Corrective Action Plans

Re: Management’s Response & Corrective Action Plan to Salary Certifications Finding (2024-005) The Wilmington Land Bank charged allowable payroll expense to the SLFRF Program from October 11, 2022 through December 31, 2024. During the September 2025 audit, the Land Bank obtained certifications from each employee to document percentage of time dedicated to each SLFRF project. To ensure timely documentation and address this deficiency, the Land Bank’s Director of Finance & Grants will collect employee certifications on a quarterly basis going forward. Responsible Individual: Becky Vogel, Director of Finance & Grants Anticipated Completion Date: Already corrected

With the addition of personnel, the finance team has been restructured to allow for a more streamlined month-end process. As part of the month-end process we have implemented more collaborative and robust communication between the grants management and finance teams to ensure accuracy in our grant management process.

The Center has implemented time and effort reports in the subsequent year to properly substantiate each employee's time and effort spent on each grant.

2024-002. Allowable Costs/Cost Principles United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee's compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or the equivalent is the most effective way to comply with this requirement. The Organization did not prepare PARs or equivalent documentation. Recommendation: The Organization should maintain PARs or equivalent documentation. This reporting of time will allow each employee to accurately reflect the time work is performed, for compensation which is funded by a federal award. Corrective Action: The Organization will modify procedures to have time records reflect actual time worked by employees on PAR equivalent documentation, which will serve as support for personnel expenses funded by federal awards. Responsible Contact Person(s): Louis Bamonte, Director of Finance Brighter Tomorrows, Inc., - P.O. Box 706 – Shirley, New York 11967 Anticipated Completion Date: December 31, 2025.

The exceptions resulted from delays in updating payroll/timekeeping systems and insufficient documentation to support allocation changes. To correct this, TRAC has implemented a Position Control Update process: any change to an employee’s grant allocation must be documented on a Position Control Update form, signed by the Finance Director, and entered into the payroll system within 5 business days of the change. Additionally, the Finance team performs monthly reconciliations between timecards, payroll registers, and the general ledger to ensure that payroll charges are accurate and properly supported before being billed to grants. Completion Date: October 1, 2025. Responsible Parties: Nicole Binkley, Chief Executive Officer Josh Runnels, Director of Finance and Operations

At the time of the audit period, TRAC was newly independent from CitySquare and had not yet integrated supervisor approval of timecards into its internal control systems. This gap contributed to missing approvals during the transition year. As of September 2024, TRAC implemented employee and supervisor approvals of timecards within the time keeping system. Additionally, the organization has and will continue to implement a thorough review process that will include the following:  Employee acknowledgement of their individual grant allocation  Employee approval of their timecard  Manager acknowledgment of their individual grant allocation as well as the allocation of each employee they supervise  Manager approval of each employee’s timecard  The finance team will review each timecard individually prior to charging salary costs to grants. This process ensures that time and effort documentation is complete, approved, and compliant with federal and state requirements. Compliance with this policy will be monitored monthly by the Finance Director to ensure continued adherence.Completion Date: October 1, 2025.Responsible Parties: Nicole Binkley, Chief Executive Officer Josh Runnels, Director of Finance and Operations

Management Response #2024-001: The time keeping system and process does not currently allow tracking of time based on funded resources. The past practice had been for the finance department manually calculated salary allocations. Due to the influx of grants and staffing resources the Corporation was unable to maintain this process. Corrective Action Plan: Finance Management, Human Resources, and Payroll will collaborate to integrate time-tracking functionality into the current timekeeping system, enabling real-time tracking of time worked on grants for FY25. The rollout of this new process is expected to begin in Q4 of FY25. Responsible Party: Tamara Barnes, CFO

Material Weakness, Allowable Costs- The following steps have been taken or will be taken to address Finding 2024-002: • Shalom Health Care Center, Inc. has been working on updating federal grant draws within the timeframe of payroll and not monthly. • Shalom Health Care Center, Inc. will also prepare semiannual attestation for management to review staff allocations. Contact Michael A. Nino, Chief Financial Officer anino@shalomhealthcenter.org 317-269-7198

Each employee will have a payroll file that includes: • Date of hire • Title • Grant(s) they are assigned to if applicable • Pay amount • Any changes to the above and the date of the change Each employee will complete a timesheet weekly that includes the number of hours worked and if applicable broken out by what grant(s) they worked on. The bookkeeper provides a budget:actual report when invoices for federal contracts are prepared. The ED notes signs off that they have been approved for draw. That report is stored on the server. The Treasurer reviews the cost-reimbursement requests prepared by the ED, along with the detailed back up.

Management understands that CFR 200.430 requires compensation for personnel services to be based on records that accurately reflect the work performed, and costs must be properly allocated to benefiting programs or cost objectives. The HR/Payroll Administrator has implemented a review process to ensure that all payroll changes are properly reviewed, verified, and approved prior to final payroll processing and the Cooperative does not believe this should be in an issue going forward.

Management agrees with the finding and will work with the City of San Antonio to correct the issue, and develop review procedures to respond to the finding.

Corrective Action Plan: Strengthen detailed process for review over payroll charges billed to federal programs. To address the significant deficiency over allowable costs identified in the Single Audit, the Organization will enhance its existing review procedures by implementing a more detailed monthly review process. This will include verifying payroll charges against supporting documentation such as payroll registers, time records, and allocation spreadsheets. Management will also explore the development of a standardized reconciliation checklist and introduce a secondary review step to ensure accuracy and completeness. These measures, combined with continued monthly oversight by the CFO, are intended to reduce the risk of billing errors due to human oversight and reinforce the reliability of payroll cost allocations. Name of Responsible Person: Nora Davis, Chief Financial Officer Anticipated Completion Date: April 30, 2026

The Commissioner’s office will consult with legal counsel to update polices to meet requirements of 2 CFR 200.

Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underlying the attestations were erroneous. In addition, LifeWire was not able to secure an attestation from a former employee before they departed the organization. In 2025, LifeWire is revising their attestation procedure such that contract-supported staff members will attest to the nature of their work instead of amounts of time to contracts. This will simplify the administrative burden of attestations and reduce opportunities for errors while still meeting our audit and contract funders’ requirements. We anticipate this revised method will be rolled out by the end of Q3-2025. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: Procedure rollout will be completed by the end of Q3-2025. Anticipated full compliance with the requirement will be in evidence through the end of 2025 and beyond.

U.S. Department of Agriculture Food Distribution Cluster - The Emergency Food Assistance Program - Assistance Listing No. 10.565, 10.568, 10.569 Recommendation: We recommend that EFN incorporate a system of internal controls that clearly documents the time and effort that each individual employee spends on each grant per month. This can be done by tracking and recording the actual hours each employee, regardless of position, spends working on each grant, on their time sheet or with a specific grant code, that specifies how many hours per day were spent on each federal and nonfederal activity. Alternatively, EFN can implement an after-the-fact review procedure to ensure the proper allocation of payroll expenditures to Federal and non-Federal awards, in accordance with 2 CFR 200.430. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Emergency Food Network (EFN) engaged a new audit firm for the 2024 audit. Before this year the EFN audit was administered by Johnson, Stone Pagano for 9 years. No deficiencies were previously reported or identified during those audits regarding time estimates for employees used for allocations including most of those specifically identified funding sources. In response to the 2024 audit finding by Clifton Larson Allen (CLA) in July of 2025, when the audit was conducted, EFN implemented an immediate individual employee time study that was approved by CLA to meet the recommendation. This time study methodology will be implemented twice per year on an ongoing basis with records retained and available for future audit verification. EFN has received written response from CLA that implementing this method meets all the requested requirements to be in compliance and mitigate future findings on this issue. Name of the contact person responsible for corrective action: Michelle Douglas, CEO Planned completion date for corrective action plan: August 2025 If anyone has questions regarding this plan, please call Michelle Douglas, CEO, at 253-208- 2962.

Personnel Responsible for the Corrective Action Plan: Darlene Sowell, President/CEO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Unleashing Potential will modify its internal procedures to track actual hours devoted to the program and perform a monthly review of actual hours incurred compared to the estimated amounts by individuals assigned to federal grant programs prior to requesting reimbursement from the funding course. The review will be performed by an individual other than the preparer of the reimbursement request, with knowledge of the federal grant program and will be formally documented.

The Board of Education has acknowledged the finding and has agreed to the finding. We have reviewed the affected payroll records and confirmed the underpayment. We have issued a check to pay the difference owed to the employee. At fiscal year end, we will implement a more detailed review process to ensure all employees' salary schedules are updated when we process the system-wide update. We will have an additional person to review and sign the new salary schedules before the first payroll is processed in the new fiscal year.

View of Responsible Official: The timesheet implemented in July 2024 properly reflects the actual vs budgeted hours for employees with multiple funding sources. We will continue to analyze discrepancies to determine if budget revisions are necessary. Finding resolved timeline: October 2025 Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President; Ricardo Colon Padilla, financial officer.

2024-001 Time and Effort Payroll Documentation Corrective action planned: Cahaba Medical Care will implement a formal process to document time and effort for personnel, subject to the level of effort requirements. This process will require time and effort for personnel to attest to the amount of time spent on a grant monthly. These personnel have been informed of the proposed process and trained to promote consistent and accurate reporting relative to federal standards Anticipated completion date: October 2025 Contact person responsible for corrective action: Russ Chambliss

U.S. Department of Commerce, Philadelphia Works, Inc. 2024-1 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.

Continued training of cost center managers. Throughout the summer we have had the Finance Manager training Community Eds administrative team and responsible grant managers to get compliance with Time and Effort requirements.

Allowable Costs - Payroll Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 COVID-19 - Substance Abuse and Mental Health Services Projects of Regional and National Significance – Assistance Listing No. 93.243 Recommendation: We recommend Shatterproof ensure monthly certifications of time allocations by employees and their supervisors are performed and documented on a consistent basis. In addition, we recommend Shatterproof retain approval of the payrates entered into the HRIS and used to pay employees and ensure controls exist to ensure the proper rates are used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Time certifications for employees involved in federal grants are completed monthly and signed by both the employee and their supervisor. • Pay increases were historically reviewed and approved by the CEO in a final meeting with the CFAO and Sr. Vice President of HR but no formal approval was retained. Going forward, the CEO will document approval of salary changes via email after the meeting. Names of the contact persons responsible for corrective action: Ellen Duffey and Young Kim Planned completion date for corrective action plan: January 1st, 2025

REFERENCE No. 2024-002 Significant Deficiency in Internal Control Over Compliance, Other Matters Program Child Support Services (Assistance Listing Number 93.563) Identification Number(s) 18000 (2024) Finding Employee time and effort charged to the program did not agree with supporting documentation. For two of thirty-three employee timesheets selected for testing, the amount claimed for employee time and effort did not agree with supporting documentation. Employee payroll data was entered incorrectly when the claim was compiled, resulting in an underclaim of the amount charged to the program. Questioned Costs None. The error resulted in an underclaim. Recommendation The County should enhance its procedures and internal controls to ensure that employee time and effort charged to the program is accurate and agrees with supporting documentation. Corrective Action Plan The Finance division will be working with payroll and IT to assist in automating this process within the WorkDay system. Employee Function Codes drive the claiming process and currently it has been a manual process; however, the need to automate is important. Until a new process is in place, staff will be trained to spot these errors and if needed correct when found. In addition, Senior staff will be reviewing this process to also ensure its accuracy. Action Date September 5, 2025 (Meeting with staff) Final Implementation Date March 31, 2026 Name And Phone No. Of Person Responsible For Implementation Jennifer Cicero 631-854-9331

dLCV has refined our policies regarding review of timesheets to ensure that all timesheets are timely submitted and are reviewed and approved by designated staff. The policy revisions will be effective as of October 1, 2025

dLCV will implement a weighted direct bill process beginning October 1, 2025. Throughout the audit review, and as recently as one month before the final report, the auditors consistently reported to us that this was likely not a compliance issue. Additionally, the auditors were not able to provide any sample for any time period in 2024 showing the potential impact of changing from an hours allocation to a dollars allocation. The auditors did not inform us of their changed opinion until late August, 2025, making it impossible to make any adjustments in the current fiscal year.