Corrective Action Plans

2025-003 The District will implement procedures to ensure all expenditures are for allowable purposes prior to disbursement. 6/30/2026 Holly Skulich, Treasurer

Management engaged an external HR consultant to assist with revising the Accounting Policy Manual to formally document written policies and procedures related to compensation and fringe benefits. Draft policies have been developed and are currently under management review for accuracy and alignment with existing practices. The finalized policies will be presented for Board approval and implemented by March 18, 2026, and responsibility for ongoing monitoring and periodic review has been assigned to the Chief Financial Officer and Director of Administration to ensure continued compliance. Training will be provided to applicable staff, and compliance with the updated policies will be incorporated into management’s periodic internal reviews.

Planned Corrective Action: Our payroll system provider corrected the backend setting to prevent employees from adjusting their timecards after they have been approved and locked. We reviewed and confirmed that the system is now functioning as intended to prevent similar issues in the future. We deducted the overage amount from the November 2025 invoice to reimburse the agency in full. Anticipated Completion Date 11/17/2025 & 12/31/2025. Responsible Contact Person: Katherine Page, Director of Finance

Significant Deficiency in Internal Controls over Compliance for Allowable Costs/Cost Principles Finding Summary: The Organization did not maintain documentation to support payroll timesheet approvals. Responsible Individuals: Danielle Smith, Executive Director Corrective Action Plan: Payroll procedures will be updated to incorporate this process and the Organization will maintain documentation of payroll timecard approval to support payroll amounts allocated to the federal award. Anticipated Completion Date: June 2026

Finding 2025-001 Allowable Costs/Cost Principles (Material Weakness) Condition: Compensation – personal services: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or the actual time spent was used as a basis for allocating personnel charges to the grant before payroll period ending February 28, 2025. Correction Action Planned: • Effective March 1, 2025, each location used a time sheet for tracking actual hours worked on grants. This time sheet includes all grants that the employee worked on and non-grant time. The time sheet is signed by the employee and reviewed and approved by the employee’s supervisor ensuring time spent on grant is accurately recorded. • The People & Operations Manager retains completed time sheets together with other expenditure support for grant reimbursement. The contract accountants review the actual salary expense against initial budgeted grant expense and make necessary adjustments to charges to reflect accurate salary expense for each grant. The Controller or Principal from the contract accounting firm reviews and approves grant accounting adjustments prior to completion of changes. Completion Date: March 1, 2025 Name of Contact Person Responsible for the Plan: Nuwan Samaraweera, COO

2025-001 – Direct Costs-Compensation Grantor: Centers for Disease Control and Prevention - Aids Activity and Coordinating Office (AACO), National Institute of Health Award Name: High Impact HIV Prevention and Surveillance Programs, Research and Development Assistance Listing Number: 93.940, 93.838 Assistance Listing Title: HIV Prevention Activities Health Department Based, Lung Diseases Award Year: July 1, 2024 to June 30, 2025 Award Numbers: CP4043 and CP5043 (2220536), 1OT2HL161847-01 Management’s Views and Corrective Action Plan Management acknowledges the finding related to delayed effort report certification. We recognize the importance of timely and accurate effort reporting as well as ensuring compliance with federal and institutional requirements. Children’s Hospital of Philadelphia Research Institute has implemented a new Effort Compensation Compliance system for effective July 1, 2025. This new system will enhance monitoring of timely effort certifications through automated reminders and greater transparency. With this implementation, training and reference materials will be provided to all personnel involved in effort reporting to ensure they understand the importance of timely certification and the potential impact of delays on grant compliance.

Finding 2025-011 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll) Repeat Finding: No Auditee’s Corrective Action Plan: MOED follows the standard process and employees’ clock in/out at timeclock or enter their time; prior to pay period close, that time is reviewed and approved as required. MOED currently runs a report named "Audit TT - Workers with Time Submitted but Not Approved" two hours prior to the final payroll submission deadline to identify timesheets that have been submitted by employees but not yet approved as of the morning following the close of the payroll period. MOED HR will run the “Audit TT - Workers with Time Submitted but Not Approved” report 30 minutes prior to the payroll submission deadline and will ensure that all timesheets are reviewed and approved by supervisors prior to final payroll processing. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: March 31, 2026

Finding: 2025-001 Condition Found: During testing of payroll allocated to the federal program, 1 of the 25 employees tested had salary charges which exceeded the Executive Level II compensation cap. Upon further review of the full population, a total of 3 employees were identified whose salary charges to the federal program exceeded the cap. Individual(s) Responsible for Corrective Action: Elizabeth Clark, Director of Finance Planned Corrective Action: Upon review of the salary allocation template, we found that the individuals whose salaries exceeded the Executive Level II compensation cap were allocated to grants without the application of appropriate proration. The result was that excess amounts could have been applied to grants in error. To identify and correct these errors, we will look back 12 months at all salaries charged against any grant that is funded directly or indirectly by federal funds. If any salaries in excess of the Executive Level II compensation cap were charged, we will reverse that charge and substitute another qualifying employee salary in its place. The procedure for allocating salaries to grants will be modified to include instructions to exclude employees with salaries exceeding the cap from grant allocations. Anticipated Completion Date: February 15, 2026

Criteria or Specific Requirement: Subparts D and E of 2 CFR Part 200 require a nonfederal entity to establish written policies, procedures, and standards of conduct, including procedures to implement the cash management requirements of 2 CFR section 200.305, procedures that comply with the procurement standards of 2 CFR sections 200.318 through 200.326, and procedures for determining the allowability of costs in accordance with Subpart E of 2 CFR Part 200. Specifically, 2 CFR sections 200.430, 200.431, and 200.475 require written policies concerning compensation for personal services, fringe benefits, and travel costs, respectively. Views from Responsible Officials: Management agrees with the finding. Management has established written policies and procedures after yearend that were the policies and procedures followed during the year under audit and meets the requirements of Subparts D and E of 2 CFR Part 200. Contact Person: John Jacques Date of Completion: November 14, 2025

Contact Person David Drapeaux Corrective Action Plan This finding was resolved in FY2025 through a joint agreement between the District and NDDPI. The questioned costs of $86,171, that were discovered during a separate NDDPI monitoring process, were all returned to the state before the beginning of the 2025 audit. This issue is resolved. Completion Date 05/08/25

Payroll Administration concurs with the recommendation pertaining to the preparation, review, and approval of employee timesheets to ensure the accuracy and completeness of payroll records. Employee timesheets and payroll records are originated, reviewed, and retained at the respective work locations. Therefore, Payroll Administration does not have direct access to these site-level records. To strengthen compliance, Payroll Administration will continue to provide targeted training and guidance to time reporters and time approvers on the timely review and approval of timesheets, the required time and effort certification, as well as the reconciliation of timesheet data with SAP entries. These topics will be reinforced during the monthly Time Reporter and Time Approver Virtual Office Hours. Furthermore, Payroll Administration will continue to issue periodic communications and disseminate the Best Practices Worksheet, which outlines key payroll compliance requirements, including adherence to payroll cut-off deadlines and reconciliation of timesheets and time entry in SAP. Payroll Administration remains committed to supporting District departments and school sites in maintaining full compliance with established payroll policies and procedures. Name: Araceli Pineda Title: Director, Payroll Administration Contact Information: araceli.pineda@lausd.net

Beginning with the next semi-annual certification period, the Special Education Director will prepare a comprehensive listing of all staff whose salaries and/or benefits are charged in whole or in part to the Special Educaiton program. This listing will be reconciled to payroll records prior to certification. Once certifications are completed and signed by the Special Education Director, they will be forwarded to the Superintendent's office (or designee) for independent review and approval to verify that every applicable employee has a completed certification on file. Additionally, the District will establish calander reminders and due dates for each semi-annual period to ensure timely completion and submission of certifications. Staff involved in this process will receive refresher training on federal time and effort documentation requirements.

Corrective Action Plan: The Finance Department Grants Reporting team will train departments on the process for timesheet monitoring and documentation as outlined in the City’s grant manual. The Grants Reporting team will conduct internal reviews/visits to the applicable departments to ensure time reporting and documentation procedures are followed and documentation retained meets the requirements listed in the grants manual. Persons(s) Responsible for Implementation: Cristen Huntz, Financial Analyst, Finance Department, (816) 513-1148, Email: cristen.huntz@kcmo.org, and Robin Flaherty, Financial Manager, Finance Department, (816) 513-1202, Email: robin.flaherty@kcmo.org. Implementation Date: The anticipated implementation date is April 30, 2026.

Management’s Response – Management is currently in the process of re-evaluating existing policies and procedures within the accounting department, including those related to payroll processes. Effective immediately, payroll journals related to performance payments will be provided to the individual(s) responsible for program oversight of the program so they can be reviewed at the time payments are made. Errors or omissions, if any are identified, can then be corrected immediately. Management will continue to evaluate processes and implement improvements as opportunities to do so are identified.

2025-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027 Special Education Preschool Grants ALN: 84.173 Condition: Subpart I, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employees work on more than one Federal award, or a Federal award and non-Federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, it was noted that in some instances, the District’s PARs were not signed by the employees. In addition, PARs for employees not charged 100% to a single grant were prepared retrospectively after year end rather than periodically throughout the year. Planned Corrective Action: PARS’s were sent to all employees on a bi-monthly basis beginning October 31, 2025. PAR’s that were not returned in a timely manner with signature were sent to the employee’s supervisor directly to obtain signature. Responsible Contact Person: Keri Loughlin Assistant Superintendent for Finance and Operations Bayport-Blue Point Union Free School District 189 Academy Street Bayport, New York 11705 Anticipated Completion Date: October 31, 2025

Corrective Action Plan: The District will implement a system of internal controls to ensure that all certifications are completed by employees working in the federal award programs and in a timely manner. Additionally, the District will ensure that time being charged to the grant agrees to actual time spent working in the grant for each employee by sharing this information with building Principals to ensure that the information is accurate and they obtain the employee signature as soon as possible. Anticipated Completion Date:This was completed by October 31, 2025 by the District Treasurer, Assistant Superintendent for Business & PPS Director

Audit Finding Reference: 2025-001 – Title I Grants to Educational Agencies (LEAs) – ALN #84.010 Planned Corrective Action: We will revise our process to ensure the appropriate approval signatures are on Student Withdrawl Forms for transferred students, and for Graduated Students Listing. Name of Contact Person: Bob Haynes Interim Controller Bobhaynes@achievementfirst.org Anticipated completion date: December 9, 2025

Audit Finding Reference: 2025-001 – Title I Grants to Educational Agencies (LEAs) – ALN #84.010 Planned Corrective Action: We will revise our process to ensure the appropriate approval signatures are on Student Withdrawl Forms for transferred students, and for Graduated Students Listing. Name of Contact Person: Bob Haynes Interim Controller Bobhaynes@achievementfirst.org Anticipated completion date: December 9, 2025

We will revise our process to ensure the appropriate approval signatures are on Student Withdrawl Forms for transferred students, and for Graduated Students Listing.

Finding 2025-002: Time and Effort Documentation Name of Contact Person: TRIO Upward Bound Project Director, Vacant. In the Interim, contact will be Dr. Kayla Devora-Jones. Corrective Action: To prevent future occurrences, the College has implemented strengthened safeguards. All Time and Effort reports are now housed in Microsoft Teams with shared access for the TRIO Directors, the supervising Institutional Project Manager, and the Human Resources Payroll Specialist, ensuring clear accountability in the submission and review process. TRIO Directors and the supervising Institutional Project Manager are responsible for the timely completion and submission of all Time and Effort reports, which must now be submitted within five business days following each payroll cycle. Human Resources is responsible for reviewing all submitted reports to verify completeness. This corrective action ensures systematic monitoring, real-time verification, and timely completion of all personnel activity reports. The shared filing structure also eliminates gaps in documentation and has been fully implemented across all four TRIO programs. Proposed Completion Date: 10/31/2025 Anticipated Completion Date: Completed

CORRECTIVE ACTION PLAN Finding 2025-001 – Allowable Costs The District concurs with the finding 2025-001. Corrective Action: The District will implement the following corrective actions to be completed by September 30, 2025: 1.The District will develop and implement new written policies and procedures for time and effort reporting. 2.All grant-funded employees will receive training on the new procedures. 3.The District will implement a new system to track and certify employee time. Contact Person: Lou D’Ambro, School Business Administrator (315) 822-2826 ldambro@mmcsd.org

The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 1 6, 2022, to administer the federal grants to ensure that the Town would comply with all federal program requirements. The Town was led to believe that they were in compliance with all federal program requirements. The Town will develop, formally adopt, and implement written policies and procedures to comply with Uniform Guidance (2 CFR 200).

CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a system for documenting time and effort in a manner that complies with Federal requirements which involves timesheets that record actual time spent on a funding source and are accompanied by supervisory approvals. This system has been formally documented in the FY 26 update to the CIF Financial Policy and includes annual training for staff responsible for managing payroll allocations and Federal reporting. Charges to Federal awards for salaries and wages are now based on records that accurately reflect the work performed. The records are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The records support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.

Material Weakness Item 2025-005 -Activities Allowed and Una/lowed Costs - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 HBLCS50772-01-00 and 6 HBHCS46163-03-01 During our audit, we noted that LBUCC charged salaries to the Section 330 grant based on pre-determined allocations or budget rather than actual hours worked. LBUCC utilized timesheets that reflect the allocations as its time and effort documentation. Recommendation: We recommend that LBUCC implement a time and effort reporting system that tracks actual hours worked on each program or grant. We recommend that they require supervisors to review and approve the actual time spent on grant activities and that such review and approval be documented. Action Taken: LBUCC will implement a time and effort reporting system to include a semi-annual certification for all employees funded by the HRSA 330 grant and a time card reporting system for those funded by multiple grants. Effectivity Date: Time and effort reporting will be implemented in January 2026 and fully in place by 1/31/2026

REFERENCE: 2025-001 – Allowable Costs/Cost Principles HIV Emergency Relief Project Grants (Assistance Listing No. 93.914) Federal Grantor: Health Resources and Services Administration Facility: Bailey-Boushay House Finding: At Bailey-Boushay House, controls over the required allowability criteria with regard to payroll expense were not performed and/or documented throughout the year. Corrective Action Plan: At Bailey-Boushay House, each Friday and Monday prior to running payroll, approval reminders are sent to all staff with the time-keeping policy attached. At least two different leaders and/or the scheduling coordinator send these reminders. Staff have been educated on the two-step approval system and it will impact their performance evaluation if there is continued non-compliance. The Finance Manager reviews the timecard allocations and populates the hours charged to the grant per the timecard on to the salary allocation spreadsheet. The salary allocation spreadsheet is utilized in completing the reimbursement request. The timecards and the allocation spreadsheet are included in the reimbursement request. Beginning in January 2026, the salary allocation spreadsheet and timecards will be reviewed and signed off by the Director of Outpatient Programs as part of the reimbursement request approval process. Additionally, timecard approval compliance for prior periods will be reviewed during Bailey-Boushay weekly leadership meetings. Person Responsible: Rob Hays, Executive Director – Bailey-Boushay House Expected Completion: January 2026