Corrective Action Plans

The College implemented additional procedures to allow earlier detection of fraud.

Responsible Person(s): Meredith Lumpkin/J’Noie Parker, Child Care Subsidy Program Manager Corrective Action Planned: 1.) Process Redesign and Standardization: DSS has redefined the redetermination packet to require submission of the application and all required verifications to ensure complete documentation to streamline eligibility review. Updated procedural guidance has been incorporated into the Interim Guidance Manual to clarify verification requirements and documentation standards. A standardized step-by-step resource guide and redetermination flow chart have been developed outlining required actions, decision points, and the importance of reviewing redetermination monitoring reports on a monthly basis to ensure cases do not exceed eligibility periods. 2.) Immediate Remediation: In January, following the initial APA audit, DSS conducted a statewide scope and scale review of all active cases to identify outstanding redeterminations. Through this analysis, DSS identified 88 overdue redeterminations (31 from January 2026 and 57 from periods prior to January 2026). Local departments and appropriate staff were notified individually of the specific cases requiring action and directed to take corrective steps. DSS will review cases at the end of March to ensure action has been taken. Going forward, DSS will direct all local departments to review the monthly system-generated redetermination monitoring report and resolve any cases identified as exceeding the eligibility period. DSS will distribute targeted overdue case lists to Regional Program Consultants (RPCs) and monitor locality progress through centralized tracking to ensure timely eligibility determinations and ongoing CCDF compliance. 3.) Centralized Oversight: DSS will implement a layered oversight process to ensure compliance with required monthly monitoring procedures: -Regional-Level Review: Regional Program Consultants (RPCs) will review redetermination monitoring activity monthly within their assigned localities and direct corrective action as needed to ensure timely processing and case closure when appropriate. -Home Office Verification: DSS Home Office, in collaboration with DOE, will conduct quarterly reviews of regional monitoring activity to verify compliance and provide direction to RPCs where additional corrective action or technical assistance is required. This dual-level oversight structure establishes both ongoing regional monitoring and periodic centralized verification to reduce the risk of recurrence. 4.) Training: Refresher training will be provided to staff at our Benefits Program Conference in April, emphasizing timely processing, required verifications, system documentation standards, and ongoing monitoring responsibilities. Additionally, DSS is collaborating with the Local Training and Development team to initiate the development of a targeted refresher course for tenured staff to reinforce critical requirements, including the redetermination process. Monthly report review, as outlined in bullet two, will inform ongoing training updates to address. 5.) System Control Evaluation: DSS will collaborate with IT to assess potential system enhancements in future releases to strengthen controls related to redetermination due dates, including additional automated functionality or reporting capabilities. DSS will deliver to CCSP leadership, by June 30, 2026, a prioritized list of recommended system enhancements with associated cost estimates for review and consideration. Estimated Completion Date: 6/30/2026

Responsible Person(s): Monique Majeus, Economic Assistance and Employment/TANF Consultant; Regional TANF Practice Consultants Corrective Action Planned: Targeted Staff Training: -Provide refresher training on TANF/VIEW eligibility requirements, case documentation standards, and mandated timelines. -Training will address specific error trends identified during the review. Training Schedule: -February 2, 2026 – Statewide training on preventing duplicate benefit issuance -March 3, 2026 – Statewide training on Child Support Income (Redirection) and Required actions Pertaining to Tasks and Reminders (e.g., child turning 18, VIEW non-compliance) -January 22, 2026 – Broadcast message attached Regional TANF Practice Consultants will conduct ongoing case reviews and deliver targeted training based on errors identified within their respective local agencies. Standardized Case Processing Tools: -Implement updated checklists, job aids, and workflow guides to ensure consistent policy application and reduce avoidable errors. -Initial tool distributed to local agencies on January 7, 2026. Claims Establishment for Overpayments: -Initial request sent to Regional Practice Consultants for distribution to local agencies on January 7, 2026 to begin the claims process. Estimated Completion Date: 3/30/2026

Responsible Person(s): Fernanda Crandol, Chief Financial Officer Corrective Action Planned: DARS’ Finance Division will develop agency-specific payroll policies and procedures governing all critical payroll processes, including payroll reconciliations and payroll certifications. Additionally, the Finance Division will ensure that payroll reconciliations are completed each pay period so that payroll transactions are accurate, complete, and properly reviewed. Estimated Completion Date: 5/31/2026

Corrective Action Planned: Management will enhance internal control processes related to grants to include controls for proper lines of communication with granting agencies to ensure all required reporting requirements are identified and adhered to. Name(s) of Contact Person(s) Responsible for Corrective Action: Veronica Bochain, Director of Finance Anticipated Completion Date: For FY26 procedures have been put in place to maintain a schedule of reporting due dates that are reviewed monthly to ensure timely submissions.

orrective Action Planned: Management will enhance internal control processes related to grants to include controls for proper lines of communication with granting agencies to ensure all required reporting requirements are identified and adhered to. Name(s) of Contact Person(s) Responsible for Corrective Action: Veronica Bochain, Director of Finance Anticipated Completion Date: For FY26 procedures have been put in place to maintain a schedule of reporting due dates that are reviewed monthly to ensure timely submissions.

orrective Action Planned: Management will implement a documentation retention policy to ensure approvals of allocations of time for employees are maintained. Name(s) of Contact Person(s) Responsible for Corrective Action: Veronica Bochain, Director of Finance Anticipated Completion Date: As of July 2025, a process was implemented to record the proper allocations of time for employees; in addition, a form was developed to record any subsequent changes.

The College’s Vice President for Academic Affairs and Dean of the College concurred with the finding identified. The College has revised its policies and procedures as follows: Historically, Student Affairs coded only those students who took a Leave of Absence during the semester (“L”) or withdrew during the semester (“W”). Student Affairs has created a new code (“N”) to track students who inform the college of their intent to withdraw at the end of a given semester. At the end of each semester, Student Affairs provides the Registrar’s Office with a report of all students who informed the college of their intent to unenroll (“L”, “W”, and “N”). Using the report, the Registrar’s Office confirms that all students have been accurately exited with the appropriate exit date and exit reason prior to submitting the final “end of term” report to the National Student Clearinghouse. This new process was implemented beginning in the Fall 2025 semester. The corrective actions will be implemented by Dr. Kristen M. Amick, Registrar. Dr. Amick’s email address is: amickkm@westminster.edu.

Corrective Action/Management Response: Ensuring that Adoption records are maintained accurately with all documented requirements. Changing Practice to include putting documents into the document management system (Traverse) in order to have a copy of required documents in the event originals are lost, or documents are damaged due to flooding (which is what occurred in the basement where documents were housed). Cases that are more than 10 years old are typically going to be more difficult to locate needed items, due to records being maintained differently at that time and requirements were different in what the Department was required to maintain in an Adoption file. Proposed Completion Date: June 30, 2026 checking monthly to ensure paper files are scanned into Traverse.

Criteria or Specific Requirement: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Views from Responsible Officials: Management agrees with the finding. Management has established written policies and procedures for procurement. Management confirmed policies and procedures were followed and monitored during the construction of the project. Written policies and procedures were completed after year-end. Contact Person: John Jacques Date of Completion: November 14, 2025

Monitoring over federal awards – The District has corrected the reporting error for ESSER fund expenditures and is increasing its monitoring responsibilities to meet the needs of federal programs in the future. The District will be developing controls over reporting of federal funds to ensure these funds reconcile to the general ledger going forward.

The Food Services Division is committed to providing great food and maintaining rigorous internal controls and continuous monitoring to safeguard program integrity. The discrepancy found at one school is not representative of our program, as we do ongoing random audits of submitted claims to verify the accuracy of submitted data. These layered oversight measures provide multiple levels of verification to minimize and eliminate the likelihood of reporting errors and ensure compliance with applicable state and federal program requirements. At Annalee El, the school with an overclaim of 104 meals, we found that the manager had moved from the school, and in the interim, our review protocol fell short. Given the large volume of meals served annually across the District, the over-claim discrepancy identified during the FY 24-25 audit represents an isolated incident rather than a systemic deficiency in LAUSD Food Services operations. The claim verification process followed at schools is stated below: • The Food Service Manager conducts a weekly review of the prior week’s daily meal count documents to identify and correct any discrepancies. • The Food Service Manager generates and reviews a weekly Meal Counts Report from the Cafeteria Management System (CMS) to verify recorded data. • The Food Service Manager compares the daily meal count documents against the five-day Meal Counts Report to ensure data alignment and accuracy. • The Manager performs an additional verification by reconciling daily meal count documents with the five-day Meal Counts Report from CMS. Any identified errors are corrected immediately in CMS. This reconciliation process is completed prior to the submission of claims to the Child Nutrition Information and Payment System. • The Area Food Services Supervisor (AFSS) and Regional Manager (RM) conduct random weekly reviews of meal counts for accuracy, utilizing reports provided by Central Office staff to support this verification process. • Central Office staff perform a monthly audit of meal count records and prepare a draft report for review by the AFSS and RM to validate findings and confirm accuracy. Retraining of the staff at Annalee El has been completed, and the manager and supervisor teams are verifying that the above protocol is being followed consistently at all schools. Name: Manish Singh Title: Director, Food Services Division Telephone: (213) 241-2993

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

2025-001 Costs Incurred Beyond the Period of Performance Criteria: According to 2 CFR §§200.1, 200.308, 200.309, 200.344, and 200.403(h), a non-Federal entity may only charge allowable costs incurred during the approved budget period of the Federal award’s period of performance, and any costs incurred before the Federal award was made that were authorized by the Federal awarding agency or pass-through entity. All financial obligations incurred under the Federal award must be liquidated within the required time period. Costs incurred outside the approved period of performance are unallowable and constitute questioned costs. Client’s Response: During the grant cycle, the Organization submitted for an extension but did not receive confirmation of said extension. During the current fiscal year, the Organization has implemented additional controls to ensure that all grant funding is expended within the timeframe allotted. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444

FINDING 2025-001: PELL GRANT AWARD We concur with the finding and will follow established procedures more closely to ensure that, in the future, Pell Grant awards are calculated and disbursed in accordance with the federal regulations. The following corrective actions have been implemented: • The institution has strengthened internal controls to ensure that all Pell Grant awards are calculated and disbursed in strict compliance with federal regulations. • A reconciliation process for Pell Grant awards has been implemented. Pell Grant awards and scheduled credits are now reviewed and reconciled at the conclusion of the institution’s add/drop period to ensure accuracy before any disbursement occurs. • The institution has discontinued the practice of early disbursements. Beginning with Winter quarter, Pell Grant funds will not be drawn down or disbursed prior to the close of the add/drop period.

Coronavirus State and Local Fiscal Recovery – Assistance Listing No. 21.029 Cause: Controls over SEFA preparation and federal award identification were not sufficient to ensure all pass-through federal awards (including ARPA CPF) were captured with required identifiers (federal agency, ALN 21.029, pass-through name/number) before year-end reporting. Effect: An initially incomplete SEFA increases the risk that major programs are not properly identified for testing, which could result in modification of opinion due to incomplete SEFA, which ultimately could result in a delayed audit. Recommendation: We recommend CCAC implement and document SEFA preparation controls to ensure completeness and accuracy over maintaining a central grant repository containing award documents with federal agency, performing year-end SEFA reconciliation, and obtaining written ALN/FAIN confirmations from pass-through entities for any awards lacking federal identifiers and retaining those confirmations in the grant file. Views of Responsible Officials: There is no disagreement with the audit finding. See below for actions taken to remedy the finding. Management Response: Christina Cultural Center experienced a SEFA completeness finding during a year with bookkeeping turnover, which affected the initial compilation of federal award activity. In response, management worked closely with the audit team to confirm the complete listing of awards, validate pass-through entity details, and support accurate SEFA presentation. The organization has also identified cross-training as a key next step to strengthen continuity and reduce key-person dependency going forward.

Broadlawns Medical Center respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF AGRICULTURE 2024-001 Special Supplemental Nutrition Program for Women, Infants and Children – CFDA No. 10.557 Recommendation; We recommend the Medical Center review the WIC expenses monthly to ensure during month end close process that all costs are allowable and deemed to be reimbursable as a part of the federal award program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization adopted a monthly review process as part of the monthly close process. Name of the contact person responsible for corrective action: Jim Lynch Planned completion date for corrective action plan: Next Fiscal Year If there are questions regarding this plan, please call Jim Lynch at 515-282-2296

View of Responsible Officials: ICMEC experienced delays in completing the audit due to the accounting for a closure of a consolidated overseas entity (ICMEC Australia). As this entity has been discontinued, ICMEC anticipates completing the single audit timely moving forward.

View of Responsible Officials: ICMEC discovered an error during FY2024 that resulted in overdraws for their Federal awards as well as drawing expenses from one award that should have been drawn under a different award. After meeting with the funder, ICMEC began to reduce its draws to reduce the overdraw balance. Additionally, ICMEC has received a modification and extension to one of its grants that allows for retroactive indirect and salary costs. As of 8/31/25, the net balance of all JTIP grants combined is close to zero. We are working to correct the individual balances.

Audit Finding Reference Number: 2024-003 Federal Program: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number (ALN): 21.027 Federal Agency: U.S. Department of the Treasury Contact Person(s) Responsible for Corrective Action: Jessica Trusty Director of Finance jtrusty@co.morgan.co.us or 970-542-3508 Planned Corrective Action: The SLFRF funds were one-time funds received during the aftermath of the COVID Pandemic and related recovery. All funds related to this grant have been spent and the grant closed out. I will work with my sta􀀁 to make any necessary corrections to the SLFRF 12/31/2024 report. Morgan County will also implement the following procedures to ensure accurate reporting of all grant expenditures and fiscal year end dates: Establish a review and reconciliation process to ensure all future federal grant compliance reports are reconciled to the Schedule of Expenditures of Federal Awards and underlying accounting records. Provide additional training to sta􀀁 responsible for preparing compliance reports on Uniform Guidance requirements and related grant reporting standards. Assign oversight responsibility to a senior sta􀀁 member to review and approve all grant related compliance reports prior to submission. Anticipated Completion Date: June 30, 2026

Mana Maoli has implemented a practical review and reconciliation step as part of payroll processing. This step compares approved timesheets to payroll register hours to help ensure that payroll allocations to federal programs are based on accurate records. This reconciliation is integrated into the existing payroll workflow to avoid added administrative burden. Management will conduct periodic reviews of payroll records and refine the process as needed to maintain reasonable assurance of accuracy, recognizing that the goal is continuous improvement. Anticipated completion date: December 31, 2026

The District Director of Student Services will monitor and make sure that all personnel who serve under federal programs have their time properly documented using semi-annual certification forms or other appropriate time and effort methods.

CONDITION: During the calendar year 2024, the City did not record the necessary adjustments to the various ‘Fund’ general ledgers of the City to properly reconcile the balance sheet accounts, such as cash, receivables, payables, and payroll-related liabilities to the underlying supporting documentation available at the City (which includes reconciliations of cash prepared independently by City personnel but do not agree to amounts reported in the various general ledgers). This included ‘Funds” containing significant federal funding such as the City’s Community Development Block Grant (CDBG) Program and American Rescue Plan Act (ARPA) funding known as the Coronavirus State and Local Fiscal Recovery Fund.CONDITION (Continued): As a result, the financial position and results of operations as shown throughout the calendar year were inaccurately stated. However, it should be noted that the Community Development Department of the City and other City personnel maintain separate financial reporting for these federal funds, independent of the aforementioned ‘Fund’ general ledgers sufficient to ascertain the revenues and expenditures of the federal programs. This is a repeat finding (2023-001) for the prior year. CRITERIA: Prudent internal control procedures in the areas of general ledger management and financial reporting include the reconciliation of all general ledger account balances to underlying supporting documentation monthly with independent oversight and approval as part of the process. In specific as it relates to federal programs, Section 2 CFR 200.403(g) of the Uniform Guidance requires that federal costs must be adequately documented which would include the applicable general ledgers of the City. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City is continuing their review of the recommended options as presented by the Audit Firm’s recommendation for feasibility considering current manpower, expertise, and budgetary constraints. In addition, the City plans to ensure that written procedures for all accounting functions are implemented, reviewed and updated as necessary with the objective of ensuring that all balance sheet account balances are supported by the underlying documentation available at the City. The timeframe for completion of this review will occur during the first nine months of calendar year 2026 with the intention of having the City be in full compliance with Section 2 CFR 200.403(g) of the Uniform Guidance which requires federal costs to be adequately documented which would include the applicable general ledgers of the City.

Finding Number: 2024-043 Audit Type: Single Audit Finding Title: Use of Unapproved Federal Funds to Satisfy Required Local Match Related Finding: 2024-022 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department2. 2. Planned Corrective Action The City will revise its grant accounting procedures to ensure only eligible local funds are used for matching requirements. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will coordinate with granting agencies to confirm match eligibility. 5. Status of Prior Year Finding This is a new finding.

Federal Program Name: Federal Transit Cluster Assistance Listing Numbers: 20.507, 20.526 State Program Names: State Urbanized Area Formula Program; State Formula Grants for Rural Areas Contact Person: Ted Ross, Executive Director Updated Corrective Action Plan: The District has revised its procurement procedures to meet Uniform Guidance requirements. Enhancements include: Mandatory documentation of quotes for applicable procurements Verification and documentation of suspension and debarment checks for all covered transactions Centralization of procurement records in accordance with best practices Policy training and practices are already in place and are being followed. Certification The Gulf Coast Transit District affirms that all corrective actions noted above are actively corrected or are being addressed. Additional documentation or clarification will be provided to auditors upon request.