Corrective Action Plans

Finding Number: 2025-002 Condition: The Organization failed to accumulate all expenditures of federal awards into their SEFA resulting in an understatement of expenditures on their 2025 SEFA. Planned Corrective Action: Management has implemented a formal SEFA preparation checklist that includes reconciliation of total federal expenditures to the general ledger and grant records. This includes establishing a control to identify all federal awards by ALN, including pass-through funding, prior to SEFA finalization and enhanced management review procedures to include verification of completeness and accuracy. Additionally, management will coordinate with program personnel to ensure all sources of federal funding are captured. Contact Person Responsible for Corrective Action: Justin Fisher, Senior Director of Accounting Anticipated Completion Date: August 31, 2026

Person Responsible for Implementing the Correction Plan: Autumn Stewart, City Recorder Anticipated Completion Date: June 30, 2026 Repeat Finding: Yes Reason Corrective Action Was Not Taken: Issue was found in the 2025 audit, so was not known at the time. Planned Corrective Action: The City will strengthen internal controls over SEFA identification and preparation to ensure compliance with Uniform Guidance single-audit requirements. The City will also implement enhanced review and communication procedures with external auditors, as the condition was significantly impacted by deficiencies in the auditors’ evaluation and classification of major programs during the audit process.

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.

Corrective Action Plan - Audit Finding 2024-001: Inaccurate and Incomplete SEFA and Delay in Reporting 1. Documentation Procedures • All federal pass-through funding received will be supported by written documentation (e.g., subaward agreements, grant award letters). • A centralized repository for federal award documentation will be maintained and made accessible to the finance team. 2. SEFA Preparation Controls • A SEFA preparation checklist will be developed and implemented to ensure all federal programs are accurately identified, classified, and reported. • Verification of Assistance Listing Numbers (ALNs) and funding sources for all awards included in the SEFA will be required. 3. Designation of Responsibility • The SEFA Compliance Lead will be assigned responsibility for verifying the federal nature of all awards and ensuring accurate SEFA reporting. • Ongoing training will be provided to finance staff on SEFA requirements and Uniform Guidance compliance. 4. Review and Approval • A formal review and approval process for the SEFA will be instituted prior to submission, including review by the Finance Director and Executive Director. 5. Monitoring and Follow-Up • The Finance Director will monitor ongoing compliance and report quarterly to the Board of Directors on SEFA preparation and submission status. • An annual internal review of SEFA procedures will be conducted to ensure continued compliance. Implementation Timeline All corrective actions will be implemented by March 31, 2026. Responsible Personnel • SEFA Compliance Lead: Mimi Lim, Sr. Finance and Operations Manager • Finance Director: Christine Kuo • Executive Director: Monique Brown This Corrective Action Plan is designed to address the auditor’s recommendations and prevent recurrence of similar issues, in accordance with 2 CFR 200.511(c) and best practices for federal grant compliance.

It should be noted that distribution of funds under this program terminated on December 31, 2024; no new loans will be originated. The Foundation will implement the recommended actions as appropriate in future programs that may be similar to this one.

Finding summary: an internal control deficiency affecting the accuracy of the Schedule of Expenditures of Federal Awards (SEFA) Responsible department: Finance and PPACG Contact person: Finance Corrective action plan: As of 2025 SEFA internally will be prepared by Grant coordinator and review by Finance. Envida will ensure that all appropriate ALNs and Federal identifications and amounts are included on the contracts. Envida will implement a process for all appropriate department directors, including CEO to sign off on each grant received. Timeline for completion: Dec 31 2025 Monitoring plan: Monthly Review with Grant coordinator Anticipated outcome: SEFA will reflect accurate federal expenditures.

Executive Director will work with all program areas to ensure that all federal awards and subawards are identified as such to ensure we track properly • ED will ensure we have written documentation for all federal pass-through funding with correct ALN numbers and communicate the information to the third party accountants • ED will verify the federal nature of all awards and stay current on SEFA and Uniform Guidance

COO will work with all program areas to ensure that all federal awards and subawards are identified as such to ensure we track properly COO will ensure we have written documentation for all federal pass-through funding We have added an experienced grants accountant supervised by the CFO to verify the federal nature of all awards and stay current on SEFA and Uniform Guidance

Corrective Action Plan 2023 – 007 FINDING 2023-007 Contact Person Responsible for Corrective Action: Kevin Beaver, Clerk – Treasurer Contact Phone Number and Email Address: Ph. 812-533-1053 Kevin.Beaver@westterrehautein.gov Views of Responsible Officials: We Concur with the SBOA Findings Finding Subject: Scope Limitation Corrective Action Plan 1. Establish Formal SEFA Preparation Procedures The Clerk-Treasurer will develop and implement written procedures for the preparation and review of the Schedule of Expenditures of Federal Awards. Procedures will require: • Identification of all federal awards received during the year. • Verification of applicable Assistance Listing Numbers (ALNs). • Documentation supporting all reported expenditures. • Completion of a SEFA preparation checklist before submission. 2. Create and Maintain a Federal Awards Inventory The Town will establish a centralized listing of all federal awards received. The inventory will include: • Federal agency • Program name • Assistance Listing Number (ALN) • Grant period • Award amount • Annual expenditures • Pass-through entity information, when applicable The inventory will be reviewed and updated monthly. 3. Implement Reconciliation Procedures for Federal Expenditures Prior to preparation of the AFR and SEFA, federal expenditures will be reconciled to: • General ledger accounts • Grant reimbursement requests • Supporting grant documentation • Cash drawdowns and receipts Any discrepancies identified during the reconciliation process will be investigated and resolved before submission. 4. Implement Independent Review Controls An independent review of the SEFA will be performed before submission. The review will verify: • Completeness of all federal programs. • Accuracy of reported expenditures. • Correct Assistance Listing Numbers. • Agreement of reported amounts to support records and reconciliations. Evidence of review will be documented through a monthly signed and dated review checklist. 5. Strengthen Grant Documentation and Record Retention The Town will maintain separate grant files for each federal program containing: • Award agreements • Amendments • Reimbursement requests • Financial reports • Supporting expenditure documentation • Correspondence with grantor agencies Records will be maintained in accordance with federal and state retention requirements. 6. Establish Ongoing Monitoring Procedures The Town will perform monthly reviews of federal grant activity to ensure expenditures are properly recorded and reported. Monitoring procedures will include: • Review of grant expenditures by program. • Verification of ALN assignments. • Review of grant balances and reimbursement activity. • Follow-up and correction of identified issues. Results of quarterly reviews will be documented and retained. Quarterly monitoring reports Responsible Party: Clerk – Treasurer and Town Council President. Completion Date: immediate first steps, March 3, 2027, for full implementation. _____________________________ Kevin Beaver, Clerk – Treasurer

Management agrees with the finding and has reached out to contacts at HRSA regarding the preferred treatment of the MHS PRF funds but have not received a response. Kevin Gessler, Vice President at MHS, is the contact person at the System. The expected completion date to receive a response and resolve is September 30, 2024.

Inaccurate Grant Reporting (Material Weakness) Person Responsible for Implementing the Correction Plan: Autumn Stewart, City Recorder Anticipated Completion Date: June 30, 2026 Repeat Finding: No Planned Corrective Action: The City will strengthen internal controls over SEFA identification and preparation to ensure compliance with Uniform Guidance single-audit requirements. The City will also implement enhanced review and communication procedures with external auditors, as the condition was significantly impacted by deficiencies in the auditors’ evaluation and classification of major programs during the audit process.

In response to the finding of a misstatement of the 2022 Schedule of Federal Awards document submitted to Frost, PLLC, the County has established a cycle of training for new and existing staff within the Grants department as well as created a multi-step review process in order to identify and correct errors prior to beginning the auditing process. This process includes coordinating with other County departments, such as the Treasurer's Office, to make sure all activities are recorded in the proper periods on the Schedule of Federal Awards.

Views of Responsible Officials and Planned Corrective Action—Management agrees with the finding and has reached out to contacts at HRSA regarding the preferred treatment of the MHS PRF funds but have not received a response. Kevin Gessler, Vice President at MHS, is the contact person at the System. The expected completion date to receive a response and resolve is September 30, 2024.

Finding Number: 2022-001 Condition: The original SEFA prepared for audit purposes did not include all federal expenditures that should have been reported under ALN 66.443. Planned Corrective Action: All programs that have both Federal and State/Local funding will be examined to ensure correct expenditure by funding source is properly recorded. Contact person responsible for corrective action: Curt A. Reppuhn, CPA Deputy Comptroller Anticipated Completion Date: Fiscal Year Ended June 30, 2023

RE: Audit of Federal Programs, fiscal year ending on December 31, 2021 In response to the finding of a misstatement on the 2021 Schedule of Federal Awards document submitted to Frost PLLC, The County has established a cycle of training for new and existing staff within the Grants department as well as created a multi-step review process in order to identify and correct errors prior to beginning the auditing process. This process includes coordinating with other County departments, such as the Treasurer’s Office, to make sure all activities are recorded in the proper periods on the Schedule of Federal Awards document.

View of Responsible Officials: Management understands and agrees with the finding and acknowledges deficiencies in SEFA preparation and reconciliation processes. Corrective actions include: • Implementing a standardized SEFA preparation checklist to identify all federal awards, including pass-through funding. • Requiring a documented reconciliation of the SEFA to the general ledger, grant schedules and supporting reports. • Establishing procedures to compare federal revenue to expenditures and investigate variances. • Strengthening documentation retention practices to support all reported federal expenditures. • Providing training to finance personnel on Uniform Guidance and SEFA requirements.