Corrective Action Plans

Single Audit Finding No. 2025-063 - Three of 40 timesheets tested (eight percent) were entered into the State’s accounting system with incorrect coding. Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department agrees with this finding and recommendation. Corrective Action (corrective action planned): The department will reinforce timesheet entry and processing procedures, and the finance officer will provide additional training to administrative staff to avoid future errors. Completion Date (list anticipated completion date): June 30, 2026 Agency Contact (name of person responsible for corrective action): Michael White, Financial Services Manager

Title II, Part A-Supporting Effective Instruction Stat Grants – Assistance Listing No. 84.367 Special Education Cluster (IDEA programs) – Assistance Listing No. 84.027, 84.173 Title I-A-Grants to Local Educational Agencies – Assistance Listing No. 84.010 Recommendation: The District should design and implement controls to ensure semi-annual time and effort certification are obtained and reviewed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To address the material weakness related to untimely and incomplete approval of Time and Effort certifications, MPS implemented process improvements to strengthen internal controls, increase accountability, and ensure certifications are completed prior to reimbursement submissions. MPS performed the following with respect to enhancing the internal controls surrounding this process: Prior to Collection • Adjusted certification timelines to allow adequate review and approval, • Established centralized email account to improve communication reliability, • Reassigned responsibility to the ESEA Manager for stronger oversight, • Beginning FY26, implemented a monthly grant report to monitor expenditures and detect and correct errors in a timely manner, • Communicated certification timelines to district leadership in advance of the collection window. During Collection • Sent daily communications and district-wide reminders, • Monitored completion through daily reporting, • Provided real-time technical support. Post Collection Window • Continued system-generated reminders, • Conducted targeted outreach via email, phone, and virtual meetings, as appropriate, • Launched a formal escalation process through supervisory channels when needed as described in our communications outlined above. These actions are supported by documented procedures and enhanced oversight to ensure timely completion of certifications and compliance with federal cost requirements. Name(s) of the contact person(s) responsible for corrective action: State and Federal Program Director, ESEA Coordination and Compliance Manager Planned completion date for corrective action plan: Completed as of December 2025.

Special Education Cluster (IDEA programs) – Assistance Listing No. 84.027, 84.170 Recommendation: The District should implement controls that allow for the identification and proper classification of vendor payments to applicable grant period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will strengthen internal controls to ensure that vendor payments are appropriately aligned with the correct grant reporting period. MPS will implement a standardized review process to validate that vendor invoices and related purchase orders are coded to the correct grant period, establish clear procedures for identifying the period of performance for goods and services, enhance coordination between program and finance staff to validate the timing and allowability of expenditures, conduct periodic monitoring of vendor payments to ensure compliance with grant period requirements, and provide training to relevant staff relating to grant period compliance and expenditure classification. Name(s) of the contact person(s) responsible for corrective action: Senior Director of Specialized Services, Accounting Director (Deputy CFO), Financial Reporting Manager Planned completion date for corrective action plan: 6/30/2026

Corrective Action Plan Audit Finding Reference Number: 2025-001 Federal Program: Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Assistance Listing Number (ALN): 21.027 Federal Agency: U.S. Department of the Treasury Contact Person(s) Responsible for Corrective Action: Whitney Gustin Connor, Executive Director Planned Corrective Action: Kid's First will implement the following procedures to address the lack of time and effort documentation and supervisory review for salary allocations charged to SLFRF grants: Require written supervisory review and approval of salary allocation percentages for all employees charged to federal grants. Develop and document procedures for periodic reconciliation of salary charges to actual time and effort records, in accordance with 2 CFR 200.430. Anticipated Completion Date: July 31, 2026

Finding Number: 2025-002 Planned Corrective Action: The City concurs with the finding and will take the following actions in response: • 100% Federally Funded Employees: Columbus Public Health will require all employees whose salaries are 100% funded by a single federal award to comply with 2 CFR § 200.430 through after-the-fact time and effort certifications completed quarterly of the grant period. These certifications will confirm that 100% of the employee’s actual work performed was allocable to the federal award and will include both employee certification and supervisory review. They will be due 30 days following the quarterly end date. In addition, CPH will implement enhanced internal monitoring procedures, including periodic activity verification and supervisory attestation by the Fiscal Analyst, to ensure that work performed aligns with the grant’s scope and that payroll charges are accurate and properly supported;• Partially Federally Funded Employees: Employees whose salaries are allocated across multiple funding sources will follow full federal time and effort reporting requirements in accordance with 2 CFR § 200.430. These employees will complete afterthe- fact time and effort reporting reflecting the actual distribution of work performed across all cost objectives. Reported time will be supported by appropriate documentation and will not be based on budget estimates. Supervisors will review and formally sign off on reported time and effort on at least a quarterly basis to ensure accuracy, reasonableness, and alignment with actual activities. Additional internal monitoring, including periodic review and payroll-to-activity reconciliation reviewed by the Fiscal Analyst, will be conducted to ensure compliance and proper allocation of personnel costs. Anticipated Completion Date: 7/1/2026 Responsible Contact Persons: Anita Clark, Assistant Health Commissioner, Columbus Public Health Katie Pettiford, Fiscal Manager

Views of Responsible Officials: Management concurs with the finding. During FY2025, in response to Federal stopwork orders and related cost reduction measures, IntraHealth experienced significant disruption, including staff terminations and the planned integration of operations with Global Communities. As part of this transition, the legacy timekeeping system was retired at the end of its renewal period, with the intent to move to Global Communities’ timekeeping process shortly thereafter. During the interim period, time for the remaining staff was captured using manual timesheets. In two instances, documented supervisory approval could not be located because the employees’ supervisor separated from IntraHealth during the transition period. Planned Corrective Actions: Effective April 1, 2025, all IntraHealth staff transitioned to Global Communities following the completion of operational integration, IntraHealth has transitioned to Global Communities’ timekeeping and payroll process using ADP, which includes electronic time entry, supervisor review/approval workflow, and centralized record retention. Management believes this materially strengthens controls by reducing reliance on manual documentation, and improving the retention and retrievability of approvals. Management will also reinforce the requirement that time records are approved prior to payroll processing and will perform periodic monitoring to confirm compliance with the approval control.

2025-006 – Allowable Costs/Cost Principles Corrective action plan: Contractors have been tasked with training and implementation during fiscal year 2026. Revised accounting staff structure will provide better on-going implementation and monitoring compliance. Personnel responsible for corrective action: Heather King, Interim Chief Operating Officer Estimated corrective action completion date: March 2026

The Organization will develop and implement formal written policies and procedures to ensure that payroll charges to federal awards are based solely on actual costs incurred, in compliance with federal requirements. As part of this effort, the Organization will require all employees whose salaries are charged in whole or in part to federal awards to complete time and effort documentation for each payroll period. This documentation will accurately reflect the actual hours worked on federal program activities as well as other activities, as applicable. Supervisors or designated management personnel will review and approve all time and effort reports on a timely basis. Evidence of this review, including signatures or electronic approvals, will be maintained in accordance with record retention policies. The approved time and effort documentation will serve as the basis for allocating personnel costs to federal awards. The Organization will ensure that payroll charges are adjusted, if necessary, to align with actual time worked. Documentation supporting these allocations will be retained and made available for audit or review. Training will be provided to all relevant staff to ensure understanding and consistent application of the new procedures. Implementation of these policies and procedures will occur June 15 2026, and ongoing monitoring will be conducted to ensure compliance.

2025-05 Allowability of Payroll Expenditures (repeat finding see 2025-02} Federal Agency- US Department of Housing and Urban Development Continuum of Care Program -Assistance Listing# 14.267 Hennepin County Contract HS00001366 Year ended June 30, 2025 Material Weakness in Internal Control over Compliance, Noncompliance Other Matter Recommendation - Controls be strengthened to ensure the accuracy and completeness of payroll documentation and additional training be provided to staff involved in the payroll process to ensure policies and procedures are followed. Personnel files should include complete and approved documentation of employee pay rates and verified final allocations to programs. Payroll documentation should include an after-the-fact determination of actual hours worked in each program or function of Agate Housing and Services, Inc. Corrective action -Agate Housing and Services, Inc. implemented a new payroll system on January 1, 2025 which incorporates built-in authorization controls and requires all employees to submit time based on actual hours worked in each program or function of the agency where required and by contract allocation method where approved. Management has also reviewed the pay-rate discrepancy identified during the audit and has taken corrective action to ensure the employee was compensated accurately. Going forward, management will perform periodic reviews to confirm pay rate changes are properly documented and that all payroll entries align with approved personnel records. Name of contact person responsible for corrective action - Donna Rapacz, Chief Operating Officer Completion date - Management implemented the above procedure as of January 1, 2025.

Payroll The University acknowledges the finding related to discrepancies between payroll charges, personnel action forms, and time and effort reporting. We understand the requirement that all salary and wage charges to federal awards must be supported by accurate records and internal controls in accordance with Uniform Guidance §200.430. Corrective Actions 1. Alignment of Personnel Actions and Payroll Distribution: The University will implement additional review steps to ensure that labor distribution reports match the approved personnel action forms before payroll is charged to the grant. Any discrepancies must now be corrected before processing. 2. Strengthened Time and Effort Verification: Time and effort reports must now be reviewed and reconciled against the percentages authorized on personnel action forms. Reports that do not match will be returned to departments for correction before certification. 3. Enhanced Internal Controls and Documentation: A standardized monthly reconciliation process will be established to ensure consistency between personnel records, effort reporting, and payroll charges. 4. Staff Training: Training will be provided to fiscal managers, the Office of Research and Sponsored Programs, human resources, and payroll personnel on Uniform Guidance requirements, proper effort reporting, and documentation standards. 5. Periodic Monitoring: Supervisory reviews will be conducted to ensure continued compliance and to identify discrepancies proactively. The University believes these corrective measures will strengthen internal controls and ensure that payroll charges to federal programs are accurate, allowable, and properly documented.

Finding 2025-003 - U.S. Department of Education (USO), TRIO Programs (Significant Deficiencies): Information on the federal program - Student Support SeNices, FAL No. 84.042A, June 30, 2025; Ronald McNair Program, FAL No. 84.217A, June 30, 2025. Under 2 CFR 200.305, non-Federal entities must request Federal funds only for allowable program costs that have been incurred, and must maintain contemporaneous supporting documentation demonstrating: a. Actual, allowable expenditures existed at the time Federal funds were drawn; and b. Records supporting the nature and timing of those expenditures were on file and readily available. These requirements ensure 1. Corrective Action Description a. The College now mandates that GS drawdown requests include approved documentation stored on the accounting drive, effective July 31, 2025. b. Time and Effort reports must be submitted monthly with supervisor sign-off before reaching the Office of Sponsor Programs, showing 100% time allocation. Any changes will require a Personnel Action Form and administrative approval signatures. c. showing 100% time allocation. Any changes will require a Personnel Action Form and administrative signatures of approval. 1. Person Responsible and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu 2. Implementation Timeline This procedure took effect as of July 31, 2025. 3. Planned Preventive Measures Following the policy and procedures to support all drawdowns with proper documentation. 4. Disagreement with the Finding None

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to the Housing Choice Voucher (HCV) Program under CFDA 14.871 must be supported by recordsthat accurately reflect actual work performed, as required under 2 CFR 200.430(i). The City's prior practice of using predetermined allocation percentages to distribute payroll across multiple funding sources did not fully satisfy the federal standards for documenting actual time worked on HCV-eligible activities. Management notes that the projected questioned costs of $214,045 represent a projection of potential unallowable payroll charges based on the sample tested, that were unsupported due to insufficient time documentation and are not necessarily unallowable. The City will coordinate with HUD to determine the appropriate resolution of these questioned costs. The corrective actions outlined in Finding 2025-007 apply equally to the HCV Program. Specifically: 1. Actual Time Reporting: All Housing Authority employees who perform HCV program activities are required to document actual hours worked per program activity on their timesheets, effective immediately. 2. Discontinuation of Fixed Allocations: Predetermined allocation percentages will no longer serve as the basis for payroll charges to the HCV Program. All charges must be supported by actual time records. 3. Timesheet System and Training: Housing Authority staff will be included in the system enhancement and training initiatives described in Finding 2025-007, with particular emphasis on documentation standards under the HCV Program's applicable requirements4. Quarterly Internal Compliance Reviews: HCV payroll charges will be included in the Accounting & Finance Division's quarterly compliance reviews, with findings reported to the City Manager and the Housing Authority Director.

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to federal awards must be supported by documentation accurately reflecting the actual work performed, as required under 2 CFR 200.430(i). The City's prior practice of distributing payroll costs using predetermined allocation percentages for employees working across multiple programs did not fully satisfy federal requirements for documenting actual time expended on CDBG-eligible activities. Management notes that the projected questioned costs of $217,355 represent a projection of potential unallowable payroll charges based on the sample tested, that were unsupported due to insufficient time documentation and are not necessarily unallowable. The City isprepared to work with HUD to determine the appropriate resolution of these questioned costs. The City is implementing the following corrective actions: 1. Actual Time Reporting: Effective immediately, all employees who charge any portion of their time to federal grant programs—including CDBG—are required to document actual hours worked on each program or activity in their timesheets. Time entries must correspond to specific program activities and must be reviewed and certified by the employee's supervisor each pay period. 2. Discontinuation of Fixed Allocation Percentages: The City is eliminating the use of predetermined payroll allocation percentages as the basis for charging personnel costs to federally funded programs. Future payroll charges to federal awards will be based exclusively on actual documented hours, in compliance with 2 CFR 200.430(i). 3. Staff Training: The City will provide mandatory training to all employees who charge time to federal programs, supervisors responsible for timesheet review, and payroll staff. Training will cover the requirements of 2 CFR 200.430, the City's updated time documentation procedures, and the consequences of noncompliance.4. Quarterly Internal Compliance Reviews: Beginning in Q1 of FY 2025-26, the Accounting & Finance Division will conduct quarterly reviews of payroll charges to all federal programs to confirm that expenditures are supported by compliant time records. Results will be reported to the applicable department directors.

2025-001. Allowable Costs/Cost Principles United States Department of Education, Passed Through New York State, Department of Education: Title I Grants to Local Educational Agencies ALN: 84.010A 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 (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with the documentation standards prescribed by Subpart E, 2 CFR §200.430; the amount of one employee’s actual payroll charged to the Title I federal award was less than the allocation percentage on the periodic certification reports that were signed by the employee’s supervisor. Planned Corrective Action: The District will adopt procedures that ensure that appropriate documentation for time and effort will be used to support costs charged to the federal award, and comply with Subpart E, 2 CFR §200.430. Responsible Contact Person: Mr. William Ludeker Assistant Superintendent for Business Lindenhurst Union Free School District 350 Daniel Street Lindenhurst, New York 11757 Anticipated Completion Date: June 30, 2026.

FINDING 2025-005 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure allowable costs are documented and that receive board approval for all pay rates moving forward. However, we disagree with the finding on the allowable costs pertaining to the Financial Consulting Claims. We wrote them into the grant, and the grant was approved. There was also no Business Manager or Chief Financial Officer in place during the pandemic, resulting in the need for the consulting firm. Anticipated Completion Date: We anticipate that this correction will be in place by July 2026.

Corrective Action Plan: The identified conditions related to timesheets for hourly employees. To mitigate the risk of missing approval documentation for payroll charged to Federal R&D awards, the College is formalizing procedures requiring PI or supervisor review of applicable timesheets, configuring the approval workflow in Workday to require and retain evidence of approval, and implementing periodic monitoring to identify and correct missing approvals. Timeline for Implementation of Corrective Action Plan: These corrective actions are being implemented before the end of fiscal year 2026.

Finding 2025-001 Condition: Semi-annual time and effort certifications were not maintained for grant employees whose salaries and wages were not supported by detailed time records. Corrective Action Planned: Controls will be implemented to ensure all time and effort certifications are completed and maintained by the appropriate grant administrators for all grant employees. Anticipated Completion Date: June 30, 2026 Contact: Larry Azer, School Business Manager

Finding Number: 2025‐001, 2024‐002 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Contact Person: Eloyce Gillespie, Business Manager Anticipated Completion Date: February 20, 2026 Planned Corrective Action: Casa Blanca Community School completed the required review process in accordance with the established procedure, however, the error still occurred due to a system limitation. Specifically, although staff followed the process and performed the required review, the system does not currently flag or prevent adjustments that exceed the allowable threshold from being rolled into the next fiscal year. Because this condition is not automatically identified or restricted by the system, the adjustment was able to process despite the control being executed. To address this, the School will work with the system support team to evaluate options for adding automated validation or warning to prevent adjustments from rolling into the next fiscal year when limits are exceeded, which will include manual review. These actions were completed by February 20, 2026, and the process owner will monitor compliance.

15.047 Indian Education Facilities, Operations, and Maintenance – Assistance Listing No. Recommendation: To implement a stronger system of review for ensuring that all changes in employee payroll are properly implemented and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Human Resources (HR) is working with Finance to process retroactive compensation for the full underpaid amount owed. Associated DRS contributions will also be reviewed and corrected to ensure full compliance. Moving forward, HR will implement an enhanced verification control at the beginning of each fiscal year. This includes documented confirmation of pay accuracy for a minimum of two employees per department following salary schedule implementation and prior to the first payroll. Ideally, this control will be performed jointly by HR and Finance to ensure segregation of duties and consistency. Name(s) of the contact person(s) responsible for corrective action: Beth Wilde, Director of Human Resources Planned completion date for corrective action plan: July 1, 2026

Finding 2025-002 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 Award Year: 2022 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: HCA’s Ventura County Public Health (VCPH) Management agrees with the recommendation to strengthen the established policies and procedures to ensure all timecards consistently document evidence of supervisor approval. View of Responsible Officials and Corrective Action: The timesheet identified during this audit were submitted in the County’s payroll system prior to the completion of the 2024 fiscal year audit and related finding 2024-003; therefore, the related corrective actions had not yet been implemented at the time of submission. In response to the prior year’s finding, VCPH Management implemented enhanced controls to ensure compliance with timecard approval requirements moving forward from that date. Payroll staff now sends reminder notifications to supervisors, managers, and VCPH Management before and after each pay period closing to identify and resolve unapproved timecards. Management has also reinforced expectations through additional training for supervisors and managers. When a primary supervisor is unavailable, the established alternate approver process will be used to ensure timely approvals. VCPH Management will continue monitoring compliance with these procedures, and these requirements will be reviewed again with all supervising staff at the next scheduled WIC Supervisor Meeting. Name of Responsible Persons: Laura Flores, Manager, VCPH Rigoberto Vargas, Director, VCPH Implementation Date: May 1, 2025 – Instructions were provided to all supervisors at the WIC Supervisor Team Meeting May 7, 2026 – Timecard instructions will again be discussed at the WIC Supervisor Team Meeting

Finding Reference 2025-002 Personnel Responsible for Corrective Action: Drafting of policy, procedures, and forms will be completed by Westen Gehring (Grants Specialist) and Laura Froese (Accounting Manager), with input and final approval provided by Tracie Thomas (Chief Operating Officer) Anticipated Completion Date: The Effort Verification Policy and related procedures will be finalized by July 1, 2026, for implementation in Fiscal Year 2027. Retroactive effort certification for the period July 1, 2025 through March 31, 2026 will be completed by June 30, 2026. Monthly implementation tests of the new policies and procedures will begin with the April 2026 reporting period. Views of Responsible Officials and Planned Corrective Action: Concur. Corrective Actions Planned: The Land Institute will implement a formal effort reporting system effective July 1, 2026 (Fiscal Year 2027), including finalized policies, procedures, and standardized effort certification forms designed to ensure compliance with 2 CFR 200.430 As part of the transition to this system, retroactive effort certifications will be completed for Fiscal Year 2026 for the period of July 1, 2025 through March 31, 2026 to support payroll costs previously charged to federal awards. The months of April through June 2026 will be utilized as an implementation and testing period to establish and refine the monthly effort certification process. During this time, The Land Institute will complete effort certifications on a monthly basis, reflecting an after-the-fact determination of actual work performed across all institutional activities, and integrate the certification process into month-end close procedures. This phased implementation approach will allow management to validate processes, ensure accuracy and completeness of certifications, and make any necessary adjustments prior to full implementation in Fiscal Year 2027. Training will be provided to all applicable staff to ensure understanding of effort reporting requirements and compliance expectations. Finance and Grants personnel will monitor compliance and timeliness of certifications, and ongoing monitoring controls will be implemented to ensure continued compliance.

Higher Education Institutional Aid – Assistance Listing No. 84.031X Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant Project directors have been notified to have their employees track and document the hours spent in support of their grants versus time spent on college duties. Name(s) of the contact person(s) responsible for corrective action: Current Controller: Elizabeth Todd and Current Human Resources Director Nicole Mote Planned completion date for corrective action plan: 06-30-26

The District will implement time and effort documentation for employees paid with federal funds. The District has already implemented allocation process on the Child Nutrition invoices in FY26.

Program: HIV Emergency Relief Project Grants (Ryan White) Federal Financial Assistance Listing Number: 93.914 Federal Grantor: U.S. Department of Health and Human Services Award No. and Year: 6H89HA00019-32-04; 2024 Compliance Requirements: Activities Allowable or Unallowed and Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing, for one (1) out of sixty (60) payroll expenditures, we noted the timecard did not contain documented evidence of supervisory approval. Cause: The County’s internal control procedures were not consistently followed to ensure that the review and approval of timecards was documented. Effect: Lack of documented review for personnel hours could lead to an increased risk that unallowable or inaccurate activities and costs to be charged to the Federal program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sampling of sixty (60) timecards were selected for testing out of a population of 5,994. The condition noted above was identified during our procedures related to activities allowed or unallowed and allowable costs/cost principles. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its policies and procedures to ensure that timecards consistently include documented evidence of supervisor approval prior to payroll processing. The County should also establish compensating controls for circumstances where timely supervisory approvals is not possible, and ensure such controls are consistently documented. Management Response and Corrective Action Plan: 1. Person Responsible: Barbara Harano, HCA Disbursements Manager 2. Corrective action plan: HCA Payroll will continue to review the Unapproved Timesheets Report in OC Time and send reminder emails to all supervisors with pending approvals. If supervisory approvals cannot be obtained by the OC Time timesheet upload deadlines, HCA Payroll will ensure documented timesheet approvals are appended through the OC Time amendment process and archived in the Unit’s shared drive. 3. Anticipated Implementation date: January 22, 2026

Program: WIC Special Supplemental Nutrition Program for Women, Infants, and Children Federal Financial Assistance Listing Number: 10.557 Federal Grantor: U.S. Department of Agriculture Pass-Through: California Department of Public Health Award No. and Year: 22-10270 A03 and 2022 Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing of the HCA’s provisions for activities allowed or unallowed and allowable costs/cost principles requirements, we noted that for one (1) of sixty (60) payroll samples tested, the employee was able to review and approve their own timecard. Cause: It was determined that the control deficiency resulted from a system configuration error that permitted the employee to approve their own timecard under the supervisor/manager review role. Effect: Failure to consistently apply internal controls over payroll charges increases the risk that unallowable or unsupported payroll costs could be charged to the Federal program and not be detected in a timely manner. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sampling of sixty (60) timecards was selected for testing out of a population of 1,144. The condition noted above was identified during our procedures related to activities allowed or unallowed and allowable costs/cost principles. Repeat Finding from Prior Years: No. Recommendation: Management should ensure appropriate segregation of duties within the payroll system by restricting approval authority to independent supervisors or managers and implementing controls to prevent self-approval. In addition, management should periodically review user access roles and system configurations to confirm that approval controls are operating as designed and that payroll charges to Federal programs are allowable, properly allocated, and adequately supported. Management Response and Corrective Action Plan: 1. Person Responsible: Barbara Harano, HCA Disbursements Manager 2. Corrective action plan: An unexpected change occurred in the OC Time system that allowed an employee to both submit and approve their own timesheet. This issue had been previously reported and resolved. Auditor-Controller IT has reported the issue again to the timekeeping system vendor and is currently validating and testing the updated configuration to ensure the problem does not recur. 3. Anticipated Implementation date: June 30, 2026