Corrective Action Plans

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

Corrective Action: The district will strengthen internal controls on the employee contract and employee board approval process. There will be checks and balances between Human Resources and the Business Office before any recommendations are presented to the board. Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: February 18, 2025

CORRECTIVE ACTION PLAN March 19, 2025 U.S. Department of Health an-d Human Services Employee & Family Resources, Inc. respectfully submits the following corrective action plan for the year ended 06/30/24. Name and address of independent public accounting firm: BerganKDV, Ltd.; 220 Park Ave South; St. Cloud, MN 56301 Audit period: July 1, 2023 - June 30, 2024 he finding from the scheduleoflindmgs and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Federal Award Finding Significant Deficiency Finding 2024-001: Proper Support for Payroll Cost Allocations Recommendation: We recommend that the Organization utilize the time and effort reporting system that ensures payroll costs are charged to federal awards based on actual hours worked and to train employees to properly code their hours. If actual hours are not used, management should review and adjust salary allocations periodically to align with documented time records. Action Taken: We concur with the recommendation. Information from the time and effort reporting system will support the payroll costs for the year July 1, 2024 - June 30, 2025. Beginning July 1, 2025, payroll costs charged to federal awards will be based on actual hours worked during the calendar month. Additional training has been conducted with staff and supervisors. Questions regarding this plan can be addressed to me at 515.471.2360. Sincerely, Tammy Hoyman CEO

Food Distribution Cluster US Department of Agriculture / Oregon Department of Human Services Federal Assistance Listing Number: 10.565, 10.568, 10.569, 10.182 Federal Program Name: Food Distribution Cluster, Local Food Purchase Assistance Cooperative OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Rut Martinez-Alicea, Director of Equity People Culture and Administration; Starr Yurkewycz, Director of Partnerships and Programs; Nathan Harris, Director of Community Philanthropy; Shannon Oliver, Interim Director of Operations Corrective Action Plan: Finance will collaborate with key stakeholders to develop and implement a time and effort reporting system that meets federal documentation standards. This plan will identify impacted personnel and tailor reporting processes based on different funding sources. This effort will be cross departmental, roll out may include iterations of testing and refining and require training adoption and monitoring. These actions will strengthen internal controls and ensure personnel costs are accurately recorded and appropriately allocated. The anticipated completion date is: Employee review & certification of time and effort estimates - June 30, 2026 Implementation of software solution for time and effort documentation - June 30, 2027

University System Response/Corrective Action Plan North Dakota State University: Agree. North Dakota State University agrees to certify federal payroll expenses in a timely manner. North Dakota State University implemented a new payroll certification system which went live Spring 2024. Previously, North Dakota State University utilized a manual effort reporting process as part of PeopleSoft. The new payroll certification process was built into Novelution Research Management System, which supports multiple aspects of grant management. Novelution allows PIs to review salary information and certify within the software, provides automated reminder emails, and provides a better tracking mechanism for compliance. There has been a learning curve in utilizing the new system, and during FY2025 we continued to refine the process and implement additional mechanisms to improve compliance. University of North Dakota: Agree. In accordance with University of North Dakota’s policy, we will remind pre-reviewers and certifiers of University of North Dakota's requirement for timely certification. As outlined in the policy, we will invoke the consequences for failing to timely certify, including removing uncertified payroll from a project. Contact Person: North Dakota State University: Karin Hegstad, Associate Vice President Finance & Administration University of North Dakota: Lauren Pite, Director Grants & Contracts Anticipated Completion Date: North Dakota State University: June 30, 2025 University of North Dakota: March 31, 2025

Information on the federal program : Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Context : For 18 selections, in a sample of 40 payroll transactions, the School Corporation based the employees’ time charged to the grant on an annual time and effort log. The employee’s time was split with a non-federal fund. The School Corporation allocated the employee’s time based on a time and effort log completed in September of each year which was reviewed by the Superintendent. The School Corporation did not complete time and effort logs more frequently than annually to ensure the amounts being charged to food service were based on worked performed for each payroll period. Contact Person Responsible for Corrective Action: Candace McDonald Contact Phone Number: 765-734-1261 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Instead of doing a time study, we will fully implement an analysis of percentages paid by the school lunch program on a monthly basis. Anticipated Completion Date: Beginning of April 2025, fully implemented and corrected by the end of May 2025.

We concur with this finding and have implemented measures to mitigate the repetition of additional occurrences. In July 2023, a new policy was implemented that requires employees to record their time as a percentage across all grants in which they work. The employee records this allocation at least weekly within a time keeping software system. Employees and supervisors are now required to review and acknowledge payroll allocations across grants by signing weekly timesheets. Timesheets will be retained and used as backup by the Grants Department when invoicing the Grantor for expense reimbursement. In addition, we have updated our Policy and Procedures Manual to reflect this policy. An additional policy was implemented in November 2024 requiring one Accounting staffer and one Grant staffer review employee timecards versus invoices prior to submission. The Policy and Procedures Manual has been updated to reflect this policy. Responsible Parties: Kimberly Yoo, CFO Whitney Gillis, Director of RD Mary Guzman, Accounting Supervisor Date Corrected: November 2024

Corrective Action Plan: The Division will implement a more detailed and precise review process to ensure the accuracy and completeness of the reimbursement request. Anticipated Date: April 2025 Name of Person Responsible for Implementation: Al Agpoon, Controller

Context: For 4 selections, in a sample of 40 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the ESSER III fund. The sample amount charged to the grant for split-funded employees without time and effort logs was $1,375. Contact Person Responsible for Corrective Action: Serena Francis, Business Manager Contact Phone Number: 765-985-3891 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will implement time and effort logs for all split-funded employees. Currently we do not have any split funded employees. Anticipated Completion Date: 3/1/2025

2024-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027 Condition: Subpart I, 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 performed. The documentation should support the distribution of the employee’s compensation among specific activities if the employees work on more than one Federal award, or a Federal award and non-Federal award. The preparation of personnel activation reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, it was noted that in some instances, the District’s payroll verification forms were either not reviewed or signed by either the employer and employee, and they did not accurately reflect the actual allocation that was charged to the grant in order to comply with Subpart I, 2 CFR §200.430. Planned Corrective Action: The District acknowledges the finding and will thoroughly review and maintain the federal personnel activity reports to ensure each employee’s salary, or other forms of compensation, are properly approved and signed off by employer and employee. Additionally, the District will ensure that the amount charged to the grant corresponds to the federal program to which the employees’ earnings were allocated, based on time and effort, in compliance with Subpart I, 2 CFR §200.430. Responsible Contact Person: Jean Mingot Assistance Superintendent for Business Southampton Union Free School District 70 Leland Lane Southampton, New York 11968-5089 Anticipated Completion Date: June 30, 2025