Corrective Action Plans

Recommendation: The Center should develop policies and procedures to help ensure pay rates are consistent with supporting employee agreements or other management-approved documentation. Corrective Action Taken: 1. Immediate Review and Correction Upon identification of the finding, the Center conducted a comprehensive internal audit of pay rates for all employees hired from January 1, 2025, to the present. Any discrepancies identified during this review were promptly corrected to ensure alignment with approved documentation. 2. Staff Training Targeted training will be provided to all Human Resources and Payroll staff. This training will emphasize: The importance of accuracy in data entry and the use of self-review as a quality control tool; Accountability at both the individual and team levels for maintaining complete and accurate payroll data; and Proper preparation and retention of documentation supporting initial payroll entries and any subsequent changes. 3. Policy and Procedure Review The Center has performed a comprehensive review of its internal policies and procedures to: Ensure clear delineation of roles and responsibilities across hiring, onboarding, and payroll processes; and Provide detailed guidance on required documentation to support each step in these processes. 4. Double-Verification Process Management has reinforced a culture of shared accountability by implementing a doubleverification process. This includes: Requiring staff to review and confirm the accuracy of their own work prior to submission; and Requiring receiving staff to independently verify information and resolve any discrepancies before proceeding with further processing. 5. Continued Monitoring In addition to standard bi-weekly payroll reviews conducted by management, the Center will implement quarterly payroll system audits. These audits will verify that all payroll changes are accurate, properly documented, and supported by appropriate approvals.

RIDOH agrees with this repeat finding and recommendations. RIDOH staff often do not pay attention to the Budgeted Allocation column on their time sheets, focusing only on their reporting of time and effort, which leads to inaccurate cumulative Budgeted Allocations on Variance Reports leading to inaccurate variances for correction. The RIDOH reconciliation methodology includes a step to compare reported time and effort to financial system payroll reports (the Variance Correction tab in each reconciliation adjustment calculation spreadsheet). This ensures that all adjustments are accurately processed to the appropriate grants even if they do not appear to agree with the variances in individual Variance Reports. 2025-043a: RIDOH abolished all “umbrella” or general Programs/Activities from Time Sheet Workbooks as of SFY2027 Qtr1. All grant activities now are reported with Appropriation numbers, and grouped activities were removed, except for Medicaid Match account pairs and consecutive federal awards for the same purpose which are spent down in sequence (e.g., DWQ State Revolving Fund awards). RIDOH continues to monitor the status of reporting by Project Tags in Workday, which will provide automatic reconciliation per time and effort reported. Currently, reporting by Project Tags results in inaccurate charging of leave time. When that issue has been resolved, RIDOH will switch to Workday Project Tag reporting and will discontinue using Time Sheet Workbooks. 2025-043b: RIDOH will review SFY2026 Time Sheet Workbooks and revise them to show the correct budgeted allocations, providing the basis for the variance adjustments. Any revisions will be documented. Time and effort reported will not be changed. For SFY2027, RIDOH Grants Management began providing payroll reports formatted by the Time Sheet Workbook Programs/Activities for Division Finance Liaisons to update and share with Division staff, to support correct recording of Budgeted Allocations in Time Sheet Workbooks. RIDOH Grants Management will continue to do this quarterly, ensuring accurate variance calculations on quarterly Variance Reports. 2025-043c: RIDOH will review the SFY2025 payroll reconciliations in question and make corrections as needed. Anticipated Completion Dates: 2025-043a: Enhanced reporting completed. Transition to Workday Project Tag reporting by June 30, 2027 2025-043b: Ongoing 2025-043c: December 31, 2026 Contact Persons: Carla Lundquist, Deputy CFO / Federal Grants Manager, Department of Health carla.lundquist@health.ri.gov Shannon Healy, Assistant Federal Grants Manager, Department of Health shannon.healy@health.ri.gov

Management concurs with the finding. During the audit period, the Organization maintained payroll records, compensation documentation, and payroll allocation schedules; however, it did not maintain personnel activity reports, periodic certifications, or other after-the-fact documentation sufficient to support compensation costs charged to the Community Development Financial Institutions Program in accordance with 2 CFR § 200.430. The Organization's methodology relied on management-established allocation percentages based on employee responsibilities and anticipated level of effort supporting CDFI Fund activities. While management believes the costs charged to the award were incurred in support of eligible program activities, the Organization recognizes that documentation supporting the allocation methodology did not meet the standards required under Uniform Guidance. Planned Corrective Action: Beginning July 1, 2026, the Organization will implement formal time and effort reporting procedures for all personnel whose compensation is charged, in whole or in part, to federal awards. Specifically, the Organization will: 1.The CFO will establish a cost allocation plan which includes a methodology to support salary, wage, and fringe benefit charges, and other applicable costs, to the federal award and to support allocation among cost objectives. 2. The CFO will implement a documented process for personnel activity reporting and/or periodic certifications (or other equivalent documentation) that reasonably reflects actual work performed and supports the allocation of compensation costs to eligible activities. 3. CFO will reconfigure the current workforce management system to ensure projects, departments, and contextual details are logged at the source. 4. The COO will review existing timesheet submission and review policy to ensure compliance with federal requirements. The policy will require supervisory review and approval of personnel activity documentation/ certifications consistent with the payroll cadence and retain documentation in the grant file and/or payroll file. The CFO will review and enforce compliance with timesheet submission requirements. 5. The CFO will implement a dynamic allocations module within Sage Intacct to facilitate automated allocation of time and fringe benefits to federal and other programs. 6. The CFO will ensure that the systems established perform periodic reconciliation and after-thefact review of payroll and fringe benefit allocations. The CFO will make timely adjustments when actual activity differs from budget estimates or planned allocations. 7. The CFO, COO, and other personnel working on federal programs will receive training on the documentation standards in 2 CFR § 200.430 and allowability factors in 2 CFR § 200.403. 8. The CFO and COO will provide training to program and finance personnel on the documentation standards. in 2 CFR § 200.430 and allowability factors in 2 CFR § 200.403. 9. The CFO will, as part of the monthly close process, review compensation charged to federal awards to ensure all costs are appropriate and supported prior to requesting reimbursement. Management believes these actions will strengthen internal controls over compensation costs charged to federal awards and ensure compliance with Uniform Guidance requirements going forward. Responsible Official: Julia Gazizova, Chief Financial Officer Anticipated Completion Date: September 30, 2026.

Managements Corrective Action Plan Year Ending – December 31, 2025 In response to the Single Audit performed by Baker Tilly US, LLP for calendar year ending December 31, 2025. Schedule of finding and Questioned Costs: Section III – Federal Award Findings: 2025-001 – Allowable Cost Principles – Payroll Evidence of Review Contact: Jennifer Moore Title: Controller Phone number: 310-795-0257 Federal Assistance # 93.217 Estimated Completion Date – September 2026 Corrective Action - Planned Parenthood Great Northwest, Hawai’i, Alaska, Indiana, Kentucky will implement a process improvement plan in 2026 that addresses the finding: • For our 2025 Single Audit, we discovered a system limitation in Dayforce preventing approval of timecards beyond the automatic cut-off time. • In partnership with the Human Resources department, staff will establish an “after the fact” approval process to ensure that all timecards are reviewed and approved by management. o The current system will continue to push through timecards to make the defined payroll cut-off time. o A manual process will be established to review and approve missed timecards after payroll is processed. ▪ Managers are to review and approve timecards, even though the timecards have been processed. ▪ A log will be maintained acknowledging missed approvals, logging hours, areas of work, and manager approval o If any errors or changes need to be made, those will be reflected within the next payroll cycle.

Finding Timesheets charged to federal programs were processed without documented supervisory approval in certain instances. Corrective Action Planned In 2026 and going forward, all staff and Department Director timesheets will be approved by an independent supervisor prior to payroll processing. Contact Person Nicole Babcock Anticipated Completion Date Implemented June 2026; ongoing monitoring thereafter.

Finding 2025-02 Insufficient Documentation of Personnel Expenses Condition: The Organization charges a material amount of payroll-related costs to its major federal program. However, for 7 months of the year, it did not maintain sufficient documentation to support the level of effort charged to the award, as required by federal regulations. While staff members are required to complete timesheets, the format did not capture the level of detail needed to substantiate payroll allocations to federal programs. Additionally, there was no formal process for supervisory review and approval of these timesheets. Although no overcharges or double-dipping were identified, the lack of adequate documentation results in known and likely questioned costs due to noncompliance with documentation requirements. A new system was implemented in August 2025 which improved the deficiencies and compliance matters for the remainder of the year. Corrective Actions Taken or Planned: The Organization started using features within Gusto beginning in August 2025 that capture employee name, pay period, hours worked by funding source, detailed notes (if applicable) and supervisory approval. The Organization trained all staff whose salaries are charged in whole or in part to grants on documentation and time allocation requirements. Monthly timesheets charged to grants are reviewed before submission for reimbursement. All timesheets require approval by a supervisor before payroll is processed and the final payroll requires two approvals by the CEO. Accounting Manager and/or the Development Manager. The Organization will conduct quarterly internal reviews to ensure compliance and adjust as needed.

Health Center Program – Assistance Listing No. 93.224 Recommendation: Management should implement a formal time and effort reporting process that ensures payroll costs charged to federal awards are supported by contemporaneous documentation of actual work performed, requires retention of historical, point-in-time allocation records for each payroll period (e.g., version-controlled or archived reports), and includes a documented review and approval process that compares allocation percentages to employee attestations or activity reports to validate the reasonableness and accuracy of costs charged to the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management concurs with the finding. To address this issue, the Organization intends to fund all staff on payroll at one hundred percent of salaries and benefits to minimize the risk that allowable costs are misstated and not in compliance with 2 CFR 200.430. Name(s) of the contact person(s) responsible for corrective action: Chief Financial Officer or their designee. Planned completion date for corrective action plan: July 1, 2026

Allowable Costs and Activities Condition: Payroll costs were allocated to grants in a manner inconsistent with the time and effort documentation provided. Recommendation: Management should reinforce the requirement to retain time and effort documentation for all employees that are allocated to multiple grants and implement a review process whereby the allocation percentages used are compared to the employee attestations provided. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: TCA Health is enhancing its time and effort and payroll allocation processes to ensure charges to grants align with documented effort. We are building on our monthly review process for time and effort by formalizing a review in which payroll allocation percentages are compared to signed attestations, with Finance documenting any corrections and follow-up. We are also partnering with HR to ensure all Personnel Action Forms (PAFs) include appropriate grant coding and to require an updated PAF whenever an employee’s grant funding or allocation changes. In addition, TCA Health is implementing an automated integration between ADP and Sage Intacct so that approved timesheets flow directly into payroll and grant reporting, improving accuracy and the audit trail. We will leverage the systems and limit manual entry. Name(s) of the contact person(s) responsible for corrective action: Bob Van Gilder Planned completion date for corrective action plan: 9/1/26 If the U.S. Departments above have questions regarding this plan, please call Veronica Clarke, Chief Executive Office, at 773-928-5090.

Management agrees with the finding and acknowledges that documentation of timesheet and payroll reviews was not consistently retained during the audit period. Management notes that this finding relates primarily to the documentation and consistency of review controls rather than an indication that reviews were not performed. To address this finding, management has implemented a formal, documented review process for timesheets and payroll prior to disbursement. Timesheets will be reviewed and approved through a centralized system or documented workflow to ensure that evidence of supervisory review is retained. Payroll changes require CEO approval prior to or concurrent with processing and documentation retained. Each payroll is subject to independent review and confirmation. Cumulative payroll and allocation are further subject to independent quarterly review by the CEO with supporting documentation. These procedures will be incorporated into standard operating practices and monitored periodically to ensure consistent application and retention of audit evidence. Anticipated Implementation Date: Implemented and ongoing; formal policy incorporation expected by September 1, 2026. Contact Person Responsible for Corrective Action: Shahara Wright, Chief Operating Officer & General Counsel and Brook Abitz, Director of People and Operations

Management Response: Management agrees with the audit finding regarding internal controls over payroll. To strengthen payroll controls and ensure the accuracy and integrity of payroll processing, the organization has implemented and will continue to enhance the following procedures: Payroll is processed based on approved employee contracts, work agreements and authorized timesheets. Supervisors are responsible for reviewing and approving employee timesheets before payroll is processed. We have a new payroll manager who is ensuring that all required documentation is on file and works closely with the HR Department. We acknowledge that HR Files were incomplete due to previous staff disassembling files for HR Audits and not replacing documents to original folders. Anticipated Completion Date: In process for FY2026, we have a new payroll manager and HR Director that started in May of 2025 and both are ensuring all proper documentation is in place. Management anticipates full implementation by June 30, 2026. Responsible Party: Business Manager, Payroll Manager, Accounting Tech & HR Director.

2025-003 Auditor’s Recommendation: UCM should develop and implement comprehensive written policies and procedures addressing time and effort, employee benefits, payroll allocations, and documentation standards. Staff responsible for grant accounting should receive Uniform Guidance training. Corrective Action: UCM is implementing Insperity, a new Human Resource and Payroll software system, to improve the accuracy and documentation of time allocation, payroll processing, and benefit allocation across programs and funding sources, including the Family Achievement Program federal award. UCM will configure Insperity and related procedures to support time allocation by program, grant, or cost objective, supervisor approval, payroll allocation reporting, and retention of supporting documentation. In addition, UCM will develop and implement written policies and procedures addressing time and effort reporting, employee benefit allocations, payroll allocation methodology, review and approval requirements, and documentation retention standards. These procedures will require that employee benefits charged to the federal award are based on actual benefit costs incurred, rather than budgeted or estimated amounts, unless otherwise permitted by the award terms and adjusted to actual costs within the required reporting period. UCM will establish a review process to ensure payroll and benefit costs charged to the federal award are accurate, allowable, based on actual costs incurred, properly supported, and consistent with Uniform Guidance requirements. Staff responsible for grant accounting, payroll processing, and federal award compliance will receive Uniform Guidance training. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Deborah Ewell, Director of Human Resources Laura D’Ambrogi, Grants Manager Anticipated Completion Date: September 30, 2026

View of Responsible Officials: Management agrees with the finding and recommendation. Corrective Action Plan: Problem The financial audit conducted by N&K identified that there were two (2) incorrect deduction amounts that were entered into the HRIS system, resulting in an overcharge to the employee. Upon investigation, it was determined that the HR Administrator updated the wrong benefits deduction entry, which caused an incorrect overcharge for the employee’s life insurance deduction and an incorrect undercharge to their long-term disability insurance deduction. The incorrect charges occurred over a span of 15 months to a total overage of $913.59, for which the employee was not reimbursed. Root Cause The error occurred during the organization’s benefits carrier switch from Prudential Financial to The Standard. Their existing process—where the Administrator inputs changes and the Assistant performs a post-entry review—failed to detect the error, resulting in a finding within the auditor’s report. The issue appears to stem from a combination of process and control weaknesses: • Manual data entry error by the Administrator • Ineffective secondary manual review, likely due to: o Lack of a standardized checklist or validation criteria o Insufficient sampling or inconsistent spot-check methodology • Lack a system-based validation controls within the HRIS system (e.g., thresholds, alerts) • Limited accountability clarity for final verification • Lack of periodic audits in case errors are missed Immediate actions to address the current issue and mitigate employee impact • Calculate and process reimbursement for the overcharged employee (completed) • Communicate transparently with the affected employee regarding: o Nature of the error o Correction made o Reimbursement payment • Conduct a targeted audit of recent deduction changes to identify any similar errors (completed) Corrective Action Plan (Preventive Controls) To prevent future occurrences from happening, unit will implement the following changes to its administrative procedures: 1. Standardized Data Entry Protocol The unit will utilize its HR Action Form as a standard processing mechanism for benefit deduction changes made within the HRIS, including:• Source documentation verification (e.g., enrollment forms, carrier files) • Confirmation of deduction amount and effective date This will require both the processor and the reviewer to initial and certify that the change was accurately completed, thus strengthening its review process. 2. Enhancing review procedure for multiple changes done at the same time The unit will replace its previous “spot check” review process with a structured verification process that mirrors its semi-monthly timesheet report for payroll. This new report will include: • The processor documenting all deductions or changes made • The processor including supporting documentation • The auditor completing a 100% review to confirm work accuracy and cross-verification against source documents • The Director providing a final spot-check and sign-off It is important to acknowledge that these enhanced controls may introduce some operational trade-offs. In the short term, the shift to 100% review and additional dual-verification tasks will likely increase processing time and workload redundancy for both the Administrator and Assistant. There is also a risk of workflow bottlenecks, particularly during high-volume periods such as open enrollment or payroll cutoffs. Closing The implementation of new corrective and preventive measures will establish a more disciplined and reliable control environment around the East-West Center’s benefits administration. By formalizing data entry protocols, strengthening independent review, and introducing layered validation controls, the unit can significantly reduce the likelihood of this occurrence (or other-related HRIS data entry errors) while improving overall data integrity and employee trust. The proposed changes will enhance audit readiness and operational transparency for the Human Resources team.Contact Person: Human Resources Director Anticipated Completion Date: Procedures have been implemented as of report issuance date 32

2025-001 Timeliness of Effort Certification Cluster: Research and Development (also applies to other major programs referenced below) Sponsoring Agency: All research and development cluster sponsoring agencies and Department of Health and Human Services (for the other major program referenced below) Award Names: All research and development cluster awards and Doorway for Substance Use-Related Supports and Services Award Numbers: All research and development cluster awards, Cheshire Medical Center 05-95-920510-7040000 Assistance Listing Title: All research and development cluster assistance listing titles and Opioid STR Assistance Listing Number: All research and development cluster assistance listing numbers and 93.788 Award Year: 2024-2025 Pass-through entity: All research and development cluster pass-through entities and New Hampshire Department of Health and Human Services This is a repeat finding of 2024-002 and in the prior year corrective action plan we had anticipated correcting this matter by March 31, 2025. Due to additional training needing to be administered to providers, we had to revise our date of completion to September 30, 2026. Management agrees with the finding related to the timeliness of effort certification. Management has continued to provide training and education to both operational and clinical leadership regarding timely effort certification. Dartmouth-Hitchcock currently has two effort certification systems: one used for research and one used to track other metrics. This has caused confusion among those required to certify effort for federal awards as they often believe that they had already certified their effort for research purposes . Management will provide additional education sessions and provide further clarification to the research community on the importance of timely effort certification and the differences in each effort reporting system. Individual Responsible: John Muhlen, System Vice President of Corporate Finance Anticipated Completion Date: September 30, 2026

Corrective Action Plan Finding 2025-001 – Allowable Costs Requirement – Time and Effort Reporting for Salaries Corrective Action: Management concurs with the findings. Day One will formalize and implement written procedures governing the documentation, review, and reconciliation of personnel costs charged to federal awards. Employees whose compensation is charged, in whole or in part, to federal awards, will be required to complete after-the-fact timesheets that accurately reflect the work performed and the total activity for which they are compensated. The documentation will be reviewed and approved by the employee's supervisor. The Finance Director is responsible for reconciling payroll allocations charged to federal awards to the certified time and effort documentation on a regular basis and ensuring that any differences identified are reviewed and corrected in a timely manner. The Finance Director is responsible for supporting documentation for payroll allocations and reconciliations is maintained in accordance with Day One's record retention policies. Day One will update its written policies and procedures to reflect these requirements and has provided training to employees and supervisors responsible for completing, reviewing, and approving time and effort documentation. The Executive Director will periodically review compliance with these procedures as part of Day One’s internal control monitoring process. We will also do a final year-end review of time and effort allocations and certification. These corrective actions are intended to strengthen internal controls over payroll allocations and ensure that personnel costs charged to federal awards are adequately documented, properly allocated, and supported in accordance with 2 CFR Part 200. Responsible Official: • Anne Patterson, Executive Director – Oversight of implementation and ongoing compliance. Anticipated Completion Date: The corrective actions will be implemented and effective as of September 1, 2026. We have already implemented this process for FY2025. Once the process is complete, Day One will update, after-the-fact documentation and approval to date and will continue the process thereafter.

Views of Responsible Officials: Management appreciates the auditors' recommendations and recognizes the importance of consistently documenting supervisory review and approval of employee timesheets.The finding relates to the documentation and retention of supervisory approval for certain employee timesheets selected for testing. The Organization appreciates the opportunity to strengthen the documentation of an existing supervisory review process to ensure approvals are consistently evidenced and retained. To address the recommendation, the Organization has reinforced supervisory expectations, updated internal procedures related to timesheet approvals, and implemented periodic monitoring to verify that supervisory approvals are consistently documented and retained. Management believes these enhancements appropriately address the recommendation and further strengthen the Organization's existing internal control environment while reinforcing its commitment to sound internal controls and compliance with applicable grant requirements.

Finding Number: 2025-001 Federal Programs: • ALN 93.696 – Certified Community Behavioral Health Clinic Expansion Grants (Grant No. H79SM087001-01) • ALN 93.788 – Opioid STR (Grant No. H79TI087831) Finding Title: Activities Allowed or Unallowed / Allowable Cost Principles Condition: During testing, it was noted that payroll was allocated to the grants based on budget estimates because the payroll system used did not allow staff to document their hours across multiple programs in real-time. However, after-the-fact reviews of charges made to the Federal awards were not done to ensure that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Planned Corrective Action: HealthWest will update payroll procedures to perform after-the-fact reviews of payroll allocations charged to federal grants. As part of these reviews, management will compare each employee's budgeted grant allocation percentages to the employee’s Salary Allocation Schedule (SAL) and actual time worked on grant activities, as supported by available program and operational records. Any differences identified will be analyzed and appropriate payroll allocation adjustments will be made during the year-end review process to ensure final amounts charged to federal awards are accurate, allowable, and properly allocated. Anticipated Completion Date: September 30, 2026 Responsible Official: Brandy Carlson, Chief Financial Officer

Condition: The Organization allocates personnel costs to federal programs based on wage forms that reflect estimated time expected to be worked across programs. Supervisors perform biweekly reviews of employee time charged within the Paylocity system and compare allocations to supporting information such as program schedules and caseloads. However, we noted that: - There is no formal documentation retained evidencing the supervisor's review of supporting records (e.g., caseloads, schedules) to substantiate that recorded time aligns with actual work performed; and - The only evidence of review is system approval within Paylocity, which indicates the timecard was approved but does not demonstrate the nature, extent, or basis of the review performed. Planned Corrective Action: Family Guidance Centers will require direct supervisors to document their review of supporting records (e.g., caseloads, schedules) of direct reports to substantiate that recorded time aligns with actual work performed as a part of their bi-weekly timesheet reviews. Family Guidance Centers will retain this documentation in accordance with its document retention policy. Contact person responsible for corrective action: Jim Hagestad, CFO Anticipated Completion Date: July 1, 2026

Saginaw-Shiawassee Habitat for Humanity respectfully submits the following corrective action plan for the year ended September 30, 2025. Auditor: Maner Costerisan 2425 E. Grand River Ave., Suite 1 Lansing, MI 48912 Audit Period: The finding from the September 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently witht eh number assigned in the schedule. Finding - Federal audit Finding 2025-001 - Material Weakness Reccommendation: Saginaw-Shiawassee Habitat for Humanity prepare required written policies and procedures that are promulgated by 2 CFR 200. Action to be taken: Saginaw-Shiawassee Habitat for Humanity concurs with the finding and acknowledges that formal written federal policies and procedures required under Uniform Guidance were not fully documented during the audit period. The Organization has begun developing and implementing written policies and procedures related to - Allowability of costs chargedd to federal awards - Procurement and bidding procedures - Compensaztion and payroll allocation procedures - Federal grant compliance and documentation standards Management is working in consultation with its auditor and grant partners, as appropriate, to ensure policies align with Uniform Guidance requirements for 2 CFR 200. In addition to policy development, the Organization will: - Review and fformally adopt policies through leadershiop and governance process - Train applicable staff on federal compoliance requirements and governance processes - Maintain centralized documentation related to fedderal grant compliance and procurement activities - Incorporate periodic internal reviews to ensure continued compliance with fedderal requirements

The City is currently implementing measures to ensure the actual hours worked is correctly coded.

Moving forward, the Chamber will use an employee’s timesheet to bill wages to federal awards. When preparing reimbursement requests, the staff will calculate the wage amount that is equal to the number of hours each employee self-attested to working to the federal grant by coding the hours on their timesheet for the applicable pay periods. If a true-up of wage expenses is done at any time during the cycle of the federal grant, the Chamber will maintain adequate documentation (the employee timesheets) to indicate how the true-up was calculated. The calculation provided by the staff will be reviewed by the Executive Director prior to the reimbursement request being submitted to the granting agency.

The Child and Family Services Agency (CFSA) concurs with the findings as stated. CFSA will review the intradistrict mandate with the Office of the Chief Technology Officer to gain greater clarity into their budgetary allocation of expenditure methodologies to subsidiary agencies, including CFSA, with a goal of providing the requested information to auditors during future audits. CFSA will initiate training for management staff to address appropriate practice for time keeping and approvals by September 30, 2026.

Management’s Action Plan: Management concurs with the findings. The deficiency was due to a lapse in management oversight related to the review and approval of independent contractor timesheets. To strengthen internal controls and ensure compliance with federal requirements, management has implemented corrective actions through the full implementation of a new enterprise resource planning system, Fusion. Under this process, all timecards are now entered, reviewed, and approved directly within Fusion and cannot be processed for payment unless they have been formally approved by appropriate management personnel. This ensures proper documentation, accountability, and adherence to internal control policies. Name of Person Responsible for the Plan: Katherine Hill, Manager of Accounting Jason Lynn, Vice President of Finance and Controller Anticipated Completion Date of the Plan: Completed – fully implemented with the rollout of the Fusion system (May 2025).

We concur with the finding and are implementing procedures to address all issues. The payroll allocation errors identified were caused by inconsistent application of time allocation procedures at the employee level and insufficient monitoring controls to detect misallocations in a timely manner. CAP plans to reimburse the related unallowable costs to the Federal Government by June 30, 2026. To address these issues, CAP is enhancing its internal controls over payroll allocations. CAP will conduct mandatory refresher training for applicable staff on time allocation requirements to reinforce compliance expectations. Additionally, CAP has implemented a new accounting system that will allow for the use of validation rules designed to prompt time allocations when employees charged to federal funding engage in non-federal activities. CAP will also perform periodic reviews of payroll allocations to ensure that they align with employees’ current duties and funding sources, and these reviews will be documented and performed by personnel independent of the preparer. These actions are designed to improve the accuracy and consistency of payroll allocations and ensure compliance with federal cost principles. CAP expects to fully implement these corrective actions by June 2026.

American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund – Assistance Listing No. 84.425 Recommendation: We recommend the District implement written procedures that require timely preparation and retention of documentation supporting the work performed and allocation methodology and supervisory review/approval consistent with the District's policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The district will ensure we are completing time and effort logs for staff who are federally funded. Name(s) of the contact person(s) responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025

Comment #2025-001 COMPENSATION METHODOLOGY SHOULD BE REVIEWED FOR INCENTIVE PAYMENTS COMMUNITY SERVICES BLOCK GRANT AND LOW-INCOME HOME ENERGY ASSISTANCE PROGRAM FAL #93.569 and 93.568 Views of Responsible Officials and Planned Corrective Actions: Management concurs with the recommendation. FACAA updated its Incentive Compensation Policy, which was approved by the Board of Directors, in accordance with 2 CFR 200.430 and 2 CFR 200.303. The policy establishes the methodology for incentive payments, and all incentive payments have been documented and supported by appropriate records to ensure compliance with applicable federal requirements. Implementation Date: Effective immediately, our policies have been enhanced to clarify and support our methodology used during the periods noted under review, and for all subsequent periods. Responsible Person(s): Dr. Howard Grant, President/CEO