Corrective Action Plans

Condition In two instances, the amounts recorded in the General Ledger (GL) did not match the corresponding amounts recorded in the payroll system. Corrective Action Plan Corrective Action Planned: Efforts were taken to verify Dayforce is configured to allocate salary expenses to an employee’s home agency and department, regardless of where the employee assigns their hours in the timekeeping system. While the timesheet programmatic reflects the agency and department where hours and dollars are functionally charged, the payroll register aligns with the General Ledger based on home agency coding. As a result, the Payroll Register and General Ledger will reconcile with each other but may not align with programmatic reports, which are based on timesheet-level allocations. This system behavior is consistent with current configuration and financial reporting practices. The Payroll Department and the DHHS will meet in Q3 2025 to ensure grant/expense tracking activities are working as intended. Name(s) of Contact Person(s) Responsible for Corrective Action: Sue Drummond, Director Payroll & HRIS Interface Anticipated Completion Date: Completed January 2025.

For payroll, procedures will be implemented to ensure that payroll costs allocated to federal grants are supported by actual time. For nonpayroll, procedures will be enhanced to ensure proper allocation of nonpayroll costs to federal grants. Allocations will be reviewed and monitored on a monthly and quarterly basis to prevent misallocation and ensure compliance with the Uniform Guidance. Personnel Responsible for Implementation: Executive Director Christy Zamani, and Beaulieu Accountancy Corporation Date of Implementation: August 5, 2025

Management will update the entity’s accounting policies and procedures to include specific guidance on payroll allocation and documentation requirements for personnel expenses charged to Federal awards.

Planned Corrective Action: The District is in the process of reviewing and updating controls to ensure required time and effort logs are kept in the District's fiscal management system and routine submission of forms is enforced by the grant managers. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Marleni Bruner, Joanette Thomas, Lisa Robinson

Comments on findings and recommendations The organization concurs with the finding and agrees that after-the-fact time documentation is necessary to comply with federal requirements, even when employees' assignments and hours are consistent. Actions taken or planned The organization has performed a time-study during 2024 to support allocations to programs and has been implemented in 2025. Anticipated completion date January 1, 2025

Finding 2024-010 – Material Weakness – Allowable Costs/Cost Principles Condition The District supports time charged to federal awards via semi-annual certifications which are approved by the grant administrator or the building principal. In order for a cost to be supported at the time of final reimbursement, the semi-annual certifications should be approved by the grant administrator or the building principal. Title I Grants to Local Educational Agencies (ALN 84.010) The final reimbursement claim for the Title I Grants to Local Educational Agencies (Title I) program were due to Wisconsin Department of Public Instruction (DPI) on September 30, 2024; however, the final reimbursement claim for the Part A award was not submitted to DPI until November 18, 2024, and the CSI award was not submitted to DPI until October 1, 2024, due to an extension. Five of the 40 individuals sampled had their semi-annual certifications not approved timely and were approved after the due date of the final reimbursement claim, but before the date of the actual submission of the final reimbursement claim. An additional two individuals of the 40 sampled had their semi-annual certifications approved after the final reimbursement claims were submitted. Upon further review of all the spring semi-annual certifications for the Title I awards, there were an additional 50 individuals that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim but before the submission of the final reimbursement. Additionally, nine individuals had their semi-annual certifications approved after the final reimbursement date of the Part A award and another 59 individuals from Part A did not have their semi-annual certifications approved at all. Head Start Cluster (ALN 93.600) The final reimbursement claim for the program was submitted to the Federal agency on November 22, 2024. Four of the 40 individuals sampled had their semi-annual certifications approved by the Head Start administrator after the submission date of the final reimbursement claims. Upon further review of the all the spring semi-annual certifications, there was an additional individual that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim and another four individuals that did not have their semi-annual certifications approved at all. The samples were not statistically valid. Corrective Action Plan The Office of Finance agrees that it is important that certifications be completed in a timely manner and award reimbursements are submitted within the deadlines. The Office of Finance and the District as a whole is working on improving its internal controls system wide. We are committed to developing sound processes and procedures that are in full compliance with federal and state regulations. An example of a process improvement is to send out reminders on a regular schedule to school leaders and central office employees for programmatic compliance. These activities will be completed in advance of due dates going forward to ensure timely submission of grant claim reimbursements. Annual training for school leaders and central office staff is also part of the process improvement plan underway. Name(s) of Contact Person(s) Responsible for Corrective Action: Chief Financial Officer, State and Federal Programs Director, Comptroller, Grant Accounting Manager Anticipated Completion: 06.30.2026

The Board of Health will adopt updated written policies periodically in accordance with the Uniform Guidance to help improve internal controls over federal compliance for the findings listed in this number.

Finding 2024-02 Insufficient Documentation of Personnel Expenses Condition: The Organization charges a material amount of payroll-related costs to its major federal program. However, it does 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 current format does not capture the level of detail needed to substantiate payroll allocations to federal programs. Additionally, there is 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. Corrective Actions Taken or Planned: The Organization will develop and implement a standardized timesheet template (Gusto) that captures employee name, pay period, hours worked by funding source, and supervisory approval. Provide mandatory training for all staff whose salaries are charged in whole or in part to grants on documentation and time allocation requirements. Require monthly reconciliation of time sheets to payroll records before submission to grants. The Organization will conduct quarterly internal reviews to ensure compliance and adjust as needed.

Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. The Organization has made efforts to ensure that proper documentation is maintained and accessible by necessary staff.

Family Star acknowledges the FY24 finding related to labor allocation. During that fiscal year, the organization experienced several operational challenges, including insufficient documentation and oversight of labor allocation reporting. These administrative issues were contributing factors in a broader leadership restructuring, which included the elimination of five middle management positions. As a result, responsibilities for labor allocation were reassigned to ensure proper oversight. Since that time, Family Star has already taken intentional steps to strengthen internal controls and improve the accuracy and consistency of key administrative functions. Labor time reporting is now aligned with organizational slot distribution across programs and funding sources to ensure compliance and transparency moving forward. To further reinforce accountability, we have implemented a new monthly monitoring procedure. On the first Wednesday of each month, the Senior Director of Community Partnerships and the HR Specialist jointly review and archive labor allocation records. This process ensures allocations are preserved, updates are made in a timely and compliant manner, and labor costs are supported by accurate documentation. These measures are designed to increase transparency, enhance internal controls, and ensure labor allocations are properly managed going forward.

2024-107 Review of Reimbursement Request Did Not Detect an Error in Amount Reported Condition: The September 2024 reimbursement request included wages paid in August 2024 instead of September 2024 in error. This is not a systemic problem but an isolated occurrence resulting in an immaterial difference in the amount reimbursed and the amount that should have been requested for September 2024 wages paid. Corrective Action Planned: We acknowledge the finding and have strengthened our review process for reimbursement requests to prevent similar errors. Finance staff verify payroll periods against reimbursement periods before submission, and supervisors perform an additional review. This process includes careful cross-checking against the appropriate pay periods. This was an isolated occurrence with immaterial impact, but corrective steps will ensure accuracy in future requests. Person Responsible for Corrective Action: Robert Thompson, Chief Executive Officer Anticipated Completion Date: Implemented

2024-106 Lack of Time and Effort Documentation Policy Condition: Time and effort reporting on actual hours spent on individual grant projects used to support the budgeted allocations of employee salary for each grant are not being kept. This is a systemic issue as a procedure for documenting time and effort by employee to justify the allocation of salaries across grants has not been put in place. Corrective Action Planned: We acknowledge the finding and have adopted a formal Time and Effort Reporting Policy. Standardized timesheets will be implemented and staff trained within 60 days, with supervisors reviewing submissions. The Finance Manager will monitor records monthly and conduct quarterly reviews to ensure compliance going forward. Person Responsible for Corrective Action: Robert Thompson, Chief Executive Officer Anticipated Completion Date: October 2025

Type of Finding: Significant deficiency in Internal Control over Compliance relating to inadequate allocation of wages to federal programs may result in noncompliance with grant regulations. Views of Responsible Officials: Management accepts this finding. Effective internal control over the allocation of wages to federal programs ensures we remain in compliance with allowable costs. In one region, two employees in ADP were not set up correctly to ensure the proper allocation of hours worked per the timesheets to the associated job cost centers. Training of staff along with additional supervision over allocations would likely have prevented this error. Corrective Action: The set up of all employees has been reviewed and now corrected. In addition, new employee set up will be reviewed by a designated staff member to ensure consistency. A new report has been developed that will be reviewed for each pay period to ensure all employees, allocating their time are set up properly.

2024-001 Head Start – Assistance Listing No. 93.600 Significant Deficiency in Internal Control Over Compliance and Noncompliance – Inadequate Payroll Review and Documentation B. Allowable Costs/Cost Principles Recommendation: The auditor recommended that management establish detective controls to ensure payroll expenses are being charged consistent with established policies and approved allocations. Action Taken: We agree with the recommendation and portions of the plan were implemented in February 2024, while the remainder was implemented in July 2025. In January 2024, the ELI team reviewed team members and their respective salary allocations, specifically for the Early Head Start program. Allocations were documented and updated in Axiom, ELI’s payroll system of record. Those allocations were then updated in early February 2024 and regular meetings to review, document and update allocations as needed, have since been held on a consistent basis. The secondary piece, corrected in July 2025, was a system correction for allocation of PTO and Holiday pay, those were not being allocated to EHS consistent with the agreed upon allocations and not going to EHS as they should have been. This has been corrected in Axiom and the ELI accounting team will now perform regular reviews to confirm allocation in agreement with the agreed upon amounts. In addition, correcting entries for 2024 and 2025 will be made by August 31, 2025.

Management will continue to reinforce utilization of the time tracking system that was implemented in 2024. In addition, management will ensure that the timecards submitted by staff are reviewed and approved timely.

Gateway Domestic Violence Services, in 2024, was utilizing paper timesheets that included the funder allocation for each staff person. The funder allocations were then entered into QuickBooks spreadsheets. In February of 2025, we engaged with Paychex Payroll Services which utilizes simple online software built to streamline payroll and automate taxes. It does include a job costing process that allows for identifying payroll costs to be distributed appropriately to funders. This electronic payroll system decreases the chances of human error. Also in August of 2025, there is a change in personnel to Finance & Operations Director rather than Finance and Operations Manager. The new position comes with increased responsibilities and increased skills. This position will be responsible for reconciling payroll allocations from Paychex to Payroll allocations in QuickBooks to government funding reports to ensure accuracy. These changes along with the systems that we have had in place should help prevent this issue from being repeated.

2024-001. Allowable Costs/Cost Principles United States Department of Health and Human Services, Substance Abuse and Mental Health Services Administration Passed Through Vibrant Emotional Health: Substance Abuse and Mental Health Services Administration - 988 National Suicide Prevention Lifeline ALN: 93.243 Substance Abuse and Mental Health Services Administration - Disaster Distress Helpline ALN: 93.243 Passed Through New York State Office of Mental Health: Substance Abuse and Mental Health Services Administration - 988 S11MY1 ALN: 93.243 Condition: Time records prepared by employees reflect the total hours worked for the day, but do not reflect the actual time spent on programs funded by each federal award, rather they are based on budgeted hours. Recommendation: The Organization’s use of Personnel Activity Report (PAR) equivalent documentation should allow each employee to accurately reflect the time work is performed for each federal award. Corrective Action: The Organization will complete the implementation of procedures for its time keeping records, which will provide information for PAR equivalent documentation. Actual time worked performing duties funded by each federal award will be reflected. Responsible Contact Person(s): Meryl Cassidy, Executive Director Response of Suffolk County, Inc., - P.O. Box 300 - Stony Brook, New York 11790 Anticipated Completion Date: December 31, 2025.

Management Response: We have had significant turnover in HR and Payroll and documentation was not maintained properly. We have a new HR Director and new Payroll Manager who will work closely together and are aware of record keeping and maintaining files for compliance. A checklist has been created to ensure all required documents are on file. Anticipated Completion Date: We are conducting a file review and will ensure all documents are in order by September 30, 2025. Responsible Party: HR Director, Payroll Manager, Benefits Coordinator and Business Manager will have oversight.

Reference # and title: 2024-004 Controls and Compliance over Disbursements Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Title I 84.010A 2024 COVID-19 Education Stabilization Funds: Education Stabilization (ESSER II) 84.425D 2021 Education Stabilization (ESSER III) 84.425U 2021 United States Department of Agriculture; passed through Louisiana Department of Education Child Nutrition Cluster: School Breakfast Program 10.553 2024 National School Lunch Program 10.555 2024 Criteria or specific requirement: Sound internal controls over federal program require that expenditures be made in accordance with the federal program budgets, properly documented and recorded. Additionally, 2 CFR section 200 requires nonpayroll expenditures over the micro purchase threshold be adequately vetted with a competitive process such as quotes or bids. Additionally, for an employee who works in part on a federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources, the School Board must maintain time and effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the portion of time and effort dedicated to (a) the consolidated cost objective, and (b) each program or other cost objective supported by non-consolidated Federal funds or other revenue sources. Employee pay should be reviewed to ensure that payment amount is correct. Employee attendance should be documented on a consistent basis. Condition found: In testing expenditures over federal programs, the following exceptions were noted: Title I: In testing 19 payroll transactions for the Title I program, there were 4 exceptions noted where the time certifications were completed, but not in a timely manner. Child Nutrition: In testing 17 payroll transactions for the Child Nutrition program, the following exceptions were noted:  3 exceptions noted where the time certifications were completed, but not in a timely manner.  3 exceptions noted where the timesheet for the employee was not reviewed by a Supervisor.  5 exceptions noted where the employee was not paid in accordance with the salary schedule. This related to 3 employees in which the employees were underpaid. In testing 23 vendor disbursements, it was noted that travel reimbursements are paid annually and not on a timely basis. Education Stabilization: In testing 17 payroll transactions for the ESSER programs, the following exceptions were noted:  2 exceptions noted where the employee was not paid in accordance with the salary schedule. This related to 1 employee in which the employees were underpaid. In testing 23 vendor disbursements for the ESSER programs, the following exceptions were noted:  1 exception noted in which the purchase could not be traced to the approved budget.  9 exceptions noted in which the School Board could not provide any support reflecting quotes were obtained before the purchase was made. Corrective action planned: The School Board will correct this immediately. We will have time certifications done on a timely basis and all timesheets reviewed by a supervisor. Payroll will be checked that it is being paid by the corresponding salary table. Travel will be required to be submitted and paid monthly. Quotes will be acquired when needed.

Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. The Organization has made efforts to ensure that proper documentation is maintained and accessible by necessary staff.

View of Responsible Official (This was implemented at the end of the 22/23 Audit, however, that audit was completed after the beginning of the next fiscal year. Therefore, the timing overlapped, and the changes implemented were not yet evident at the beginning of the new fiscal year.) Currently, based on the capacity of the Organization’s staffing pool, the most efficient and effective means of review and reconciliation of cash disbursements and payroll is the Organization’s Board Chair and CEO reviewing the cash disbursements and payroll every two weeks, prior to payments being made. The Organization’s Director of Operations forwards the Board Chair and CEO a listing of cash disbursements and payroll due with the suggested payments. The Board Chair and CEO each will ask questions and formally “approve” or “disapprove” each transaction, prior to any disbursements. Once reviewed, the CEO will return the reviewed materials to the Director of Operations with the amounts to pay. Also, the Organization’s outsourced accountant will review and approve each monthly bank reconciliation and bank statement for all Organizational accounts, as well as the monthly credit card statements. The outsourced accountant does not have the ability to access the monthly bank statements or make purchases.

CORRECTIVE ACTION PLAN July 17, 2025 Health Resources and Services Administration Jewish Child Care Association of New York (d/b/a JCCA) and Affiliated Organization respectfully submits the following corrective action plan for the year ended June 30, 2024. ____________________________________________________________________________________ CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2024 The findings from the June 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT FINDINGS Finding 2024-001 – Account Analyses MATERIAL WEAKNESS Recommendation We recommend that the Agency implement policies, procedures and controls to ensure that all accounting records are analyzed and reconciled on a monthly basis. In addition, the Agency should follow the policies and procedures for the proper and timely review of all journal entries. The personnel reviewing the journal entries should agree the journal entries to the source documents or underlying support and should document his or her review of the journal entry. Action Taken Management of the Agency is in agreement with this finding. The Agency experienced turnover in key positions of the finance department and therefore they have outsourced their finance function to BTQ Financial from the end of November. BTQ is focusing on the implementation of reconciling the accounts on a more routine and timelier basis which is consistent with financial policies and procedures of the Agency. Revised Policy and Procedures that incorporate this finding will be in place by 8/1/2025. Finding 2024-002 – Information Technology – General Control Activities SIGNIFICANT DEFICIENCY Recommendation We recommend the Agency follow their policy for password age. We also recommend that the Agency enable multi-factor authentication. Lastly, we recommend the Agency perform a risk assessment over the information technology environment. We recommend a written risk assessment and penetration test to be performed annually and vulnerability scans to be performed quarterly. Action Taken Password policy had been updated with stricter complexity and retention requirements, aligning to or exceeding best practices. Multi-Factor Authentication (MFA) had been implemented on all VPN and remote access to JCCA resources. HIPAA Risk Assessment will be completed by July 31, 2025. A SOCaaS (Security Operation Center as a Service) with continuous internal and external vulnerability scanning and assessment will be implemented by July 25,2025. A contract to purchase network security and email security solutions was signed and will be implemented in October 2025. Penetration testing is planned for Q1 2026 after all the mentioned security enhancements are in place. FINDINGS – FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, Unaccompanied Alien Children Program (Assistance Listing Number 93.676), FAIN # 90ZU0385, 90ZU0603, 90ZU0567, and 90ZU0536, for FY 2024 - Significant Deficiency Finding 2024-003 – Procurement, Suspension and Debarment Recommendation We recommend that the Agency train its personnel in relation to the exclusion screening and proper documentation thereof and that the Agency conduct regular reviews to ensure the completeness of exclusion search documentation. Action Taken As per the Purchasing policy, new vendors are sanctioned by the Purchasing department prior to the creation of a purchase order. Compliance conducts a monthly sanction review of all vendors. Sanction checks have now been completed for the vendors previously missed, and we have strengthened internal controls to ensure all newly added vendors are screened moving forward. In addition, employees whose salaries are charged to federal grants are also subject to suspension and debarment checks. JCCA ensures to actively conduct these checks in compliance with federal regulations. U.S. Department of Health and Human Services, Unaccompanied Alien Children Program (Assistance Listing Number 93.676), FAIN # 90ZU0385, 90ZU0603, 90ZU0567, and 90ZU0536, for FY 2024 - Significant Deficiency Finding 2024-004 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Recommendation We recommend that the Agency strengthen their internal control policies and procedures to ensure that the allocations per the time and effort attestation forms agree with the amount charged to the grant per the general ledger. Action Taken We acknowledge the recommendation and recognize the importance of aligning time and effort attestations with the amounts charged to grants in the general ledger. We ensure that any changes to employee allocations are reflected timely in our payroll and accounting systems to maintain consistency between documentation and financial records. Additionally, we are reviewing our internal controls and procedures to identify any process gaps and reinforce communication between HR, Payroll, and Finance teams. Going forward, we will enhance oversight to ensure that updates related to employee funding sources are promptly recorded, which will help maintain accurate grant reporting and compliance with applicable regulations The anticipated completion date of this action is August 1, 2025. If the Health Resources and Services Administration has questions regarding this plan, please call Kenneth Shieh, Chief Administrative Officer at (718) 747-4367. Sincerely yours, Signature:  Name: Kenneth Shieh Title: Chief Administrative Officer

Corrective Action Plan for Current Year Findings 2024-001 - Internal Control over Payroll Major Program: AL#93.569 - Community Service Block Grant Corrective Action Plan DONNA M. KELLEY, LCSW President & CEO Waldo CAP was finally able to hire an additional Human Resources staff member in May of 2025, who will complement our current payroll review process by adding a second layer to ensure not only the accuracy of the Wage Change of Status form (among other enhanced review duties) but to also ensure the completeness of the form including required signatures. Person(s) Responsible: Katie Bagley, Human Resources Director Timing for Implementation: August 1, 2025

Corrective Action Plan Year Ended December 31, 2024 Findings Related to the Financial Statements Reported in Accordance with Government Auditing Standards None Findings Related to Federal Awards 2024-001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: U.S. Department of Homeland Security: Passed through the State of New Jersey, Department of Law and Public Safety Program Titles and Assistance Listing Numbers (ALN): Disaster Grants – Public Assistance (Presidentially Declared Disasters) – ALN 97.036 Federal Grant Numbers: State of New Jersey pass-through number: UH1WX, Project #2365 – Award Year 2024 (Application 696220) Contact Person: Donna Wilser, Deputy Executive Director, 732-750-5300 Corrective Action: Management agrees with the finding. Beginning in December 2024, as a commitment to strengthen our processes and ensure that all physical timesheets related to FEMA-declared disaster events are properly maintained and readily accessible, management put a process in place to enhance procedures and controls for timesheets going forward to ensure full compliance with the Uniform Guidance requirements. This process was successfully implemented as of this date and for prospective periods. However, this process does not remedy the issue noted in the finding which relates to time worked from 2020-2022, which is before the process was in place. Therefore, the finding is repeated from the prior year. Anticipated Completion Date: Completed

Payroll and Human resources will adhere to established policies and procedures and improve internal controls policies ensuring timecards are reviewed and approved by appropriate supervisors before payroll processing. Personnel Action Forms (PAFs) will be required for part-time employees along with full-time employees and regularly updated to reflect on any salary step or compensation changes. Finance and HR staff will periodically review payroll records and ensure accuracy of positions, pay, step, and general accounting cost center allocations. Responsible Persons: Alvaro Castellon – Director of Finance & Ela Pappo – Director of Human Resources Date of Implementation: June 30, 2026