Corrective Action Plans

August 15, 2025 To: Clausell & Associates, P.C. From: Tabirus Lockhart, Chief Financial Officer of Enrichment Services Programs, Inc. Below is the Agency’s corrective action plan as it relates to the findings for the fiscal year ending July 31, 2024, Single Audit Act audit. Comment #2024-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED GENERAL (Repeat) Views of Responsible Officials and Planned Corrective Actions: We concur with this finding - Management is in the process of assessing the organizational structure, capacity to provide adequate financial reporting. With Board review and approval of the Agency’s financial funding sources, the Agency will hire additional fiscal clerk to further support financial requirements and segregation of duties to ensure adequate internal controls are fully implemented. The CFO will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The new automated financial systems, will support financial reporting to meet GAAP requirements and to provide informative reports for Board and Management. All enhancements will be implemented by December 31, 2024. Concerning preparation of external reports required by various funding sources (i.e., SF-425, DHS’s reports for LIHEAP, LIHWAP, etc.), the Agency will ensure adequate training is performed to improve the skills and knowledge of key personnel. Policies and procedures will also be revised to support external reporting. Implementation Date: The plan correction date will be completed no later than December 31, 2025. Responsible Person: Tabirus Lockhart, CFO, will be responsible for the corrective action. Comment #2024-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND EARLY HEAD START, LIHEAP, LIHWAP, CSBG, ASTHO, CACFP, and SLFRF FAL # 93.600, 93.568, 93.499, 93.569, 93.185, 10.558, 21.027 (Questioned Costs - Undetermined) Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Management and staff are in the process of assessing and updating the policies and procedures over the accounting and reporting of federal and state grants and contracts. In connection with training staff on the new and updated accounting system, we are providing ongoing training on the requirements of the Uniform Guidance and the specific requirements for each individual grant award as outlined in each applicable Compliance Supplement issued by Office of Management and Budget (OMB). We are currently reconciling all cash accounts and completing and amending, where necessary, all SF-425 reports and other external reports required by each funding source (state and federal). We anticipate completing this corrective action by December 31, 2025. See also the response to Comment #2024-001. Implementation Date: The plan correction date will be completed no later than December 31, 2025. Responsible Person: Tabirus Lockhart, CFO, will be responsible for the corrective action.

Corrective Action Plan 8/15/2025 Department of Health and Human Services Semcac respectfully submits the following corrective action plan for the year ended 09/30/2024. BerganKDV, Ltd. 220 Park Ave S St. Cloud, MN 56301 Audit Period: 10/1/2023 – 9/30/2024 The finding from the 9/30/2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Finding 2024-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2023-001 Submission of the Audit Reporting Package and Data Collection Form Recommendation: We recommend that management address the lack of capacity in the finance department and monitor the year-end closing schedule for a timely audit reporting package and data collection form to ensure compliance with federal deadlines. Action Taken: We agree with the auditors’ recommendation and the following action will be taken to address the finance departments capacity constraints and year-end closing schedule to ensure timely submission of the audit reporting package and data collection form. We have added capacity to the finance department at the beginning of FY2025 by 1.0 FTE. We have also contracted with an outsourcing accounting firm to enhance and improve our internal controls, processes, and procedures to ensure we both follow our year-end closing schedule and provide a timely audit reporting package. If the Department of Health and Human Services or the Department of Energy have questions regarding this plan, please call Adam Larson at (507) 864-8218. Sincerely yours, Adam Larson, Semcac Fiscal Director

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.

COO will work with all program areas to ensure that all federal awards and subawards are identified as such to ensure we track properly COO will ensure we have written documentation for all federal pass-through funding We have added an experienced grants accountant supervised by the CFO to verify the federal nature of all awards and stay current on SEFA and Uniform Guidance

The City's Finance Department, in preparing the annual SEFA, will have a review and approval process. The SEFA will be prepared by the accounting division based upon federal grant expenditures recorded in the City's General Ledger. The SEFA document will then be reviewed by the Deputy Finance Director and approved by the Finance Director prior to submission to the auditing firm. In addition to federal grants adopted as part of the City's annual operating budget, after adoption of the annual operating budget any federal grant approved by City Council for acceptance and expenditure will be maintained in the City's electronic archival system. The SEFA will be compard to the list of budgeted grants and the grants accepted after adoption of the annual operating budget to ensure grants are appropriately reported on SEFA.

Recommendation: After thoroughly reviewing the unique circumstance that led to this audit finding, we have determined that it is highly unlikely to recur. Given the organization's strong compliance history and familiarity with SEFA reporting under Uniform Guidance, we do not see a cost-effective benefit to revamping internal controls specifically for the issue. Instead, we recommend continuing to: review government awards, provide refresher trainings to staff, and conduct periodic reviews of internal controls to ensure ongoing compliance. These measures will effectively address the finding without incurring unnecessary costs. Planned Action: The organization acknowledges this was a unique situation and it is unlikely to recur. As a precaution, we will be reviewing training with staff and conduct periodic and annual reviews of the SEFA related funds. We will also continue to bring unique situations to the attention f the auditors to maintain our strong compliance history.

Finding 2024-004 – Material Misstatement of the SEFA Contact Person: Nicole Roberts, Village Manager Planned Corrective Action: The Village will enhance its grant tracking processes and assign responsibility for SEFA preparation and reconciliation to a designated individual before audit submission. Anticipated Completion Date: December 31, 2026

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

2024-003 Inaccurate Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding and plans on creating a formal process for SEFA preparation. Training will be provided for responsible staff.

Views of Responsible Officials: Despite difficulty preparing the report within the timeframe requested, the grant was administered in accordance with Uniform Guidance and no questioned costs were identified. To assist with more efficient and accurate reports, AcademyHealth will begin implementing a new accounting system (Sage Intaact) in August 2025 which includes an integrated SEFA module to ensure complete and accurate reporting in future years.

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

Recommendation: We recommend that the Parish enhance policies and procedures over financial reporting and preparation of the SEFA so that duties are well defined, and responsibilities are properly outlined to assist periods of transition or turnover of key employees, as well as identifying and correcting errors on a more frequent basis through a monthly reconciliation process for all material and/or significant account balances. Additionally, we recommend that all journal entries proposed are reviewed and approved by the chief financial officer or designee. Corrective Action: The Parish has written a Standard Operating Procedure for “Grant ManagementFinancial Reporting & Reconciliation” which outlines the role of the Finance Department in monitoring grant activities including measures to ensure correct general ledger coding for budget planning, complete and accurate recording of grant expenditures and revenues, and administrative review to confirm reconciliation of grant activities against the general ledger on a monthly basis. This corrective action was approved and implemented effective 6/30/2025.

2024-003) Preparation of Schedule of Expenditures and Federal Awards CFDA Listing Numbers Name of Federal Program or Cluster 97.036 Disaster Grants-Public Assistance (Presidentially Declared Disasters) Disaster Grants through FEMA are managed by rules and processes that are not easily accounted for in traditional accounting systems. Procedures will be strengthened to fully and accurately identify all federal program expenditures and record in the appropriate accounting funds. Procedures will be implemented to prepare documentation necessary to support the information in the financial statements earlier and more accurately, for the information to be completed, available and provided to auditors for the audit. Persons responsible: Dennis Bent, C.F.O.; Martha Witherwax, Director of Accounting Expected Completion date: July, 2025

Reporting Administration will work to ensure that a procedure is in place for reconciliation which is documented and reviewed by the VP for Administrative Services and the College Controller by the end of 2025.

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

Action Taken: Management agrees with the recommendation from the audit and has implemented additional steps in its close process to review new grants to ensure the source of the funds is identified and the schedule of expenditures of federal awards is accurately prepared. Name of Contact Person: Landen Fledderjohn, Financial Manager Estimated Completion Date: June 30, 2025

Views of Responsible Officials: FASEB acknowledges the audit finding regarding the exclusion of certain Federal expenditures from the Schedule of Expenditures of Federal Awards. We recognize the critical importance of accurately reporting all Federal expenditures to ensure compliance with Federal requirements and to maintain transparency in our financial reporting. Managements Response to Audit Finding on missing Federal expenditure on final SEFA: 1. Review and Update Financial Reporting Procedures:  We will review and revise our current financial reporting procedures to ensure that all federal expenditures are accurately captured and reported in the SEFA.  Specific emphasis will be placed on identifying all sources of federal funding and ensuring they are correctly classified and included in the SEFA.2. Training for Staff:  Comprehensive training will be provided for all staff involved in the preparation and review of the SEFA.  The training will cover federal reporting requirements, proper identification of federal expenditures, and the importance of accurate SEFA reporting. 3. Enhanced Review and Reconciliation Process:  We will establish an enhanced review and reconciliation process to verify the completeness and accuracy of the SEFA before submission.  This process will involve cross-checking federal expenditures against grant agreements, payment records, and other relevant documentation. Conclusion: FASEB is committed to addressing the findings related to the omission of Federal expenditures in the SEFA. We are confident that the steps outlined in our corrective action plan will ensure comprehensive and accurate reporting of all Federal expenditures. We value the opportunity to improve our financial reporting practices and will provide progress updates as requested.

Preparation of and Internal Controls Over Monthly Invoicing and SEFA Preparation Planned Corrective Action: 1. All invoices created and submitted will run through the Accounts Receivable module. 2. All Accounts Receivable will be posted from the subledger to the ledger by the Director of Finance. Person Responsible for Corrective Action: Jereme Fish, Director of Finance. Anticipated Date of Completion: June 1st, 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.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. The Group will prepare and maintain an accurate SEFA in accordance with 2 CFR 200.510 to ensure proper documentation and compliance with federal reporting requirements. Group staff are trained on the requirements related to federal award reconciliations and SEFA preparation which mitigates the risk of noncompliance in the future.

Solvista Health management agrees with the auditor’s finding. In conjunction with the shared services agreement, the Group will design and implement internal control procedures to reconcile federal awards with the expenditures and revenue received to ensure completeness and accuracy in financial reporting. The Group will prepare and maintain an accurate Schedule of Expenditures of Federal Awards (SEFA) in accordance with 2 CFR Part 200.510 to ensure proper documentation and compliance with federal reporting requirements. Group staff are trained on the requirements related to federal award reconciliations and SEFA preparation which mitigates the risk of noncompliance in the future.

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