Corrective Action Plans

FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA)- Procurement and Suspension and Debarment Federal Agency: Department of Education Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the Procurement and Suspension and Debarment compliance requirements. Contact Person Responsible for Corrective Action: Kim Holmquist Contact Phone Number and Email Address: 219-924-4250 kholmquist@griffith.k12.in.us View of Responsible Officials: We concur with this finding. Description of Corrective Action Plan: We will establish a proper system of internal controls and develop policies and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Anticipated Completion Date: June 30, 2026

FINDING 2025-001 Finding Subject: Child Nutrition Cluster – Procurement Suspension & Debarment Contact Person Responsible for Corrective Action: Annette Guenther Contact Phone Number and Email Address: 317-205-3332 x 77209 aguenther@msdwt.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Child Nutrition will ensure that all procurement procedures are followed for both the simplified acquisition method and the small purchase method. Documentation will be retained to verify that required procedures were followed. Anticipated Completion Date: September 30, 2026

2025-018 PROCUREMENT HIGHER EDUCATION POLICY COMMISSION (HEPC), BLUEFIELD STATE UNIVERSITY (BSU) Assistance Listing Number: Various – Research & Development Cluster Higher Education Policy Commission (HEPC) response: HEPC maintains procurement policies consistent with state law, which is one of the three allowable criteria recognized in 2 CFR §200.320(a)(1)(iv) for establishing a micro purchase threshold of up to $50,000. A Self-Certification letter will be developed and maintained by April 30, 2026, while formally defining micro-purchase thresholds applied to federal awards. This selfcertification letter will be retained as part of our procurement documentation and will provide how the micro-purchase threshold was determined and applied in accordance with 2 CFR §200.320(a)(1)(iv). Bluefield State University (BSU) response: Beginning in FY 2026, the BSU Controller and Director of Purchasing will review the criteria recognized in 2 CFR §200.320(a)(1)(iv) for establishing a micro purchase threshold of up to $50,000. These requirements will be presented to the Board of Governors before June 30, 2026.

The Company will work with the audit firm to ensure the data collection form is filed timely in the future. The late filing was an oversight as the single audit package was not filed within 30 days after the receipt of the audit report, but prior to the nine-month deadline of February 28, 2025. Anticipate completion by 12/31/2025.

Finding Number: 2024-007 Finding Title: Regulatory Deadline for Submission of Schedule of Expenditures of Federal Awards Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Reporting - Audit Requirements and Single Audit Submission (2 CFR §200.512(a)) Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization engaged a firm to perform the audit with the intent of completing and submitting the audit within the requirement timeframe. Due to unforeseen issues, the completion of the audit was delayed. Corrective Action Plan: Corrective Action #1: Audit Planning Timeline • Action: Develop detailed audit preparation timeline working backwards from nine-month deadline. Engage auditors by March 31 following fiscal year end to allow adequate planning and completion time. Board Treasurer will schedule regular status meetings with auditors throughout audit process. Build contingency time into schedule for unforeseen delays. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: December 31, 2025 (for FY 2025 audit); Annually thereafter by October following fiscal year end Corrective Action #2: Enhanced Year-End Close Procedures • Action: Implement enhanced year-end closing procedures ensuring financial records are audit-ready within 60 days of fiscal year end. Contract Accountant will prepare preliminary SEFA and supporting schedules by January 31 following fiscal year end. Board Treasurer will conduct internal pre-audit review identifying and resolving issues before auditors begin fieldwork. • Responsible Person/Title: Contract Accountant and Board Treasurer • Anticipated Completion Date: February 28, 2026 (procedures development); January 31, 2026 (first implementation for FY 2025) Corrective Action #3: Audit Documentation Preparation • Action: Prepare all audit supporting schedules and documentation in advance of audit fieldwork. Organize federal grant files with all required documentation readily accessible. Board Treasurer will coordinate with Contract Accountant to ensure prompt responses to auditor requests. • Responsible Person/Title: Contract Accountant and Board Treasurer • Anticipated Completion Date: March 31, 2026 (for FY 2025 audit); Annually thereafter Corrective Action #4: Board Oversight and Accountability • Action: Assign Board Treasurer responsibility and accountability for ensuring timely audit completion and submission. Require monthly status updates from Board Treasurer to full Board on audit progress during audit period. Include audit status as standing agenda item at Board meetings from April through September. • Responsible Person/Title: Board President • Anticipated Completion Date: April 30, 2026 (initial); Ongoing monthly April-September annually Corrective Action #5: Board Engagement and Resource Authorization • Action: Board Treasurer will immediately notify full Board if any issues arise that could jeopardize meeting submission deadline. Board will authorize additional resources (e.g., consultant support for Contract Accountant) if needed to meet deadline. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: Ongoing, as needed Corrective Action #6: Compliance Calendar with Milestones • Action: Incorporate FAC submission deadline into Organization's compliance calendar with milestone checkpoints. Set internal deadline of eight months (rather than nine months) to provide buffer for unforeseen issues. Track key milestones: audit engagement (by March 31), fieldwork completion (by July 31), draft report (by August 15), final report (by August 31), FAC submission (by September 15). • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: January 31, 2026 Corrective Action #7: Contingency Planning • Action: Develop contingency plan if audit delays occur, including escalation procedures and potential for additional temporary accounting support. Maintain regular communication with auditors to identify potential delays early. Board will evaluate whether additional contracted accounting support is needed during audit season. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: March 31, 2026 Corrective Action #8: Resource Capacity Assessment • Action: Board will assess whether current Contract Accountant arrangement provides adequate capacity to meet federal compliance requirements. Consider increasing Contract Accountant hours or engaging additional professional support for federal grants administration. Evaluate cost-benefit of engaging grants management consultant to support compliance activities. • Responsible Person/Title: Board of Directors • Anticipated Completion Date: March 31, 2026

2024-003 Finding - In accordance with 2 CFR § 200.512(a), the audit must be completed and the reporting package, which includes the Data Collection Form (SF-SAC), must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Recommendation - The Organization should review internal controls and implement necessary procedures to ensure that accounting processes are completed timely so the audit can be completed within the parameters of the due date. Action to be taken – Additional staffing has been added and long with ensuring that bank reconciliations are completed by the 10th day after the month ends in order to ensure audit field work is completed in a timely manner. Responsible person – Tony Postma, Interim Chief Financial Officer

Finding: 2024-002 Condition Found: FAC filing for fiscal year ended March 31, 2024 was submitted late. Individual(s) Responsible for Corrective Action: Tafta McCain, Interim CEO, Fraction CFO – Community Link Consulting, Financial Team Planned Corrective Action: The late FAC filing was primarily the result of delays in finalizing financial statements and staff turnover. Executive leadership has addressed these issues through the corrective actions implemented under Finding 2024 001, including strengthened monthly close procedures and improved oversight of financial reporting timelines. The organization has also participated in financial technical assistance hosted by HRSA. In addition, the Organization has formalized responsibility for monitoring Single Audit and Federal Audit Clearinghouse deadlines within finance leadership, with executive level oversight to ensure compliance. The Organization has also retained a fractional CFO to provide continuity, expertise, and accountability on an ongoing basis. Management expects these actions to result in timely and compliant FAC submissions in future reporting periods. Anticipated Completion Date: Already completed with anticipated timely filing of FY 2026.

Western-Washtenaw Area Value Express, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2024. Auditor: Maner Costerisan, 2425 E. Grand River Ave, Suite 1, Lansing, Michigan 48912 Audit period: The funding from September 30, 2024 schedule of findings and questioned costs is discussed below. The finding is number consistently with the number assigned in the schedule. Finding - noncompliance with the Uniform Guidance Recommendation: As this was WAVE’s first Single Audit, management was still developing familiarity with Uniform Guidance audit submission requirements. The late submission resulted from an incomplete understanding of the deadlines associated with filing the Data Collection Form (DCF) and audit reporting package with the Federal Audit Clearinghouse (FAC). Action to be taken: To ensure timely submissions in future periods, management is implementing the following corrective actions: 1.Establish a formal written procedure for completing and filing the DCF and Single Auditreporting package in accordance with 2 CFR 200.512. 2.Assign a responsible individual within the finance department to oversee the Single Auditsubmission process and monitor related deadlines. 3.Create a compliance calendar that includes required federal reporting deadlines, including the30-day and 9-month submission rules. 4.Implement an internal review and approval step to confirm the completeness and accuracy of allrequired components prior to submission and to verify that submission occurs within therequired timeframe. 5.Provide training to finance personnel on federal audit reporting requirements and the FACsubmission process. These procedures will ensure future Single Audit submissions are completed on time and in accordance with Uniform Guidance. Anticipated Completion Date: December 31, 2025

BRHC has hired additional accounting staff to better ensure the month-end and year-end close processes are performed timely and will work with the audit firm to ensure that audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filled in a timely manner in the future.

Submission of the Audit Reporting Package and Data Collection Form Recommendation: We recommend the organization strengthen its internal controls over the reconciliation process, including implementing a formal review procedure and ensuring reconciliations are supported by complete and accurate documentation prior to audit fieldwork. Timely and accurate reconciliations are critical to maintaining reliable financial reporting and audit readiness. Action Taken: CMJTS acknowledges the delay and has been making improvements to ensure reconciliations are done timely. Accounting staff have been given additional training on bank reconciliations, and they are now reconciling bank transactions daily. This real time reconciling helps ensure that all transactions are processed accurately. Bank reconciliations are then signed off by Finance Manager and the Board Treasurer monthly. Accounting staff have been given additional training on statement of financial position reconciliations and will be reconciling them monthly. The statement of financial position, with supporting documentation, will then be signed off by the Finance Manager monthly.

Finding 2024-002: Submission of the Reporting Package and Data Collection Form Management Response: Agreement with Finding: Management acknowledges and concurs with the finding. Root Cause: The agency experienced unanticipated delays in the preparation and submission processes for the Schedule of Expenditures of Federal Awards (SEFA) and related audit documentation, resulting in the audit reporting package and Data Collection Form not being submitted within the required timeframe. Management Plan: Lakes and Pines has engaged a professional accounting firm to assist with comprehensive process improvements for financial reporting. The agency will work with the firm to establish enhanced procedures and internal controls for the timely preparation of the SEFA and all required audit materials. New processes will include earlier preparation timelines and milestone checkpoints to ensure submission deadlines are met Responsible Party: Dawn van Hees, Fiscal Controller Implementation Timeline: Improvements will be implemented during the 2025/2026 fiscal year, with the enhanced processes fully operational for the next audit cycle reviewing that fiscal year. Current Status (as of November 5, 2025): The professional accounting firm has been engaged and process improvement work is underway.

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 September 15, 2025, which was 168 days past the March 31, 2025 deadline. Action planned in response to finding: Management will implement procedures to ensure that all audit documentation, is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Repeat Finding: Similar to prior year finding 2023-005. Planned completion date for corrective action plan: June 30, 2025 Name of the contact person responsible for corrective action: Dolores Silva, Chief Financial Officer

Corrective Action Plan 8/15/2025 Department of Health and Human Services Semcac respectfully submits the following corrective action plan for the year ended 09/30/2024. BerganKDV, Ltd. 220 Park Ave S St. Cloud, MN 56301 Audit Period: 10/1/2023 – 9/30/2024 The finding from the 9/30/2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Federal Agency: Various Assistance Listing Number: Multiple Compliance Requirement: Reporting Finding 2024-001: Submission of the Audit Reporting Package and Data Collection Form (Repeat of Finding 2023-001 Submission of the Audit Reporting Package and Data Collection Form Recommendation: We recommend that management address the lack of capacity in the finance department and monitor the year-end closing schedule for a timely audit reporting package and data collection form to ensure compliance with federal deadlines. Action Taken: We agree with the auditors’ recommendation and the following action will be taken to address the finance departments capacity constraints and year-end closing schedule to ensure timely submission of the audit reporting package and data collection form. We have added capacity to the finance department at the beginning of FY2025 by 1.0 FTE. We have also contracted with an outsourcing accounting firm to enhance and improve our internal controls, processes, and procedures to ensure we both follow our year-end closing schedule and provide a timely audit reporting package. If the Department of Health and Human Services or the Department of Energy have questions regarding this plan, please call Adam Larson at (507) 864-8218. Sincerely yours, Adam Larson, Semcac Fiscal Director

Management’s Corrective Action Plan The Town of Stanton respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: ATA, PC 185 North Church Street Dyersburg, TN 38024 Responsible officials for corrective action: Norman Bauer, Mayor Town of Stanton Signature: Audit period: June 30, 2024 The findings from the June 30, 2024, schedule of findings, recommendations and responses are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2024 – 001 – Segregation of Duties – Significant Deficiency Corrective Action Taken or Planned: We have hired an additional employee at City Hall in order to properly segregate duties. Anticipated Completion Date: June 30, 2025 Finding 2024 – 002 – Single Audit Data Collection Form Not Filed by Due Date Corrective Action Taken or Planned: The Town will work with the audit firm to ensure that the audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed timely in the future. Anticipated Completion Date: June 30, 2025

Procurement Cluster: Research and Development (R&D) Federal Agency: Various Assistance Listing Title and Number: Various Award Name: Various Award Identifying Number: Various Award Year: Fiscal year 2024 Pass-Through Entity: VariousThe University concurs with the auditors' finding. The University did not communicate the change in auditee status and the resulting impact on the micro-purchase threshold to Procurement Services in a timely manner. This oversight led to continued application of the higher $75,000 threshold after the University no longer qualified under 2 CFR 200.320(a)(1)(iv). To address this issue, management is implementing the following corrective actions: 1. Cross-Functional Communication Protocol – A formal communication protocol will be established between Accounting and Financial Reporting and key compliance stakeholders to ensure timely notification of changes in auditee status or other compliance-related designations following the completion of the annual financial statement audit. 2. Policy Update and Staff Training – Procurement policies and procedures will be updated to reflect the requirement that UAH is subject to the lower micro-purchase threshold. Staff will be trained to take appropriate action when the University either qualifies for or no longer meets the criteria for a higher micro-purchase threshold, including timely adjustments to procurement policies and procedures. 3. Monitoring and Review – The Controller’s Office will conduct an annual review of auditee status immediately upon issuance of the audited financial statements, with documented confirmation sent to key compliance stakeholders. The University expects to complete this corrective action plan by September 30, 2025. For follow-up questions or if you need any additional information, please feel free to contact Brad Cooper, Interim Chief Financial Officer, at jbc0038@uah.edu who is responsible for this corrective action.

Finding 2024-003 Contact Person Responsible for Corrective Action Plan: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 We concur with the finding. Corrective Action plan: As of 3/1/25. Cindy will look the company up on Sam.gov. and the Food Service Director will look it over and both of us will initial and keep a copy on file. Anticipated Completion Date: March 2025

The Organization will work with the audit firm to ensure that the data collection form is filed timely in the future.

Finding Reference: 2023-001 Compliance with Reporting Under the Uniform Guidance Description: The data collection forms for the years 2019 through 2021 have not been submitted timely. Recommendation: The Town should follow federal guidelines by submitting the data collection form to the FAC in a timely manner. Corrective Action: The Town of Guilderland Comptroller’s Office suffered significant turnover in key positions during the fiscal years of 2019 and 2021 including the retirement of the Town Comptroller and Fiscal Officer. The Town also implemented a new accounting software during 2018 that caused significant delays in the monthly and year-end reporting. Lastly, the COVID-19 pandemic had significant impact to the Town, particularly during 2020 when remote work was encouraged. This combination and sequence of events made it impossible to meet the required external audit reporting deadlines. Since these vents, the Town has filed the vacant positions and has scheduled all remaining audits. The auditors are working as expeditiously as possible to complete the remaining audits. The required reporting noted in the guidelines above cannot be completed until each prior year audit is finished, therefore causing a delay in each fiscal year’s reporting. Person(s) Responsible for Corrective Action: Darci Efaw, Comptroller & Jessica Gulliksen, Fiscal Officer Anticipated Completion Date for Corrective Action: The remaining audits that are left to become fully in compliance have been tentatively scheduled with the external auditors since 2022. The Town of Guilderland works as efficiently as possible with the auditors to complete these remaining audits.

BRHC is in the process of hiring additional accounting staff to better ensure the month-end and year-end close processes are performed timely and will work with the audit firm to ensure that audit field work is scheduled with sufficient time to allow the audit report and data collection form to be filed in a timely manner in the future.

2023-004: Reporting Type of Finding: Noncompliance, Material Weakness Condition: The school submitted its audit for the fiscal year ending June 30, 2023, in a timely manner. The audit was submitted December 4, 2024, which was 248 days past the March 31, 2024 deadline. Action plan in response to the finding: Management will implement procedures to ensure that all audit documentation, is available for the audit promptly and the audit report is completed and submitted within the appropriate timeframe. Repeat Finding: No. Planned completion date for a corrective action plan: June 30, 2024 Name of the contact person responsible for corrective action: Marie Rose, Principal

Department of Health and Human Services Department of Energy Semcac respectfully submits the following corrective action plan for the year ended 09/30/2023. BerganKDV, Ltd. 220 Park Ave S St. Cloud, MN 56301 Audit Period: 10/1/2022 - 9/30/2023 The finding from the 9/30/2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS- FEDERAL AWARD PROGRAMS AUDIT SIGNIFICANT DEFICIENCY Department of Health and Human Services Department of Energy 2023-001Low-Income Home Energy Assistance -ALN 93.568 Head Start -ALN 93.600 Submission of the Audit Reporting Package and Data Collection Form Recommendation: We recommend the submission of the audit reporting package and the data collection form as soon as the audit is available. Action Taken: We agree with the auditors' recommendation and the following action will be taken to ensure timely submission of the audit reporting package and data collection form. We will implement a plan which includes: adding capacity in the accounting department along with a schedule for a timely fiscal year close out, audit fieldwork, as well as an actionable plan to ensure audit tasks are completed in a timely fashion in order to submit the audit reporting package and data collection form by the deadline. If the Department of Health and Human Services or the Department of Energy have questions regarding this plan, please call Adam Larson at (507) 864-8218. Sincerely yours, Adam Larson, Semcac Fiscal Director

2023-005: Reporting Type of Finding: Noncompliance, Material Weakness Condition: The School did submit their audit for the fiscal year ending June 30, 2023 timely. The audit was submitted August 16, 2024, which was 138 days past the March 31, 2024 deadline. Action planned in response to finding: Management will implement procedures to ensure that all audit documentation, is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Repeat Finding: Similar to prior year finding 2022-004. Planned completion date for corrective action plan: June 30, 2024 Name of the contact person responsible for corrective action: Dolores Silva, Chief Financial Officer

Programs: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, and Special Education Cluster Federal Assistance #: 15.042, 15.046, 15.047, and 84.027 Federal Agency: U.S. Department of the Interior and U.S. Department of Education Grantor Number: N/A Questioned Costs: N/A Type of Finding: Noncompliance, Other Matters Compliance Requirement: L. Reporting Condition: The School did not submit their audit for the fiscal year ending June 30, 2023, timely. The audit was submitted May 28, 2024, which was 58 days past the March 31, 2024 deadline. Repeat Finding: Same as prior year finding 2022-04. Action planned in response to finding: The School will implement procedures to ensure that its closeout process is completed timely and accurately to allow adequate time for the audit firm to complete the audit process, draft the financial statements, and allow adequate time for review procedures to take place. Planned completion date for corrective action plan: For the period ending June 30, 2024. Name of the contact person responsible for corrective action: Jagdish Sharma, Principal

2023-006 Late Audit Submission Programs: Impact Aid, Education Stabilization Fund (COVID-19) Federal Assistance #: 84.041, 84.425 Federal Agency: U.S. Department of Education Grantor Number: N/A Questioned Costs: N/A Type of Finding: Noncompliance Compliance Requirement: L. Reporting Planned completion date for corrective action plan: For the period ending June 30, 2024. Name of the contact person responsible for corrective action: Contact person: Becky Tinney, Business Manager Condition: The District did not submit their audit for the fiscal year ending June 30, 2023, timely. The audit was submitted on May 16, 2024. Corrective Action Plan: The District will implement procedures to ensure that all audit documentation is available for auditing in a timely manner and the audit report is submitted within the appropriate timeframe.

Department of Education, United States Department of Agriculture, Federal Aviation Administration 2023-004 R&D Cluster – Assistance Listing No. 84.334, 10.001, 20.109 Condition: MSU established a micro-purchase threshold of $75,000 for contracted services and was not able to provide documentation to support this threshold. Recommendation: We recommend the institution review and revise their current procurement policy and review requirements to ensure that their policy is meeting Federal requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Mississippi State University will make corrections to the Procurement and Contracts Manual to ensure compliance with 2 CFR 200.320. Name(s) of the contact person(s) responsible for corrective action: Jennifer Mayfield, Director of Procurement and Contracts and Jonathan Tucker, Director Sponsored Programs Planned completion date for corrective action plan: June 30, 2024 If the Department of Education, United States Department of Agriculture, or Federal Aviation Administration has questions regarding this plan, please call Jonathan Tucker at 662-325-1930.