Corrective Action Plans

Since January of 2024, CRA has done the following: Created a Human Resources Department, which did not exist before. Hired a Full Time Human Resources Director to oversee the department. Initiated a comprehensive Human Resources system where staff can review their pay, track their time, and review benefits. Initiated the process of uploading personnel information to our new system, while keeping backups secured in our Google Nonprofit workspace - including hiring documentation and change of status forms for employees.

Finding 2023-002 Assistance Listings: 93.567 & 93.576 Issue: Inadequate timekeeping allocation procedures. We respectfully acknowledge the finding inadequate allocation procedures, and we offer the following clarifications. Corrective Actions 1. Payroll System Upgrade – Implementing UKG with grant allocation fields (configuration underway). 2. Manager Review Cycle – Monthly allocation reports auto-sent to managers; signed approvals returned to Accounting. 3. CFO Review & Sign-off – CFO verifies and finalizes allocations before posting to FundEZ. 4. Written Policies – Comprehensive timekeeping and allocation manual (draft completed; final issue by July 15 2025). Responsible Official: Renee Carroll, CFO Target Completion: System live and policies finalized by July 30, 2025.

Views of Responsible Officials: Management has implemented mandatory on-boarding training and annual training of all staff on overall grant management, with a focus on compliant entry of time and effort. New budgeting and forecasting tools and processes have been implemented to allow more effective and timely monitoring of expenditures. In addition, CIPE has reviewed and revised relevant policies to ensure they align with best practices. CIPE worked closely with stakeholders on all these remedial efforts.

Twin Oaks has updated their payroll provider to Paylocity as of 4/1/2024. This change has given us better oversight and documentation of hours worked at all our programs. Benjie Read CFO and Felecia Read Staff Accountant, will educate the payroll staff on federal and state requirements for payroll allocations within 90 days of audit completion.

U.S. Department of Commerce, Philadelphia Works, Inc. 2023-2 Direct Labor Costs – Assistance Listing Number 11.307 Recommendation: We recommend that the PALM utilize a time management software which integrates with their payroll processing, to easily identify direct labor costs related to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented a new time management software in 2025 to track and manage direct labor costs relating to the administration of federal programs.

The Auditor’s Office will work with the Commissioner’s Office and Prosecutor’s Office to implement the required policies.

Finding Number 2023-213 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action 1. Implementation of Time Distribution Record (TDR) Procedures: OSDE has adopted the Time Distribution Records (TDR) procedures as outlined in the ESEA Consolidated Monitoring Toolkit and the "Time Distribution Records" presentation provided to districts on October 3, 2023 . These documents establish that all employees whose salaries are funded by federal programs must document their time and effort based on actual work performed, not budget estimates. 2. Required Documentation from Subrecipients: Going forward, LEAs will be required to submit certified time and effort records using the templates provided in the ESEA Resource Toolkit (June 2024) . These forms are designed to ensure: o Records are maintained for employees working on a single or multiple cost objectives. o Monthly or semi-annual certifications, depending on the funding structure, are completed by employees and supervisors. o Reconciliations are conducted to adjust salary allocations if actual time varies from budget estimates. 3. Training and Technical Assistance: OSDE's Office of Title Services will conduct training sessions and provide technical assistance to LEAs to ensure proper understanding and implementation of the TDR process. OSDE will also establish a central repository to track and audit submitted TDRs. 4. Monitoring and Compliance Checks: A risk-based monitoring system will be implemented to conduct periodic reviews of LEA payroll reimbursements. During desk reviews and on-site monitoring, OSDE will verify that certified time and effort records support all payroll expenditures submitted for reimbursement. 5. Policy Revision and Dissemination: OSDE will revise its federal programs procedures manual to formally include the updated TDR requirements. This policy will be shared with all LEAs and included in routine programmatic updates. These steps demonstrate OSDE’s commitment to compliance and accountability. We believe that the implementation of the certified time and effort process will provide sufficient assurance that payroll reimbursements are accurate, allowable, and appropriately allocated under Assistance Listing Number 93.323. Anticipated Completion Date 6/30/2025 Responsible Contact Person Kellie Carter, Program Manager, School Health Services

Finding Number 2023-047 Subject Heading (Financial) or AL no. and program name (Federal) TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES AL #84.010 SPECIAL EDUCATION IDEA PART B & PRESCHOOL AL #84.027; 84.173 AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425U) Planned Corrective Action The Office of Title Services will ensure that our department completes and collects Time and Effort records semi-annually. The Office of Special Education Services will ensure that this department completes and collects Time and Effort records semi-annually. Anticipated Completion Date Jan-2024 June-2025 Responsible Contact Person Tammy Smith Sherri Coats

Finding Number 2023-088 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action Condition and Context: When reviewing SFY23 payroll administrative expenditures, we noted that Communities Foundation of Oklahoma paid $2,372,400 in bonuses to 146 employees. Of these bonuses, 47 people received between $10,000 - $19,999, and 44 people received more than $20,000. We found the expenditures to be unallowable; we found no guidance that stated ERA administrative funds could be expended on bonuses. • Community Cares Partners (CCP) was established as a temporary, emergencyresponse initiative tasked with administering Emergency Rental Assistance Program (ERAP) funds on behalf of the State of Oklahoma and multiple jurisdictions. Although initially conceived as a short-term project, CCP ultimately administered nearly $150 million in federal funds over multiple years in response to a historic public health and housing crisis. To meet U.S. Treasury mandates to rapidly disburse funds—or risk recapture—CCP had to scale quickly, adapt continuously, and deliver results under unprecedented pressure. The complexity of federal guidance, evolving compliance expectations, and intense audit scrutiny required a workforce that was agile, highly skilled, and capable of operating in a fast- paced, high-stakes environment. To achieve this, Communities Foundation of Oklahoma (CFO), as CCP’s fiscal sponsor, implemented an innovative staffing model in which all CCP team members—including leadership—were engaged as independent contractors. This model allowed for rapid onboarding and deployment of services without placing undue strain on CFO’s internal team or disrupting the core functions of other nonprofit and government agencies during the pandemic. However, because these contractors were not employees, they did not receive traditional benefits such as health insurance, paid time off, or retirement contributions. To support retention, motivation, and high performance in the absence of such benefits, CCP established a performance bonus structure, as outlined in its “Fee-for-Services Rendered” policy. Bonuses were based on merit and tied directly to both individual and team accomplishments. Performance Bonuses Were Structured, Purposeful, and Aligned with Program Goals Bonuses were awarded in recognition of critical achievements, such as the complete spend-down of ERA-1 funds before the federal deadline—a milestone that required sustained, coordinated effort well beyond routine contract deliverables. These incentives were calculated using a combination of objective factors, including: · Tenure with the organization (recognizing longterm commitment); Recommendation of the team director (based on direct performance observations); · Average weekly hours worked (accounting for parttime vs. full-time contributions); · Pay rate and level of responsibility (reflecting role complexity and expectations); · Performance indicators such as quality of work, accuracy, initiative, leadership, teamwork, positive attitude, and contributions to process improvements. Bonuses were not automatic or uniformly distributed. Rather, they were awarded based on documented performance and in alignment with the responsibilities and accomplishments of each contractor. The process involved director-level recommendations and required approvals from CCP’s Chief Operating Officer and the Executive Director of CFO, ensuring appropriate oversight and accountability. Allowability Under Federal Guidelines While the ERA guidance does not specifically address performance bonuses, U.S. Treasury FAQs instruct grantees to establish their own internal policies and procedures—consistent with the statutes—and to follow them consistently when specific guidance is not provided. CCP’s bonus practices followed this directive. Moreover, the incentive structure aligns with the principles in 2 CFR § 200.430(f), which permits incentive compensation when it is reasonable, tied to performance, and paid pursuant to a good-faith agreement established before services are rendered. These bonus payments were not arbitrary. They were essential tools for incentivizing high-quality performance, encouraging efficiency and innovation, and sustaining a capable team during a national emergency. Each bonus was grounded in documented policy, approved through established protocols, and tied to clearly defined. For 4 of 116, or 3.45% of claims tested, the contract was for an unreasonable rate and the invoices provided were not itemized and specific enough to determine if the time spent was for an allowable activity related to ERA 1 or ERA 2. • The contract rates for CCP’s executive leadership—specifically, Executive Director and Chief Operating Officer were reasonable and justified given the scope of responsibility, experience, and industry standards. Both leaders operated as full-time independent contractors (a structure applied to all team members at CCP), and neither received employee benefits such as health insurance or paid time off, which materially impacts total compensation calculations. CCP was a high-capacity public-private partnership program of CFO. CCP/CFO was responsible for administering over $440 million in Emergency Rental Assistance Program (ERAP) funds from the U.S. Department of the Treasury on behalf of the State of Oklahoma and multiple local jurisdictions. CCP executive leadership managed a team of more than 150 individuals and carried out complex, time- sensitive operations to deliver critical housing stability services during the COVID- 19 public health emergency. Industry benchmarks (e.g., Guidestar / Candid data, 990 analyses) show that for nonprofits with comparable annual budgets ($150M+), full-time executive compensation for experienced leaders often ranges from $175,000 to over $300,000 annually— excluding benefits. Both contractors brought more than 15 years of relevant leadership experience and operated within that reasonable range. Their rates reflected both the magnitude of the public responsibility and the demands of launching and managing a large-scale, federally funded program under emergency conditions. Regarding invoice specificity, the submitted invoices reflected agreed- upon deliverables and outcomes consistent with contract terms and allowable activities under federal guidance. While not time-stamped or broken down by hour, they were reviewed and approved based on performance milestones. Additional documentation is uploaded to further demonstrate the alignment of time spent with allowable ERAP administrative activities. Invoices submitted followed the contract terms, including hours rendered. A sample calendar page was provided and redacted for PII. § 200.338 Restrictions on public access to records. For 9 of 116, or 7.76% of claims tested, the payment was for more than the contracted rate. • PARTIALLY AGREE: overpayment of $37 • DISAGREE: see Bonus justification below. • 4.2.22 addendum with $29.60/hr rate • 4.2.22 addendum with $29.60/hr • 4.2.22 addendum with $36/hr rate • 4.2.22 addendum with $31.25/hr rate • 4.2.22 addendum with $29.60/hr rate • 4.2.22 addendum with $38/hr rate • 4.2.22 addendum with $28/hr rate Also see CCP Contractor Increases April, 2022 spreadsheet Attachments OneDrive_1_4-22-2025 OneDrive_3_4-22-2025- Contracts For 23 of 116, or 9.83% of claims tested, the subrecipient was unable to provide a contract for the period paid. • The Independent contractors each signed contracts in 2021 which laid out specific terms and conditions under which the independent contractors would provide their services and be compensated. Although some of these contracts expired, second contracts and/or addendums were signed by those same independent contractors in 2023. The independent contractors continued to work under the same terms and conditions and continued to be paid the same remuneration in the time period between the expiration of the original contracts and when the new contracts and/or addendums were created and signed. According to 15 O.S. Section 133, an implied contract is on where the existence and terms are not explicitly stated but are inferred from the conduct of the parties. Because the original contracts contained the specific terms regarding services and payment and because these independent contractors continued to operate under those same terms and receive payment even in the interim between signed contracts, this shows that an implied contract existed under Oklahoma law. The original contracts expired in 2021 which was at the height of the Covid- 19 crisis. The entities involved were addressing more urgent matters to assist the people of Oklahoma with the objectives of the program and did not have the bandwidth to draft and sign new agreements when responding to more urgent matters. Therefore, given the surrounding circumstances and the overall intent of the parties, it can be logically deduced that an implied contract existed in the interim periods between any expiration of an original contract and the second contract and/or addendum being signed. For 9 of 116, or 7.76% of claims tested, the contract was not signed by the Executive Director and was not valid. • We partially agree the contracts for three are not currently available with the Executive Director’s signature. • We disagree, fully executed contracts for two are available for review in the attachment OneDrive_3_4-22- 2025. For 22 of 115, or 19.13% of claims tested, the payroll cost was allowable; however, the expense was attributable to multiple jurisdictions and only 90.33% of the cost should have been charged to the State of Oklahoma, but the subrecipient was unable to support the allocation was completed and that 100% of the cost was not charged to the State. • See response to audit finding 2023-028 regarding the second Condition and Context. Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. Beginning with FY2025, OMES has taken the following measures: • Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience. • To ensure that the subrecipient agreement includes all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) have recently executed a Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies. See Attached – Grant Agreement Amendment. • OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed. • OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multilayer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES-GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements. • Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMES-GMO conducts bi-weekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek

Corrective Actions Taken or Planned Management concurs with the finding and has already initiated enhancements to its review process to ensure that expense reports are consistently reviewed and approved by both supervisors and finance personnel prior to being charged to federal awards. These steps are designed to further strengthen internal controls and support compliance with federal requirements. In addition, Finance staff are formalizing procedures to reconcile payroll charges on a regular basis to ensure compliance with federal requirements and to confirm that all charges to federal programs are supported by actual time and effort records. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: October 31, 2025

2023-006 – Payroll (Material Weakness in Internal Controls over Compliance/Material Noncompliance) Recommendation: We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts. Action Taken: The 2022-2023 fiscal year was entirely encompassed by the separation Memorandum of Understanding (MOU) of March 2022 and then the final release settlement in December 2023. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Unfortunately, due to the untimely receipt of the completed audit report, the College did not have the opportunity to review and begin addressing several of the findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. Corrective Action Taken / Planned: • Policy and Procedure Development o The institution will revise or develop written policies and procedures to ensure compliance with 2 CFR §200.430. The revised procedures will include:  Detailed requirements for supporting documentation for payroll costs.  Clear guidance on time and effort reporting  Procedures for periodic payroll reconciliation between payroll records and grant charges. • Staff Training o Training will be provided for payroll, grants accounting, and department personnel involved in charging payroll costs to federal awards to ensure understanding and compliance with the new procedures. • Payroll Reconciliation o A process will be established to reconcile payroll charges to the grant with actual payroll records at least quarterly, with reviews and approvals documented. • Effort Certification o Employees whose salaries are charged to federal grants will be required to complete effort certifications, which will be reviewed and retained per federal guidelines. • Monitoring and Review o Grant accounting and payroll offices will implement an annual review to ensure continued compliance and address any gaps or errors identified. Due Date of Completion: August 31, 2025 Responsible Official: Carolyn Kasdorf, Vice President for Business and Finance (or appropriate official), Karla Volpi, Dean of Business and Finance, Lisa Ryan, Restricted Funds Manager, Steven Gonzales, Payroll Manager

The District received the findings. We have implemented the requirement for all staff working under federal programs to complete Time & Effort and/or Semi-Annual Certification Documents.

Criteria: Recipients of federal awards must follow the costs principles set out at 2 CFR section 200.430 to substantiate compensation and other purchases charged to a federal program. “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: …(iii) reasonable reflect the total activity for which the employee is compensated by the non‐Federal entity” 2 CFR section 200.430(i). The Organization’s processes did not maintain sufficient documentation of the approval of the activity of each employee or the purchase of goods/services. Audit Recommendation: We recommend the Organization ensure it 1) maintains records of each employee’s activity and 2) monitors compliance with the job‐costing system implemented. Auditee Response: The Organization believes that leadership/personnel turnover, along with outsourced financial management, allowed paychecks to be approved without the proper approval flow. We have ensured documenation is downloaded/kept each pay period to ensure such documentation is not lost when a change in service provider is made. Corrective Action Plan: UICSL has moved away from its prior payroll processor to better account for these labor allocations and grant classifications. In our FY23 audit, we requested data from our prior processor multiple times. They were unable to provide some of the reports and data which was purged from their system. Our new payroll processor ensures employees' time is allocated to each grant program and there is a designated reporting funcation allowing us to reviews what is assigned. UICSL also has better defined leadership and directors for each division so there are clearly defined approvers and supervisors for each purchase and transaction. Person Responsible: Matt Poss, Executive Director and Eva Leyer, Human Resources Manager Timeline: UICSL transitioned to a new payroll processor at the end of 2023 and Leadership was designated and assigned for 2024.

Finding Number: 2023-005 Planned Corrective Action: The Authority has updated our allocation plan and added actual percentages to the plan. A/P was unaware that all employee benefits were at a different percentage; has since then been remedied. Anticipated Completion Date: April 15, 2025 Responsible Contact Person: Sherrie Boudinot

2023-002 Payroll Costs Contact Person – Erin Metcalf, Finance Director Description of Corrective Action – Training has been provided and currently the payroll allocations are matched to weekly payroll reports from outside payroll company. Allocations of vacation and sick time are done according to actual payroll reports and entered into accounting software based on true numbers instead of tracked on a spreadsheet. Completion Date – June 30, 2025 Root Cause – Outdated procedures in place.

Issue: Summary Condition: The Auditee submitted reimbursement requests to the Mississippi Department of Education (MOE) that were not fully supported: Standard monthly amounts requested for Digital Learning Instructor (DU) labor exceeded actual contract costs, resulting in overstatements. 1 of 60 items sampled lacked support for $11,700 in charges. Cause: The Consortium requested funds before receiving invoices or verifying actual expenses. There was no reconciliation process in place to verify that reimbursement requests matched actual expenditures. Effect: Federal funds were received in excess of allowable costs and not returned to the grantor. These excess reimbursements represent questioned costs which the grantor could request funds to be refunded. Criteria: In accordance with 2 CFR 200.403 and 200.430, costs must be necessary, reasonable, and allocable, and adequately documented to be allowable under federal awards. Questioned Costs: Total known questioned costs are $49,082, which includes: $37,382 related to Digital Learning Instructor (DLI) contract labor, including $34,445 in excess labor charges and $2,937 in related indirect costs. These charges were identified through a 100% review of all DU contract labor activity for fiscal year 2023. $11,700 from a single reimbursement request that partially lacked supporting documentation. This item was identified during testing of a sample of 60 items totaling $6,545,759.87. Response: The Consortium acknowledges the finding and agrees with the audit's assessment. The practice of requesting reimbursement based on estimated monthly amounts without timely reconciliation to actual expenses was not in alignment with federal cost principles under 2CFR 200.403 and 200.430. We recognize that this oversight led to the disbursement of excess federal funds, and we are committed to promptly resolving this issue and implementing strong internal controls to prevent recurrence. Corrective Action Plan: Reconciliation Process Implementation: We have implemented a formal reconciliation process to ensure reimbursement requests are in line with actual cost. This includes reviewing all invoices and matching them to amounts requested. Return of Excess Funds: We are identifying and preparing to return any excess federal funds that were distributed as a result of these overstatements, as part of our reconciliation review. Corrective Action Timeline: The reconciliation process was initiated in June 2025. The return of fund to Mississippi Department of Education will begin with sending the audit report to MDE and getting directions on how to return overstated funds. Responsible Individuals: Mark Brown, business manager, is leading the implementation of the corrective action measures, in collaboration with Projects Coordinator, Susan Scott.

Finding 2023-002 Name of Responsible Individual: Carolina Liriano, Grant Manager; Holly Forester, Controller; Sheri Brady, VP and Chief Program Officer Corrective Action: CDF hired an Outsourced Grant Manager starting January 2025 to oversee compliance and internal control processes for federal awards, ensuring adherence to 2 CFR Part 200. The Outsourced Grant Manager will implement systems to accurately allocate salaries, wages, and other expenditures. Key actions include:  Payroll Expenditures: Establish procedures to approve payroll allocations based on actual time and effort reporting, requiring supervisor approval and periodic reviews for compliance.  Non-Payroll Expenditures: Develop approval processes for non-payroll expenses, ensuring detailed documentation and implementing checks to verify overhead allocations.  Documentation and Review: Implement a comprehensive filing system for approvals and supporting documents, with regular training for staff.  Ongoing Compliance Monitoring: Conduct periodic internal audits to ensure adherence to internal controls and federal regulations, addressing issues promptly. These measures will strengthen CDF’s internal controls, ensure compliance, and maintain the integrity of federal award management. Anticipated Completion Date: December 31, 2025.

2023-006 Management Response: Management respectfully disagrees with this Finding. • Under Condition, the finding states, “Time and effort is being tracked and maintained by employees, including hours charged to the specific efforts for the programs.…” This is not accurate. Employees report their time worked each day, including the amount of time they worked on different projects if applicable. Employees report this in our commercial HRIS/Payroll system, where it is maintained and where it is reviewed and approved by the employee’s manager. The employees report the time they worked and which project(s) they worked on, their managers review and approve the time and the distribution, and the data is tracked and maintained in our HRIS/Payroll system (ExponentHR). • Also under Condition, the finding states, “The specific amount of employee salaries and wages that are allocated to specific federal programs for reimbursement, and which are less than the amounts reflected in time and effort records, are determined by members of the finance staff.” It is correct that we would have to invoice sponsors for less than the total cost of an employee’s allocated time and effort if a sponsor’s budget is not sufficient to cover that full amount. This is the correct procedure to follow. Employees correctly continue documenting their hours worked on a specific project even if the budget is expended and the accounting staff can no longer bill the sponsor. If a particular grant does not have sufficient sponsor funds, then the Grants Accounting staff reduce the bill accordingly. • Also under Condition, the finding states, “The rationale for the amount actually allocated for reimbursement, if less than the amount reflected in time and effort records, is not documented”. This is incorrect. Our monthly invoices to each sponsor accumulate, with each invoice clearly showing not only that month’s expense but also the year-to-date expense and remaining balance, which forces the sponsor invoice to stop at an amount less than the total cost of employees’ time and effort when the budget is exhausted. • Also under Condition, the finding states, “Review and approval of the allocation of employee compensation to specific federal programs reimbursement requests is not maintained.” Each employee records their hours worked, and the project(s) on which they worked those hours, in our HRIS/Payroll system. The employee’s manager reviews and approves both the hours worked and the projects on which the hours were worked. This review and approval is maintained in our HRIS/Payroll system. Financial staff calculate the amount to allocate to specific federal programs based on these HRIS/Payroll system records (or other records such as clinical units produced, based on the terms of each grant). Separate accounting staff review the sponsor invoice and post the Receivable once they deem the invoice correct. • Under Cause, the finding states, “…..the Organization has not implemented a structured process for documenting the extent to which allowable [emphasis added] compensation costs will be allocated for reimbursement to specific federal programs in instances where the allowable compensation cost exceeds the amount allocated for reimbursement.” This means that we do not have a process for documenting how much of a payroll expense already deemed allowable on a particular grant will actually be invoiced there. We disagree and believe that the presence and documentation of a limited sponsor budget, along with cumulative tracking and documentation of compensation expenses against that budget, proves and documents why sometimes full compensation costs are not charged to a grant. • Under Possible Effect, the finding addresses possible effects of “the absence of documented allocation methodologies.” We don’t agree that our process could lead to improper allocation between federal programs (as the finding states) nor to misstating federal expenditures (as the finding states). When a sponsor’s budget is insufficient to cover its appropriately allocated compensation costs, those costs are paid from unrestricted, non-federal funds. As also noted in the finding, no questioned costs were identified.

Description of Finding: Payroll charges for grants were based on a percentage of time reported by employees. The percentage was based on management’s decision and set when budgeting and not based on actual hours worked. There was not sufficient documentation to provide the basis for an appropriate allocation of payroll charges to the federal program. Planned Corrective Action: To ensure accurate payroll allocation to federal programs, YWCA New Hampshire will implement the following: 1. Time and Effort Reporting: Implement a time and effort reporting system by August 31, 2025, requiring employees to track actual hours worked on grant-funded activities weekly. 2. Policy Update: Revise the Payroll Allocation Policy to mandate that payroll charges to grants be based on actual hours worked, supported by time and effort reports. 3. Training: Train all grant-funded employees and supervisors on the time and effort reporting system by September 15, 2025. 4. Certification Process: Require employees and supervisors to certify time and effort reports monthly, with certifications retained for audit purposes. 36 5. Monitoring: The Finance Manager will review time and effort reports quarterly to ensure accurate allocation, with findings reported to the Executive Director. Responsible Party: Finance Manager, overseen by Caroline Catlender, Executive Director Anticipated Completion Date: September 30, 2025

Description of Finding: Payroll documentation was found to be inadequate, as there were missing approved pay rates, lack of supporting documentation for stipends and differentials paid, and timecards submitted which were not approved, mathematically incorrect, and/or which did not agree to the payroll paid. Planned Corrective Action: To strengthen internal controls over payroll, YWCA New Hampshire will implement the following: 1. Payroll Policy Revision: Update the Payroll Policy to require documented approval of pay rates, stipends, and differentials, with all documentation retained in employee files. 34 2. Timecard Approval Process: Implement an electronic timekeeping system by July 31, 2025, requiring supervisor approval of timecards before payroll processing. The system will flag mathematical errors and discrepancies. 3. Training: Provide training for supervisors and payroll staff on the new timekeeping system and documentation requirements by August 15, 2025. 4. Reconciliation Process: The Payroll Coordinator will perform a monthly reconciliation of timecards against payroll records, with discrepancies investigated and resolved before finalizing payroll. 5. Audit Checks: The CFO will conduct quarterly audits of payroll records to ensure compliance with the updated policy, with results reported to the Executive Director. Responsible Party: Payroll Coordinator and Finance Manager, overseen by Caroline Catlender, Executive Director Anticipated Completion Date: August 15, 2025

Views of responsible officials and planned corrective actions: Management acknowledges the oversight in not utilizing timecards for salaried employees whose compensation is charged to federal contracts. To strengthen internal controls and ensure compliance with applicable federal regulations, management is committed to implementing corrective measures. As part of this effort, management will update existing policies and procedures, and will identify and provide targeted training for accounting personnel responsible for allocating salary charges to federal contracts.

Management stated they will purchase a professional time tracking software program to help all employees track their work hours and activities.

Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation and has implemented hiring for temporary work assignments in order to facilitate update. Corrective Action Plan: The HR and payroll software will be updated by the City by December 2025. Planned Implementation Date: December 2025 Responsible Person(s): City Manager

Finding 2023-103 - Allocation of Payroll Costs Determination - Material Weakness in Internal Controls over Compliance Responsible Party: Ervin Reed, Director of Finance Anticipated Completion Date: July 1, 2025 Planned Action: Engage in active and regular conversations with program leadership to ensure that staff are appropriately budgeted to programs based on a pre-determined expectation. Actual time spent will be allocated during the program year, compared to the budget, and adjusted if needed. If administrative staff are budgeted to a program, a time study will be undertaken to determine appropriate portions of time charged.

View of Responsible Official Currently, the Organization’s CEO and the bookkeeper will review each grant’s funding details prior to the grant’s fiscal year to determine how each employee’s salary percentages should be allocated according to the grant contract. Throughout the fiscal year, the CEO and bookkeeper will meet regularly to review and incorporate any new hires to determine how their salary is expected to be allocated. Additionally, the outsourced accountant will review the allocations periodically throughout the year to ensure that it is being done properly. Over the next year, as considered efficient, the Organization will implement a daily timesheet record, which requires each program service employee to classify their daily time between federal grant programs. At the end of each week, staff members will submit their timesheet to their supervisor. The supervisor will review each week’s daily timesheet to confirm the staff are recognizing their activities properly. At the end of each month, the Organization’s outsourced accountant, will review these timesheets and determine the proper allocation needed to record each employee’s payroll activities in the accounting software by appropriate federal program. This process will allow for the allocation of actuals to each federal program by the end of the month.