Corrective Action Plans

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.

Views of Responsible Officials and Planned Corrective Actions: The Finance Department will ensure an accurate SEFA in conjunction with the response for Finding 2024-002.

Organization Response: Management acknowledges the auditors’ comments, with the clarification below, and has taken the actions listed below. The overstatement noted in this finding was a misstatement. The omission noted in this finding references funds received from state and county agencies. Therefore, the funds were recorded consistent with the information and documentation provided by the pass-through entity (Cascade County) which did not clearly identify the original funding source as the federal entity. To ensure internal controls over funding sources and expense reporting, the grant award and processing policy has been reviewed and updated to include due diligence of original funding sources.

Finding No. 2024-001 Implement System-Based Tracking of Federal Expenditures Finding: During our review of the SEFA, we noted that CAIR-CA utilizes workbooks outside of its accounting software to track federal expenditures. The workbooks do not reconcile directly with the general ledger (GL), so management performs a separate reconciliation to support the SEFA amounts. This approach was similarly observed in the prior year's audit. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding and has already updated the accounting system to incorporate grant-specific tracking codes to further align with federal reporting standards. Because the organization’s first single audit in FY2023 was conducted concurrently with the FY2024 single audit, there was limited opportunity for these procedural improvements to be reflected in the FY2024 single audit testing cycle. As a result, the impact of these changes will be more fully reflected in the FY2025 single audit, which is scheduled to commence this year. As part of a layered approach to internal controls, excel worksheets will continue to be used as a supplementary monitoring tool, providing an additional cross-check to the system-generated reports. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Implementation date: November 20, 2025

Planned Corrective Action: The Division will design and implement a precise control to ensure that the amount of food distributed is properly reviewed and that the Division maintains such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller

Finding Number: 2024-033 Finding Name: Inaccurate Reporting of Federal Expenditures Finding Condition(s): The Illinois Department of Employment Security (IDES) did not accurately report federal expenditures under the Unemployment Insurance (UI) program. Additionally, the auditors noted IDES’ controls over reporting federal expenditures were not designed at a sufficient level of precision to ensure complete and accurate reporting in a timely manner. Name of Contact Person(s): Kelly McGrath, Manager of Accounting and Reporting – Illinois Department of Employment Security, Accounting Services Division Corrective Action(s): This was a one-time event, which resulted in a finding in two fiscal years, resulting from the return of unused funds on debit cards held by a bank. As of December 2021, the bank was no longer IDES’ debit card provider. The bank asked to return the unused funds and the United States Department of Labor (DOL) agreed we could. If this was to happen again, the IDES will now know how to record it properly. No further action is needed at this time. Proposed Completion Date: February 28, 2026 – Completed

Finding Number: 2024-028 Finding Name: Inaccurate Reporting of Federal Expenditures Finding Condition(s): The Illinois Student Assistance Commission (ISAC) did not accurately report federal expenditures, including amounts passed-through to subrecipients, under the Child Care Development Fund (CCDF) Cluster. Additionally, the auditors noted ISAC’s controls over reporting federal expenditures, including amounts passed-through to subrecipients, were not designed at a sufficient level of precision to ensure complete and accurate reporting in a timely manner. Name of Contact Person(s): Rolake Adedara, Chief Financial Officer - Illinois Student Assistance Commission, Finance & Accounting Corrective Action(s): The CCDF Cluster program ended as of June 30, 2024. Lapse period payments (reported on a cash basis) made to beneficiaries during the year ended June 30, 2025, have been properly classified, and are not included as payments to subrecipients on the Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2025. Proposed Completion Date: February 28, 2026

Finding Number: 2024-014 Finding Name: Inaccurate Reporting of Federal Expenditures Finding Condition(s): The Illinois Department of Human Services (IDHS) did not accurately report federal expenditures, including amounts provided to subrecipients, under the Supplemental Nutrition Assistance (SNAP) Cluster, the Food Distribution Cluster (FDC), the Supplemental Nutrition for Women, Infants, and Children (WIC) programs, the Vocational Rehabilitation (VR) program, the Temporary Assistance for Needy Families (TANF), the Child Care Development Funds (CCDF) Cluster, the Social Services Block Grants (SSBG), the Block Grants for Prevention and Treatment of Substance Abuse (SAPT) program, and the Disability Insurance/SSI (SSDI) Cluster. Specifically, the auditors noted differences between the expenditure amounts provided for audit by the IDHS and the Schedule of Expenditures of Federal Awards (SEFA) amounts reported to the IOC, differences relative to amounts provided to program subrecipients, the cash basis expenditures provided by the IDHS for audit procedures included accrued (not paid) expenditures, and amounts passed through to other State agencies from the IDHS provided by the IDHS for audit procedures included expenditures paid outside of the fiscal year. Finally, IDHS’ controls over reporting federal expenditures were not designed at a sufficient level of precision to ensure complete and accurate reporting in a timely manner. Name of Contact Person(s): Sarah Eves, Deputy Chief Financial Officer – Illinois Department of Human Services Corrective Action(s): The IDHS will hire additional staff to ensure accurate review, reconciliation, and presentation of its federal grant expenditure data. Additionally, the IDHS has written draft procedures that will include (1) the identification and exclusion of accruals from total expenditures, ensuring cash-basis reporting, (2) how to identify and include/exclude current and prior year vouchers in transit, and (3) the review and validation of federal expenditures (and subrecipient expenditures). Proposed Completion Date: June 1, 2026

Finding Number: 2024-006 Finding Name: Inadequate Process for Monitoring Interagency Program Expenditures Finding Condition(s): The Illinois Department of Human Services (IDHS) does not have an adequate process for monitoring interagency expenditures claimed under or used to meet maintenance of effort (MOE) requirements of the Temporary Assistance for Needy Families (TANF) and Child Care Development Fund (CCDF) Cluster programs. Name of Contact Person(s): Sarah Eves, Deputy Chief Financial Officer – Illinois Department of Human Services Corrective Action(s): The IDHS will request quarterly certifications, control assessments, and program expenditure questionnaires for those agencies receiving funds from federal awards. Additionally, the IDHS will sample interagency expenditures and request that the agency provide supporting documentation for the expenses. This documentation will be reviewed by the IDHS to ensure that the expenditures meet federal program requirements. Proposed Completion Date: October 1, 2026

Other finding – SEFA Preparation Preparation of Schedule of Expenditures of Federal Awards Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agencies: Department of Treasury Recommendation: The Corporation should update its policies and procedures and internal controls to ensure accurate reporting of the Schedule as required by the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. The ORSPA department created a standard pre-award approval process for all sponsored proposals prior to submission or award acceptance. The pre-award approval process applies to all federal, state, local, private and commercial funding opportunities across all UMMS entities and covers new, renewal, resubmission and supplemental proposals. The establishment of a central intake process through one department, for all grants across the Corporation, enhances the controls to ensure complete and accurate reporting of the Schedule as required by the Uniform Guidance. Additionally, ORSPA and Corporate Financial Reporting implemented the following controls to ensure all expenditures of federal awards are included on the Schedule. These controls include:  Reconciliation of the grants from the pre-award approval process to the grants tagged in the accounting system;  Use of a specific grant identifier within the accounting system to track expenditures and revenue recognition and tag grants as federal, state or private funded;  Comparison of grant expenditures per the accounting system to the grant agreement;  Comparison of grant expenditures per the accounting system to the financial reporting submissions made to the federal agencies;  Certification from legal entity Finance Executives that the draft Schedule is complete and accurate;  Comparison of the prior year Schedule to the current year Schedule with further investigation around changes in grants and agencies included, and significant changes in the expenditures. Anticipated Completion Date – June 30, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

The City will ensure that all future expenditures are tracked and reported to the proper periods and recorded appropriately.

We have developed a communication procedure that any such project documents that are provided to the City of Vermilion Service Department or City Engineer reflecting revenue and/or expenditures related to work conducted in the City of Vermilion will be promptly provided to the Finance Office for any transaction recording required to have the dollars accurately reflected on our financial statements. This would include road work, water, waste water, storm water or other future project areas that may be included. Once received in the Finance Department, the funding status will be verified to determine if federally sourced. All federally sourced projects will be promptly recorded as revenue or expenses of the city as well as included on the SEFA for the year in question.

2024-006: 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. Contact person responsible for corrective action: Emily DeSalvo, County Administrator Anticipated Completion Date: March 2026

The Authority will develop and implement a standardized fiscal year transition and grant charging process to ensure controls are in place for accurate and timely recording of grant eligible expenditures. As part of this process, WMATA will develop a verification checklist for all funding source reclassification journal entries to ensure compliance prior to posting. This process will: - Identify all stakeholders responsible for year end grant reconciliation and reporting. - Establish a required review and approval process to be completed before any change in funding source or charging mode. - Update Accounting Policies and Procedures Manual to include guidelines to limit reclassification of expenditures incurred in prior fiscal years. - Set a formal annual cut-off date for Program Offices to request current year funding source reclassifications, allowing sufficient time for the Funds and Grants Management team to review and meet fiscal year end reporting deadlines. - Refine current monitoring mechanism for “yet‑to‑bill” transactions throughout the fiscal year for transferred transactions that originated in the general ledger to ensure all federal expenditures incurred within the period are reviewed and reported in accordance with the accrual basis of accounting. - Ensure the requirements for eligibility of expenses for Federal grants from 2 CFR 200.403 are enforced.

Understated SEFA (Material Weakness) Individuals Responsible for Corrective Action Plan: BGCA State Alliances Fiscal Team (Shelby Mahoney) Corrective Action: Management will enhance controls over the preparation and review of the Schedule of Expenditures of Federal Awards (SEFA) to ensure completeness and accuracy in accordance with Uniform Guidance (2 CFR Part 200). Corrective actions include: - Establishing a formal secondary review and approval process by management prior to submission to the auditors. - Maintaining detailed supporting schedules that reconcile the SEFA to the general ledger and grant documentation. Anticipated Completion Date: June 30, 2026

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