Corrective Action Plans

View of Responsible Officials and Corrective Actions: Management agrees with the finding. Management will implement procedures to identify all federal awards expended, including funds passed through state and local governments. For each grant and contract, management will review the executed agreement and related funder documentation for indicators of federal funding, including an Assistance Listing Number, a federal award identification number, the originating federal agency, the pass-through entity identifying number, and references to the Uniform Guidance, and should confirm the federal funding status with the pass-through entity when it is not clear. Management will maintain a centralized listing of awards that is reconciled to the general ledger and reviewed for completeness in preparing the schedule of expenditures of federal awards. Contact Persons Responsible: Dr. Sharrone Ward, President and Chief Executive Officer Kim Shelton-Mamon, Vice President of Finance Completion Date: July 31,2026

The Department of Behavioral Health (DBH) agrees with the findings and will put controls in place to resolve the issue. On May 20, 2026, DBH trained all grants staff on how to use combo codes in the timekeeping system (Peoplesoft) so that individuals whose time is split across grants or split between grant and local projects can record their time to each funding source. This new process will be rolled out starting June 12, 2026.

The Organization acknowledges and concurs with the auditor’s finding as discussed within the Schedule of Findings and Questioned Costs for the year-ended September 30, 2025. During the audit for PTV’s fiscal year 2025, it was determined that we should add an additional layer of confirmation to our approval process. Currently, the President reviews invoices prior to signing the checks, thereby signaling approval. Moving forward, in addition to this review, the President will also confirm approval by initialing the invoice itself. Beyond this initial next step, PTV will also review its current Fiscal Policy to consider implementation of an approval process that allows other authorized approvers the authority to review expenses up to certain thresholds. Policy development at this level requires Finance Committee involvement and full Board approval, so it may take several months to fully implement a new process. We appreciate the opportunity to continue to strengthen PTV’s internal controls and financial operations.

Management agrees with the finding and recommendations. The City will begin to implement policies and procedures to assist with monthly reconciliations and review processes to mitigate these errors in the future.

The Municipality shall establish procedures, training programs, and internal controls to ensure compliance with the preparation and timely submission of the Single Audit Report to the Federal Audit Clearinghouse, as required by the OMB Super Circular Uniform Guidance and in accordance with the nine-month deadline established therein. In addition, the Department of Finance will monitor the progress of the work, including the preparation of financial statements, as well as the external audit and the single audit, so that for the fiscal year ending June 30, 2026, the reports are submitted by the established deadline of no later than March 31, 2027.

Condition: During the years ended June 30, 2023, 2024, and 2025, National Church Residences entered into capital advance grant agreements (Section 202) with HUD, which were directly funded to affiliates of National Church Residences, and, in turn, National Church Residences entered into notes receivable from the related parties in the same amount as the capital advance. The loan expenditures and outstanding loan balances related to the ALN 14.157 U.S. Department of Housing and Urban Development - Supportive Housing for the Elderly (Section 202) - Capital Advance were not included on the SEFA for the years ended June 30, 2025, 2024, and 2023. Planned Corrective Action: National Church Residences is in the process of establishing additional layers of internal controls to help ensure that all new agreements and any subsequent modifications are captured timely, completely, and accurately within the special purpose financial statements and SEFA. Contact person responsible for corrective action: Lindsey Dehring, Vice President of Financial Planning & Analysis Anticipated Completion Date: July 1, 2026

Management will review and update processes and procedures over reporting and additional training will be provided as needed to ensure accurate grant reporting and compliance.

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Jill VanDriessche Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. We believe this finding to be the result of an isolated incident that was reported to SBOA and Title. Description of Corrective Action Plan: The Business Manager/Treasurer provides to the corporation grant administrator monthly grant reports, as well as a grant tracking spreadsheet. The appropriations for each grant are entered into Komputrol, according to the budget located in the approved grant documents. The appropriations are presented to the Grant Administrator for approval. All spending from each grant is approved by the corporation grant administrator. Any wages paid via the corporation payroll that is charged to grant funds is approved by the business manager/treasurer and the corporation grant administrator. The Payroll Specialist/Deputy Treasurer completes the payroll and sends the distribution account records to the Business Manager/Treasurer and Grant Administrator. Any payroll claims for payment via grant funds is required to have three signatures for approval. We believe the system of internal control in place has been strong and in compliance since March 2025. Anticipated Completion Date: March 1, 2025 and ongoing

FINDING 2025-004 Finding Subject: Child Nutrition Cluster, Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jennifer Felke & Amy Kraszyk Contact Phone Number and Email Address: 574-936-3115, jfelke@plymouth.k12.in.us, Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Since January 2025, the internal controls that resulted in this finding have been corrected. The finding stated that “The lack of internal controls and noncompliance over Allowable Activities and Allowable Costs/Cost Principles is an isolated incident.” The Food Service Director and the Business Manager/Treasurer meet monthly to review the school lunch accounts and to concur with the month end balances. The Deputy Treasurer approves all monthly fund transfers completed by the Business Manager. Anticipated Completion Date: January 1, 2025 and ongoing

The Organization acknowledges and concurs with the auditor’s finding as discussed within the Schedule of Findings and Questioned Costs for the year-ended June 30, 2025. The Organization has taken steps in the year ending June 30, 2025 to strengthen internal control by engaging appropriate personnel along with an outside bookkeeping firm to ensure consistency and continuity of practices. In addition, during the year ending June 30, 2025, the Organization has implemented a new electronic timesheet with embedded management review and approval and automated vendor invoice approval process.During the FY25 Audit, it was found that samples of the approval of time sheets from our electronic system were found without the requisite approvals (checkmarks). We believe that this is the result of lack of awareness on our part (Employees and Supervisors) that time sheets must be saved after clicking the approval check box to ensure that the approval is recorded.VPQHC has implemented a corrective action plan that requires an Approval Status Report after each pay period to ensure that all-time sheets are approved by both the employee and supervisor. VPQHC will will conduct training for new employees during their on-boarding on how to enter time using the Asure Time & Attendance System along with periodic refresher training for employees as necessary.

Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and Neglected Audit Finding Reference: 2025-001 ________________________________________ 1. Finding Summary The Single Audit identified a deficiency in the documentation and communication of federally funded position percentages and the alignment of Time & Effort attestations with the actual period of work performed. Specifically, the current CPS Federal Funds platform (Oracle) generates Time & Effort Attestation reports based on the month reimbursement claims are submitted, rather than the period during which the work was performed, creating a compliance gap. ________________________________________ 2. Root Cause ● Staff were not consistently informed of the exact percentage of their position funded by federal sources at the start of each semester. ● Time & Effort attestations were generated from the CPS Oracle system based on claim submission timing, not the actual work period. ● There was no formal internal SOP layer to supplement Oracle-generated reports with staff attestation aligned to Semester 1 and Semester 2 work periods. ________________________________________ 3. Corrective Actions Action 1: Internal Funding Percentage Notification System Description: PIE-IL will implement an internal tracking and notification system to ensure all staff funded in whole or in part with federal funds are formally notified of the exact percentage of their position supported by federal funding. Implementation Steps: ● Develop a standardized Federal Funding Allocation Notice template. ● Distribute notices to all applicable staff at the start of Semester 1 and Semester 2. ● Require staff acknowledgment (electronic or signed) confirming receipt and understanding. ● Maintain records centrally in the federal compliance folder. Responsible Party: Manager of Instructional Compliance Timeline: Implemented by the first day of each semester Monitoring: Semester-based review of acknowledgment logs ________________________________________ Action 2: Semester-Based Time & Effort Attestation Description: All federally funded staff will complete and sign a Time & Effort Attestation for both Semester 1 and Semester 2, certifying that time worked aligns with the funding source and percentage assigned. Implementation Steps: ● Issue Time & Effort forms at the end of each semester. ● Require staff to certify actual work performed during the semester. ● Collect supervisor verification signatures. ● Store completed attestations in the federal compliance repository. Responsible Party: Site Administrators / Federal Compliance Officer Timeline: Within 10 business days of semester end Monitoring: Quarterly internal compliance audits ________________________________________ Action 3: Internal SOP as Supplemental Documentation Layer Description: PIE-IL will implement a formal Standard Operating Procedure (SOP) for Time & Effort as a self-managed, internal documentation layer that supplements CPS Oracle-generated attestation reports. This SOP will ensure that Time & Effort documentation reflects the actual period of work performed, rather than the month in which reimbursement claims are submitted. Implementation Steps: ● Draft and approve a written SOP outlining: ○ Semester-based attestation requirements ○ Alignment between funding percentages and staff assignments ○ Reconciliation process between internal records and Oracle reports ● Train administrators and federally funded staff on SOP procedures. ● Maintain SOP as a controlled document with annual review and updates. Responsible Party: Federal Programs Director / Compliance Manager Timeline: SOP finalized within 30 days of audit response submission Monitoring: Annual SOP review and internal compliance testing ________________________________________ 4. Reconciliation Process with CPS Oracle System PIE-IL will perform a monthly reconciliation between: ● Oracle-generated Time & Effort Attestation reports (claim-based), and ● Internal Semester-Based Time & Effort attestations (work-period-based). Any discrepancies will be documented, corrected, and reviewed by the Federal Compliance Officer prior to reimbursement submission. ________________________________________ 5. Evidence of Implementation The following documentation will be maintained for audit and monitoring purposes: ● Federal Funding Allocation Notices with staff acknowledgments ● Signed Semester 1 and Semester 2 Time & Effort Attestation forms ● Approved Time & Effort SOP document ● Training sign-in sheets and materials ● Monthly reconciliation logs between Oracle and internal records ________________________________________ 6. Completion Dates Corrective Action Target Completion Date Funding Percentage Notification System [9/30/2026] Semester-Based Time & Effort Attestation Process [02/06/2026] SOP Finalization and Staff Training [02/28/2026] Monthly Reconciliation Process Ongoing ________________________________________

525 North 1st Street, Lakeview, Oregon 97630 | (541) 947-2020 | www.townoflakeview.org Finding 2024-004 – Inadequate Schedule of Expenditures of Federal Awards (SEFA) (Material Weakness) Condition: During the audit, we noted that the SEFA prepared by the organization was incomplete, and inaccurate. Specifically, federal revenue amounts were shown instead of expenditures, and not all Federal awards were listed and amounts shown were not reconciled to the underlying accounting records. In addition, Grant funds were drawn (requested and received) for the same underlying expenditures in two different fiscal years, resulting in duplicate reimbursement. Cause: The inaccuracies appear to be due to inadequate procedures and controls over the identification, tracking, and reporting of federal awards. Management did not implement a formal process to compile and review SEFA information for completeness and accuracy. Context: The auditee did not provide a complete and accurate SEFA that included all federal expenditures that reconciled to the general ledger for Federal Awards, and did not list all federal awards. Specifically: • Management did not initially provide a SEFA for the audit period, it was not provided until late in the audit process. • During the audit procedures, the auditor identified additional federal expenditures that were not provided by the client, and not included in the original SEFA. • The SEFA submitted by management contained material errors, including incorrect expenditures amounts (revenues instead of expenditures), and inconsistencies with the general ledger (grant revenues from prior year expenditures included as expenditures again). • The SEFA required multiple revisions and significant auditor assistance due to incomplete data and reporting errors. This condition demonstrates that management did not have sufficient processes in place to identify, accumulate, and report federal expenditures, and did not provide accurate information for the SEFA preparation. Recommendation: We recommend that The Town of Lakeview establish policies and procedures to ensure that all Federal awards are identified and reported accurately on the SEFA. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The Town of Lakeview should provide appropriate training to staff who are assigned to prepare and review the SEFA. Client's Response: The Town of Lakeview concurs with the recommendation and will work through the Corrective Action Plan to improve or solve the deficiency. Corrective Action Plan: The Town of Lakeview has taken significant organizational and procedural steps to strengthen its administration of federal awards and ensure future compliance with Uniform Guidance reporting requirements. Corrective actions implemented include: • The Town has hired a Finance Director with substantial experience in state and federal grant administration and financial reporting. The Finance Director is responsible for oversight of all federal financial reporting, including preparation and review of the annual Schedule of Expenditures of Federal Awards. 525 North 1st Street, Lakeview, Oregon 97630 | (541) 947-2020 | www.townoflakeview.org • The Town has hired a new Town Manager who has established improved financial oversight and accountability throughout the organization. The Town Manager will work closely with the Finance Director to monitor compliance with federal grant requirements and ensure adequate internal controls are maintained. • The Town Council has established a Citizen Finance Advisory Committee to provide independent oversight and review of the Town’s financial management practices. The committee will review financial reports, budget performance, and federal grant administration processes, providing recommendations to improve accountability and transparency. • The Town has developed and implemented formal policies and procedures governing the administration of federal awards including: o Identification and tracking of awards o Documentation of expenditures charged to federal programs o Procedures for maintaining grant files o Reconciliation of grant expenditures to the general ledger o Annual preparation and supervisory review of the Schedule of Expenditures of Federal Awards • Prior to completion of the annual financial statements and Single Audit, the Finance Director will perform a comprehensive reconciliation of all federal expenditures to the accounting records and grant documentation. The completed SEFA will undergo management review and approval by the Town Manager before being provided to the external auditors. Planned Implementation Date: The corrective actions described above have been implemented. The Town will continue to monitor compliance throughout the fiscal year, and the revised procedures will be fully incorporated into the preparation of the next annual SEFA. Responsible Person: Town of Lakeview Mayor.

Management’s Response: Management concurs with the finding and has implemented additional review procedures to ensure all federal programs are identified and included in the SEFA in future years.

The Municipality is working diligently to publish its statements on time. In 2025 the Municipality published two audited statements (2022 and 2023) and the 2024 audited statements are expected to be published in January 2026. The 2025 audited financial statements will be published on time.

Finding 2024-003 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education CFDA Title and Number 84.010 Grants to Local Education Agencies (Title I) Name of Federal Agency: U.S. Department of Education Compliance/Internal Control over Compliance: Auditee Responsibilities Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the total Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit on an untimely basis, and with values that were not reconciled with the general ledger. Cause: The District staff had insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Errors in recording and reporting of revenues and expenditures of federal awards may not be detected and/or corrected. Because the Auditee’s SEFA that was presented for audit was completed incorrectly, and not reconciled to the general ledger, the SEFA was materially misstated, prior to auditor's correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following:  SEFA was originally presented for auditors with incorrect information.  SEFA was not presented for auditors on a timely basis.  No reconciliation between federal expenditures reported on the GL and the SEFA was presented. Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFA reports. Planned Implementation Date: August 1, 2025 Responsible Person: Director of Business Services, Yamhill County School District No. 8

Chaffee County will establish internal controls over grants management and SEFA preparation processes during the year to make sure the Federal expenditures are properly reflected on the information used to prepare the SEFA and match the accounting records.

Auditee Corrective Action Plan Finding 2024-001: Schedule of Federal Awards (SEFA) Preparation – Significant Deficiency Audit Finding: During our audit, we noted that the Schedule of Expenditures of Federal Awards (SEFA) initially prepared by Western Landowners Alliance did not include the required Assistance Listing Numbers (formerly CFDA numbers) for each federal program, and the amounts of federal expenditures reported contained inaccuracies. We understand this was Western Landowners Alliance’s first year preparing a SEFA and that staff are still becoming familiar with the detailed requirements of the Uniform Guidance (2 CFR Part 200). As the SEFA is a critical component of the Single Audit reporting package and serves as the basis for major program determination and compliance testing, it is essential that it be prepared accurately and in accordance with Uniform Guidance. We recommend that management enhance its understanding of SEFA preparation requirements, consider additional training on Uniform Guidance, and implement review procedures to help ensure the completeness and accuracy of the SEFA in future reporting periods. Audit Recommendation: We recommend that management enhance its understanding of SEFA preparation requirements, consider additional training on Uniform Guidance, and implement review procedures to help ensure the completeness and accuracy of the SEFA in future reporting periods. Management’s Response and Corrective Action Plan: Western Landowners Alliance (WLA) acknowledges and agrees with the finding, and have taken the following corrective actions to address the issue: (1) Implementation of SEFA Template: given the diversity of awards WLA receives (primary, subawards, and awards with both federal/non-federal funding), a standardized template has been developed and implemented to ensure accurate tracking and reporting of awards, funding sources, and expenditures. (2) Proactive Collection of Assistance Listing Numbers: WLA will proactively request and document the Assistance Listing Numbers (formerly CFDA numbers) from funding agencies upon receipt of awards to ensure compliance, and complete and accurate reporting. (3) Documentation of Expense Allocation Process for Awards with Federal and Non-Federal Funding: WLA’s financial policies and procedures have been updates (as of August 2025) to document the process for allocating expenses on awards that include both federal and non-federal resources. Documentation of this process will ensure consistent and appropriate allocation in accordance with federal requirements. (4) Per recommendation from RGO, Robinson has enrolled in two trainings: Uniform Guidance Training Part 1 and Part 2-Single Audit Training-the importance of the SEFA, hosted by Illumeo, to augment knowledge to support future compliance. Contact and Completion Date: Rachael Robinson, 505-466-1495, rrobinson@westernlandowners.org, is the primary contact, and the Chief Operating Officer at Western Landowners Alliance. The corrective action is currently in effect and trainings will be completed by August 31, 2025, to ensure compliance with the current fiscal year. Please reach out with any questions. Rachael Robinson Chief Operating Officer Western Landowners Alliance 505-466-1495

Finding 2024-004 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.041 Impact Aid Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Sched-ule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the to-tal Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipi-ents. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements.   Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger, and contained inaccuracies, including: • Overclaimed revenues for Title I • Inability to provide sufficient documentation of Impact Aid revenues and specific Impact Aid program infor-mation • Incorrect reporting of state and federal revenues for National School Lunch Program. Cause: The District does not have effective internal control over the preparation of the Schedule of Expenditures of Federal Awards. The district did not reconcile the expenditures reported on the SEFA with the amounts reported on the district's general ledger. Effect or Potential Effect: Potential understatement or overstatement of expenditures could exist in the Schedule of Expenditures of Federal Awards and not be detected and corrected. Because the SEFA was completed incorrectly, and not reconciled to the general ledger, the financial statements were materially misstated prior to the auditor's adjust-ments. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting re-sulted in the following: SEFA was originally presented for auditors with incorrect information, and not reconciled to the general ledger Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or cor-rect errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and re-view the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identi-fied and reported accurately on future SEFAs. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager Section IV—Summary Schedule of Prior Audit Findings There were no findings for the fiscal year ended June 30, 2023.

Responsible Official’s Response and Corrective Action Planned: We have implemented procedures to ensure that the SEFA includes all federal expenditures incurred during the reporting period, regardless of whether reimbursement has been requested. Reconciliation of the SEFA amounts are completed monthly. Management will also offer and require training to all personnel responsible on the Uniform Guidance requirements for SEFA reporting.

Reference Number: 2024-005 – Incomplete Schedule of Expenditures of Federal Awards Name of Contact Person: Chia Lor, Accounting Manager Corrective Action: Management agrees with the finding and recommendations. The City will begin to implement policies and procedures to assist with monthly reconciliations and review processes to mitigate these errors in the future. Proposed Completion Date: December 31, 2025

Recommendation: Controls should be implemented so that a complete understanding of grant compliance requirements should be obtained and monitored to ensure that the appropriate audits and financial statements are prepared and issued. Management Views: Management agrees with the finding as the issue was identified during the 2024 fiscal year audit. Action Planned: Controls have been implemented so that compliance requirements of grants are documented, reviewed, and monitored on a regular basis to ensure that appropriate audits are performed and financial statements are prepared and issued. A single audit was performed and appropriate financial statements were issued. Anticipated Completion Date: Complete Responsible Party: Catina Downey, CPA with oversight of Heidi Hooker, Executive Director

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

Reference: Finding 2024-002 Access Restricted to Documentation for Various Compliance Requirements – Research & Development Cluster; Noncompliance – Period of Performance, Procurement (Micro Purchasing), Subrecipient Monitoring, and Equipment and Real Property Management Contact: Erica Classing, Controller; classinge@battelle.org; 614-424-3372 Views of Responsible Officials: Battelle acknowledges this finding is the result of access restrictions to classified contract documents imposed by federal agencies that are beyond Battelle’s control. Battelle does not have the authority to grant auditor access to classified programs without the proper security clearance and program permissions, rather this authority resides with the federal awarding agency, in accordance with applicable federal security regulations. These restrictions prohibited access to classified contracts for required audit procedures in those areas noted in Finding 2024-002. Classified contracts are a small subset (10%) of Battelle’s total reportable expenditures. Battelle provided all unclassified documentation required to support transactions selected for testing. In addition, Battelle provided all documentation necessary to audit compliance with requirements on all non-classified contracts selected. Management upholds high standards of compliance and transparency and continues to support audit processes to the fullest extent possible. Battelle agrees to explore options to satisfy audit requirements while maintaining compliance with classified contract security regulations. Corrective Action Plan: Summary of finding: During compliance testing of period of performance, procurement (micro purchasing), subrecipient monitoring, and equipment and real property management, access to classified contracts was restricted. The auditor was unable to view federal award documents to confirm the following information: • Period of performance (5 of 50 selections) - unable to confirm the authorized project period • Procurement (micro purchasing) (2 of 40 selections) - unable to review applicable requirement relating to consent to subcontract • Subrecipient monitoring (2 out of 40 selections) – unable to inspect subaward information and applicable terms • Equipment and real property management (3 out of 50 selections) – unable to obtain proof of active use and safeguard of the classified equipment and validate whether the equipment disposal was handled properly in accordance with the contractual terms and conditions. Root cause: Access to classified contracts is subject to confidentiality requirements mandated by external regulators, requiring appropriate security clearance levels and verified need-to-know status. If the classified contract is a special access program, obtaining program-specific approvals from the awarding agency in addition to possessing the appropriate security clearance and need to know is required. There is no guarantee that the federal awarding agency will ultimately grant cleared auditors access to the classified contract. Corrective action: Battelle is taking the following steps to address the finding: • Internal Review: We conducted an internal review of the areas affected by the scope limitation to validate each selection complied with the applicable contractual and regulatory requirements. This action was completed by December 19, 2024 and did not identify any instance of non-compliance with applicable rules, regulations, or contractual requirements. • We have existing monitoring mechanisms in place to ensure compliance in the areas affected by the scope limitation. • Early coordination with external auditor: We are collaborating with our external audit team to identify any classified contract audit selections earlier in the annual audit process. A proactive approach will allow Battelle extra time to engage clients for required approvals to either gain access to the classified information or obtain appropriate alternative audit evidence. In addition, any other related steps that can be completed in advance such as verifying auditor clearance types and levels will be performed early to help mitigate any delays. This corrective action requires the audit firm to provide auditors with the appropriate security clearances. • Engagement with regulatory agencies: We are in dialogue with impacted federal awarding agencies to explore options to provide necessary audit evidence. • Enhanced documentation: We are enhancing our audit support procedures to provide guidelines on how, within the bounds of regulatory restrictions, we can provide access to audit evidence for future audits. Overall Anticipated Implementation Date: December 31, 2025

Reference: Finding 2024-001 Qualified Auditor’s Opinion for Allowable Costs and Activities Allowed and Unallowed and Special Tests and Provisions for Research & Development Cluster Due to Material Scope Limitations Contact: Erica Classing, Controller; classinge@battelle.org; 614-424-3372 Views of Responsible Officials: Battelle acknowledges the scope limitation is the result of access restrictions to classified contract documents imposed by federal agencies that are beyond Battelle’s control. Battelle does not have the authority to grant auditor access to classified programs without the proper security clearance and program permissions, rather this authority resides with the federal awarding agency, in accordance with applicable federal security regulations. These restrictions prohibited access to classified contracts for required audit procedures in those areas noted in Finding 2024-001. This limitation was only on classified contracts which is a small subset (10%) of Battelle’s total reportable expenditures. Battelle provided all unclassified documentation required to support transactions selected for testing. In addition, Battelle provided all documentation necessary to audit compliance with requirements on all non-classified contracts selected. Management upholds high standards of compliance and transparency and continues to support audit processes to the fullest extent possible. Battelle agrees to explore options to satisfy audit requirements while maintaining compliance with classified contract security regulations. Corrective Action Plan: Summary of finding: During testing of allowable costs and special tests and provisions, access to classified contracts was restricted. The auditor was unable to view federal award documents to determine allowability terms and conditions, security clearance requirements, or other special provisions for sample selections of classified contracts. Consequently, this restriction on access to the source contract document resulted in a material scope limitation for these testing areas. Root cause: Access to classified contracts is subject to confidentiality requirements mandated by external regulators, requiring appropriate security clearance levels and verified need-to-know status. If the classified contract is a special access program, obtaining program-specific approvals from the awarding agency in addition to possessing the appropriate security clearance and need to know is required. There is no guarantee that the federal awarding agency will ultimately grant cleared auditors access to the classified contract. Corrective action: Battelle is taking the following steps to address the finding: • Internal Review: We conducted an internal review of the areas affected by the scope limitation to validate each selection complied with the applicable contractual and regulatory requirements. This action was completed by December 19, 2024 and did not identify any instance of non-compliance with applicable rules, regulations, or contractual requirements. • We have existing monitoring mechanisms in place to ensure compliance in the areas affected by the scope limitation. • Early coordination with external auditor: We are collaborating with our external audit team to identify any classified contract audit selections earlier in the annual audit process. A proactive approach will allow Battelle extra time to engage clients for required approvals to either gain access to the classified information or obtain appropriate alternative audit evidence. In addition, any other related steps that can be completed in advance such as verifying auditor clearance types and levels will be performed early to help mitigate any delays. This corrective action requires the audit firm to provide auditors with the appropriate security clearances. • Engagement with regulatory agencies: We are in dialogue with impacted federal awarding agencies to explore options to provide necessary audit evidence. • Enhanced documentation: We are enhancing our audit support procedures to provide guidelines on how, within the bounds of regulatory restrictions, we can provide access to audit evidence for future audits. Overall Anticipated Implementation Date: December 31, 2025

Finding 2024-003: SEFA Preparation – Subrecipient vs. Subcontractor Determinations Name of Responsible Official: Nikolos Oakley, CFAO Anticipated Completion Date: 09/30/2025 Condition: Subcontractor amounts were improperly included in the Amounts Provided to Subrecipients column on the Schedule of Expenditures of Federal Awards (SEFA). Context: Management made improper subrecipient vs. subcontractor determinations, resulting in inaccurate SEFA preparation. This resulted in $2.6 million being removed from the Amounts Provided to Subrecipients column in the original SEFA provided to the auditors by management. Views of Responsible Officials and Planned Corrective Action: IntraHealth acknowledges the finding regarding the improper inclusion of subcontractor amounts in the Amounts Provided to Subrecipients column on the Schedule of Expenditures of Federal Awards (SEFA). We will improve our reporting and review processes to ensure subcontractor amounts are not incorporated under Amounts Provided to Subrecipients column in SEFA. Corrective Action: • Implement a more rigorous review process to ensure that only true subrecipients are included in the Amounts Provided to Subrecipients column of the SEFA. Subcontractor amounts will be reported separately as required. We will also improve training for the finance and grants management teams to ensure they fully understand the regulations. IntraHealth is committed to ensuring the accuracy of future SEFA reports and will complete the corrective actions by 09/30/2025. We will also continue to monitor the effectiveness of these changes to prevent future misclassifications.