFA Preparation o Grant Accounting Best Practices and Workday Billing o Award Set-up Best Practice & Potential Pitfalls o Extra Features in Workday (including reporting and how to set up award tasks and deadlines) o Subrecipient Monitoring Best Practices o Cost-reimbursable grant invoicing in Workday o FY 25 SEFA preparation o FY 26 Grant Work tag Preparation o Grant Management Roles and Responsibilities o Specific training on the SEFA, including information on understanding the importance of the SEFA, what information is included and how to review SEFA data, was conducted. Citywide training sessions were held in FY 24 and FY 25 to ensure that the reporting is understood by city agencies, with special emphasis on subrecipient payments being reported properly. The training schedule is ongoing and continuous. • To improve SEFA reporting data, in FY 25 there is an emphasis on subrecipient set up and spending to ensure that functionality is refined to improve uniformity in subrecipient set up. GMO, in conjunction with BAPS, the Bureau of Procurement and city agencies will work to refine subrecipient set up, spending and monitoring, including improved reporting. o GMO has hosted three subrecipient monitoring and management–related trainings since December 2024. Additionally, to improve subrecipient managing and monitoring, GMO modified the award setup business process in Workday to include verification of subaward status before final award setup approval. In FY 25, GMO provided training on how to setup subawards accurately in Workday. As discussed above, these trainings will be ongoing. • Additionally, GMO and the BBMR will collaborate on a subaward dashboard to monitor subrecipient spending data in real time. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City Completion Date: FY26 3rd Quarter- • Design and complete a grants management dashboard within Workday • Ongoing and continuous - GMO will continue to conduct trainings on SEFA reporting and subrecipient management and reporting.

Finding 2024-006 Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing No.: 97.036 Federal Grantor: U.S. Department of Homeland Security Passed-through: California Governor's Office of Emergency Services Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the Schedule of Expenditures of Federal Awards. Compliance Requirements: 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) §200.510(b) - Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control Over Compliance Department’s Management Response: Management agrees with the recommendation that the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance. View of Responsible Officials and Corrective Action: To ensure the completeness of Disaster Grant expenditures reported on the SEFA, the Auditor-Controller’s Office will obtain a listing of all projects from the FEMA Grants Portal. This list will be used to verify that all obligated projects have been accurately reported on the SEFA. Name of Responsible Persons: Jason McGuire, Deputy Director, Auditor-Controller Implementation Date: July 2025