Corrective Action Plans

Finding 2024-003 Name of Responsible Individual: Tamara Hill, AVP Research Operations and Finance Corrective Action: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025. Anticipated Completion Date: June 30, 2025

Plan: 1. Internal Control Review: Fiscal staff must upload appropriate documentation, such as an invoice, for each expense entered into QuickBooks. Each of these expenses is then reviewed by a member of the executive team, making sure allocations are appropriately recorded. 2. Training and Awareness: OBT has provided training to all relevant personnel, especially those involved in procurement, expenditure documentation collection, and allocation designation to ensure they understand the requirements of federal awards and the importance of proper documentation. 3. New Technology: OBT Has purchased new technology to better support documentation collection and allocations for all orders made. 4. Continuous Monitoring: OBT is continuously monitoring compliance with allowable cost principles, identifying any gaps, and taking corrective actions as needed. Name of Contact Person: Greg Rideout, Co-CEO Target Date: OBT will implement all four steps within this plan by March 31, 2025, with ongoing monitoring and improvement.

Finding 2024-002, Timesheet – Timekeeping (Assistance Listing 16.575 and 93.696) Persons Responsible: Irene Math, Chief Financial Officer, Jessica Schneibolk Controller Comment: Per 2 CFR § 200.430 requires that the distribution of salary and wages charged to federal awards be based on actual employee activity as reflected in personnel activity reports (timesheets), prepared after-the-fact, and includes the total activity for which employees were compensated. Response: In January 2025, WJCS implemented an automated time and attendance system for staff to track time which integrates with the payroll and financial systems to ensure appropriate allocations to Federal awards. Prior to implementation of the new system weekly manual timesheets were used to track staff time and attendance on Federal contracts. However, these manual timesheets were not integrated into a standard agency-wide payroll processing system. The new system enhancements to payroll tracking will allow WJCS to completely and accurately allocate payroll costs to grants with fewer mechanical steps which increase the risk of miscalculations. Estimated Completion Date: The agency-wide time and attendance system was implemented in January 2025.

2024-001 - Allowable Costs/Cost Principles – Internal Control and Compliance over Payroll Expenditures (Significant Deficiency) Condition: Community Development Block Grants-Entitlement Grants Cluster During the audit period, the City has required all Housing Department staff, including administrative support staff, to fill out project activity timesheets reflecting the actual hours worked on the program. The City performed reconciliation on the staff payroll charges to reflect actual hours worked. However, not all staff members have fully complied with this policy. Payroll costs for the fourteen (14) out of forty (40) payroll samples tested were allocated to programs based on percentages provided by management. These allocations were not supported by approved time samples or updated cost allocation plan, nor were they reconciled to actual time spent on the various programs. Employee timesheets did not record the actual labor efforts expended on the grant. Housing Voucher Cluster During the audit period, the City has required all Housing Department staff, including administrative support staff, to fill out project activity timesheets reflecting the actual hours worked on the program. The City performed reconciliation on the staff payroll charges to reflect actual hours worked. However, not all staff members have fully complied with this policy. Payroll costs for the thirteen (13) out of forty (40) payroll samples tested were allocated to programs based on percentages provided by management. These allocations were not supported by approved time samples or updated cost allocation plan, nor were they reconciled to actual time spent on the various programs. Employee timesheets did not record the actual labor efforts expended on the grant. Management concurs. Corrective Actions: Management has enforced the existing policy, which mandates that employees funded by federal grants document the actual time they spend working on those grants. The staff responsible for reporting the actual time spent on federally funded programs dedicate a significant portion of their time to these programs. However, there are administrative staffs that provide support towards these programs, and tracking their time spent towards the time spent on the program would require more time and effort than the minimal allocation the City allocated for each administrative staff as appropriated in the Adopted Budget. The City is in the process of implementing an indirect cost allocation plan to allocate the administrative staff time and anticipates this will be in effect in fiscal year 2025-26. In the meantime, staff will make every effort to document the actual time spent working on the grants. Name of Responsible Person: Ron Garcia, Director of Community Development Ryan Mulligan, Housing Manager Rose Tam, Director of Finance Albert Trinh, Accounting Manager

Planned Corrective Action: The two employees are no longer with America’s Finest Charter School (AFCS). However, AFCS will ensure that all Title I employees responsible for reviewing the Semiannual Certification Form will certify it after the pay period. We will continue to provide training for all employees funded by federal programs and for the HR Manager regarding the requirements for federal time accounting under 2 CFR §200.430. We will also review payroll records to ensure that payroll is accurately charged to the correct programs on a semimonthly basis.

Department: Administrative and Financial Services Title: Internal control over monitoring of employee classification and compensation needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The procedure referenced in 5 M.R.S. Sec. 7061(4) is laid out in 18-389 C.M.R. Ch. 4. The Department complies with these written policies and procedures as required by federal and state law. Section 7061(4) was last updated in 2023, with an effective date in October 2023. Pursuant to the JSC on Appropriations, Section 7061(4)(A) requires a review every five years of the state compensation plan for each class or position in the classified service. The FJA process is not related to the compensation plan, however, it is administered under a separate internal control structure that is in place and operating effectively and ensures that the compensation for individual employees is reasonable for the services rendered. The requirement for review of each classification through the FJA process is covered under Section 7061(4)(C) and is required to be reviewed every 10 years. It is also important to note that the Department has conferred with the OAG, who determined that Section 7061(4)(C) is not retroactive, meaning the Department has another 8.5 years to complete a review of all classifications. Additionally, salary studies conducted on State employee wages have shown that the salary and wages of job classifications paid by the State are consistently lower than industry averages, removing the risk that the utilization of these salary schedules as a component of payroll costs will cause overcharges to Federal grants. Completion Date: N/A Agency Contact: Michael J. Dunn, Acting State Human Resources Officer, Bureau of Human Resources, DAFS, 207-287-4651

Finding Number: 2024-001 Planned Corrective Action: Meals on Wheels of the Monterey Peninsula (MOWMP) will address the finding by taking the steps outlined below: 1. Expenditure Allocation: Controller and/or bookkeeper will allocate expenditures based on the number of meals prepared each month and the percentage of meals prepared for each program and funding. Yearly reviews of the allocation process will be conducted to ensure accuracy and relevance. Adjustments may be made based on changes in meal demand, program requirements, funding sources, or other factors affecting meal preparation costs. 2. Payroll Reporting: On a yearly basis, Managers and/or Directors will allocate the amount of time each employe works based on tasks performed and the amount of time worked on federal award activities. This allocation will be expressed as a percentage of total work hours performed. Periodic adjustments to time allocations may be necessary to reflect changes in project priorities, staffing levels, or other factors affecting workload distribution. Person Responsible for Corrective Action Plan: Leadership Oversight – Christine Winge, Executive Director Operational Oversight – Kay Smith, Controller Anticipated Date of Completion: MOWMP will complete the Corrective Action Plan by June 1, 2024 and these new policies and procedures will be in full effect throughout fiscal year 2025 and beyond. We will continue to review effectiveness and make changes as necessary.

Concur. To help ensure the County’s policies and procedures include a process for reconciling budgeted payroll allocations to actual time spent on grant activities and provide sufficient documentation to support the actual time worked on the grant program, the County has revised its process for tracking the actual time spent on grant activities in order to provide sufficient documentation to support the actual time worked on the grant program and a reconciliation process to adjust these charges to reflect the actual effort expended on the grant projects. The recommended solutions include strengthening its comprehensive internal control policies and procedures to ensure that payroll costs charged to federal award are accurate, allowable, and properly supported. Additionally, the County will implement a process to reconcile the budgeted payroll allocation with actual time spent on grant activities. The County’s goal is to meet and complete recommendations by the end of fiscal year 2025-26.

Concur. To help ensure the County’s policies and procedures include a process for reconciling budgeted payroll allocations to actual time spent on grant activities and provide sufficient documentation to support the actual time worked on the grant program, the County has revised its process for tracking the actual time spent on grant activities in order to provide sufficient documentation to support the actual time worked on the grant program and a reconciliation process to adjust these charges to reflect the actual effort expended on the grant projects. The recommended solutions include strengthening its comprehensive internal control policies and procedures to ensure that payroll costs charged to federal award are accurate, allowable, and properly supported. Additionally, the County will implement a process to reconcile the budgeted payroll allocation with actual time spent on grant activities. The County’s goal is to meet and complete recommendations by the end of fiscal year 2025-26.

Condition: Of the 11 employees included in the hourly payroll expenditure sample selected for testing in the TRIO Cluster (TRIO), the University did not complete a full, executed review of the effort certifications with the time period outlined for 1 employee. Of the 7 employees included in the hourly payroll expenditure sample selected for testing in the Special Education Cluster (IDEA), the University did not complete a full, executed review of the effort certifications with the time period outlined for 5 employees. Planned Corrective Action: The university implemented a new grant management software in June 2024 that provides greater functionality to complete the effort certification process within the time requirement identified in the University's Time and Effort Reporting Policy. Winter Semester 2024 was certified timely under the new system and the university considers the finding to be fully corrected. Please note that this finding occurred prior to the implementation of the new system. Contact person responsible for corrective action: Associate Controller, Brenda Lindberg Anticipated Completion Date: The new effort reporting system was implemented in June 2024.

DISTRICT RESPONSE: Finding 2024-001 Condition: The District recognizes that Time and Effort certifications were not maintained for grant funded employees that had salaries funded by the FC 240 and 262 grants, which are federal special education entitlement grants that fall under the Individuals with Disabilities Act (IDEA). Corrective Action Plan: The special education entitlement grants (FC 240 and 262) require certification of Time and Effort on a tri-annual basis (fall, spring, summer). The District has put into place a certification process, effective Spring of 2025, that will capture Time and Effort of all grant funded employees that have salaries funded by the FC 240 and 262 grants. This process included the development of certification records in which grant funded employees will be able to document and certify that they have been working solely in activities supported by the FC 240 or 262 grants during each of the tri-annual reporting periods. The certification record will be signed by the Director of Student Support Services as an after-the fact determination of actual effort expended for the grants on a tri-annual basis.The certification records will be kept on file in the Office of Student Support Services. Anticipated Completion Date: Process verified on 3/18/2025. Time and Effort will be maintained on a tri-annual basis. Contact: Shari Haire Director of Student Support Services 77 Poland Street Webster, MA 01570 508-943-3646 ext. 4022 shaire@webster-schools.org

This issue was identified during the FY 2023 audit which occurred in February 2024. Corrective action was taken immediately with the following controls implemented in the fourth quarter of fiscal year 2024: • The CFO evaluated the procedures involved in recording employee time on timesheets and transferring this data to the financial management system. • The CFO evaluated the need for additional controls to ensure accurate recording of time charged to programs as reflected on the employee's timesheet. • The CFO implemented new processes that establish checks and balances to verify that the programs charged in the general ledger align with the time recorded by the employees and is verified by their supervisor. • The CFO and HR director provided training to all staff and new hires on the importance of accurately capturing and recording payroll costs. • The CEO provided training to the CFO and staff accountant on the significance of aligning time charged with the programs designated in the general ledger for proper grant award billing. • The CFO conducts periodic reviews of payroll transactions to identify any discrepancies or irregularities promptly and take action immediately upon identification of such. These reviews will continue through FY 2025. The controls implemented above should reduce the risk of such errors occurring in the future.

The plan will be to do several things in order to correct the issue. Hold training for management and clerical staff on updates to timesheet and time accounting protocols to ensure understanding of the processes. Have staff and management update timesheets to include the source of funding, the name of the project and resource code applicable to the project. Have management and clerical staff verify information on timesheets and sign and date the timesheets once verified.

The Business Administrator will review all the prepared contracts to ensure all grant information is provided and that the semi-annual certifications are signed and completed.

Matching, Level of Effort and Earmark Significant Deficiency in Internal Control over Compliance, Instance of Noncompliance We concur. Corrective Action Plan: The City was not provided with payroll registers or pay stub copies for the in‐kind local match contribution from Solano County and the Travis Community Consortium. However, the City did maintain hourly tracking for the two agencies when they attended meetings and used a lower pay rate, as outlined in the approved grant budget, when reporting back to the agencies. The required 10% in‐kind match was exceeded by $9,224.28, with a portion of the $30,000 mentioned above included in the excess match. Additionally, the grant had a pay rate cap of $87 for one of the County employees, so using the actual pay rate to calculate the in‐kind match was not permitted. The City will collaborate with the other agencies to obtain better documentation for the shared local match. Responsible Individual(s): Liz Aptekar, Assistant to the City Manager Anticipated Completion Date: To be completed by 6/30/2025

Corrective action plan: The VES Budget Analyst will continue to review the monthly Forecast and Payroll reports with the VES’s Director or Operations Manager. Upon review, the Director or Operations Manager will sign-off on both the monthly Forecast and the monthly Payroll Report which identifies each employee’s payroll costs and operation costs approved to be charged to the grant. VES’s Director or Operations Manger will also sign-off on the VES Annual State Plan which identifies employees and operating costs approved to be charged to the grant for the grant period, prior to submitting to the U.S. Department of Labor. Implementation dates: January 2025 Responsible persons: Anna Baker, Director of Veteran Employment Services and Julie Pusan, VES Budget Analyst,

Corrective action plan: DSHS will reinforce new hire training to ensure all supervisors understand the purpose and procedures addressing labor account codes, monthly time reporting, and task profiles. DSHS will further evaluate related training materials for opportunities to strengthen understanding and compliance overall. Implementation dates: March 1, 2025 Responsible persons: Christy Havel Burton, Chief Financial Officer

U.S. Department of Education -Passed-through the NYS Education Department Title I Grants to Local Educational Agencies (LEAs); Assistance Listing Number (ALN) 84.010; Project # 's 0021-23-2955, 0011-23-6011, 0011-23-7200, 0011-24-2160, 0021-24-2955, Grant Period ­ Fiscal Year Ended June 30, 2024 U.S. Department of Education -Passed-through the NYS Education Department - Education Stabilization Fund COVID-19 - Elementary and Secondary School Emergency Relief (ESSER) Fund; ALN 84.425D; Project #5891-21-2955; Grant Period - Fiscal Year Ended June 30, 2024 COVID-19 - American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP­ ESSER) Fund; ALN 84.425U; Project 5880-21-2955, 5884-21-2955, 5883-21-2955, 5882-21- 2955; Grant Period -Fiscal Year Ended June 30, 2024 COVID-19 -American Rescue Plan -Elementary and Secondary School Emergency Relief - Homeless Children and Youth; ALN 84.425W; Project#5218-21-2955; Grant Period - Fiscal Year Ended June 30, 2024 Significant Deficiency Compliance Req uirement: Allowable Activities and Cost Principles Criteria: Per Uniform Guidance (2 CFR §200.430), payroll costs charged to federal grants must be supported by appropriate documentation reflecting actual time and effort spent on grant-related activities. Per District policy employees are required to submit Personnel Activity Reports (PARs) to certify time worked on a federal grant. PARs are then required to be reviewed and approved by a direct supervisor. Condition: We identified seventeen (17) instances of missing or incomplete PAR forms for Title I. Six (6) out of (17) employees did not complete a PAR form. Eleven (11) out of (17) did not document supervisor review and approval. For the education stabilization fund the District was unable to provide support for time and effort worked on the grant for eleven (11) employees. Cause: Due to significant changes in personnel and work environments of key employees, the District was unable to maintain adequate oversight over the payroll function. Effect: The District is not in compliance with federal grant requirements and District policy. Questioned Costs: None Recommendation: We recommend the District enhance internal control measures to verify the accuracy and completeness of PARs in a timely manner. We also recommend the District conduct independent reviews of the payroll process and time and effort reporting to verify established controls are functioning as intended. District's Response: The District agrees with this finding. The procedures that are typically followed were not in place during the 2024 school year due to staff changes but the District is back on track and following the correct protocol for the current year and going forward

2024-002 Adult Education - Assistance Listing Number 84.002 Recommendation: We recommend procedures to maintain records that accurately reflect the work performed for payroll charges to the grant be implemented/strengthened. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Adult Education department will be collecting the Time and Effort certifications for staff on Federal grants. Name(s) of the contact person(s) responsible for corrective action: Dr. Kevin O’Connor, Claudia Castro Alves and Kate Fiore Planned completion date for corrective action plan: Effective as of 10/10/2024 so will have Time and Effort certifications for all FY25 staff on Federal grant #2340

Program: AL 20.509 – Formula Grants for Rural Areas – Allowability & Subrecipient Monitoring Corrective Action Plan: • NDOT will continue to enhance its financial review procedures to ensure that all subrecipients provide adequate supporting documentation for expenditures, including personnel charges and cost allocations. • Training sessions will continue to be conducted for subrecipients to reinforce compliance requirements related to allowable costs, proper documentation, and cost allocation methods. • Revised internal procedures will clarify expectations for travel costs, fuel charges, personnel reimbursements, and revenue reporting to prevent improper charges to the grant. • Assigning audit staff to conduct periodic sampling throughout the year enhances our ability to ensure costs are properly supported, adapt to necessary changes, and effectively communicate updates to our subrecipients. Contact: Jodi Gibson Anticipated Completion Date: NDOT appreciates the audit’s recommendations and remains committed to ensuring compliance with Federal requirements through strengthened internal controls and enhanced subrecipient oversight. This will be an ongoing and continual effort to address anticipated compliance requirements and evolving state and federal regulations.

Program: AL 15.611 – Wildlife Restoration and Basic Hunter Education and Safety – Allowability & Subrecipient Monitoring Corrective Action Plan: NGPC will continue to work closely with our subrecipients. We will review subrecipient monitoring procedures and determine documentation that can be provided to meet the intent of federal regulations. Contact: Eli Kass Anticipated Completion Date: July 1, 2025

Program: AL 84.048 – Career and Technical Education – Basic Grants to States – Allowability Corrective Action Plan: The Nebraska Department of Education’s Office of Career, Technical, and Adult Education will carry out the following actions to improve procedures to ensure that all payments are supported by adequate documentation: Provide ongoing technical assistance to subrecipients and NDE staff to ensure they are familiar with and fully informed on the documentation necessary to process reimbursement for all types of expenditures. Ensure all subrecipients have a stipend policy in writing. Conduct regular desk audits to ensure subrecipients are adhering to all applicable state and federal laws and regulations. Contact: Katie Graham, Sydney Kobza, Teri Sloup Anticipated Completion Date: June 2025

Program: AL 93.778 - Medical Assistance Program; AL 93.959 - Block Grants for Prevention and Treatment of Substance Abuse; AL 93.767 - Children’s Health Insurance Program; AL 93.575 – Child Care and Development Block Grant; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Allowable Costs/Cost Principles Corrective Action Plan: The entire payroll process is being reviewed and changes will be made. Contact: Heather Arnold Anticipated Completion Date: 12/30/2025

Program: AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance; AL 93.568 – Low Income Home Energy Assistance (LIHEAP); AL 93.575 – Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – Adoption Assistance; AL 93.667 – Social Services Block Grant; AL 93.767 – Children’s Health Insurance Program; AL 93.778 – Medical Assistance Program; AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program – Allowable Costs/Cost Principles Corrective Action Plan: Time and Effort: Agency has submitted retroactive PACAP amendment (complete). For the IST Fiscal Projects Admin cost center, a time study will no longer be utilized, and the hours will be treated as General IST Administration without direct grant allocations. RMTS Allocations: Agency has clarified with staff what the “Non-DHHS Activities” selection pertains to (complete). Labor Hours Statistics: This was the first audit cycle of the new Cost Allocation system. DHHS will create a checklist of items for the new system that will be reviewed prior to completion of the quarterly cost allocation compilation. This checklist will address specific issues presented during this audit cycle. Recipient Counts: This was the first audit cycle of the new Cost Allocation system. DHHS will create a checklist of items for the new system that will be reviewed prior to completion of the quarterly cost allocation compilation. This checklist will address specific issues presented during this audit cycle. Contact: Patrick Werner Anticipated Completion Date: 6/30/2025

Condition: Time and effort certifications were not maintained for grant employees. Corrective Action Planned: We will utilize the template provided by the auditors to ensure time and effort certifications are maintained going forward. Anticipated Completion Date: July 1, 2025 Contact: Martin Anguelov, Chief Financial Officer for Nantucket Public Schools and Deb Gately, Director of Special Education for Nantucket Public Schools