Corrective Action Plans

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

Finding Number: 2025-001 Condition: The 2025 Schedule was initially overstated to include federal awards relating to ALN 14.251, Economic Development Initiative, Community Project Funding, and Miscellaneous Grants, expended during the year ended June 30, 2024. Planned Corrective Action: Food Bank of the Rockies, Inc. received a reimbursement grant for vehicles from the Department of Housing and Urban Development (HUD). While we purchased the vehicles in fiscal year 2024, we could not file the claim for reimbursement until fiscal year 2025. Guidance on the HUD claims process was greatly delayed for multiple reasons. We posted the cost and asset when ordered, following accounting principles generally accepted in the United States (GAAP). However, we did not include the funding on the 2024 Schedule as we had not yet filed the reimbursement claims, nor been given assurance they would be paid. Instead, we included it in the fiscal year 2025 Schedule as that was when the claims were filed and we had confirmation they would be paid in full. We understand now that, per Uniform Guidance 2 CFR 200.51(b), those funds should have been shown the fiscal year 2024 Schedule. With this understanding, moving forward we will include in the Schedule amounts that have been spent for which we have an agreement for reimbursement, regardless of timing of the claim being filed or level of certainty of reimbursement. Contact person responsible for corrective action: Heather MacKendrick Costa Anticipated Completion Date: Completed

2025-002 SEFA Presentation Error – Prior Year Criteria: Uniform Guidance (2 CFR §200.510(b)) requires that the Schedule of Expenditures of Federal Awards (SEFA) accurately present all federal awards, including the correct identifying numbers assigned by pass-through entities for each award. Accurate reporting is essential to ensure compliance with funding requirements and enable proper tracking and monitoring of federal awards. Client’s Response: Last year was the organization’s first time going through a Single Audit. Although the organization accurately tracked expenditures corresponding to the grant award, the transactions were charged to an unrestricted program. The correction was detected and corrected during this fiscal year. We have implemented the necessary internal controls to ensure that our grant reporting accurately reflects the expenditures for each of our respective grants. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444

Corrective Action Plan Finding 2025-001 Federal Award Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance – Reporting Name of Contact Person Kimberly Carlo, Executive Director Corrective Action In this case it was noted that our Organization did not perform reconciliation procedures between the federal program reporting of direct client expenditures with our financial accounting records. Not performing this reconciliation lead to an unreconciled difference when determining whether the data was complete and accurate. We have thoroughly reviewed our internal procedures, identified weaknesses and implemented changes to assure this will never happen again. To prevent and detect such errors in the future, we have changed our internal procedures to include: Project files that are being closed and reported to the grantor are being reviewed on a monthly basis. During the review, project files will be verified that the funding sources used for expenditures reconcile with the funding sources used for payment as recorded in the financial accounting records. Any differences will be reconciled at this point and such documentation will be retained. Additionally, an annual reconciliation of all population data used for program expenditures will be reconciled with our financial accounting records. To prevent and detect such errors in the future, we have changed our internal procedures to include: 1. Each material list along with measures and funding sources will be printed for the client file for direct material and labor charges. 2. The financial coordinator will verify funding sources match with amounts reported in the financial accounting records. 3. Any changes to funding for material and labor will be printed for the client file and given to the financial coordinator to change funding sources in the IWI accounting system. 4. Once funding is changed, verification will be printed for the client file. 5. An annual reconciliation of client program expenditures will be reconciled with our revenue and expenditure report for each funding source. Implementation Immediate.

Recommendation: We recommend management establish an informal procedure to reconcile grant funds received with funds expended on a regular basis. We also recommend management implement a formal procedure to reconcile the SEFA with the general ledger at year end. Corrective Action: The Comptroller will reconcile this report on a monthly basis making sure that all grants and other Federal / State expenditures are on the SEFA and that the two numbers reconcile with the general ledger. This will be kept in a notebook and the calendar kept in the Comptroller’s desk. The Comptroller will also create a folder in the business office folder on the server and input the current SEFA in this folder and show any discrepancies on a monthly basis and every time this report is run for drawdowns. This process will start immediately. The Comptroller will also make sure at year end that all items are on this report and they have been reconciled with the general ledger. This process will also be in the notebook and calendar within the desk of the Comptroller.

Management has strengthened controls over SEFA preparation by implementing procedures to identify federal awards with unique reporting requirements, including FEMA grants. A formal review process and year-end reconciliation of federal expenditures to the SEFA will be performed to ensure expenditures are reported completely and accurately in accordance with Uniform Guidance requirements.

The School District will review the Uniform Guidance requirements and ensure all expenditures are accurately reported on the School District’s Schedule of Expenditures of Federal Awards.

2024-001 – Material Difference Between Federal Expense Detail and Federal Expenses Reported Condition: During the audit, the detailed expenditure support for Special Programs for the Aging, Title III, Part C, Nutrition Services (“Title III C”), ALN 93.045 federal expenditures did not agree to the original expenditures disclosed on the original SEFA. As a result, a journal entry in the amount of $34,005 was needed to reduce Title III C federal expenditures to agree the SEFA to the supporting expenditure detail. This deficiency is less severe than a material weakness, yet important enough to merit attention by those charged with governance. Accordingly, we consider this matter to be a significant deficiency. In conjunction with our FY2024 single audit, please see the ASI’s corrective action plan below: Management concurs with the finding. Management will implement procedures to reconcile grant expenditure detail to the general ledger, SEFA, and transmittal reports by program and Assistance Listing number prior to submission for audit. The reconciliation will be reviewed and approved by management, and any variances will be investigated and corrected timely Expected completion date: 6/30/2026

2024-001 Late Submission of Single Audit Report Root Cause: In May of 2020 SEA unexpectedly experienced the loss of its Chief Financial Office during the midst of a global shut down. SEA was unable to close out the fiscal year in a timely manner due to challenges of identifiying and hiring qualified staff after this loss. This began a domino effect of let audits. Name of Contact Persons: Nathan Arias, President and Chief Executive Officer and Mirna Romero, Director of Opertations and Chief Financial Officer Corrective Action: Once the FY 23-24 audit is finalized, SEA will immediately begin working on the audit for FY 24-25 and are ready to diligently work on completing this audit with a new team. Proposed Completion Date: SEA will esnure that the next single audit, for fiscal year 2024-25 is completed by October 15, 2026, with plans to expedite the 2026 audit thereafter.

1. Comprehensive Grant Reconciliation Process- Management will perform a formal year-end reconciliation of all federal grant expenditures to the general ledger, grant agreements, reimbursement requests, and funding agency reports prior to completion of the SEFA. 2. Centralized Federal Award Inventory- Management has established a centralized schedule of all federal awards that identifies the fed eral agency, Assistance Listing Number {ALN), passthrough entity, grant number, award period, and responsible program personnel. This inventory will be reviewed and updated throughout the year. 3. Formal SEFA Review Control -A secondary review of the completed SE FA will be performed by a member of management independent of the preparer. The review will include verification of all federal programs, ALNs, pass-through awards, expenditures, and required disclosures. 4. Year-End Program Certifications - Program and finance personnel responsible for grant administration will provide written confirmation of all federal awards and expenditures incurred during the reporting period to ensure completeness. 5. Training and Compliance Monitoring- Finance staff responsible forfederal grant accounting and reporting will receive periodic training regardi ng Uniform Guidance requirements, including SEFA preparation and reporting responsibilities.

Finding Number 2024-020 Subject Heading (Financial) or AL no. and program name (Federal) EMERGENCY RENTAL ASSISTANCE PROGRAM (ERA) AL #21.019 Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges they did not implement the proper internal controls and oversight of the ERA Program during FY2024. However, OMES has taken steps to correct these findings and has followed the recommendations set forth by SAI as evidenced in the Recommendation section of this finding. Beginning with FY2025, OMES has taken the following measures:  Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience.  OMES ensured that the subrecipient agreement included all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) executed an updated Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies.  OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed.  OMES-GMO has in place a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements. Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMES-GMO conducted bi-weekly monitoring meetings with CFO and reviewed documentation provided by CFO to ensure all ERA projects were eligible under the ERA guidelines and that CFO exercised the proper oversight over their subrecipients and spending. Anticipated Completion Date Completed Responsible Contact Person Brandy Manek

Finding Number 2024-094 Subject Heading (Financial) or AL no. and program name (Federal) 97.036 – Disaster Grants – Public Assistance Planned Corrective Action To address this finding, OEM will strengthen its review procedures for the SEFA by implementing a documented review process to verify the accuracy and completeness of information provided by ABS. OEM will coordinate with ABS to obtain and retain sufficient supporting documentation for amounts reported on the SEFA and will work with ABS to resolve any discrepancies identified during the review process. In addition, OEM will ensure staff responsible for reviewing the SEFA receive additional guidance and training on SEFA reporting requirements. These actions are intended to improve the accuracy and reliability of future SEFA reporting and strengthen compliance with applicable federal requirements. Anticipated Completion Date SFY26 Reporting Period Responsible Contact Person Brianna Thomas

Finding Number 2024-042 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action Management acknowledges the variances identified in the Medicaid, CHIP (COVID), and CHIP 64.21 federal expenditure amounts reported in GAAP Package Z. Upon review, the discrepancies were determined to result from formula reference errors, missed carry-forward updates, and omitted adjustments within internal reporting worksheets. These issues were limited to the preparation of the financial schedules and did not affect underlying program expenditures, eligibility determinations, or federal claiming. Management has corrected all affected worksheets, updated the formula references, and ensured that all required adjustments— including administrative expenditures, Soon-to-be-Sooners updates, and 64.21 Line 4 collections—are accurately reflected in the revised totals. All impacted quarters have been updated accordingly. To strengthen controls and prevent recurrence, management has implemented a formal quarter-end reconciliation checklist, enhanced review procedures, and instituted secondary reviewer sign-off for all federal expenditure schedules. Worksheet dependencies and adjustment requirements are being developed in a federal reporting procedures manual that should be complete in October 2026. With the team now fully staffed, management is able to reinforce these procedures and improve the consistency and quality of the review and approval process. Management believes these corrective actions fully address the causes of the variances and will support accurate, complete, and reliable reporting in future periods. Anticipated Completion Date December 31, 2026 Responsible Contact Person Calvin Cole, OHCA Director Financial Accountability & Compliance, Susan Crooke, OHCA Senior Director Accountability & Compliance

Finding Number 2024-103 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action Management agrees with this finding and is revising the standard operating procedure around preparation of Schedule Z to accurately capture PeopleSoft transactional data for appropriate accruals of federal revenues matching the fiscal year the related expenditures were incurred. Additionally, we will provide training for appropriate use of the budget reference field within PeopleSoft for recording expenditures and revenues relating to the period incurred to further address the cutoff issues identified. Anticipated Completion Date 6/30/26 Responsible Contact Person Ryon Fields, Interim CFO

Finding Number 2024-102 Subject Heading (Financial) or AL no. and program name (Federal) 93.268: Immunizations Cooperative Agreements Planned Corrective Action Management agrees with this finding and is revising the standard operating procedure around preparation of Schedule Z to accurately capture PeopleSoft transactional data for appropriate accruals of federal revenues matching the fiscal year the related expenditures were incurred. Additionally, we will provide training for appropriate use of the budget reference field within PeopleSoft for recording expenditures and revenues relating to the period incurred to further address the cutoff issues identified. Anticipated Completion Date 6/30/26 Responsible Contact Person Ryon Fields, Interim CFO