Corrective Action Plans

Schedule of Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-004: Significant Deficiency in internal Controls and Noncompliance Over Reporting Responsible Official’s Response and Corrective Action Plan We concur with the findings. We acknowledge the importance of adhering to the federal guidelines for the submission of the reporting package within the mandated nine-month period. To address this, BCI will implement the following actions: 1. Policies and Procedures Development: We will create and enforce comprehensive policies and procedures to ensure that audits are initiated and completed promptly. This will include detailed timelines and checkpoints to monitor progress throughout the audit process. In addition, we will adhere to a year-end closing process that reconciles all significant accounts. 2. Training for Grant Administration: We will provide training for individuals responsible for administering federal assistance programs within BCI. This training will cover essential aspects of grant administration, ensuring that our team is well-equipped to manage these programs efficiently and in compliance with federal requirements. Planned Implementation Date of Corrective Action Plan September 1, 2024 Person Responsible for Corrective Action Plan Caryn York, President & CEO

Audit Finding: Late Issuance of the Single Audit Reporting Package. The Single Audit package for the City’s fiscal year ended June 30, 2024 was not submitted to the Federal Audit Clearinghouse by March 31, 2025. Corrective Action: Management agrees with the finding. The City is evaluating the process and design of internal controls, including the ongoing implementation of a new ERP system, in order to ensure readiness from the audit and to avoid late filing of the single audit reporting package and data collection form. Name of Contact Person and Completion Date: Leah Kagan, Interim Director of Administration, December 31, 2026 Anita Carpenter, Grants Officer, December 31, 2026

Views of Responsible Officials and Planned Corrective Actions: The Finance Department acknowledges the late submission for the 2023 fiscal year. To ensure future compliance with Uniform Guidance deadlines, year-end close and audit preparation timelines have been restructured as per the response for Finding 2024-001.

The Organization has hired new staff, changed accounting systems and is developing a strict month-end and year-end close procedure to ensure timely financial reporting and future compliance.

Management has implemented the following corrective actions: 1. Established a formal year-end closing timeline that includes deadlines for completion of the trial balance, account reconciliations, and supporting schedules. 2. Assigned responsibility to the Executive Director to monitor progress toward year-end closing milestones and ensure information is provided to the auditors on a timely basis. 3. Developed a comprehensive audit preparation checklist identifying all schedules, reconciliations, and documentation required by the auditors. 4. Scheduled pre-audit planning meetings with the auditors to establish mutually agreed-upon deadlines and identify potential issues that could delay audit completion 5. Implemented periodic status reviews during the audit process to monitor progress and address outstanding auditor requests promptly.

Finding 2024 – 103 – Single Audit Reporting Package and U.S. Housing and Urban Development REAC Submissions Not Filed Timely. (Significant Deficiency, Compliance Finding-Other Matter) Federal program information: Funding agency: U.S. Department of Housing and Urban Development Title: Supportive Housing for people with disabilities Assistance Listing Number: 14.181 Award year: 2023/2024 Award numbers: Project 123-HD042; AZ20Q081002 Pass-Through grantors: N/A Compliance Requirement: Reporting Questioned Costs: N/A Contact Name: Joe Keeper, Chief Financial Officer of the Sponsor Corrective Action Planned: Part 1: Immediate corrective actions (to address immediate noncompliance). Submit all overdue Single Audit and REAC reporting packages immediately to resolve the current noncompliance. Task Responsible Party 1.1. Prepare and submit delinquent reports: 1.1.1. Assemble and finalize the overdue Single Audit Reporting Package for FY 2024 and submit it to the Federal Audit Clearinghouse (FAC). Chief Financial Officer (CFO) 1.1.2. Assemble and finalize all overdue REAC Annual Financial Statements (AFS) for FY 2024 and submit them to HUD's Financial Assessment Subsystem (FASS-MF) via the REAC Secure Systems. Property Manager 1.2. Notify HUD: 1.2.1. Immediately notify the local HUD Field Office and the assigned Account Executive of the finding and the plan for submission of all delinquent reports. Property Manager 1.3. Document and address penalties: 1.3.1. Address any penalties or noncompliance flags resulting from the late filings, which may include interaction with HUD's Departmental Enforcement Center (DEC). Property Manager / CFO Part 2: Systemic corrective actions (to prevent future noncompliance) Implement new policies and procedures to ensure all future HUD Single Audit and REAC submissions are filed on time. Task Responsible Party 2.1. Revise and implement internal policies: 2.1.1. Draft a written policy defining the timelines and responsibilities for all HUD financial and audit reporting, including Single Audit and REAC AFS submissions. This policy will be housed in the organization's Operations Manual. CEO / CFO 2.2. Develop a comprehensive compliance checklist: 2.2.1. Create and implement a calendar-based checklist for all HUD reporting requirements, with deadlines for every stage of the process, including financial data collection, auditor engagement, and submission. CFO / Property Manager 2.3. Enhance financial review and control procedures: 2.3.1. Implement a formal review and approval process for all financial statements and audit packages. Require a documented review by the CFO and sign-off by the CEO and Board of Directors before any submission. CFO 2.4. Improve communication and oversight: 2.4.1. Establish a quarterly meeting with all key staff involved in HUD reporting (CFO, Property Manager, accounting staff) to review deadlines and ensure all tasks are on schedule. CEO 2.4.2. Assign a designated staff member as the primary point of contact for external auditors and the HUD REAC Secure Systems. Property Manager 2.5. Provide staff training: 2.5.1. Schedule and conduct training for all relevant staff on the new policies, checklists, and the HUD reporting platforms (FAC and REAC Secure Systems). Third Party Training Professionals, HUD and Property Manager’s compliance officer 2.6. Address external auditor issues (if applicable): 2.6.1. Evaluate the relationship with the current external audit firm. If timeliness was a factor in the audit report delay, establish clear communication protocols and deadlines in the new engagement letter. Consider a different firm for future audits if necessary. CFO Part 3: Monitoring and future enforcement (to sustain compliance) Create a monitoring plan to ensure the corrective actions are working and that late filings do not recur. Task Responsible Party 3.1. Ongoing monitoring: 3.1.1. The CFO will provide a monthly report to the CEO on the status of all HUD reporting deadlines. The report will highlight upcoming deadlines and progress toward completion. CFO 3.2. Annual review: 3.2.1. Conduct an annual review of the HUD Reporting Policy and Compliance Checklist to ensure they are current and effective. CEO / CFO 3.3. Update internal audit program: 3.3.1. Incorporate the timely filing of HUD reports into the organization's internal audit or quality assurance program. CFO Anticipated Completion Date: December 2025

Finding 2024 – 103 – Single Audit Reporting Package and U.S. Housing and Urban Development REAC Submissions Not Filed Timely. (Significant Deficiency, Compliance Finding-Other Matter) Federal program information: Funding agency: U.S. Department of Housing and Urban Development Title: Supportive Housing for people with disabilities Assistance Listing Number: 14.181 Award year: 2023/2024 Award numbers: Project 123-HD046; AZ20Q091002 Pass-Through grantors: N/A Compliance Requirement: Reporting Questioned Costs: N/A Contact Name: Joe Keeper, Chief Financial Officer of the Sponsor Corrective Action Planned: Part 1: Immediate corrective actions (to address immediate noncompliance). Submit all overdue Single Audit and REAC reporting packages immediately to resolve the current noncompliance. Task Responsible Party 1.1. Prepare and submit delinquent reports: 1.1.1. Assemble and finalize the overdue Single Audit Reporting Package for FY 2024 and submit it to the Federal Audit Clearinghouse (FAC). Chief Financial Officer (CFO) 1.1.2. Assemble and finalize all overdue REAC Annual Financial Statements (AFS) for FY 2024 and submit them to HUD's Financial Assessment Subsystem (FASS-MF) via the REAC Secure Systems. Property Manager 1.2. Notify HUD: 1.2.1. Immediately notify the local HUD Field Office and the assigned Account Executive of the finding and the plan for submission of all delinquent reports. Property Manager 1.3. Document and address penalties: 1.3.1. Address any penalties or noncompliance flags resulting from the late filings, which may include interaction with HUD's Departmental Enforcement Center (DEC). Property Manager / CFO Part 2: Systemic corrective actions (to prevent future noncompliance) Implement new policies and procedures to ensure all future HUD Single Audit and REAC submissions are filed on time. Task Responsible Party 2.1. Revise and implement internal policies: 2.1.1. Draft a written policy defining the timelines and responsibilities for all HUD financial and audit reporting, including Single Audit and REAC AFS submissions. This policy will be housed in the organization's Operations Manual. CEO / CFO 2.2. Develop a comprehensive compliance checklist: 2.2.1. Create and implement a calendar-based checklist for all HUD reporting requirements, with deadlines for every stage of the process, including financial data collection, auditor engagement, and submission. CFO / Property Manager 2.3. Enhance financial review and control procedures: 2.3.1. Implement a formal review and approval process for all financial statements and audit packages. Require a documented review by the CFO and sign-off by the CEO and Board of Directors before any submission. CFO 2.4. Improve communication and oversight: 2.4.1. Establish a quarterly meeting with all key staff involved in HUD reporting (CFO, Property Manager, accounting staff) to review deadlines and ensure all tasks are on schedule. CEO 2.4.2. Assign a designated staff member as the primary point of contact for external auditors and the HUD REAC Secure Systems. Property Manager 2.5. Provide staff training: 2.5.1. Schedule and conduct training for all relevant staff on the new policies, checklists, and the HUD reporting platforms (FAC and REAC Secure Systems). Third Party Training Professionals, HUD and Property Manager’s compliance officer 2.6. Address external auditor issues (if applicable): 2.6.1. Evaluate the relationship with the current external audit firm. If timeliness was a factor in the audit report delay, establish clear communication protocols and deadlines in the new engagement letter. Consider a different firm for future audits if necessary. CFO Part 3: Monitoring and future enforcement (to sustain compliance) Create a monitoring plan to ensure the corrective actions are working and that late filings do not recur. Task Responsible Party 3.1. Ongoing monitoring: 3.1.1. The CFO will provide a monthly report to the CEO on the status of all HUD reporting deadlines. The report will highlight upcoming deadlines and progress toward completion. CFO 3.2. Annual review: 3.2.1. Conduct an annual review of the HUD Reporting Policy and Compliance Checklist to ensure they are current and effective. CEO / CFO 3.3. Update internal audit program: 3.3.1. Incorporate the timely filing of HUD reports into the organization's internal audit or quality assurance program. CFO Anticipated Completion Date: December 2025

Management will implement enhanced year-end closing and audit coordination procedures, including earlier preparation timelines, improved tracking of audit deliverables and reporting deadlines, and increased coordination with outsourced accounting and audit partners to help ensure timely completion and submission of future Single Audit reporting packages.

Recommendation We recommend that Management enhance its internal control structure, to include milestones for submitting the Single Audit Reporting Package. Management Response Corrective Action Corrective Action: DNA will comply with the recommendation. DNA will ensure processes are in place to comply with the due date of nine months after year end. Due Date of Completion: September 30, 2026. Responsible Party(ies) Chief Financial Officer

The District acknowledges the failure to submit the Single Audit data collection form for the fiscal year ended June 30, 2023 to the Federal Audit Clearinghouse within the required 30-day post-opinion deadline. The form was never submitted for that fiscal year. Additionally, for the fiscal year ended June 30, 2024, the District’s accounting records were not available until March 2026, causing the audit to extend well beyond the required nine-month completion deadline and resulting in further noncompliance with Single Audit reporting requirements. Current management has improved procedures related to the management of Single Audit compliance obligations. The District, in coordination with the third-party accounting firm and the external auditor, has established a compliance calendar that identifies all Single Audit submission deadlines and assigns responsibility for preparation, certification, and submission of the data collection form. Procedures have been implemented to ensure accounting records are available on a timely basis to support completion of the audit within the required nine-month window, starting with the fiscal year ending June 30, 2026. We plan to ensure that the fiscal year ended June 30, 2023 data collection form is submitted to the Federal Audit Clearinghouse and that the fiscal year ended June 30, 2024 Single Audit is completed and submitted within 30 days of the audit opinion date, and that all future Single Audit data collection forms are submitted in a timely manner. Estimated date of implementation of the corrective action plan: Ongoing Person responsible for implementation of the corrective action plan: Dr. Kirk Henwood

To ensure the audit is submitted in a timely manner, and on time, we will begin at the beginning of the year.

Management Response / Corrective Action: The City acknowledges the finding. Federal reporting deadlines will be incorporated into the City's annual compliance calendar, and management will coordinate earlier completion of audit deliverables and required submissions. For the FY2024 Single Audit reporting package, the City will complete the Data Collection Form and Federal Audit Clearinghouse submission upon final issuance/receipt of the auditor's reports and retain evidence of submission. For future single audits, the City will monitor the Uniform Guidance deadline and submit the Data Collection Form and reporting package by the earlier of 30 calendar days after receipt of the auditor's reports or nine months after year-end.

2024-004—Late Audit Report Corrective Action: FCCH leadership inherited a situation in which the organization was woefully behind in its accounting records. The existing team has relentlessly pursued getting caught up. Turnover has hampered our efforts, yet we remain committed to the task. We are committed to continuing the effort to become fully compliant and to submit our 2025 audit on time. The FCCH Board of Directors shall ensure accountability for completing all audits in the future on time. Person Responsible: Shawna Gonzales, Chief Financial Officer Completion Date: May 31, 2026

Finding 2024-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended December 31, 2024, management did not properly accrue federal grant expenditures that were incurred during the fourth quarter of fiscal year 2024. As a result, federal grant expenses on cost reimbursement grants and related revenues were understated as of December 31, 2024, and required year end audit adjustments to properly reflect expenditures incurred but not invoiced or recorded as of year end. Recommendation We recommend that individuals overseeing the accounting and finance department continue to review the Organization’s current accounting policies and update existing policies or implement new policies, as needed, to ensure that federal grant expenditures are accrued for and recorded in the proper period and reconciliations between incurred expenditures, invoices submitted and amounts recorded in the general ledger are completed and reviewed monthly or quarterly, as appropriate. Management’s Corrective Action Plan Management is working to improve the timeliness of reconciliations and has implemented procedures to identify and accrue grant expenditures incurred but not yet invoiced at period end, as needed. Management will perform periodic reconciliations between incurred expenditures, invoices submitted to grantors, and amounts recorded in the general ledger, and will ensure such reconciliations are reviewed and approved by the appropriate personnel. Management is confident that the issues that have been noted have been rectified. Contact Person: Patricha Paul, Finance Director Anticipated Completion Date: June 30, 2026

We agree with the finding. The Hospital's annual financial statements were not issued until February 2026 and we were not able to complete the single audit filing until that time. The Hospital doesn't anticipate delays in the future.

2024-004: Reporting Type of Finding: Noncompliance, Material Weakness Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted May 1, 2026, which was 396 days past the March 31, 2025 deadline. Action plan in response to the finding: The Principal will ensure that all required audit documentation is organized, complete, and readily available to the auditors upon request. This includes maintaining updated financial records, supporting documents, reconciliations, and schedules throughout the fiscal year so that materials can be provided promptly during the audit process. To support timely completion of the annual audit, the Principal will formally request the 2025 audit to be completed by August 30, 2026. This timeline allows adequate opportunity for fieldwork, review, and finalization of the audit report. The Principal will monitor progress, respond quickly to auditor inquiries, and verify that the final audit report is submitted within the required timeframe. The 2026 Audit Request for Proposal will be submitted at the End of April 2026 for School Board approval. Repeat Finding: No. Planned completion date for a corrective action plan: June 30, 2026 Name of the contact person responsible for corrective action: Marie Rose, Principal | Lynnette Greyeyes, Business Manager

Finding No.2024-003: Noncompliance with Annual Financial Statements Audit and Single Audit Submission Requirements Finding: The single audit reporting package for the year ended December 31, 2023, was submitted by CAIR-CA in August 2025. CAIR-CA also failed to complete its financial and single audit for the year ended December 31, 2024 within the required nine month deadline under 2 CFR 200.512. As of September 30, 2025, no single audit report has been issued or filed, resulting in noncompliance with federal audit requirements. Views of Responsible Officials and Corrective Action Plan: Management has developed and implemented corrective actions to address this finding. As of January 1, 2026, formal procedures for FAC submission have been established, including defined roles, internal deadlines, and review protocols. A compliance tracking system has been implemented to monitor key reporting deadlines, and staff have received training on federal requirements. Management will continue to monitor adherence to these procedures to ensure timely submission in future reporting periods. Implementation date: January 1, 2026

Corrective Action Plan: Management acknowledges the delay in submission of the audited financial statements, which was partly due to this being the organization’s first Single Audit and delays in completing the year-end close process. To address this, the organization will implement a structured year-end closing timeline, including a detailed checklist, assigned responsibilities, and internal deadlines to ensure all reconciliations and journal entries are completed prior to the audit. Management will also establish a pre-audit review process and coordinate closely with auditors to ensure timely completion and submission to the Federal Audit Clearinghouse within required deadlines. Responsible Official: Abel Olivo, Executive Director, with support from the outsourced accounting firm Anticipated Completion Date: December 31, 2025

Views of Responsible Officials Management agrees with the federal award finding identified in the audit. The System Fund will file the audit reporting package shortly after issuance and ensure that any future audits are completed and filed timely, by working closely with audit partner and frequently accessing the substantive status, stage of completion or any other pertinent aspect of the audit necessary to meet the filing deadline.

Name of Auditee: Town of Potsdam, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2024 CAP Prepared by: Marty Miller, Supervisor Telephone: (315) 265-4310 (A) Current Findings on the Schedule of Findings and Questioned Costs (3) Finding 2024-003 Management’s Response: Management will develop policies and procedures, and anticipates starting and completing the audit more timely in order to meet the required filing deadlines. Persons Responsible for Implementation: Marty Miller, Town Supervisor Implementation Date - December 31, 2026

MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT WILL ENSURE THAT THE AUDIT PREPARATION IS COMPLETED TIMELY IN ORDER TO COMPLETE THE 2025 AUDIT WITHIN 9 MONTHS OF YEAR END.

Due in part to delays from the Organization’s prior auditor addressed in the Corrective Action Plan for the June 30, 2023 audit, the 2024 and 2025 audits were significantly delayed. Management has already taken steps to strengthen controls for year-end closing and audit preparation procedures to ensure timely submission of the federal single audit reporting package. These steps included replacing the Chief Financial Officer and engaging an accounting firm to assist with the closing process. Furthermore, the Organization is working quickly to complete the 2025 audit to bring federal reporting fully up to date. Lastly, the Organization is updating its accounting procedures manual to reflect these improved practices.

The Organization has started audit preparation for the 2025 audit. We expect to be caught up by our 2025 audit.

Name of Contact Person: Willow Hetrick-Price Corrective Action Planned: Due to turnover of the Commission's accounting staff, the Commission was unable to have the annual audit completed within the required timeframe, and subsequently was also late in submission of the FAC report. The Commission has hired internal staff to help with the audit preparation and contracted with an accounting firm that has provided the Commission a CPA to conduct audit preparation and other financial services as requested. The Commission will work on getting financial information in a timely fashion and submit the reporting package in accordance with the guidelines. Anticipated completion date: September 30, 2026.

While the Authority continues to be delinquent on the current year audit completion, a consulting firm was hired to assist with bringing records up to date. The Authority also had hired an assistant fiscal officer in the fall of 2021 and another assistant fiscal officer in the fall of 2022. As a result of the hiring, job responsibilities have been re-assigned and data gathering for future audits will occur in a timely manner. Accounts have been reconciled through December 31, 2025 prior to the 2024 audit commencing. The Authority will continue to execute their plan to have the audits completed on a timely basis and expects to submit the audited financial statements and single audit reporting package for the year ended December 31, 2025 to the Federal Audit Clearinghouse timely.