Corrective Action Plans

Views of responsible officials and planned corrective actions: Management agrees with this finding and will review time certifications in comparison to salaries and wages recorded to federal programs. See 2024-005 for management's detailed action plan surrounding the time certification findings.

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the maintenance, review, and approval of time certifications. See 2024-005 for management's detailed action plan surrounding the time certification findings.

Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the review and approval of time certifications. Action Plan:  Review current staffing for employees paid with federal funds: o To ensure accurate financial reporting, the Finance Team must establish a structured filing system within Google Drive/Team Sheets under Payroll with the following structure: [FY25 / Time Certifications].  Subfolder Structure:  Semi-Annual Time Certs  Monthly Time Certs  Time Certs Internal Audit o Time Certs Internal Audit  Download the Detail Distribution Report for the current year to date.  Add a column identify the Source of Funds based on budget unit coding.  Create a Pivot Table using the Source of Funds column, employee names, and amounts.  Time Certification Requirements: Employees paid with federal funds must complete time certifications.  Less than 100% federal funded: Monthly time certification required.  100% federally funded: Semi-annual time certification required.  One-time stipend from federal funds: No time certification required, but the offer letter documenting the stipend must be saved.  Anticipated completion date of May 15, 2025, with an updated monthly review.  Create, review, and secure signatures for time certs: o All time certifications must be created, reviewed, and signed by both the employee and supervisor as soon as possible.  If a time certification is not received, a payroll redistribution will be required to move the salary out of the federal fund – this is not ideal and should be avoided. o Timely completion ensures compliance and prevents unnecessary adjustments.o Anticipated completion date of May 15,2025, with an updated monthly review.  Conduct a quarterly audit of time certifications and federally funded payroll records: o As stated above, if a time certification is not received, a payroll redistribution will be required to move the salary out of the federal fund, which is not ideal and should be avoided. o The anticipated completion date is May 20, 2025, with an updated monthly review.

Recommendation We recommend that NIYC strengthen its payroll controls by: Implementing a secondary review of WEX timesheets prior to payroll processing, - Requiring all pay rate changes to be documented using standardized personnel action forms, and -Conducting periodic payroll audits to verify compliance with documentation and approval requirements. Management Response Corrective Action: NIYC will strengthen internal controls over payroll by implementing additional monitoring and review processes. Going forward, the HR Accounting Coordinator will be responsible for an annual review of all staff employment files to ensure that all required documentation is present and up to date. Furthermore, no changes will be made to any employee pay rate without prior written approval and documentation using the standardized personnel action form. Once the change has been made in the payroll system, all approvals and documentation for the change in pay rate will be given to the HR Accounting Coordinator to include in the employee's file. We have also implemented a secondary review of WEX timesheets by the Accounting Manager during the payroll process. This should find and correct any errors in the spreadsheet used to summarize the timesheets and process WEX payroll. Due Date of Completion: Implementing new internal controls starting June 1, 2025 Responsible Person(s): Accounting Manager, HR Accounting Coordinator

Recommendation Implement a centralized, access-controlled digital system for participant file storage. Additionally, management should require the use of a standardized eligibility checklist and conduct periodic file audits to ensure documentation completeness and compliance with WIOA requirements. Management Response Corrective Action: In response to this incident, we have reinstated the Eligibility Determination and Intake (EDIR) Form. This form clearly states the participant identification information, the characteristics tracked by our program data management tool (GPMS), and states what has been provided by the participant to determine their eligibility for the program. Provided in a check list format, the form clearly demonstrates what makes the participant eligible for our program services. The form also lists the documentation included in the application that has been provided by the participant. This form added to the program application and maintained in the participant's official record will ensure that all WIOA eligibility documentation has been received, reviewed, and approved at the time of intake. Due Date of Completion: Completed as of May 31, 2025 Responsible Person(s):Director of Programs and Development is responsible for re-instating the use of the form and the Field Office Managers and Job Developers are responsible for filling out the form and including it in the participant's official record.

FA 2024-001 Improve Control over Employee Compensation Compliance Requirement: Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: $102,234 Prior Year Finding: 2023-004 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Corrective Action Plans: The District is developing correction action to strengthen controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: June 30, 2026 Contact Person: Connie Walker, School Nutrition Executive Director Telephone: 678-676-1780 Email: Connie_R_Walker@dekalbschoolsga.org

Corrective action planned: In alignment with 2 CFR 200.430, Housing Connector will develop and implement a formal time tracking policy and procedure to ensure that personnel expenses charged to federal grants are supported by records reflecting the actual time worked on each award.

Finding Reference Number: 2024-007 Description of Finding: Lack of Semi-Annual Certifications for Special Education Personnel (Controls over Compliance - Special Education Cluster) Corrective Action Planned:The district has implemented new procedures for fiscal year 2025 to ensure that semiannual certifications are prepared, signed, and retained for all employees working solely on federal programs, including the Special Education Cluster (IDEA). A tracking system has been established, and staff training has been completed to reinforce documentation requirements. The district will continue to monitor compliance to ensure procedures are consistently applied. Responsible Contact Person: Patrick M. Faour, Interim Superintendent Anticipated Completion Date: August 30, 2025

To address this issure and ensure timely approval of time sheets, the following corrective actions have been implemented and will be maintained: 1. Recurring Communications on Payroll Deadlines: A structured communication schedule has been developed, through which both HR and the CEO will issue regular notices to staff and payroll supervisors. These communications will serve as timely reminders of payroll approval deadlines and emphasize the importance of compliance. 2. Ongoing Training and Support: Staff and supervisors will continue to receive training to address common barriers to timely approvals. On April 28, 2025, a leadership team training was conducted, which included all payroll supervisors. During this session, the importance of timely time sheet approvals was strongly emphasized. This training is part of our ongoing effors to ensure that all personnel involved in payroll processing understand their responsibilities and are equipped to meet them. 3. Escalation and Accountability: A clear escalation procedure has been established for instances where approvals are not completed by the deadline. Repeated non-compliance will result in disciplinary action, as part of a commitment to maintaining accountability. 4. Internal Processing Buffer: An internal buffer has been integrated into the payroll schedule. This allows additional time for finalizing approvals and ensures payroll can be processed accurately and on time. 5. Mandatory Immediate Action: In cases where time sheet approvals are not completed by the specified deadline, both staff and supervisors will be required to take immediate corrective action. This ensures delays are minimized and payroll operations are not disrupted.

Finding Summary: During the testing performed, it was noted that the Organization transferred payroll costs between programs, however, no time and effort certification or equivalent documentation was updated to reflect the changes. Additionally, the transfer of payroll costs between grants was not properly reflected within the accounting system records by grant. These transfers between grants were completed after the end of the fiscal year. Responsible Individuals: Andre Stringfellow, Chief Financial Officer Corrective Action Plan: Management agrees with this finding. Staff will be trained to ensure future changes in payroll costs are updated timely within the system and documentation maintained.. Anticipated Completion Date: August 2025

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization consider updating its cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities, and that are reflective on employees’ time and effort records Explanation of Disagreement With Audit Finding: Management partially agrees with this finding. First, 45 CFR Part 1635 codifies the timekeeping requirement. CLS keeps track of every case and time dedicated by staff in strict compliance with this requirement. Additionally, the distribution of expenses in the general fund, which includes LSC and two other funding sources, represents a fair method and allocation. Regarding the questioned costs, CLS disagrees with the finding of material weakness given the extremely low total dollar value. Action Taken in Response to Finding: The Organization will review this finding and current methodology and propose corrections as part of a broader review of its technologies. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026

BVCASA agrees with the audit finding and is working to complete the final assessment of the unallowable payroll costs and reallocate the expenses to the appropriate programs. Management will self-report on the total impact of the finding to HHSC within 60 days of the date of the audit report. Additionally, management will ensure internal controls are strengthened over payroll processing and adequate reconciliations are performed each pay period to verify that payroll costs are allocated appropriately.

As a corrective measure, BGCPR will take the following actions and will anticipate completing on June 30, 2025: a. Establish clear guidelines for the creation, storage, access, updating, and disposal of records. b. Define retention periods in accordance with legal requirements. c. Develop periodic monitoring procedures to verify record completeness and compliance. d. Implement scheduled internal reviews and standardized checklists. e. Assign specific responsibilities to Human Resources personnel for policy enforcement.

Views of Responsible Officials: Timesheets are now being submitted with every payroll to the proper supervisor for review and signatures.

Finding Number – 2024-001 Procurement Finding & 2024-002 Payroll Finding Planned Corrective Action 1. Policy Development: Draft a comprehensive procurement policy that aligns with federal standards and addresses all required elements, including conflict of interest provisions and procurement methods. 2. Approval Process: Present the drafted policy to leadership or the governing body for review and approval. 3. Implementation: Roll out the approved procurement policy to all relevant departments and stakeholders. 4. Training: Conduct training sessions to ensure staff understand and comply with the new procurement procedures. 5. Monitoring: Establish a system to regularly review procurement activities for compliance with the policy and federal regulations. 6. Implement a system of internal controls to ensure payroll charges are supported by accurate records reflecting actual work performed. This system should include regular reconciliation of estimated payroll allocations with actual time worked and documented certifications by employees or supervisors. Anticipate Completion Date – May 31, 2025 Responsible Contact Person – Monique Langston, Grant Director

The district has reviewed the time and effort issues with the new food service director, and going forward the Treasurer will see that all time and effort sheets are signed by both the employee and supervisor.

Finding 2024-005 Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Assistance Listing No.: 97.036 Federal Grantor: U.S. Department of Homeland Security Passed-through: County of El Dorado, California Award No.: FEMA 5302-FM-CA, LEMA Year: 2024 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Material Weakness in Internal Control Over Compliance and Material Noncompliance Department’s Management Response: Ventura County Sheriff’s Office’s (VCSO) management agrees with the recommendation to implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval. View of Responsible Officials and Corrective Action: To ensure compliance with program policies and requirements, VCSO management has developed a Reimbursement or Invoice Review form to document the internal review of cost allowability and cost calculation accuracy for reimbursements. The use of the Reimbursement or Invoice Review form will ensure that claims and invoices are properly reviewed and approved by a supervisor or fiscal grant manager. VCSO management understands the complexity of the manual calculations of claims and reimbursements for salaries and benefits. Additional training will be provided for all VCSO fiscal grant managers and accounting staff on the calculation of salaries and benefits. Name of Responsible Persons: Amber Butler, VCSO Director of Finance Implementation Date: April 1, 2025, Implemented the usage of the Reimbursement or Invoice Review Form April 30, 2025, Salaries & Benefits Training

Finding 2024-003 Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Year: 2024 Compliance Requirement: Activities Allowable or Unallowed and Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance Department’s Management Response: VCPH Management agrees with the recommendation to strengthen the established policies and procedures to ensure that all timecards consistently document evidence of supervisor approval. View of Responsible Officials and Corrective Action: To ensure compliance with timecard approval policies, VCPH Management will take steps to strengthen oversight and accountability. Health Care Agency’s payroll personnel currently sends email reminders to supervisors, managers, and VCPH Management before and after the close of each pay period to identify any outstanding unapproved timecards. Management will reinforce the importance of timely approvals by providing additional training for supervisors and managers. In cases where a supervisor is unavailable, an existing alternate approver process is in place and will be utilized to ensure timely approval. VCPH Management will monitor adherence to these procedures and ensure all timecards are approved promptly. Name of Responsible Persons: Laura Flores, Manager, VCPH Rigoberto Vargas, Director, VCPH Implementation Date: May 1, 2025, instructions to be provided to all supervisors at a WIC Supervisor Team Meeting.

MVRTD is in the process of procuring and implementing software that will be managed regularly to ensure that the general ledger reflects the allocation and disbursements that will assist in reconciling the payroll costs with the grant budget. MVRTD will assign different individuals to handle payroll preparation, approval, and reconciliation.

RIDOH agrees with the finding and recommendation. Corrective action plan: • In gathering time sheets for the requested audit samples, RIDOH found that some Master Time Sheet Coordinators (staff responsible for receiving signed time sheets, populating the Master Time Sheet spreadsheets sent weekly from/to HR/Payroll, and saving time sheets to the Time Sheet Repository in Teams) were saving documents locally instead of in the central Teams site. RIDOH is providing training and increased oversight of the non-compliant Time Sheet Coordinators and is conducting ongoing checks of the time sheets uploaded to Teams weekly to assure the time sheets are saved properly. • Instructions have been provided and will be reiterated Department-wide that all time sheets must be signed and dated by both the employee and supervisors, and signatures without dates are not acceptable. • RIDOH will adjust the questioned costs for ELC and DWSRF to appropriate non-federal funds. • RIDOH has been working to move staff that use the general category codes (i.e., EH Management & Leadership) to non-federal funding sources as much as possible and will begin requiring staff on federal funds to record their hours for each federal grant separately. This is a complicated process and will be fully implemented once Time and Effort reporting is transferred to Workday (the ERP). Anticipated Completion Date: The first three bullets above will be completed by June 30, 2025. Transition of Time and Effort reporting to Workday has been delayed, and the new target implementation date has not been announced. Contact Persons: Alisha Colella, Chief Financial Officer, Department of Health alisha.colella@health.ri.gov Carla Lundquist, Deputy CFO / Federal Grants Manager, Department of Health carla.lundquist@health.ri.gov

Georgia Tech management agrees that internal audit reports demonstrated departmental deficiencies in knowledge of policies and procedures that needed to be addressed. Upon disclosure of Internal Audit’s recommendations, the departments and central offices immediately responded with additional training, proactive compliance reviews, and re-enforcement of existing policies and procedures via Institute wide communications and enhanced reviews of support. New system controls regarding spend authorizations were put in place, with Georgia Tech’s Internal Audit department continuing to test these controls through the month of February. Central and departmental units within Georgia Tech will continue to work together to further enhance guidance and training to faculty and staff and to identify and test controls in our systems that will mitigate these issues.

March 21, 2025 CORRECTIVE ACTION PLAN Pursuant to federal regulations under Uniform Administrative Requirements (2 CFR § 200.511), the following finding was noted in Manistee County’s Single Audit report for the year ended September 30, 2025, along with the corresponding corrective actions to be implemented. Finding: 2024-001 – Child Support Services - Unallowable Costs Auditor Description of Condition and Effect: During the audit of Manistee County’s Child Support Services federal grant expenditures, it was determined that the County lacked effectively operating controls to ensure that salary and wage expenses charged to the Child Support Services program were allowable and properly allocated. As a result, the County received an overpayment of federal funds of $5,528.41 during FY 2024. Auditor Recommendation: It is recommended that the County take actions to strengthen internal controls over payroll expenditures related to federal grants to ensure compliance with federal cost principles and proper expense allocation. Corrective Action: We agree with the finding and will strengthen internal controls over payroll expenditures related to federal grants. We will implement written policies and procedures, provide staff training on federal cost principles, and establish a review process to ensure salary and wage expenses are properly documented and allocated. Additionally, we will work with the grantor agency to resolve the $5,528.41 overpayment. Responsible Person: Susan Zielinski, Finance Director Anticipated Completion Date: September 30, 2025

The University concurs with the recommendations. The University will review and enhance its procedures and internal controls to monitor or ensure the completeness and accuracy of all federal grants, to ensure they are separately recorded within the general ledger and all expenditures and activities are processed in accordance with applicable federal guidelines. The University will implement effort reporting procedures for the SNAP Cluster program that include accounting for all employee activities for the program and implement appropriate controls to ensure costs charges to the SNAP program are based on actual costs incurred and are properly determined and calculated based upon the Uniform Guidance allowable costs criteria.

FINDINGS – Single Audit Audit Finding Summary: 2024-001 The organization failed to implement adequate internal controls to ensure compliance with federal timekeeping and documentation requirements for personnel expenses. Additionally, there appears to be a lack of understanding of the documentation and certification requirements under 2 CFR Part 200, Subpart E. Corrective Action Plan: Contact Person Responsible for Corrective Action: Marilyn Lovelace-Grant, Chief People and Culture Officer marilyn@movementstrategy.org | (510) 414-2674 Planned Action: MSC acknowledges the importance of accurate time and effort reporting in accordance with 2 CFR 200.430. To address the identified deficiencies, we will implement the following corrective measures. Policy and Procedure Enhancement: MSC is developing and implementing updated policies to ensure compliance with federal grant requirements. Employees who charge 100% of their time to a federal grant will be required to submit semi-annual certifications, while those working across multiple activities will maintain detailed time and effort reports aligned with federal guidelines. Improved Documentation and Controls: A standardized timekeeping and certification system will be enforced, requiring supervisory review and approval for all-time records. This will ensure that all reported work is properly documented and verified. Training and Compliance Monitoring: MSC will provide training for employees and supervisors to enhance their understanding of federal grant timekeeping and documentation requirements. Regular Internal Reviews: A periodic internal review process will be established to verify the accuracy and completeness of timekeeping records and ensure compliance with federal regulations. Resolution of Questioned Costs: MSC will work directly with the federal awarding agency to resolve the identified $50,000 in questioned costs and implement any additional corrective actions deemed necessary Expected Completion Date: September 30, 2025

Education Stabilization Fund – AL #84.425 2024-004 Noncompliance – Payroll Allocation Support Significant Deficiency Recommendation: The Auditor recommended the Organization develop internal controls to ensure proper documentation to support the allocation of payroll is maintained. Planned Corrective Action: Due to personnel changes, the necessary documentation of payroll allocations was not properly maintained. Clear records, with support regarding how amounts were determined for each payroll, shall be documented and matched to accounting files. Michelle Krauter, VP, Chief Financial Officer, will ensure the work performed and corresponding wages applicable to the grant programs is not only within budget but easily identifiable as a proper calculation. www.herronclassical.org Diverse. Tuition-Free. College Prep. If the U.S. Department of Education has questions regarding this plan, please call Michelle Krauter, Vice President, Chief Financial Officer at 317.231.0010