Corrective Action Plans

2025-001: Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Educational Stabilization Fund ASSISTANCE LISTING Numbers: 84.425C – Governor’s Emergency Education Relief Fund 84.425R – Emergency Assistance to Non-Public Schools 84.425U – Elementary and Secondary School Emergency Relief Fund 84.425V – Emergency Assistance to Non-Public Schools Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Recommendation: We recommend that the University evaluate its cutoff procedures to ensure that federal costs are identified and reported in the correct fiscal year. We also recommend that the University evaluate its internal controls to ensure that federal awards are properly identified as such at inception. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OSU is implementing a campus-wide Administrative Modernization Program (AMP) to update technology, improve efficiencies, and ensure a comprehensive internal control environment. This modernization includes redesigning the university’s administrative and grant processes, including budget development, payroll lifecycle, employee recruitment, grant effort reporting, procurement, and others. A primary aspect of this optimization is a transition of the university’s enterprise resource planning (ERP) system from Banner to Workday effective July 1, 2026. To reflect this system transition, OSU’s actions in response to the finding will be taken in two stages: 1. For FY26, the Division of Research and Innovation (DRI) will run reports and screen for anomalies and mismatches of revenue type and fund type to identify awards with the correct federal fund when a federal program is identified with an ALN#. The screening will take place before the fiscal year end, allowing time for corrections to be made in Banner while the fiscal year is still active. 2. For FY27 and beyond, rather than a warning, critical custom validations will be required and established in Workday as follows: • Any award that uses an ALN# also must include the appropriate Fund and Revenue Category worktags on the award line • Any award with a federal sponsor or federal prime sponsor must have ALN# entered • Any award with a federal sponsor or federal prime sponsor must include the appropriate Fund and Revenue Category worktag on the award line Name of the contact person responsible for corrective action: Jennifer Creighton, Associate Vice President for Research Administration, Finance and Operations Planned completion date for corrective action plan: Corrective action to screen for anomalies and mismatches of revenue type and fund type in Banner to ensure awards are identified with the correct federal fund will occur by June 30, 2026. The establishment of custom validations in Workday to ensure identification of federal awards will occur and be ongoing with the new system implementation after July 1, 2026.

Management will strengthen SEFA preparation and review procedures to ensure federal expenditures are complete, accurate, and properly reported in accordance with 2 CFR 200.510(b). • Reconciliation: Reconcile SEFA totals to the general ledger and grant-level records and resolve discrepancies. • Management Review: Implement documented management review of the SEFA for completeness and accuracy prior to issuance.

Finding Reference 2025-02 Corrective Action Plan: The Designated Office responsible for processing federal funds received through state agencies will deliver to the Finance Office a transaction list and a reconciliation of the disbursements made during the fiscal year. The Finance Office will review all transactions recorded during the current fiscal year and will prepare an accrual entry. These transactions will be reconciled against the transactions recorded during the subsequent fiscal year to confirm that funds were recorded in the appropriate fiscal period. The review and recording of these transactions will be completed during the final phase of the accounting closing process and prior to delivery of the Trial Balance to the external auditors. Responsible: Ms. Maria Del R. Ramos Ocasio, Accounting and Finance Manager Planned Implementation Date: In process. Expected to be completed on or before September 30, 2026.

2025-006 – Internal Control Deficiency in Financial Reporting – Untimely Recording of Grant Program Expenditures Cluster: Not applicable Sponsoring Agency: United States Agency for International Development (USAID) Award Name: USAID Foreign Assistance for Programs Overseas Award Number: 7200AA19CA00018, 7200AA21LE00003 Assistance Listing Title: USAID Foreign Assistance for Programs Overseas Assistance Listing Number: ALN 98.001 Award Year: 2024-2025 Pass-through entity: Not applicable Compliance Requirement: Schedule of Expenditure of Federal Awards Reporting and Period of Performance On January 1, 2024, the campus converted from the Kuali Financial System (KFS) to the Oracle Cloud financial system (AE). There was a pre-conversion blackout period from mid-November 2023 through January 1, 2024. Additionally, as part of this transition, advance account balances were not initially migrated and were subsequently moved into AE projects. This resulted in changes to how these balances were tracked and processed. Initially, these balances were placed in a single project, and there were delays in processing liquidations until balances could be reconciled and distributed to the individual projects established for each sub awardee. Due to these delays and the pre-conversion blackout period, a backlog of transactions was created. Reconciliations and liquidations were subsequently processed in September 2024. As of September 2024, the process for advance liquidations has been implemented, including distributing balances to the appropriate projects. These procedures are now in place and have been fully implemented through the established process. For inquiries regarding this finding, please contact Mario Reina-Guerra at mreinaguerra@ucdavis.edu.

Department: Administrative and Financial Services Title: Internal control over Medicaid SEFA reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS Service Center will update the internal SEFA procedure to include the step of removing appropriations 0129, 0147 and 0148 from the subrecipient queries. The DHHS Service Center will update the reviewer's checklist for the SEFA to include a check that appropriations 0129, 0147 and 0148 are being excluded from subrecipient queries. The DHHS Service Center will add a note within the "Subrecipient" tab of the internal SEFA Cubes Workbook to exclude appropriations 0129, 0147 and 0148. Completion Date: February 20, 2026 (first item), and October 31, 2026 (second and third items) Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626

Department: Health and Human Services Education Administrative and Financial Services Title: Internal control over PDG SEFA reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The DHHS Service Center will consult with OSC to help ensure our current processes are correct and are designed to provide accurate information for the SEFA. The DHHS Service Center will update procedures and provide guidance/trainings as necessary to staff to ensure reporting of expenditure amounts for the SEFA is accurate. Completion Date: August 31, 2026 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626

Department: Administrative and Financial Services Title: Internal control over Health Disparities program SEFA reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Service Center will consult with OSC to help ensure our current processes are correct and are designed to provide accurate information for the SEFA. The Service Center will update procedures and provide guidance and trainings as necessary to staff to ensure reporting of expenditure amounts for the SEFA is accurate. Completion Date: August 31, 2026 Agency Contact: Sarah Gove, Director, DHHS Service Center, DAFS, 207-458-6626

Finding 2025-702: Research and Development Cluster—Reporting in the Schedule of Expenditures of Federal Awards Planned Corrective Action: The Universities of Wisconsin (UW) will revise documented procedures for preparing the Schedule of Expenditures of Federal Awards (SEFA) to include updated steps for the compilation of federal grant activities using the new accounting system by June 30, 2026. Existing procedures will be strengthened and implemented to review whether federal expenditures related to agreements with other state agencies that specify the relevant assistance listing number are property classified in the SEFA. Additional training and guidance will be provided to UW university and administration stakeholders on revised documented procedures as a critical part of the improvement in the SEFA reporting process. Anticipated Completion Date: November 2026 Person responsible for corrective action: Josh Smith Senior Associate Vice President for Finance Universities of Wisconsin josh.smith@wisconsin.edu

Significant Deficiency 2025-002 (Internal Control Over Federal Award Reporting – ESSER III) Federal Program: Education Stabilization Fund - ARP-ESSER ALN: 84.425U Condition: Allowable ESSER III expenditures incurred during fiscal year 2023-24 were not identified or included on the Schedule of Expenditures of Federal Awards (SEFA) for that year. In addition, expenditures related to Federal Set-Aside awards were mistakenly included in the Final Expenditure Report for ESSER III, resulting from a misunderstanding of the structure of the federal awards. Recommendation: Strengthen internal controls Corrective Action: The District will provide targeted training to staff responsible for federal grant accounting to ensure a clear understanding of federal grant award structures, including the distinction between ESSER III and related Federal Set-Aside awards. This training will cover grant setup, expenditure coding, and reporting requirements. Person Responsible: Brenda VanBuskirk, Business Manager Proposed Completion Date: December 31, 2025

Planned Corrective Action: The new policy was discussed during the fiscal year for identifying federal awards. The written memo detailing the new policy was updated on September 30, 2025. This is the policy in place to be followed when preparing the schedule of expenditures of federal awards Contact Person: Name: Brianne Hoelschen Title: Controller Phone: (617) 209-5222 Email: bhoelschen@maloneyproperties.com Completion Date: September 30, 2025

Management concurs with the audit finding and has implemented a corrective action plan.

Program: Various, including 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds; 10.555 – National School Lunch Program – Reporting Corrective Action Plan: State Accounting will continue to work with State agencies on correct coding and business unit setup to reduce agency errors. Contact: Philip Olsen Anticipated Completion Date: Continuous review performed.

Condition: The City did not accurately prepare a SEFA that included all federal expenditures in fiscal year 2025, which resulted in a difference of approximately $7.6 million. Planned Corrective Action: The City will ensure that all future expenditures of federal awards are included on the SEFA by assigned staff to prepare and review the SEFA and track the amounts throughout the year. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 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, the Authority 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.

Responsible Person(s): Darin Moore, Deputy Director of Administration and Outreach; Sarah Boggs, Accounting Manager for Planning and Finance; Suzanne Robinson; Tim Springer, Budget Manager for Planning and Finance Corrective Action Planned: Review the current DWR process and determine whether DWR should petition the Comptroller for an exception to CAPP Topic 20605 or modify the DWR process to the “split coding” method instead. This will include: 1.) Evaluation of grant program guidance to ensure no obstacles exist from the Federal Awarding Agency to changing DWR's current methodology; 2.) Meeting and discussing with other (like) state agencies for policy, procedure, and training examples for split coding grant eligible expenditures; 3.) Scheduling meetings with Department of Accounts and the previous APA Audit Team to discuss DWR's evaluation, decision, and next steps; 4.) Developing and implementing new DWR policies and training to ensure compliance with the approved methodology. (Estimated completion date: July 1, 2026) Update current policies and procedures to conform with CAPP Manual Topic 20405 and to enhance the agency's current supporting documentation for all journal entries. At a minimum, these new policies and procedures will require that Voucher ID/Expense Report IDs that are moved within a journal entry are documented in the journal reference line in the system to improve transparency, will add more detailed explanations to justify coding changes, will upload applicable documents into the system to assist in manager approval, and will maintain all documentation centrally in one location for easier access and review. (Estimated completion date: July 1, 2026) Publish and maintain a sustainable federal drawdown schedule, by: 1.) Evaluating DWR's current federal drawdown schedule in accordance with current policies, procedures, employee workload, cashflow, and Federal Awarding Agency's guidance; 2.) Developing specific controls, and revised job descriptions as needed to ensure the drawdown schedule can be consistently maintained; and 3.) Incorporating both the new schedule and controls into appropriate policies and procedures to ensure accountability. (Estimated completion date: June 1, 2026) Evaluate current policies, procedures, and practices pertaining to how DWR manages and records Program Income. Develop and update policies and procedures to ensure compliance with CAPP 20205. Provide training on new policies and procedures to employees within the Planning and Finance Division. (Estimated completion date: June 1, 2026) Review current internal procedures for reporting federal expenses on the SEFA and Attachment 15 and identify training gaps. Enlist training support from Department of Accounts and/or other state agencies to address training gaps. Develop new written policies and procedures, along with new supporting documentation requirements, to conform to SEFA and Attachment 15 guidelines and expectations. Provide training on new policies and procedures to employees within the Planning and Finance Division. (Estimated completion date: July 1, 2026) Review all other written policies and procedures for administering federal grants and contracts, and develop and update as necessary to address insufficient guidance and noncompliance. (Estimated completion date: August 31, 2025) Estimated Completion Date: 7/1/2026

Reference Number: 2025-001 Name of Contact Person: Julie Bondarchuk, Financial Controller Corrective Action: The expenditure occurred in calendar year 2020 and 2021. Since these funds were emergency funds, no deferred revenue was accrued since staff was uncertain of whether costs would be eligible for reimbursement. Final revenues of $101,355 were received in FY2025, and staff recorded the revenue received on the SEFA, but not the expenditure. Going forward, staff will report expenditures on the SEFA when eligible expenditures are approved by FEMA. Proposed Completion Date: 6/30/2026

Views of responsible officials and corrective action: The organization hired an individual contractor to assist with the implementation of a formal financial closing process, which includes identifying a detailed and specific process to review and reconcile procedures to ensure accurate reporting of federal expenditures and alignment with the general ledger. Responsible Individual: Okeema Polite, CEO/Executive Director Todd Falcone, Independent Contractor Bookkeeper Vannessa Lindsey, Board President Implementation Date: ACAC has begun implementing the procedures with the assignment to the Independent Contractor as of May 2025. Recommended procedures will be implemented by July 30, 2026

Views of Responsible Officials and Planned Corrective Action The County fully implemented a grant software program in FY 2026 to provide accurate and complete tracking and reporting of federal award expenditures. Finding resolution timeline: This has been resolved as of 12/4/2025. Designation of employee position responsible for meeting this deadline: Andrea Montoya (Deputy County Manager), Gabriella (Betty) Orosco (Assistant Finance Director) and Francine Mondello( Grant Administrator)

Management acknowledges the deficiency in the preparation and oversight of the Schedule of Expenditures of Federal Awards (SEFA) for the year ended May 31, 2025. To address this finding, the College will: • Implement a formal SEFA preparation policy aligned with 2 CFR §200.510(b) • Develop and maintain a centralized federal awards tracking log identifying: o Federal agency o Program name o Assistance Listing Number (ALN) o Award number o Pass-through entity (if applicable) o Expenditures by fiscal year • Establish quarterly reconciliations between the general ledger and the federal awards tracking log • Require structured cross-departmental communication between the Business Office, Financial Aid Office, Grants Administration, and program departments to ensure all federal awards received and expended are identified timely • Implement documented management review and approval of the SEFA prior to submission to auditors These corrective measures will strengthen internal controls over federal award tracking, improve the accuracy and completeness of the SEFA, and ensure compliance with Uniform Guidance requirements. Anticipated Completion Date: May 31, 2026

Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: Implementation of a formal procurement and suspension and debarment policy that includes procedures over review of the federal suspension and debarred listing, that is in compliance with the Uniform Guidance. Procurement policy should include general procurement standards as described by the Uniform Guidance, that include standards on conduct covering conflicts of interest; method of procurement for micro-purchases, small purchases, sealed bids, and proposals; and all other criteria as outlined in 2CFR 200.318 through 200.327. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will develop and implement a procurement policy that is in compliance with the Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Sydney Falk, CFO Planned completion date for corrective action plan: February 28, 2026

RE: Finding 2025-003 Misreporting of Pass-Through Grant Expenditures in Compliance Report In conjunction with our FY25 annual audit, please see the City's corrective action plan below: The City of Sand Springs will strengthen internal controls over federal grant reporting to ensure proper distinction between direct federal awards and federal pass-through grants, in accordance with Uniform Guidance and SLFRF requirements. Specifically, the City will implement the following corrective actions: Separate Tracking of Direct vs. Pass-Through Funds o The Finance Department will revise grant accounting procedures to clearly segregate expenditures related to: Direct SLFRF (ARPA) awards administered by the City, and Federal pass-through grants administered by external entities, including OWRB. o Separate project codes and/or accounting identifiers will be maintained to prevent commingling of expenditures. Revision of SLFRF Reporting Procedures o Written procedures for preparation and review of the SLFRF Compliance Report will be updated to explicitly state that: Only expenditures related to direct federal awards are to be reported by the City, and Expenditures related to pass-through grants are excluded and reported by the pass-through entity. o A documented review step will be added to verify that reported expenditures align with the funding source prior to submission. Staff Training and Awareness o Finance staff involved in grant accounting and reporting will receive targeted training on: Uniform Guidance requirements (2 CFR 200), The distinction between direct federal awards and pass-through grants, and Proper SEFA and SLFRF reporting responsibilities. o Training will be documented and incorporated into onboarding materials for future staff. Coordination with Pass-Through Entity (OWRB) o The City will coordinate with OWRB to confirm: The sequence of fund utilization (pass-through vs. direct ARPA funds), and Roles and responsibilities for federal expenditure reporting. Expected completion date: Procedures will be implemented for the fiscal year ending June 30, 2026, and applied during interim processing and year-end close. Party Responsible: Finance Director and Finance Staff, in coordination with applicable Department Heads and Project Managers. Contact Information: Arlena Barnes 918-246-2646 arlena.barnes@sandspringsok.gov

The District will implement procedure to ensure that grant activity is charged during the proper period and sufficient documentation is maintained.

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

By requiring Finance Department signatures for all grant applications, a comprehensive list of all potential program awards can be maintained. From this information, potential expenditures can be monitored for the awards inclusion on the SEFA.

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