Corrective Action Plans

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Lyle School District No. 406 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Susan Carabin, Business Manager PO Box 368 Lyle, WA 98635 (509) 365-2191 Corrective action the auditee plans to take in response to the finding: Since learning of the requirement regarding payroll reports, the District immediately asked our contractor to build a shared file that contains the certified weekly payroll reports. We now download and document the reports once per week. Anticipated date to complete the corrective action: 3/28/2024

Views of Responsibte Officials and Planned Corrective Actions: The School District will immediately begin collecting the time and effort documentation for the impacted grants for the current fiscal year (FY24) and into future periods as required. lf the Oversight Agency has questions regarding this plan, please call Amanda Dupont, lnternal Auditor, at 978-674-2102

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Montesano School District No. 66 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Sheila Baker, 502 E Spruce Avenue, Montesano, WA 98563, (360)249-3942 Corrective action the auditee plans to take in response to the finding: The district has recently participated in a training provided by the Department of Labor & Industries regarding prevailing wage requirements. In the coming months, the Superintendent and Business Manager will be creating a checklist for district use when we hire contractors to perform work for our district as well as a standard contract with language relating to prevailing wage requirements and source of funding. Under normal operations we do not hire contractors using federal funds and our ESSER funds have now been totally expended. Anticipated date to complete the corrective action: May 2024

Finding caption: The District did not have adequate controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Nikkie Maceda, External Business Manager, P.O. Box 1389, Soap Lake, WA 98851 (509) 223- 6941 Corrective action the auditee plans to take in response to the finding: For future federal prevailing wage projects, the district will review and update contracts to include language regarding Davis Bacon wages and contractor’s responsibility to file weekly certified payroll. The district will verify the filing of weekly certified payroll reports. Anticipated date to complete the corrective action: May 2024

Education Stabilization Fund – Assistance Listing No. 84.425 Recommendation: CLA recommends the School ensures it documents the underlying support for how allowable payroll expenditures were charged to the program along with approval of that determination. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The School will ensure as they allocate wages to federal programs going forward they will specifically identify the underlying disbursements and document their approval of that allocation. Name of the contact person responsible for corrective action: Abdi Shekh Planned completion date for corrective action plan: June 30, 2024.

Finding Number: 2023-003 – Procurement/Full and open competition Anticipated Completion Date: April 2024 Responsible Contact Person: Jocelyn Lombardozzi Planned Corrective Action: In response to this finding, an analysis of 2023 labor charged to awards was conducted. The results of the analysis revealed that a net amount of $35,238 more could have been charged to the awards which the Company will not pursue charging to the awards. An analysis of labor charged to awards active in the first quarter of 2024 has also been performed to ensure that active awards are being charged according to employee’s actual pay. As of April 1, 2024, the Company has transitioned to a new accounting system. This system is configured to require employees working on sponsored projects to utilize percentage of effort and effort certification functionality for tracking actual time and actual labor costs to awards. Budgeted labor rates are no longer being used as of April 1, 2024.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Okanogan School District No. 105 September 1, 2022 through August 31, 2023 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Klancy Allen, Director of Finance P.O. Box 592 Okanogan, WA 98840 (509) 422-3629 Corrective action the auditee plans to take in response to the finding: The District will implement internal control procedures around the monitoring of third party contract managers in order to facilitate adequate internal controls for ensuring compliance with the federal wage rate requirements in any contracts for future federally funded projects. Anticipated date to complete the corrective action: May 2024

The district does not concur with the audit finding or the $3.5 million of questioned costs. According to FCC bulletin/order #6.16 states “the applicant is not required to perform a new unmet need survey at the time of submitting the request for reimbursement if the applicant already performed a survey at the time of submitting the application.” The district believes the unmet need requirements have been met as outlined: Determining Need: • The district determined its need based on its inventory of devices supporting remote learning and did not have enough RAM to have district and learning platforms operating at the same time. • Students and staff need a District device for safety, installed software for instruction, technical support and equity as explained in above reasoning and attached mobile access for student laptop handbook. • The district conducted a survey that determined that over 6,500 students required devices. Between the survey and the lack of RAM, the district determined that over 12,000 devices were needed to support learning. In addition, the district has no intention of applying for other Emergency Connectivity Funds.

The District made sure the Federal Wage Rate requirements were in the contract as a requirement. The District relied on the contracted Architect to ensure these requirements were followed before the district received the pay application. The District now understands that a designated district program director should receive weekly certified payroll reports to ensure compliance. On the next project that requires Prevailing Wage Rates, the District will make sure to receive weekly certified payroll reports to ensure compliance.

INVOICES: A copy of all invoices will be kept in the cafeteria. An employee of the District will review the invoices for allowable costs

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2022 through June 30, 2023 The finding from the June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through the Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 Special Education Cluster Special Education Grants to States and Special Education Preschool Grants Federal Assistance Listing Numbers, 84.027 and 84.173. COVID-19 Education Stabilization COVID-19 Education Stabilization Federal Assistance Listing Numbers, 84.425, 84.425C, 84.425D, 84.425U, and 84.425W Twenty-First Century Community Learning Centers Twenty-First Century Community Learning Centers Federal Assistance Listing Numbers, 84.287 and 84.287C 2023-001: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with the applicable cost principles. Condition: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management also has not adopted and implemented standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Questioned Costs: None reported. Context: Payroll expenditures charged to the programs are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. This supporting documentation should be standardized and should include all required elements in accordance with Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. The City did not have an adequate system of internal controls in place to provide sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Lack of documented policies, procedures and guidelines in place to ensure compliance with time and effort reporting requirements. Repeat Finding: This matter was reported as a finding for the Title I major program and special education cluster grants in the previous year as finding 2022-001. Recommendation: Management should establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management should also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training should be provided to ensure that the program managers fully understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures will indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and will indicate due dates for when this information must be provided to the school business office. Management will also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training will be provided to ensure that the program managers fully understand the time and effort reporting requirements. Management intends to implement these procedures in fiscal 2024. If the Oversight Agency has questions regarding this plan, please call Michael Pfifferling, Assistant Superintendent of Finance and Operations at 978-374-3400. Sincerely yours, Michael Pfifferling Assistant Superintendent of Finance and Operations City of Haverhill

The District does not concur with the audit finding or the $858,725 of questioned costs. This finding is the same as reported in the 21/22 audit. The District still contends that the costs were allowable. The issues regarding internal controls and reporting were not brought to the District’s attention until 10 months into the 22/23 audit period, leaving no time for discussion or changes in interpretation and process. The audit’s condition states that our internal controls were ineffective for ensuring we requested reimbursement only for students and staff with a documented unmet need and that our internal controls were ineffective for demonstrating per location and per user limitations. Based on guidance from the Federal Communications Commission (excerpted below), the District contends we have spent all funds for allowable costs, that those costs were reasonable and necessary, and for students and staff with unmet needs. Districts were able to determine whether students and staff had unmet needs. For our district this meant addressing instances where students may have shared a home device with other siblings; student or staff devices were too old or slow to function properly when running multiple required applications; and / or student owned devices did not have the appropriate security in place to protect students during remote learning (especially from unauthorized websites). Home drives, where all educational digital resources were stored, couldn’t be accessed unless using a district issued device. Additionally, the district’s technical support could not access personally owned devices to provide for thousands of trouble tickets and support issues students faced during remote learning. Based on these factors, unmet need was defined broadly, but within allowed parameters and inventory records were kept, albeit, not perfectly. Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by the health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. Seattle Public Schools followed guidance from the Federal Communications Commission outlined in a document titled: . “Emergency Connectivity Fund Common Misconceptions”, “Misconception #2: If schools have returned to in-class instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus is eligible for Emergency Connectivity Fund Support.” Additionally, from the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: “We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.” And from question 51: “…we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students…with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.” Finally, SAO did not apply any reasonable measure to reduce questioned costs but did state they know that at least some of the equipment addressed unmet needs, while still choosing to question all costs. That is clearly out of alignment with the FCC guidance. There are no corrective actions to take at this time as the funding source has been exhausted and the timeline has passed.

Recommendation We recommend that the District follow the guidance in NM PED’s PSAB Supplement 13, Purchasing. Management Response Corrective Action: We will work with the District staff to plan and obtain purchase orders before receiving items and/or placing orders. Due Date of Completion: June 30, 2024 Responsible Party(ies): Business Manager

Finding 2023-001 – Internal Control Deficiency Over Activities Allowed or Unallowed and Activities Allowed/Allowable Costs Federal Grantor: Department of Homeland Security; Federal Emergency Management Agency (FEMA) Assistance Listing No.: 97.036, Disaster Grants – Public Assistance (Presidentially Declared Disasters) Award Period of Performance: January 20, 2020 – May 11, 2023 Finding: Management did not consistently retain documentation evidencing the performance of controls to ensure allowable COVID-19 expenses were charged to the program. Corrective Action Plan: All of these deficiencies were related to the selections being more than 36 months old, which is past the current documentation retention policy of PVHMC for non-controlled substances and non-patient records. In order to ensure that documentation is retained for future audits, all FEMA related documentation that is still retained will be kept indefinitely to ensure compliance in future years. Person Responsible: Juli Hester, Chief Financial Officer Estimated Completion Date: May 31, 2024

Finding 2023-003: 2023-003 - Significant Deficiency in Internal Control over Compliance and Noncompliance – Allowable Costs/Cost Principles Contact: Michael Bailey, Chief Financial Officer Corrective Action Plan: The Accounting department at Alaska Behavioral Health has stabilized staffing in accounting personnel, including the replacement of the Chief Financial Officer. Prior to submission of financial reports, the CFO will review and verify that personnel related expenditures are supported by payroll allocation records, and other direct expenditures have adequate documentation associated with the allowable expenditure. Proposed Completion Date: 06/30/2024

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment and restricted purpose requirements. Name, address, and telephone of District contact person: Tim Papendorf, Information Services Supervisor 124 E. Lawrence Street, Mount Vernon, WA 98273 360-428-6110 Corrective action the auditee plans to take in response to the finding: Concern: The district failed to maintain sufficient documentation proving that the equipment provided to students matched their actual unmet needs. Reimbursement was sought based on estimated unmet needs rather than documented, actual unmet needs. Response: The Mount Vernon School District mandates that students use districtassigned devices for remote learning. According to grant training provided to the district, if students are required to use district-owned devices for remote learning, Chromebooks could be distributed to any student who did not have a district-assigned device that meets hardware standards. The standards used to assess the hardware included Chromebooks that were older than four years, unable to support the necessary software and digital learning tools, and devices at their end-of-life stage, meaning they no longer received automatic updates from Google. We assessed our inventory and supplied new Chromebooks to students based on our understanding of their needs. Chromebooks were only provided to students who lacked a device that met our hardware standards. Resolution: During this audit, the district learned that its understanding was inaccurate. However, we are confident our need exceeded our request. In May 2020, Page 71Office of the Washington State Auditor sao.wa.gov as directed by OSPI, the district conducted a survey which revealed that only 38% of our families had access to a device at home suitable for online learning. Given our students in poverty population was 4,365 during the 2022-23 school year, the 1,869 devices for which funding was requested only partially met our overall device needs. This audit has improved our understanding of the requirements related to verifying unmet needs. Moving forward, we will directly contact families and collect signatures to confirm their needs. These records will be attached to student profiles within our asset management system (Destiny) before ECF funded Chromebooks are assigned to them. Concern: Inventory records were incomplete, missing the names of 273 students assigned laptops funded by the ECF, thus failing to fully meet FCC documentation requirements. Response: The district acknowledges challenges related to student device assignment. Staff reductions and changes in our inventory and check-out processes necessitate updates and training, which is ongoing. We are committed to ensuring accurate and timely updates to our records. Resolution: A list of inventory discrepancies has been distributed, and action is being taken to update our records. To strengthen our existing systems, we will implement additional biannual training sessions with our inventory managers. These trainings will cover best practices for record keeping and emphasize the importance of maintaining accurate inventory records. We will conduct monthly audits of our records, and correction requests will be sent to individual sites to promptly address any information inaccuracies. Concern: MVSD lacked documentation to show that it only provided one device per student or location, leading to possible over-issuance of equipment. Response: While the district acknowledges the need to improve its student assignment inventory within Destiny, we have confirmed that only one device is assigned per student through the use of our additional inventory system (Google Workspace). Resolution: The district will enhance its inventory practices and explore additional redundancies to ensure effective contingencies if future data issues arise. Anticipated date to complete the corrective action: ● Unmet Needs Documentation: May 31, 2024 ● Inventory Update: June 20th, 2024 ● Staff Training: June 20th, 2024 (Ongoing)

Federal Agencies: U.S. Department of Homeland Security Assistance Listing No.: 97.036 COVID-19 Disaster Grants – Public Assistance Award Period of Performance: March 25, 2020 to July 01, 2022 Corrective Action Planned: Management agrees that evidence of our internal determination that certain expenses incurred for the Medline Spot Buy program was not fully documented. The Medline Spot Buy program was used as a guarantee of delivery of Personal Protection Equipment (PPE) which was in short supply during the initial stages of the Covid pandemic. These purchases were subsequently charged to the FEMA COVID grant, reviewed, and properly reimbursed to Driscoll through that grant by FEMA. Although evidence of review was not retained for the purchases through this program, management believes that adequate review was conducted in the decision to charge these costs to the grant. As it relates to the Medline Spot Buy program, Driscoll Children’s Hospital took part in the program to ensure that the Hospital was adequately stocked with necessary PPE during the COVID pandemic. This program allowed for rapid purchasing and delivery of PPE. Orders were submitted for the program by uploading a spreadsheet to Medline. This ordering process resulted in these purchases bypassing the normal purchase order approval structure. These expenses were correctly charged to the FEMA grant and their appropriateness is not in question. We have reviewed our processes related to the retention of evidence of expense review to improve audit evidence should this program ever be awarded in future periods. We will keep minutes of meetings documenting committee approval for these invoices and/or other documentation that clearly shows our internal review and decision tree. Responsible party: Steve King, CFO Implementation Date: Procedures were reviewed along with the finalization of the FY23 Uniform Guidance audit in May 2024.

The Northeast Texas Public Health District (NET Health) will take steps to ensure overall effective grant monitoring and to increase communications between NET Health Grant Managers and the Chief Financial Officer and Chief Executive Officer. The NET Health Leadership Team will discuss any issues during our weekly Leadership Team meetings to ensure compliance. These weekly meetings will address costs expended within the grant parameters and ensure grant funds will be more evenly expended during the year as appropriate. NET Heatlh will continue to develop effective methods of grant oversight as it finds weaknesses in its processes. To ensure compliance with the period of performance requirements, NET Health will change its processes effectively immediately. Going forward checks will only be prepared, dated, signed, and mailed to vendors after work is completed or items are received. There will be enhanced internal controls by establishing procedures to monitor and ensure timely payment of accrued expenditures, such as regularly accounting for any outstanding checks and actively communicating with vendors on performance requirements. In addition, we will enhance communication and coordination among relevant departments to expedite the payment process while maintaining compliance with grant regulations. George T. Roberts, CEO, and Lawanda Owens, CFO, are the persons responsible for this action plan going forward. NET Health is expected to have this action plan implemented by May 1, 2024.

At this time, the Foundation can confirm all employees have rate of pay documentation in their employee files. The Foundation is working to adopt stronger policies around contractors engaged with the organization with oversight to contractors’ pay provided by the staffed CEO.

Christopher M. Sandini, Sr. Director of Finance / Comptroller Phone: (508) 553-4864 E-mail: csandini@franklinma.gov Thursday, April 11, 2024 RE: 2023-001 Improvement Time and Effort Documentation Planned Corrective Action Plan For each employee being charged to a Federal Grant, time and effort documentation for that employee will be maintained that shows their name, school, position, percentage (FTE) charged to the grant, the grant name, the school year and the grant period. It will be signed by both the employee and their supervisor. Anticipated Completion Date: 4/11/24 Sincerely, Christopher M. Sandini, Sr. Director of Finance / Comptroller

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum School District No. 200 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate controls for ensuring compliance with federal requirements for allowable costs and cost principles Name, address, and telephone of District contact person: Sue Ellyson, Business Manager P.O. Box 398 Cathlamet, WA 98612 (360) 795-3971 Corrective action the auditee plans to take in response to the finding: The District will be more prompt in requesting refunds. Anticipated date to complete the corrective action: The refund was requested 3/1/24 and received 3/15/24.

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Andrea Cooper 2689 Hoover Ave SE Port Orchard, WA 98366 360-874-7015 Corrective action the auditee plans to take in response to the finding: The District was compliant with federal wage rates and will ensure that all public works projects funded with federal funds have appropriate contract language included in order to comply with all federal wage rate requirements. Anticipated date to complete the corrective action: Immediately.

The Chief Executive Officer (CEO) and LANWT accounting department will review and train on 45 CFR 1631 regarding the subject of Purchasing and Property Management. LANWT will review its policies and protocols to require prior purchase approval and exigent circumstances approval. Deadlines shall be calendared by the CEO and the accounting department whenever there is an exigent circumstance and approval will need to be requested within the 30-day notice period. The CEO will remain in periodic contact with LSC if any extenuating circumstances exist. The accounting manual will be updated with this protocol. Date of Completion: June 1, 2024 Person Responsible to Ensure Completion: Maria Thomas-Jones, CEO

LAEP encountered significant delay in the implementation of the new payroll processing software, hence, this repeat finding. LAEP has since transitioned from Gusto to Paylocity effective its March 30th, 2023 payroll. This new system has automated the process of tracking approvals and real time audit trail. LAEP encountered a significant delay in implementing salary allocations with proper documentation support within the software due to finance staff transitions in the organization. LAEP will be contracting a consultant to assist in the implementation of salary allocations within the software.

Finding #2023-001 – Material Weakness and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-02-02, Contract year: 08/27/22 – 08/26/23, Contract #NAVCA210403-03-00, Contract year: 08/27/23 – 08/26/24. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPS, Contract year: 09/01/22 – 08/31/23, Contract #HHS000539700204 YPU, Contract year: 09/01/22 – 08/31/23. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain costs are impacted as they are charged to the program based on the direct salary percentages. Repeat of finding #2022-001. Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Planned corrective action: Salaries and wages charged to the grant will be based on actual work performed determined by hours submitted by employee and approved by the applicable supervisor. Policies and procedures have been updated to include this required process to ensure that the allocation methodology used to allocate costs between programs reflect the actual relative benefit to the grant. Training will be provided to program and accounting staff to review the updated policies and procedures and to ensure implementation is complete. Responsible officer: Angelica Castillo, CFO. Estimated completion date: June 1, 2024.