Corrective Action Plans

VIEWS OF RESPONSIBLE OFFICIALS In response to the Audit finding related to maintaining adequate records the Department will implement and follow up on previous Correction Actions Plans in order to complete the requirements. 1. The Department will maintain adequate accounting records related to the federal programs and properly keep records accessible for each program. And updated SOP was drafted and is pending final review by the Federal Agency (EPA) to implement. 2. The Department drafted a new internal control implementation/Review/Monitoring process in order to resolve the systemic internal controls issues. Specific Work Plan and implementation will be started once final approvals of the aforementioned documents. IMPLEMENTATION DATE June 30, 2026 RESPONSIBLE PERSON Finance Director

Finding 2024-244: The Department’s original Schedule of Expenditures of Federal Awards submitted to the Office of the State Controller underreported the amount disbursed to subrecipients by $3,500,000 under the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) program. Related to Prior Finding: N/A Agency’s view: Agree Corrective Action Plan: The Department will improve training and the review process for the SEFA closing package to ensure appropriate reporting of subrecipient expenditures on the SEFA. The Department will review the FY 2025 SEFA closing package that was submitted to the Office of the State Controller to ensure the appropriate subrecipient expenditures were reported. Anticipated Corrective Action Date: November 30, 2025 Responsible for Corrective Action: Sascha Marston Financial Officer (208) 287-4819 Sascha.marston@idwr.idaho.gov

Finding 2024-242: The Division did not accurately report federal grant expenditures on the Schedule of Expenditures of Federal Awards (SEFA) Closing Package. Related to Prior Finding: N/A Agency’s view: Agree 6.1 Corrective Action Plan: Develop and Implement Written SEFA Procedures: Create formal written procedures describing how SEFA amounts are compiled, reconciled, reviewed, and approved prior to submission within Grants Management Manual. 6.2 Strengthen Internal Controls and Oversight: Implement internal review and approval steps that require documented verification of SEFA amounts against Luma accounting records. 6.3 Ensure Accurate Grant Coding: Review and correct all federal grant fund transactions not assigned to specific grants, ensuring proper coding and allocation in Luma. 6.4 Training and Staff Development: Provide training to fiscal staff on SEFA preparation, reconciliation, and documentation requirements. 6.5 Establish Continuous Monitoring: Perform periodic reviews of federal expenditure coding and SEFA data to identify discrepancies before year-end reporting. Anticipated Corrective Action Date: 04/01/2026 Responsible for Corrective Action: Eric Bjork, Fiscal Officer

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

Finding 2024-205: The Commission could not provide documentation to support the review of the Schedule of Expenditures of Federal Awards (SEFA) Closing Package. Related to Prior Finding: N/A Agency’s view: Agree Corrective Action Plan: ICBVI acknowledges that it did not document the review process for the SEFA closing package. Review Documentation: Procedures will be implemented requiring a documented review prior to submission, with signatures from both preparer and reviewer and archiving of supporting schedules. Procedural Update: We will ensure that the preparer and reviewer/approver are assigned to different individuals for closing packages going forward. This separation of duties will be incorporated into our procedures to strengthen internal controls and enhance the accuracy and integrity of our financial reporting. Anticipated Corrective Action Date: 12-15-25 Responsible for Corrective Action: Corey Bresina, Administrative Services Manager, 208-639-8369, cbresina@icbvi.idaho.gov

After a review of the draft audit findings, Nodaway County shows that the original amount reported on the SEFA page was the full amount spent and should have only been the 75% (less the match amount which was paid through the Coronavirus State and Local Fiscal Recovery Funds). For future compliance, the County Clerk has already implemented a SEFA reporting spreadsheet to better track the expenditures of federal funds.

Submission of the Audit Reporting Package and Data Collection Form Recommendation: We recommend the organization strengthen its internal controls over the reconciliation process, including implementing a formal review procedure and ensuring reconciliations are supported by complete and accurate documentation prior to audit fieldwork. Timely and accurate reconciliations are critical to maintaining reliable financial reporting and audit readiness. Action Taken: CMJTS acknowledges the delay and has been making improvements to ensure reconciliations are done timely. Accounting staff have been given additional training on bank reconciliations, and they are now reconciling bank transactions daily. This real time reconciling helps ensure that all transactions are processed accurately. Bank reconciliations are then signed off by Finance Manager and the Board Treasurer monthly. Accounting staff have been given additional training on statement of financial position reconciliations and will be reconciling them monthly. The statement of financial position, with supporting documentation, will then be signed off by the Finance Manager monthly.

Corrective Action Plan - Audit Finding 2024-001: Inaccurate and Incomplete SEFA and Delay in Reporting 1. Documentation Procedures • All federal pass-through funding received will be supported by written documentation (e.g., subaward agreements, grant award letters). • A centralized repository for federal award documentation will be maintained and made accessible to the finance team. 2. SEFA Preparation Controls • A SEFA preparation checklist will be developed and implemented to ensure all federal programs are accurately identified, classified, and reported. • Verification of Assistance Listing Numbers (ALNs) and funding sources for all awards included in the SEFA will be required. 3. Designation of Responsibility • The SEFA Compliance Lead will be assigned responsibility for verifying the federal nature of all awards and ensuring accurate SEFA reporting. • Ongoing training will be provided to finance staff on SEFA requirements and Uniform Guidance compliance. 4. Review and Approval • A formal review and approval process for the SEFA will be instituted prior to submission, including review by the Finance Director and Executive Director. 5. Monitoring and Follow-Up • The Finance Director will monitor ongoing compliance and report quarterly to the Board of Directors on SEFA preparation and submission status. • An annual internal review of SEFA procedures will be conducted to ensure continued compliance. Implementation Timeline All corrective actions will be implemented by March 31, 2026. Responsible Personnel • SEFA Compliance Lead: Mimi Lim, Sr. Finance and Operations Manager • Finance Director: Christine Kuo • Executive Director: Monique Brown This Corrective Action Plan is designed to address the auditor’s recommendations and prevent recurrence of similar issues, in accordance with 2 CFR 200.511(c) and best practices for federal grant compliance.

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

Share Food Program has developed procedures and processes to manage, maintain, and reconcile the Financial Statements to the Schedule of Expenditures of Federal Awards as part of our year end closing procedures. This was implemented, and it is expected that the June 30, 2025 reporting will be timely and accurate.

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

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

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.

We are taking steps to address the ongoing issue by coordinating with department heads and the Treasurer to ensure all grant paperwork is properly received and documented.

Finding 2024-002: Submission of the Reporting Package and Data Collection Form Management Response: Agreement with Finding: Management acknowledges and concurs with the finding. Root Cause: The agency experienced unanticipated delays in the preparation and submission processes for the Schedule of Expenditures of Federal Awards (SEFA) and related audit documentation, resulting in the audit reporting package and Data Collection Form not being submitted within the required timeframe. Management Plan: Lakes and Pines has engaged a professional accounting firm to assist with comprehensive process improvements for financial reporting. The agency will work with the firm to establish enhanced procedures and internal controls for the timely preparation of the SEFA and all required audit materials. New processes will include earlier preparation timelines and milestone checkpoints to ensure submission deadlines are met Responsible Party: Dawn van Hees, Fiscal Controller Implementation Timeline: Improvements will be implemented during the 2025/2026 fiscal year, with the enhanced processes fully operational for the next audit cycle reviewing that fiscal year. Current Status (as of November 5, 2025): The professional accounting firm has been engaged and process improvement work is underway.

The SEFA information needed for this finding was from the 2025 budget. The 2025 budget can be amended up to 12/31/2025. Even though the ARPA funds in question were not reported on the SEFA page of the 2025 budget, it was reported within the budget within its own fund, which would show actual expenditures of the year ended December 31, 2024. Going forward the County Clerk will have the Treasurer review the SEFA report for accuracy.

Scotland County’s response for issues found: 1. We will double check to make sure we didn’t miss something for the SEFA report. 2. We will update the 2024 SEFA for the corrected amounts. 3. The Highway Planning and Construction (MODOT Intermodal) included the railroad bridge that no one could tell us where the money was coming from. This accounted for $1,228,104.64. We will correct this on the SEFA. 4. The ARPA was the interest received in 2024. We didn’t receive any more money from the state in 2024. We will get this added to the SEFA. 5. The HAVA Election Security Grant was missed when we were putting them in the report. We will get this added to the SEFA.

Mrs. Clark (the County Clerk) didn’t realize she hadn’t included the number of monies in the SEFA report from ARPA monies. The correction was made when auditors were here.

Views of Responsible Officials and Planned Corrective Actions: Management agrees and has adopted a SEFA tracking template. Corrective Action: Track federal expenditures monthly by funding source and Assistance Listing Number (ALN), reconcile SEFA totals to the general eldger, and train staff on Uniform Guidance.

CONDITION: The Regional Office of Education No. 39 did not have sufficient internal controls over the preparation of the SEFA to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was complete and accurately reported. PLAN: The Regional Office of Education No. 39 will implement controls over financial statements for both the internal Business Office Manager and the contracted accounting firm to prepare and review the financial statements including the schedule of expenditures of federal awards, to ensure program titles, assistance listing numbers and other pertinent information is accurate for financial statement presentation. ANTICIPATED DATE OF COMPLETION: Implemented August 2025

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

Finding 2024-002 Significant Deficiency, Inaccurate Schedule Of Expenditures Of Federal Awards Personnel Responsible for Corrective Action: Monet Edwards, Finance Director Anticipated Completion Date: October 15, 2025 Corrective Action Plan: The City will strengthen internal controls by requiring that all new grants have a pre-audit meeting for between the Department Head administering the grant and the Finance Director to review all relevant grant paperwork and the SEFA spreadsheet.

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

We have employed a third-party accounting firm to review and reconcile the accounting records and post necessary bookkeeping entries. Additionally, we have re-organized management and responsibility to ensure timely and effective record keeping. This will ensure timely preparation of the SEFA and we will submit the SEFA to the auditor.

Validate that future federal allocations received in fund 245 are properly classified as federal funds in the SEFA (Schedule of Expenditures of Federal Awards). To ensure compliance with reporting requirements and fiscal transparency, guidance will be provided to the responsible team regarding the appropriate procedures for identifying, documenting, and accurately reflecting each federal received in the SEFA. This measure is intended to strengthen internal controls, ensure the traceability of federal resources, and facilitate compliance with external audits and applicable regulations. IMPLEMENTATION DATE Immediately RESPONSIBLE PERSON Lumary Ojeda Ocasio