Corrective Action Plans

National Park Service Conservation, Protection, outreach, and Education – Assistance Listing No. 15.954 and Research and Development Cluster – Assistance Listing No. 15.608 and 15.945 Recommendation: We recommend management incorporate review control procedures to ensure the 10 percent de minimis rate is properly applied in accordance with UG and ensure appropriate costs are charged to the awards consistent with their federally approved budgets. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Upon conducting the FY21 audit TAS was informed that the inclusion of the Biological Expertise line item on federal budgets (approx. 7.5% additional uplift) was not allowable as it was currently being calculated. TAS is allowed a 10% de minimus rate on noted FY21 Federal awards some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimus rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation. Moving forward TAS will be billing the de minimus rate (10%) as a percentage and will calculate the Biological Expertise line item as an hourly rate. Name(s) of the contact person(s) responsible for corrective action: Kim Lopez, Director of Finance & Operations Planned completion date for corrective action plan: effective immediately / in progress

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

Management and accounting personnel will create procedures to ensure that direct cost is charged at the actual amounts incurred and will develop a payroll cost allocation and allocable direct cost allocation methodology that ensures costs are charged in compliance with the applicable federal costs principles.

Contact person(s) responsible: Executive Director Vanessa Timmons; Associate Director Keri Moran Kuhn; Accounting Manager Linda Koonce. Corrective action planned: OCADSV added an Administrative Cost Center to its General Ledger effective 10-01-22, the beginning of FY23, and began costing administrative payroll costs to that cost center. Additionally, the organization re-trained administrative staff on direct cost-allowable activities vs. administrative activities relative to timekeeping and timesheet preparation and the necessity of daily work descriptions supporting the hourly allocation. The payroll policy that requires supervisors to review and sign off on timesheets and hourly allocations to cost centers was also reviewed. OCADSV is developing a formal cost allocation plan to recover direct and indirect costs using the 10% de minimis of Modified Total Direct Cost. The allocation will be applied monthly and incorporated into the annual budgeting process. Anticipated completion date: Effective 6-21-23 and ongoing

Contact person(s) responsible: Executive Director Vanessa Timmons, Associate Director Keri Moran-Kuhn Corrective Action planned: OCADSV will ensure that all future federal subawards will contain the information required by CFR §200.332. All contracts, sub-grantees, and MOU’s, will include information required. Anticipated completion date: Effective 6-1-2023 and ongoing

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton