Corrective Action Plans

Name of auditee: THF Highland Oaks Holdings, LLC HUD auditee identification number: 115-11319 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Allison Milliorn Position: Chief Executive Officer Telephone number: 830-693-8100 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2024-001: Comments on the Finding and Each Recommendation: For the year ended December 31, 2023, the Company did not submit the Data Collection Form (SF-SAC) to the Federal Audit Clearinghouse in the time period required by Uniform Guidance Section 2 CFR 200.512. Action(s) taken or planned on the finding: The Data Collection Form was submitted to the Federal Audit Clearinghouse on May 10, 2024 and management will submit the Data Collection Form timely going forward.

Name of auditee: THF Vistas Holdings, LLC HUD auditee identification number: 115-11319 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Allison Milliorn Position: CEO Telephone number: 830-693-8100 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2024-001: Comments on the Finding and Each Recommendation: For the year ended December 31, 2023, the Company did not submit the Data Collection Form (SF-SAC) to the Federal Audit Clearinghouse in the time period required by Uniform Guidance Section 2 CFR 200.512. Action(s) taken or planned on the finding: The Data Collection Form was submitted to the Federal Audit Clearinghouse on May 10, 2024 and management will submit the Data Collection Form timely going forward.

2024-001: Late Audit Submission Condition: While the audit report was completed on June 30, 2025, the submission of the audit package to the Federal Audit Clearinghouse (FAC) was not completed until after nine months after the end of the audit period, June 30, 2025, which is the due date for audit report submission. Corrective Action Plan: Daniel V. Walker, CFO inadvertently neglected to maintain an active UEI number per annual registration renewal with SAM.Gov. CFO has implemented a system both electronic and manual to update annual registration with SAM.gov in order to continually maintain active UEI number status. Person(s) Responsible: Daniel V. Walker, CFO Timing for Implementation: Immediate 7-8-2025

Finding: The data collection form for the year ended June 30, 2024, was filed after the March 31, 2025, deadline, making it a late submission. Corrective Actions Taken or Planned: Envision Unlimited will schedule and complete future external audits in a manner that will allow timely reporting of the Single Audit. Contact person responsible for corrective action is Dennis James, CFO. The anticipated completion date is June 30, 2025.

2024-002: Complete, accurate and timely financial reporting Management’s Response: As of June 4, 2025, due to the agency’s growth in services and staff, a Human Resource Generalist was hired. With the addition of this new position, our Chief Operating Officer will be focused on complete, accurate and timely financial reporting. Views of Responsible Officials and Corrective Action: See response for finding 2024-002. Anticipated Completion Date: June 4, 2025.

JO DAVIESS RESIDENTIAL SERVICES, INC. 521 S. WEST STREET GALENA, IL 61036 CORRECTIVE ACTION PLAN June 26, 2025 U. S. Department of Housing and Urban Development Ralph Metcalfe Federal Building 77 West Jackson Boulevard Chicago, IL 60604-3507 Jo Daviess Residential Services, Inc. respectfully submits the following Corrective Action Plan for the year ended June 30, 2024. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 Period: Year ended June 30, 2024 The findings from the June 30, 2024 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2024-001: Supportive Housing for the Persons with Disabilities (Section 811), CFDA #14.181 Recommendation: We recommend management and the board of directors ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. Management's Response: We agree with Finding 2024-001 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will provide additional oversight to ensure the data collection forms are submitted electronically to the FAC each fiscal year going forward within required due dates. If HUD has questions regarding this corrective action plan, please call (815) 288-6691. Sincerely yours, Jeff Stauter Director Kreider Services, Inc. Managing Agent

The late audit submission was a result of significant leadership and staffing turnover, unresolved audit support items, and missing reconciliations from prior months. The University engaged an external firm to stabilize the finance function and has since appointed an interim Controller. Beginning with FY26, the University will adopt a rolling monthly close schedule, establish an internal audit prep calendar, and define internal deadlines for deliverables to external auditors. These steps will support timely completion of future audits. Target: Audit submission by March 31, 2026 for FY25.

Recommendations: The Organization should implement stronger internal controls to ensure that reporting deadlines are effectively monitored and met. This may include: - Developing and maintaining a reporting calendar with clearly defined deadlines for financial reporting. - Assigning responsibility for tracking and ensuring timely submission of reports. Additionally, the Organization should conduct a root cause analysis to address any underlying issues and implement corrective actions to prevent future delays. Views of responsible officials and planned corrective actions: Management agrees with the finding and will implement processes to mitigate the risk of future late file reports. Anticipated Completion Date: June 2025

Recommendation: We recommend that the Project implement stronger internal controls to ensure that reporting deadlines are effectively monitored and met. Management Response: Management agrees with the finding and will implement processes to mitigate the risk of future late file reports.

2024-003- Significant Deficiency, Data Collection Form (Repeat Finding 2023-003) Audit Finding; The Town did not submit the 2024 or 2023 federal reporting packages with the Federal Audit Clearinghouse within the required timeline of either 30 days after receipt of the auditor’s reports or nine (9) months after the end of the Town’s fiscal year as required by CFR 200.512(a)(1). Corrective Action Taken: We agree with this audit finding, resulting from turnover at the BOE. The delays should not reoccur in the future. Name and Phone # of Person Responsible for Implementation Mr. Peter Mynarski, Comptroller 203-622-2226

Action taken: Management has updated the process to verify that the reporting package, including the Single Audit report, is submitted to the FAC successfully. While management previously certified the reporting package properly, the final step of submission was not properly monitored and verified. Effective immediately, management has implemented a new step requiring the inclusion of a physical screenshot for the final submission to the FAC. This adjustment ensures proper documentation and alignment with compliance requirements. Person responsible: Maria Cardiellos, Executive Director Date completed: March 13, 2025

View of Responsible Officials: Management carried out an after action review to identify the root cause of delays in completing the FY23 audit and timely filing of the single audit report packet. During FY24, we implemented strict timeline in completing the FY24 year end financial closing process and accounts reconciliation. An overall Audit Coordinator was appointed and worked closely with the business process leads while Regional and Country Managers helped ensure completion of the FY24 field offices and affiliates audit reports prior to start of the global audit fieldwork. Timely filing of the single audit report packet for FY24 is a high organizational priority. While significant improvements were noted during the recent audit, management continues to identify ways to improve existing processes and ensure that any challenges encountered were assessed and action immediately taken to address them.

Finding 2024-005: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2024, 2023 and 2022 Single Audit Reporting Packages Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of federal awards for the years ended June 30, 2024, June 30, 2023, and June 30, 2022. Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed, and the data collection form and reporting package should be submitted within 30 days after receipt of the auditor’s report or nine months after the end of the audit period. The Single Audit packages for the City’s fiscal year ended June 30, 2024, June 30, 2023, and June 30, 2022, should have been submitted to the Federal Audit Clearinghouse by March 31, 2025, March 31, 2024, and March 31, 2023, respectfully. The City missed the filing deadlines, making the filings for 2024, 2023 and 2022 late. Corrective Actions Taken: 1. Improved Reporting Processes: The City has streamlined the audit reporting process through enhanced coordination with auditors and improvements to internal procedures. The City recently hired an Internal Auditor, Joan Appiah Yankson, to review City policies and implement standard operating procedures 2. Resource and Training Enhancements: Standard operating procedures are being implemented along with additional staffing and training to support the timely completion of audit reports. Contact: Dr. Kristy Samperi, Controller, Ongoing

The audit for the year ended June 30, 2023 was not submitted to the Federal Audit Clearinghouse due to issues with the UEI numbers not being renewed timely on the Academy's side. The Finance Director is now responsible for the renewals going forward, and this will not be an issue in the future.

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2024-001: Significant Deficiency - Late Audit Reporting Recommendation: Implement procedures and controls to ensure that future audits are completed and submitted in a timely manner. Action Taken: Management agrees with the auditor's finding and recommendation. The new Deputy Director of Finance will play a key role in ensuring adherence to audit timelines and enhancing overall reporting efficiency.

Corrective Action Taken or Planned: As part of the policies and procedures update, the Business Office has included a section on compliance, with the creation of a compliance calendar to ensure all filings are completed on a timely basis. The Business Office will continue to follow internal policies and procedures, including deadlines for fiscal year-end process. Contact Person Responsible for Corrective Action Plan: Anne Cothran, Executive Director Completion Date: March 31, 2025

Identifying Number: 2024-001 Finding: Untimely Submission of the 2024 Single Audit Reporting Package Corrective Action Taken or Planned: As part of the policies and procedures update, the Business Office has included a section on compliance, with the creation of a compliance calendar to ensure all filings are completed on a timely basis. The Business Office will continue to follow internal policies and procedures, including deadlines for fiscal year-end process. Contact Person Responsible for Corrective Action Plan: Elsa Velazquez, Assistant Director and Chief School Business Official Completion Date: December 31, 2025 ______________________ Andrew Bernard, Assistant Director and Chief School Business Official

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Forest Service Schools and Roads Cluster, Education Stabilization Fund Assistance Listing Number: 10.665, 84.425 Contact Person: Andrea Despain, Business Manager Anticipated Completion Date: June 30, 2025 Planned Corrective Action: The District will collaborate with all grant stakeholders to strengthen internal controls by clearly defining responsibilities, tracking submission deadlines, and ensuring strict adherence to policies. Oversight will be reinforced through regular grant management meetings and reviews conducted by the Business Manager. To enhance reporting accuracy and documentation practices, staff will receive targeted training on compliance requirements. Additionally, recordkeeping processes will be standardized, with periodic reviews to verify adherence and improve efficiency. These corrective actions will be implemented promptly and continuously supported through ongoing monitoring, ensuring more timely and accurate audits while maintaining compliance with federal regulations.

Recommendation We recommend that management enhance its internal control structure, including financial close and reporting, to ensure timely filing of future Single Audit reporting packages. Management Response Corrective Action: NIYC has been working towards getting caught up on the timely audit completion requirement as per the 2CFR 200.512, including the retention of a larger audit firm to schedule and complete the audit in a more timely manner. We have also implemented a monthly and year-end closing process to facilitate filing of future Single Audit reporting packages. Due Date of Completion:March 31, 2026 Responsible Person(s): NIYC Management

Along with FY22 financial data changes to the Financial Data Schedule, and changes to the FY23 Financial Data Schedule and the issuance of FY23 audit on March 21, 2025, caused a delay in the finalization of the FY24 Financial Data Schedule submission. With the completion of the HUD requested changes, the Agency anticipates future submissions to be timely and accurate without continuous changes to balance sheet accounts. Additionally, The Authority has restructured the accounting team and implemented multiple internal controls, policy and procedures over financial reporting. To ensure a timely audit, the finance team and the auditors maintain clear and detailed communication throughout the entire process. Additionally, confirm that the auditors have sufficient capacity to complete the audit within the agreed-upon timeline.

Management’s Comments and Corrective Action Plan: Management has reviewed finding 2024-001 related to timely Single Audit report submission to the Federal Audit Clearinghouse and has developed the following plan to address this finding and ensure compliance going forward. 1. Root Cause Analysis – Previous to 2023, the last time the Y was required to have a Single Audit was the year ended December 31, 2012. Because this was a new process to the Y, we were unaware that we needed to submit the Single Audit to the Federal Audit Clearinghouse. In past years, the independent audit firm initiated the e-filing process on our behalf. 2. Action Steps – The Y will develop a year-end Federal Awards checklist to include all necessary preparation steps including but not limited to preparation of the Schedule of Expenditures of Federal Awards (SEFA); corresponding audit documentation; and procedures for filing the completed Single Audit to the Federal Audit Clearinghouse including confirmation that independent auditors have reviewed and certified the submission to the Clearinghouse. 3. Responsible Parties – The Controller will complete the checklist and perform the filing to the Federal Audit Clearinghouse and the CFO will review and approve. 4. Timeline – Submission of the Single Audit to the Federal Audit Clearinghouse as well as completion, review, and approval of the checklist will be done within 30 days of receipt of the final Single Audit report. 5. Monitoring & Evaluation – The checklist and approval process will be monitored on an annual basis to ensure ongoing compliance and effectiveness of this corrective action plan.

Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Auditee’s Corrective Action Plan: The city’s legacy financial system did not collect data required for SEFA. Agencies had to provide most details manually and work between spreadsheets and multiple systems to input and track receipt grant awards and spend on personnel, supplies and services and sub-recipient awards related to grants. The steps to address this legacy finding have been phased and include the technology implementation, staff training and additional oversight. As noted, the City implemented Workday, an Enterprise Resource Planning (ERP) system, across workstreams so that Financial Accounting, Grants, Procurement, Supplier Accounts, Banking, Payroll and Human Resources are all in one system. As with any ERP, an ongoing process of evaluation and updates are needed to continuously align workflow and business processes. This approach has led to continued improvement over the years as the grants management module is fully implemented in Workday. Since implementation, additional enhancements have been adopted and utilized with a robust workflow process for grant approval, grant budget tracking, and invoice scheduling. In addition to the technology adoption, an increase in citywide grants training and oversight has been implemented. The progress is detailed below: • FY 23 represented the first year in the new system. To compile the SEFA, the City used a hybrid approach to leverage Workday and Agency provided data. o There were some data accuracy challenges from data entry errors. To address those data entry challenges the award modification business process was improved post-implementation to add a GMO review and approval step of award modifications. o As of May 2024, all award modifications now require centralized GMO review to verify data accuracy. o Additional process changes in FY 23 included implementation of the requirement as part of the FY 24 budget preparation process that grant worktags must be created and budgeted for during the City’s annual budget process. The grant worktag creation process includes approvals at the agency program and fiscal levels, as well as at the Department of Finance level. • In FY24 further Award Module enhancements were adopted to provide key new data points in Workday. o Each grant award now includes information: Federal Assistance Listing Number (fna CFDA#), Passthrough Agencies & Passthrough Identifier. DRAFT CITY OF BALTIMORE Corrective Action Plans Year Ended June 30, 2024 146 Finding 2024-007 (continued) Auditee’s Corrective Action Plan: (continued) o Additionally, in FY 24, GMO, in collaboration with BAPS launched the Grants Workstream Training sessions. These monthly citywide virtual live trainings are on a variety of grant management related topics, averaging 60 attendees per session. Attendees are city agency grant managers and city agency fiscal staff. • In FY 24 and FY 25 the topics covered included: o FY 24 Grant Work tag Preparation o FY 24 SEFA Preparation o Grant Accounting Best Practices and Workday Billing o Award Set-up Best Practice & Potential Pitfalls o Extra Features in Workday (including reporting and how to set up award tasks and deadlines) o Subrecipient Monitoring Best Practices o Cost-reimbursable grant invoicing in Workday o FY 25 SEFA preparation o FY 26 Grant Work tag Preparation o Grant Management Roles and Responsibilities o Specific training on the SEFA, including information on understanding the importance of the SEFA, what information is included and how to review SEFA data, was conducted. Citywide training sessions were held in FY 24 and FY 25 to ensure that the reporting is understood by city agencies, with special emphasis on subrecipient payments being reported properly. The training schedule is ongoing and continuous. • To improve SEFA reporting data, in FY 25 there is an emphasis on subrecipient set up and spending to ensure that functionality is refined to improve uniformity in subrecipient set up. GMO, in conjunction with BAPS, the Bureau of Procurement and city agencies will work to refine subrecipient set up, spending and monitoring, including improved reporting. o GMO has hosted three subrecipient monitoring and management–related trainings since December 2024. Additionally, to improve subrecipient managing and monitoring, GMO modified the award setup business process in Workday to include verification of subaward status before final award setup approval. In FY 25, GMO provided training on how to setup subawards accurately in Workday. As discussed above, these trainings will be ongoing. • Additionally, GMO and the BBMR will collaborate on a subaward dashboard to monitor subrecipient spending data in real time. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City Completion Date: FY26 3rd Quarter- • Design and complete a grants management dashboard within Workday • Ongoing and continuous - GMO will continue to conduct trainings on SEFA reporting and subrecipient management and reporting.

The Town has implemented a year-end closing process. Once the Town becomes current this compliance issue will be mitigated.

As a corrective measure, BGCPR will take the following actions and will anticipate completing on June 30, 2025: a. Developing and enforcing a structured reporting calendar. b. Allocating dedicated resources to support audit preparation. c. Establishing internal checkpoints to monitor progress and ensure accountability. d. Ensure future submissions meet the required deadlines.

In July 2024, the Chief Financial Officer, Veronica Koller, was hired, along with an Accounting Manager, Nicole Sullivan in September 2024. The staffing of these two positions, along with the Controller, Hannah Pawlowski, will ensure that the completion of the financial statements and single audits for the period of June 30, 2025 will occur in time necessary to submit the data collection form within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period