Corrective Action Plans

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

The City concurs with the finding and will take the following actions in response:Development’s Fiscal Team shall continue the process developed in response to the 2023 finding, with one modification: instead of a quarterly ‘true up’ process, Development shall perform a monthly ‘true up’ process. This provides the opportunity for more frequent fiscal review of work logs and quicker identification of non-compliance by programmatic staff and supervisors. If a work log is not signed by the employee and/or supervisor, fiscal staff shall notify the employee and supervisor of the issue and request it be signed as soon as possible. Only after the work log is signed by both employee and supervisor shall it be included in the monthly true up. If the employee and/or supervisor is non-responsive to the request to sign the work log, the Deputy Director of Housing Strategies shall be notified and requested to address the issue as soon as possible; Development’s fiscal team shall continue to review signature timeliness as a part of the monthly ‘true up’ process. If fiscal identifies work logs signed by either employee and/or supervisor outside of the allotted time per the Department’s work log policy, fiscal shall notify the Deputy Director of Housing Strategies and request the issue be addressed as soon as possible; and The Compliance Officer shall provide a written reminder to all applicable staff and supervisors to sign the work log in a timely manner and shall perform a periodic review of the work logs throughout the year. Work log review shall also be included in internal monitoring done by the Compliance Officer. Documentation of reviews will be retained per the Department’s record retention schedule.

Recommendation: During our review of the grant expenditures, it was noted that budgeted amounts were charged to the grant instead of the actual costs incurred. This practice was observed in multiple instances, leading to discrepancies between the reported expenditures and the actual costs. Management did not review time and effort to make after-the-fact adjustments to the amounts charged to the grant. We recommend that the Organization establish a review process to ensure that all costs charged to the grant are based on actual expenditures and are properly documented Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has established a review process to ensure that all costs charged to the grant are based on actual expenditures and are properly documented. Name(s) of the contact person(s) responsible for corrective action: Theresa Watters Planned completion date for corrective action plan: February 21, 2025

Corrective action plan: Management is in the process of implementing a method for employees to charge their time to grants, as needed, from the payroll system. Personnel responsible for corrective action: Timothy Jodway, Interim Chief Financial Officer. Estimated corrective action completion date: May 2025

Management Response/Corrective Action Plan: The School Department completed the necessary time and effort documents for expense reimbursement that were approved by the Department of Education. The time and effort was not specific to actual time worked for those split among multiple grants or funds. Moving forward, any employee who has time split between multiple grants or Federal and non-Federal activities will be expected to complete a personnel activity report. This report will record actual time spent working on eligible activities for each fund. If the employee has a regular schedule, the employee’s schedule will suffice as their personnel activity report, as long as it follows the guidelines. The personnel activity reports will be requested each month during the reimbursement request process and will be signed by the employee and their supervisor.

Management Response/Corrective Action Plan: The School Department completed the necessary time and effort documents for expense reimbursement that were approved by the Department of Education. The time and effort was not specific to actual time worked for those split among multiple grants or funds. Moving forward, any employee who has time split between multiple grants or Federal and non-Federal activities will be expected to complete a personnel activity report. This report will record actual time spent working on eligible activities for each fund. If the employee has a regular schedule, the employee’s schedule will suffice as their personnel activity report, as long as it follows the guidelines. The personnel activity reports will be requested each month during the reimbursement request process and will be signed by the employee and their supervisor.

CORRECTIVE ACTION PLAN (Concerning Finding 2024-001) Contact Person Responsible for Corrective Action: Catrina Kemp, Business Manager Corrective Action: The Regional School Unit No. 70 will take the following actions to address finding 2024-001. Managerment will review standards and requirements annually to ensure that the district is following federal guidelines. Management will also employ a signature and date on all federal grant disbursements to ensure that all criteria and requirements are met. Allowable costs will be assesed monthly before submission for allowability. Management will implement a two step review process for contracts and payroll. Anticipated Completions Date: July 1, 2025

The District acknowledges this finding and is committed to strengthening internal controls to ensure compliance with federal time accounting requirements. The State and Federal Programs Department has received training on Time and Effort procedures, and additionally training is being provided to school sites to reinforce accurate time certification and documentation for federal fund expenditures. To address the deficiencies, the district will shift from an annual to a monthly reconciliation process, ensuring that employee salaries charged to Title I accurately reflect actual work performed. The State and Federal Programs Department will collaborate with the Budget Department to systematically track employees funded through Title I and verify that all required PARs are completed and maintained.

U.S. Department of Education AL 84.010A Title I, Basic Grants to Local Education Agencies AL 84.010A Title I, Part A - Investment in Schools 2 AL 84.367A Title II: Improving Teacher Quality State Grants AL 84.424A Title IV: Student Support and Academic Enrichment Grants Type of Finding – Noncompliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll) Repeat Finding: No Auditee’s Corrective Action Plan: The School recognizes the importance of maintaining records and ensuring adequate internal controls over activities allowed and allowable costs/costs/principles. To strengthen internal controls in this area, in July 2024, the school introduced EdOps to work on payroll and to conduct an additional layer of review in addition to the HR Manager and the CEO. The School recognizes that its documentation and record-keeping requires improvement. Should the School resume operations, it will assess review and record-keeping processes to ensure the integrity and accuracy of payroll and related documents. Contact Person: Aaron Lentner

Audit Finding Reference: 2024-001 Management’s Response and Planned Corrective Action: The District will ensure that any further retention bonuses be formally reviewed and approved by the School Board and Superintendent. Stipends for work performed are now included in a formal Letter of Agreement and signed by the employee and administrator. Name of Contact Person and Completion Date: Name: Kathryn Ducharme Anticipated Completion Date – July 1, 2024