Corrective Action Plans

Exempt employees will enter time into their timesheet every payroll and supervisors will approve the timesheet.

Our Agency has included activities as a joint force’s initiative with other agencies and entities in an outreach task. We have been authorized to use the distribution waiver of percentages to have a better or bigger span for our youth populations. We also signed a memorandum of understanding with attractive entities like the PR National Guard and have planned activities reaching youth from school programs to communities without school youths. Our alliances with DDEC, Azore and the Department of Education will contribute to an increase in youth program expenses. We have strategically created an initiative that targets in-school youths where we’ll provide workshops focused on elevating their skills and creating real-time experiences. The memorandum we have with the Department of Education has facilitated this strategy. The Individual Training account (ITA) program will also be promoted in our school district to identify candidates with barriers that can be served through our program. As part of our outreach strategy, we plan to visit foster homes alongside the Department of the Family, which we have signed a memorandum to target this group of disadvantaged youths, as well as projects we have signed with the vocational schools in our district providing real time and paid work experience. With the nine municipalities comprising our area will develop summer work experience targeting our in-and-out school youth (TSY, OSY) populations. The estimated expenses for these initiatives, based on last year's outcome, will reach the goal parameters of programs under WIOA Act. IMPLEMENTATION DATE June 2025 RESPONSIBLE PERSONS Budget Director, Executive Director, Directors of Programmatic and Operations

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Year – May 31, 2024 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Corrective Action Plan Corrective Action Planned: {The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring. Identify the specific actions to be taken to eliminate or mitigate the recurrence of the finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Kemia Himon, Financial Aid Director Anticipated Completion Date: 3.3.25

MENT OF HEALTH AND HUMAN SERVICES 2024-002 Period of Performance Block Grants for Community Mental Health Services – ALN 93.958 Condition: Expenses incurred in fiscal year 2023 were included as expenses to the federal program in fiscal year 2024. Recommendation: We recommend the organization enhance its internal controls to ensure expenses for the correct grant period are charged to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will enhance its internal controls to ensure expenses for the correct grant are charged to the federal program properly. Name of the contact person responsible for corrective action: Michelle Glines, Chief Financial Officer Planned completion date for corrective action plan: 6/30/2025

In order to strengthen internal controls, the School District will train the staff responsible for reimbursement requests, final reports, and amendments as well as those responsible for purchasing for the grant to ensure that there is proper supporting documentation and grant management. The training will include but is not limited to: NJ Finance law, good business practice, as well as a review of the purchasing manual. After this training in completed, the business office will be responsible for the review of reimbursement requests, final reports, amendments and purchases, prior to completion and submission to ensure compliance with the grant requirements and purchasing laws.

Finding 2024-002 Federal Agency Name: Department of Education Assistance Listing Number: #84.268 Program Name: Federal Direct Student Loans Finding Summary: 1 of the 60 students selected for testing the reporting of student status changes were reported with the incorrect enrollment status based on NSLDS Enrollment Reporting guidance. 3 of the 60 students selected for testing the reporting of student status changes were reported to NSLDS with incorrect program begin dates based on NSLDS Enrollment Reporting guidance. 1 of the 60 students selected for testing the reporting of student status changes were reported to NSLDS with an incorrect status effective date based on NSLDS Enrollment Reporting guidance. Corrective Action Plan: LATC currently runs a SQL database script against the enrollment file before sending it to NSC. This script checks for missing and erroneous data (race/ethnicity, nondegree seeking majors, anticipated grad dates, etc.) in the file and updates it to correct values. The Director of Enrollment will work with the Database Administrator to regularly update these tables and review to ensure accurate information is being imported. The Registrar’s office will manually investigate these records and (if necessary) updated before sending the file to NSC. Every 30 days, representatives from the Financial Aid and the Registrar’s departments will pull 10 randomly selected student files to compare information in National Student Clearinghouse, PowerFaids, and NSLDS. The Director of Enrollment will work the error reports that the National Student Clearinghouse sends to LATC after every enrollment file upload with the assistance of the Database Administrator to ensure data submitted is compliant with DOE regulations. The Director of Financial Aid will review NSLDS to ensure corrections submitted by the Director of Enrollment are being properly recorded. Responsible Individual(s): Eric Schultz, Director of Enrollment and Kayla Bossly, Director of Financial Aid Anticipated Completion Date: Corrections complete by December 31, 2024. New process is ongoing.

2024-003 Segregation of Duties: Internal Control Finding - Allowable costs and related activities made electronically were made without documented approval in 3 out of 51 transactions. Corrective Action Plan – Internal controls over electronic payments have been established and documented to ensure appropriate segregation of duties. Ginny Willey, Human Resource Director, will verify the invoice tied to the ACH Disbursement matches the bank statement each month, and initial the bank statement and invoice once this is verified. Documentation of this approval will be maintained with the invoice and bank statement. Implementation Date of Corrective Action Plan - January 5, 2024

Finding No. 2024-003: Grant Tracking Responsible Individuals: Trista Olney, Business Manager Corrective Action Plan: The District will make efforts to accurately track and present grant funding to ensure only expenditures actually incurred during the reporting period and period of performance are reported. Anticipated Completion Date: Current fiscal year

Condition: The Organization lacked sufficient controls to ensure consistent reviews/approvals of monthly reimbursement requests and tenant rent calculations throughout the year. Planned Corrective Action: - The Rent Analyst will complete the rent calculations and sign off. - The Director of Accounting will review and approve the checklist in writing. Contact person responsible for corrective action: The Director of Accounting will oversee all rent calculations. Anticipated Completion Date: Effective 01-13-2025.

Management's Response: Management concurs with the above finding and will ensure that human resources, fiscal services and Title Ill all have proper approvals, budgets and written authorization of anything that deviates from the approved budget. The corrective action will be implemented immediately and completed by June 2025.

The audit identified that inaccurate program start dates were recorded due to poor report programming and the absence of clear internal policies governing the program date. The root cause of this issue appears to be poor report programming practices, compounded by a lack of a well-defined internal policy to guide the accurate reporting of program start dates. In response to the finding, the NSC enrollment report has been rewritten with improved programming and internal quality control measures. A more robust process is being implemented to ensure data accuracy moving forward. The new report will be in place for Spring 2025. By addressing both the technical and procedural gaps, Palomar College will enhance the accuracy of program start dates and ensure better alignment with NSC reporting requirements.

During fiscal year 2024, the College had two grant awards with Natural Resources Conservation Services (NRCS). The first grant award was from September 1, 2022 through August 31, 2023. The second grant award was from the date of final contract signature which was September 29, 2023 through September 21, 2028. Due to the gap period between contracts, the September 2023 NRCS general ledger was cleared of any expenses. A grant program staff member attended a training in August 2023 and submitted for travel reimbursement in October 2023. Grant program staff members attended a conference in September 2023 and the registration fees were paid in October 2023. The travel reimbursement, conference registration fees and corresponding indirect costs were included in the October 2023 financial report submitted to NRCS for reimbursement. Once the error was discovered, the expenses were removed from the NRCS general ledger and charged to an ·appro pri at e account. An adjustment was made to reduce the expenses on the October 2024 financial report submitted to NRCS. The college recognizes the importance of proper reporting for financial reports and reimbursement requests and that those reports should only include costs that are incurred during the grant period. The grant finance team will work with grant program staff to implement a schedule that will help to ensure that goods, services and travel are completed during the grant term, that invoices are submitted in a timely manner and prior to grant end, and when possible, payment will be made for said items prior to the end of the grant term. The grant finance team will review expenses incurred during the grant term and immediately following the grant term to confirm expenses are being reported in the correct period for financial reporting and reimbursement requests. Person(s) Responsible: Carrie Patton, Jen Evans Timing for Implementation: Immediate

CORRECTIVE ACTION PLAN: Staff transitions in Financial Aid and the Enrollment Center at the onset of the Fall 2023 term contributed to the later-than-usual submission/certification of First of Term enrollment reporting. Financial Aid and the Enrollment Center experienced staff shortages with resignations and leave. The initial fall enrollment (First of Term) was certified by the Institution and submitted to the National Student Clearinghouse (NSC) on October 18, 2024 within 60 days of the start of the term on August 21, 2023, but the National Student Loan Data Systems (NSLDS) did not receive the submission within the 60-day requirement. Although we anticipate this to be a one-time incident, to prevent any recurrence and ensure enrollment changes are reported to NSLDS within 60 days, Financial Aid provided additional staff training in the Enrollment Submission process, and Early Registration enrollment submissions will be submitted within the first week of classes with the First of Term enrollment submission sent during the third week of classes. Financial Aid also updated the Institution’s NSLDS profile to ensure that records submitted for NSLDS Transfer Monitoring and Financial Aid History are added to the Enrollment Roster submitted to NSC. Financial Aid and the Registrar established an updated policy to ensure that Financial Aid is informed of students who graduate after the graduation process runs each term. After that, the Registrar will report late graduations to the National Student Loan Data System (NSLDS) via the National Student Clearinghouse (NSC). Financial Aid updated the student in question’s graduation status in NSLDS. Person(s) Responsible: Angela Weaver Timing for Implementation: Immediate

Federal Program, Assistance Listing Number and Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Condition: Original Finding Description - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days from the end of the grant period and certain costs were liquidated after 60 days. Contact Person Responsible for Corrective Action / Anticipated Completion Date - Regina Greear, Terri Daniels, Denise Fair; Anticipated completion date: June 2025 Planned Corrective Action - The City has ongoing efforts to implement enhanced processes over the final review of invoices to address timing related to the liquidation requirement.

CORRECTIVE ACTION PLAN December 11, 2024 Southwestern Virginia Transit Management Company (SVTMC) respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs (the "Schedule “) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS- FINANCIAL STATEMENT AUDIT 2024-001: Segregation of Duties and Management Oversight (Material Weakness) Condition: Due to staff turnover, duties handled by the Director of Finance included incompatible duties during the year under audit such as: collection of cash, post receipts to general ledger, and prepare bank deposit slips. ln addition, the Inventory Manager has access both to physical inventory and to the inventory tracking system. Criteria: A fundamental concept of internal controls is the separation of duties. No one employee should have access to both physical assets and the related accounting records, or to all phases of a transaction. ln addition, all significant transactions and controls should involve reconciliations and supervisory, or management level, reviews of those processes. An effective and timely review process is intended to prevent and detect both fraud and errors. Cause: Turnover in key positions can result in individuals performing duties that are not appropriately segregated. In addition, turnover can also create challenges in the oversight or review function. Effect: Internal controls are designed to safeguard assets and detect losses from employees dishonesty or error. Recommendation: Steps should be taken to eliminate conflicting duties and implement compensating controls, where possible. Corrective Action: Although turnover in key positions increased the need for staff to undertake incompatible duties, small staff sizes will likely perpetuate the need for the Director of Finance and Inventory Manager to occasionally perform duties which would be ideally segregated. To help alleviate the risks involved, management will develop additional compensating controls around these activities, including working with system vendors to identify activity logging capabilities and additional reports for periodic review by management. 2024-002: Grant Management and Operating Assistance (Material Weakness) Condition: During 2024, various functions related to financial management were not performed timely resulting in difficulties and delays in completion of the annual audit. Additionally, the untimely nature of grant reconciliations and drawdowns has led to significant cash and grant management issues. Criteria: Internal controls related to financial management should be designed to ensure timely reconciliations are performed, including submission of reimbursement requests and reconciling grant and local revenue. Cause: Turnover in financial positions and increased levels of federal and state grant usage caused significant delays in performance of and reduction in effectiveness of certain financial duties. Effect: Untimely drawdowns could result in vendors not being paid timely, result in cash shortages, and inability to pay payroll. Recommendation: We recommend that the Company establish financial management procedures to ensure that timely reconciliations and submissions of reimbursement requests. We would recommend these procedures be performed monthly and include tracking and reconciling grant activity by type (federal, state, and local). Corrective Action: The Interim Director of Finance and Accounting Supervisor are currently reviewing operating procedures and implementing methods to streamline work and eliminate duplicate activity. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. Additionally, detailed spreadsheets tracking grant activity have been developed, which will allow staff members to better monitor reimbursement requests and ensure vendors are paid timely moving forward. 2024-003: Bank Reconciliations (Material Weakness) Condition: Monthly bank reconciliations were not prepared by an accountant and reviewed and approved by a supervisor in a timely manner. Criteria: Monthly bank reconciliations should be performed by the 15th of the next month. Cause: Staff shortage and lack of cash flow management. Effect: Poor cash flow management resulting in vendor and contractor invoices not being paid timely. Recommendation: We recommend bank reconciliations be prepared by an accountant and reviewed by a supervisor to ensure unreconciled or unusual items, or other matters noted in the reconciliation, are detected and addressed in a timely manner. Corrective Action: The Interim Director of Finance and Accounting Supervisor are currently reviewing operating procedures and implementing methods to streamline work and eliminate duplicate activity. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. Currently, the Interim Director of Finance is preparing all company bank reconciliations. 2024-004: Trade Receivables and Revenue- Billing (Material Weakness) Condition: There were multiple customer accounts that were not billed throughout the year as services were provided by the Company. Criteria: Customers should be billed in a timely manner after being provided with services by the Company. Cause: Staff shortage, lack of revenue cycle oversight, and lack of cash flow management. Effect: Poor revenue cycle management, leading to customers not being billed. This leads to cash shortages from operations and a further reliance on grant funding for operations. This could also lead to the Company being unable to collect billed balances, as certain customers were hit with substantial bills when invoices were caught up in June 2024. Recommendation: We recommend billing customers for services rendered in a timely manner to improve cash flow and prevent collection issues. Corrective Action: Management is working to fill vacant Finance positions, including Accounts Receivable Associate. Until that time, the Interim Director of Finance has taken over responsibility for both advertising and operating billings. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2024-005: Federal Transit Cluster - AL# 20.507, Cash Management - Material Noncompliance/Material Weakness in Controls over Compliance Condition: A lack of cash flow and grant management oversight resulted in contractors and vendors not being paid timely during FY2024 . We noted 14 instances where contractors and vendors were not paid for over 30 days. We also noted four vendors were not paid for over 90 days. Criteria: All grant activities should include management level oversight to ensure timeliness, accuracy, and compliance with specified grant requirements. Cause: Lack of proactive cash flow and grant management occurred when invoices were received. Effect: Multiple contractors and vendors were not paid for over 30 days after receipt of invoice. Four vendors were not paid for over 90 days. Recommendation: A designated management level individual should have oversight to require timely drawdowns of capital grants and timely payment of invoices. Corrective Action: Issues with the implementation of new Federal and Commonwealth transportation grant portals hindered staff from being able to submit grant draw requests in a timely manner. Management is addressing these issues as they arise. The Interim Director of Finance and Accounting Supervisor are currently reviewing operating procedures and implementing methods to streamline work and eliminate duplicate activity. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. Additionally, detailed spreadsheets tracking grant activity have been developed, which will allow staff members to better monitor reimbursement requests and ensure vendors are paid timely moving forward. 2024-006: Federal Transit Cluster - AL# 20.507, Period of Performance - Significant Deficiency, Controls over Compliance Condition: There were numerous grants awarded to the Company that had award end dates prior to June 30, 2024, that had not been appropriately closed out at year-end. Criteria: All grants that are not active should be closed out within the grant awards management system after their award end date. Cause: Lack of proactive cash flow and grant management. Effect: Out of 18 federal grant awards tested, 6 had award end dates prior to June 30, 2024. All 6 were still marked as active in the grant award management system as of June 30, 2024, with total remaining funds on these awards totaling $673,179. Two of these grant awards had award beginning dates over 15 years old, had no activity during FY2024, and had not been closed out by June 30, 2024. Recommendation: A designated management level individual should close out all grant awards whose period of performance has expired within the grants management system. Corrective Action: Five FTA grants are in Active Award/Ready for Closeout (as of August 1 3, 2024), including VA-202 1- 038-01, YA- 2016-009-0 1, VA-202 1- 037-01, YA-2016-016-01 and YA-04-0027-01. Additionally, an inquiry was sent to the FTA on August 19, 2024, on what could be done with the remaining funds in VA-2019-018. Grant VA-2023-002- 00 has experienced delays due to the all-electric vehicle demand and supply chain issues. GRTC has been in communications with the FTA regarding this situation. All other active FTA grants have end of performance dates in 2025. 2024-007: Federal Transit Cluster - AL# 20.507, Procurement - Finding, Non-material Non-compliance Condition: As award recipients of Federal Transit Administration (FTA) funds, the Company is required to include certain clauses in contracts funded by FTA funds. We noted that the Company did not include the required " prohibition on certain telecommunications and video surveillance services or equipment" clause and the " notification of legal matters " clause as required clauses in their procurement manual and did not contain these clauses in one contract tested. Criteria: The FTA mandates that contracts funded with FTA awards must contain certain clauses related to prohibited vendors under the Code of Federal Regulations section 200.216 and requires contractors to notify the Company and the FTA of any current legal matters. Cause: Lack of compliance with FTA contract regulations. Effect: Contracts do not meet FTA contract regulations and are non-compliant. Recommendation: We recommend that the Company incorporate these required FTA clauses in their procurement manual and their standard contracts to properly incorporate in any future FTA funded contracts. Corrective Action: Missing FTA clauses will be addressed via revisions / updates to all of GRTC ' s solicitation and contract templates. As templates can often be edited by mistake, another tool to proof contracts is the " FTA Clause Matrix 2023 Applicability of Third-Party Contract Provisions" . The current version of this matrix includes provision from 2 CFR 200, Master Agreement 30 (FY 23) and Circular 4220.1 F. Procurement received this matrix during an NTI Procurement 101 training course December 2023. Referencing this matrix has been added as a step in project checklists. If the Federal Audit Clearinghouse has questions regarding this plan, please call Kevin Price , General Manager at 540-982-0305. Sincerely Kevin Price General Manager

Finding #2024-001 – Program Income Contact – Suzanne Tobin, Chief Financial Officer Telephone Number – (301)-832-3810 Completion Date – December 10, 2024 Corrective Action Plan: Effective immediately, the Organization will comply with the program income compliance requirement of the U.S. Department of Housing and Urban Development (HUD) Continuum of Care Program by netting program income generated from the pass-through grant to the amount to be reimbursed prior to submitting the reimbursement request to HUD, in accordance with the protocol outlined in the manual issued by the Behavioral Health Authority (BHA).

Cash Management Management agrees with the finding and the auditor's recommendation. There was confusion at the time of this agreement as the nature of the work was in line with providing institutional services rather than a federal grant agreement. This led to a misunderstanding of cash management requirements due to the nature of the award. Mass General Brigham (MGB) has removed the $215K of questioned costs from the Schedule of Expenditures of Federal Awards (SEFA). The funding will be returned to Advanced Regenerative Manufacturing Institute, Inc. in January 2025. Additionally, management will review the limited instances where departments have been previously approved to request federal cash. This review is to confirm that an exception to the standard practice of managing this through the central Research Finance team is appropriate. Based on results of this review, to be completed by March 2025, management will determine criteria and prior approval requirements for departments to request federal cash if MGB concludes this practice will continue on a limited exception basis. The review will be conducted with oversight by the MGB Vice President of Research Management and Research Finance and the MGB Research Controller.

The District's management will evaluate the grant monitoring process and ensure all reporting for federal grant requirements is accurate, with a planned implementation date by the Financial Officer of December 13, 2024.

We will review the respective requirements to evaluate and determine the most efficient and effective solution to ensure all required reports are prepared, reviewed, and submitted within the COVID-19 State and Local Fiscal Recovery program’s required timeframes, and with the correct amounts.

New York State Education Department’s Adult Career and Continuing Education Services-Vocational Rehabilitation (ACCES-VR) will update RSA 911 Reporting Data Validation policies and procedures. This updated policy and procedure will address the input of information provided through supporting documentation, the storing of supporting documents and review protocols of the RSA 911 data elements.

New York State Education Department will update the payment processing procedures and provide training to staff involved in preparing or processing payment forms to understand the appropriate application of cost centers to align with the Period of Performance for Federal awards, including the VR grant. Additional controls will be explored to ensure that the accounting details on the payment form are accurate and entered correctly into the Statewide Financial System.

Response to Finding 2024-002 Federal Award Agency: Department of the Treasury Name of Contact Person: Marat Saks, Chief Financial Officer Views of Responsible Officials: The housing authority’s property management company attempted to submit proposed 2023-2024 budgets and financial reports including form RD 3560-7 within the proscribed timeframe but encountered technical issues relating utility allowances. After an initial attempt to remediate the technical issue with RD, the property management company failed to submit the proposed budget. Corrective Action: 1. The housing authority is in the process of transitioning to a new property management company which will have better technical resources to resolve similar issues. Furthermore, the housing authority will institute a checklist with the new property management company which will include submission of the annual proposed budget and financial reports which will be reviewed by the housing authority for compliance. Date of Planned Corrective Action: Immediately following being notified of this finding.

The Housing Authority of the Town of Carrollton, Missouri, is a small PHA defined by HUD and lacks in segregation of duties for Internal Control. The Director has developed a spreadsheet to track obligation dates, amounts, contracts, and expenses to justify the amount obligated each month in the system.

Finding 2024-001 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance Federal Grantor: United States Department of Homeland Security Assistance Listing No.: Assistance Listing 97.036, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Indiana Department of Homeland Security Federal Award Period of Performance: March 1, 2020 – May 11, 2023 A material weakness was identified related to internal controls over payroll expenses charged to FEMA funds, subject to the Uniform Guidance (UG) audit. This guidance requires internal controls to comply with the terms of the federal award as well as with the "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control—Integrated Framework" issued by COSO. The finding was a compliance matter and did not result in any questioned costs. Community Foundation of Northwest Indiana, Inc. and Subsidiaries (CFNI) acknowledges the finding related to the lack of documented review and approval of all timecards for payroll expenses charged to federally funded programs. In line with industry standards, CFNI prioritizes timely payroll processing and does not delay payroll for outstanding timecard approvals. While this is not a recurring issue and did not result in any questioned costs, CFNI recognizes the importance of ensuring compliance with all federal requirements. To address this finding and prevent recurrence, CFNI is implementing a comprehensive policy that mandates timely review and approval of all timecards associated with payroll expenses charged to federal grants. Additionally, CFNI is establishing a formal process to monitor adherence to this policy, including regular audits and detailed documentation of the review process. CFNI is committed to strengthening internal controls, improving oversight, and ensuring full compliance with federal grant requirements. Responsible Official: Pamela Pokropinski, VP Finance Status of finding: Completion expected June 2025

We recommend the Agency review its cost transfers procedures and implement additional procedures to monitor federal awards period of performance.There is no disagreement with the audit finding. The Agency agrees that additional cost transfer procedures are needed to ensure expenses incurred against an award fall within the award period of performance, but believes there are adequate procedures in place to monitor the actual award period of performance. Starting immediately, Grants will implement procedures to review expenses moved into projects via the Manual Transaction process (Also referred to as Miscellaneous Transaction) to ensure the expenses fall within the award period of performance. See updated procedure: Miscellaneous Transaction Procedures. To further mitigate the chance of this issue occurring, grants will minimize the transfer of labor costs to new awards if a project goes over budget. Instead, Grants will return the expenses back to the cost center. Grants has also been working with IT to put controls in our time keeping system, Kronos that would minimize the chance of labor expenses for over budget projects to be processed into Oracle.