Corrective Action Plans

Auditors? Recommendation - We recommend the College follow their policies and procedures related to time and effort certifications. Views of Responsible Officials and Planned Corrective Action - The College agrees and states that due to staff turnover and limited staff resources time and effort certifications were partially completed, or not maintained in the Business Office central file. The College will review its central file for time and effort certifications for all required positions and correct accordingly. The College will note that federal and non-federal award expenditure reconciliations are performed monthly and as required, and this process is another control for payment validation. Responsible Official - Denise Montoya, Vice President for Finance & Administration, Theresa Storey, Chief Financial Officer, TBD, Grant Manager, and Stephanie Lovato, Accountant Timeline and Estimated Completion Date - June 30, 2023

Finding 2022 ? 002/50000 Section III ? Federal Award Findings U.S. Department of Education ? Passed through California Department of Ed (Title I Part A) TITLE I SCHOOLWIDE PROGRAMS County Response: The Alternative Education Department has established a procedure to ensure that the relationship between the planned supplemental instructional program and the planned expenditures are clearly reflected in the School Plan for Student Achievement (SPSA). Annually the department shall evaluate the effectiveness of the SPSA plan. The Alternative Education Department shall monitor student progress and if there is a need to modify the school?s plan in the current year, the Alternative Education Department shall update the SPSA and determine if a budget adjustment is required. Contact Person responsible for corrective action: Victoria Sorensen 831.784.4226 Ernesto Vela 831.755.1405 Completion Date: January 15, 2023

CORRECTIVE ACTION PLAN (Concerning Finding 2022-001) Contact Person Responsible for Corrective Action: Shelley Lane, Superintendent of Schools Corrective Action: The Millinocket School Department will take the following actions to address finding 2022-001: All employee paid with federal funds will be required to complete personal activity reports or a semiannual certification will be completed and signed monthly or semi-annually as required to comply with the terms of the grant. Timesheets will also be utilized to reconcile time worked and wages paid to the grant on a monthly basis. Employees paid with grant funds, supervisors and the payroll department will be provided the documentation and training on certification and time reporting. Anticipated Completion Date: April 14, 2023.

St. Vincent de Paul Society of Marin ? 822 B Street ? PO Box 150527 ? San Rafael, CA 94915 ? PHONE 415?454?3303 ? r.u 415-454?3406 ? v1s1r www.vinn Corrective Action Plan For the Year Ended September 31, 2022 Finding 2022-001 Corrective Action Plan: Management will continue to follow the revised methodology that was implemented in July 2022 for allocating payroll costs to Federal awards such that payroll costs charged to Federal awards reflects the actual time incurred. The Society has notified the funding agency of the overbilling and accrued the overbilling amount as of September 30, 2022. Name of Responsible Person: Forest Thomas, Director of Finance Anticipated Completion Date: September 31, 2022

Management accepts the finding and notes that the prior year finding was not reported until near the end of the current audit period, contributing to the repeat finding. Effective in June 2022, payroll authorizations were directed through the PeopleSoft system to the Payroll Manager who prepared and documented the necessary allocation calculation. This calculation, along with a copy of the original payroll authorization for the employee and the superseding payroll authorization were sent to the Associate Controller for review and verification. This secondary review was marked approved and returned to the Payroll Manager for final entry in the payroll system and records archiving. Further, a campus committee with representatives from the offices of; Controller, Information Technology, Sponsored Research Services, Payroll and Academic Affairs Operations was formed to further review and address this prior year finding. The Committee has developed a form within PeopleSoft that will allow for entering payroll authorization data, system calculation of applicable fringe adjustments, and a system driven workflow review and approval process from initial entry by the Principal Investigator to approval by Sponsored Research Services to the approval by either the Research Accountant or the Associate Controller for posting of all prior period reallocations. Any adjustments affecting future periods will be processed through the existing payroll authorization process and system entered by the Payroll Office. System testing of this reallocation process is currently taking place with implementation scheduled for April 1, 2023. A further enhancement of automating the related journal entry posting upon final approval by the Research Accountant or Associate Controller is expected to be implemented by May 1, 2023. InAnticipated Completion Date June 30, 2023 Responsible Person Keith Rosser, Controller William McGarry, Chief Financial Officer light of the repeat finding, the University will further engage an outside firm to conduct an internal audit of the Payroll Department with a focus on reviewing current processes from employee set up through issuance of compensation and filing of state and federal forms. This expected outcome of this review will be to identify areas of potential weakness, process improvement, and current utilization of existing financial systems and tools.

Finding 2022-003: Inadequate Support for Salaries and Wages-Time Certifications not maintained (5000) Federal Agency: U.S. Department of Education Pass through Entity: California Department of Education Program Names: Elementary and Secondary School Emergency Relief I, II, III (ESSER, ESSER II, ESSER III) (Assistance Listing 84.425, C, D, U), Title I (Assistance Listing 84.010) Criteria: 2 CFR 200.430 requires that an LEA must maintain time and effort distribution records that support the distribution of the employee?s salary or wages among specific activities or cost objectives. 2 CFR, section 225, appendix B, Section 8(h) states in part: Support of salaries and wages- These standards regarding time distribution are in addition to the standards for payroll documentation. (1) Charges to Federal awards for salaries and wages, whether treated as direct or indirect costs, will be based on payrolls documented in accordance with the generally accepted practice of the governmental unit and approved by a responsible official(s) of the governmental unit. (2) No further documentation is required for salaries and wages of employees who work in a single indirect cost activity. (3) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employee worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. CSAM Procedure 905 states, in part: Periodic (Semiannual) Certification Employees who work solely on a single federal award or cost objective need only complete a periodic certification. The periodic certification must: Be prepared at least semi-annually. Be signed by the employee or the supervisory official having firsthand knowledge of the work performed by the employee. State the employee worked solely on that single federal program or cost objective during the period covered by the certification. Where multiple employees work on the same cost objective, a blanket certification may be used as the documentation for all employees who worked on the cost objective?. Personnel Activity Report Except as provided in ?Substitute Systems for Time Accounting,? employees who work on multiple activities or cost objectives of which at least one is federal must complete a personnel activity report (PAR) or equivalent documentation. A PAR may be as detailed as a document that identifies the employee?s activity daily by hours, or it may be as simple as a report of the total hours or percentage of hours spent in each categorical program or cost objective. The level of detail can generally be determined by the diversity and variation of the employee?s work activities. The safest approach is to provide more documentation rather than less. Finding: The District provided approved time sheets for only 3 employees out of 20 selected that were paid from ESSER funding. The District provided 9 of 10-time accounting records that included PARS for Title I. Cause: The District does not have adequate controls in place to ensure that time certification documentation is prepared and maintained to support all employees who are paid with federal funds. Effect: The District did not provide time certification records for 17 of the 20 employees selected for review, who were paid with Education Stabilization Funds. As a result, the amount of $736,116.27 is in question. The District did not provide time certification records for 1 of 8 employees selected for review, who was paid with Title I funds, as a result, the amount of $ 91,794, is in question. Recommendation: We recommend the District comply with Title 2, CFR 200.303, and CSAM Procedure 905 which require that employee time certification forms be maintained for employees who charge time to federal programs. Action: Management will ensure that the District does have adequate controls in place and comply with Federal rules and guidelines. Completion Date: Effective immediately. Contact: Zach Klemish, Director of Fiscal Services, Adelanto Elementary School District, (760) 246-8691

July 6, 2023 Harshwal & Company, LLP 333 Hegenberger Rd, Suite 328 Oakland, CA 94621 As required by Title 2 As required by Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), we have provided below our responses and corrective action plans addressing the findings noted in the PRC's Single Audit reporting package for the year ended June 30, 2022. Response and Corrective Action Plan 1. Finding 2022-002 (Prior Year Finding 2021-002) - Activities Allowed or Unallowed and Allowable Costs/Cost Principles, No Time Studies, Proper Time Tracking, Time Allocation and Time Reporting (Significant Deficiency) Response and Corrective Action Plan: 35& DQG %DNHU 3ODFHV ,QF FROOHFWLYHO\ ?35&' FRQFXUV ZLWK WKH ILQGLQJ DQG has implemented the following steps to correct the condition: a. PRC instituted new payroll procedures requiring supervisors to document approval of time submitted by all staff through our electronic payroll system, including a retroactive review and approval of all time submitted since July 2022. b. Staff were trained on the new procedures during June 2022 and the procedures are being incorporated into a new combined PRC and Baker Places, Inc. Financial Policies and Procedures Manual which will be finalized and circulated to all staff in July, 2023. Anticipated completion date: July 2023 Responsible person: Leo Levenson, CFO, PRC and Baker Places, Inc.

* The rate of pay for after school tutoring programs has been added to the Board approved salary schedule. The list of employees that will be compensated for after school tutoring is also Board approved. Time sheets will be documented and approved by the site supervisor/superintendent. The Board action is shared with the payroll department after each board meeting to ensure compensation is correct. The payroll department has been trained/advised that no compensation for after school tutoring can be made without Board approval and a signed/approved time sheet. * All contracts must be Board approved and signed by the Superintendent. Human Resources is responsible for maintaining copies of all contracts. The contract template has been reviewed by the board attorney for necessary requirements. The compensation amount must be clearly stated when the contract is board approved. Accounts Payable has been trained/advised that no compensation can be made to an independent contractor without Board approval and signed contract with specified rate of pay and documentation of services rendered. * All current supplements have been added to the Board approved salary schedule. The FY24 Salary Schedule was approved at the September 12, 2023 meeting. The list of personnel receiving supplements must be Board approved. The Board action is shared with the payroll department after each board meeting to ensure compensation is correct. The payroll department has been trained/advised that no compensation for supplements can be made without Board approval and a signed/approved time sheet documenting that the required work/duties has been performed. * All independent contractor contracts must be board approved and signed by the Superintendent. Human Resources is responsible for maintaining copies of all contracts. The contract template has been reviewed by the board attorney for necessary requirements. The compensation amount must be clearly stated when the contract is board approved. Accounts Payable has been trained/advised that no compensation can be made to an independent contractor without Board approval and signed contract with specified rate of pay and documentation of services rendered. * Documentation must be provided that students were identified as homeless students or eligible to received benefits under the Homeless Children and Youth grant before any payments can be made. Accounts Payable has been advised/trained that this documentation must be on file and confirmed before any payment is made. The Federal Programs Director is currently serving as the Homeless Liaison Coordinator and is responsible for this documentation.

Finding 2022-001: Time and effort reporting Department of Education Passed through the New York State Department of Education 84.027, 84.173 Special Education Cluster Condition/Criteria: Under 2 CFR 200.430, Uniform Guidance requires that payroll systems must be based on records that accurately reflect the work performed and are supported by a system of internal controls that provides reasonable assurances that charges are accurate; allowable and reasonable; and properly allocated. Although the District does have a process to track time and effort within the grants, the District did not have proper reporting performed during the school year for teachers that were tested under the grant. Their internal controls failed to detect the lack of reporting performed. Context: A sample of 2 out of 11 employees were haphazardly selected for testing. This was not a statistically valid sample. Cause. The District does not currently have records that support time and effort for teachers under the grant. Effect? The District is not in compliance with time and effort reporting. Recommendation: We recommend the District examine the control procedures in place related to this area and ensure they are designed sufficiently for the District to meet the requirement of 2 CFR 200.430 under Uniform Guidance. Action Taken: Starting September 2022, any staff member who is either fully or partially compensated from a grant has signed a monthly statement noting the hours worked, percentage of his or her FTE funded, and the grant source. This statement is also signed by his or her supervisor.

Audit Finding Reference: 2022-001 Planned Corrective Action: CDC's management performed a review of timekeeping and reimbursement practices in relation to reimbursements submitted to the U.S. Small Business Administration ("SBA") regarding the Microloan Technical Assistance Program and noted that SBA had likely overpaid CDC for multiple years for expenses related to personnel hours spent. After review, all relevant personnel were advised and instructed to comply with revised timekeeping practices to address the issue going forward. Additional processes/controls were also established to mitigate future occurrences. CDC's management notified the SBA of the matter and repaid the estimated amount of overpayment on April 17, 2023. Name of Contact Person: Natalie Gunn, Chief Financial Officer Phone: 703-647-2360 Email: ngunn@capitalimpact.org

Finding Number: 2022-005 Condition: An internal control was not in place to document that the current rates of pay were approved. During our testing of payroll for ALN 17.258, 17.259 and 17.278 - WIOA Cluster and ALN 17.207 Employment Services Cluster, we determined that actual pay was charged to the federal grants tested. However, there was no documentation (within personnel files or other means) to support that the rates of pay were approved. Planned Corrective Action: DESC was unable to locate evidence due to turnover with the HR department. We have hired a new Director of Human Resources (Director), who has implemented an employee filing system that incorporates up to date employee information and salary information. This information is noted in offer letters, promotion letters and salary increase letter. All payroll updates are required in writing to evidence approval of the Director of Human Resources and another executive team members authorization (President or CFO). This confidential information is stored in the Director?s locked office. Contact person responsible for corrective action: Calethia Binion, HR Director Anticipated Completion Date: 06/30/2023

Management agrees that we should improve our timesheet input and approval process. The current process is manual, and the corrective action includes two elements: 1.Education process of proper timesheet reporting for new employees and an annual review. 2.Automate the process to increase efficiencies and make the review process more effective. Our 2024 budget submission will include a tool that can be used for these purposes. Name of the contact person responsible for corrective action: Sharon Pinder, President, (301)593-5860. Planned completion date for corrective action plan: December 31, 2023.

Funding Summary: The district was missing Time & Effort documentation details, and documents were signed and dated before the work period end date. Responsible Individual: Teresa Taylor, Business Manager Corrective Action Plan: Per our audit requirement, the current forms we were using for the Semi-Annual Certification and Time & Effort (PAR) have been updated to reflect the required information and proper signatures and date. In the past Time & Effort was not tracked for those paid a stipend for Mentoring, but as of this school year we are requiring that this time is tracked monthly as required per 2 CFR 200.430. Per the grant audit, we have retroactively completed forms for both FY21 & FY22. These records are filed with the respective grants. Anticipated Completion Date: January 20th, 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: The bus rates will have in every weekly pay attached the rates for each route and submitted with their timecards. The bus rates will be prepared by the Transportation Director and will be reviewed by the Deputy Treasurer and then the Treasurer. Anticipated Completion Date: March 2023

View of responsible officials and planned corrective action: Due to inaccuracies in the preparation of the monthly payroll journal entry, the Agency is establishing new internal controls. The Agency Accountant has developed a spreadsheet that accurately logs the hours staff works in certain programs. This will result in percentage that will be used by the Accounting Assistant to accurately charge the correct program on the payroll journal entry spreadsheet. Once this is completed each month, the Agency Accountant will review the payroll journal entry for accuracy and that it matches the percent breakdowns given.

Department: Administrative and Financial Services Title: Internal control over monitoring of employee classification and compensation needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will require Service Center and Agency HR Directors to notify supervisors at least twice per year of overdue performance evaluations. The Department will require Service Center and Agency HR Directors to review Hiring Requests to ensure duties identified are consistent with classifications. The Department will require Service Center and Agency HR Directors and/or HR recruiters to review job vacancy postings to ensure duties are consistent with classifications. The Department will implement a 'review of classification specification date' on class specs (currently only note date when a change is made). Completion Date: October 1, 2023 (first item), and April 30, 2023 (remaining items) Agency Contact: Breena D Bissell, Director, Bureau of Human Resources, DAFS, 207-215-0886

CORRECTIVE ACTION PLAN February 16, 2023 Community Action Association of Pennsylvania respectfully submits the following corrective action plan for the year ended June 30, 2022. Cognizant or Oversight Agency for Audit: Community Service Block Grant Program Name and address of independent public accounting firm: Hamilton & Musser, PC 176 Cumberland Parkway Mechanicsburg, PA 17055 Audit Period: July 1, 2021 ? June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Findings ? Financial Statement Audit Significant Deficiencies #2022-001 ? Significant Deficiency ? Segregation of Duties Recommendation We recommend someone other than the Finance Director, preferably the CEO or another office staff, open the mail and record/scan the checks received into a check log. View of responsible officials and planned corrective action The Executive Administrative Assistant is now tasked with and responsible for opening the mail and recording the checks into a check log. The Executive Administrative Assistant will forward checks to the financial services team for additional action steps. #2022-002 ? Significant Deficiency ? Authorization and Approval Recommendation We recommend that all credit card charges are matched to a receipt and reviewed and approved by both the Board President and Board Treasurer, as is the policy with other payables/disbursements. This eliminates the risk associated with having the CEO issue approval over his own credit card charges. View of responsible officials and planned corrective action All credit card receipts will be submitted by the CEO or appropriate staff member to the financial services team. Credit card reconciliation documentation and appropriate receipts will be provided to the Board Treasurer for regular review. -28- Findings ? Financial Statement Audit (Continued) #2022-003 ? Significant Deficiency ? Authorization and Approval Recommendation Non-cash journal entries make it easy for organizations to overstate their revenue or understate their expenses with unsubstantiated accruals/deferrals. We recommend that all journal entries be authorized and approved by the CEO prior to entry. View of responsible officials and planned corrective action As noted, this is no longer an issue with internal controls having been corrected as of December 31, 2021. All non-recurring journal entries will be approved by the CEO. Findings ? Federal Award Programs Audit Community Service Block Grant, CFDA #93.569 #2022-004 ? Significant Deficiency ? Allowable Costs Recommendation We recommend maintaining weekly timesheets with CEO approval, itemized by time allocated per grant. The financial statement records should be supported by direct time allocated to the grant as indicated on the approved timesheets. View of responsible officials and planned corrective action CAAP will do its due diligence in appropriately allocating costs should similar costs be incurred. If the Community Service Block Grant Program has questions regarding this plan, please call Community Action Association of Pennsylvania Chief Executive Officer Beck Moore at 717-233-1075 extension 12.

The District will ensure that all employees not on a formal allocation plan or entirely allocated to a single source complete daily activity reports.

2022-001 Crime Victim Services - Assistance Listing No. 16.575 Recommendation: The Organization should implement internal controls to ensure that time and effort is reviewed on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Women's Advocates has systematized time and effort within the payroll system whereby employees and their supervisors approval timecards with the appropriate grant coding. Name(s) of the contact person(s) responsible for corrective action: Yulanda Williams Planned completion date for corrective action plan: 1/23/2023

Item 2022-001 Written policies, procedures, and standards of conduct Recommendation: Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non-Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: ? ? 200.302 Financial management ? ? 200.305 Payment ? ? 200.319 Competition ? ? 200.320 Methods of procurement to be followed ? ? 200.430 Compensation?personal services ? ? 200.431 Compensation?fringe benefits We recommend that the Board implement the required written policies and procedures. Action Taken: The Board?s management, namely Stacey Parker, CFO and General Manager, acknowledges the finding and will implement the necessary written policies to comply with the UG. Management anticipates completion by September 30, 2023. Audit finding 2022-001 relates to prior year 2021-001 finding. Updated reference number to current audit year 2022.

December 20, 2022 Finding: 2022-001 Allowable Cost/Cost Principal Agency: U.S. Department of Education AL Number: 84.425D Grant: Education Stabilization Fund Under the Coronavirus Aid, Relief and Economic Security Act Name of contact person and title: Crista Perkins, Business Manager Anticipated completion date: 06/30/2023 Agency's response: Concur The Department agrees with this finding and will implement the following: ? ?Review policies and procedures that require time and effort records for employees working in federal grants are properly documents according to grant requirements ? ?Distribute policies and procedures ? ?Train/Update staff on the policies and procedures ? ?Grant manager will review and approve time and effort records to be sure they are covering a six month period per the Compliance Supplement

View of responsible officials and planned corrective action The Association will conduct reconciliation of payroll allocation twice each year at the end of the second quarter and at the end of the third quarter to actual time recorded to ensure salary expense allocated to the federal awards is supported by actual time worked. A budget revision based on actuals will be implemented effective the fourth quarter.

2022-002 Research and Development Cluster ? Assistance Listing No. 93.310 Recommendation: We recommend the Blood Bank implement procedures to ensure all personnel charges to the program are supported by the minimum time and effort documentation outlined within 200 CFR 200.430. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Blood Bank added review and approval processes to compare actual vs budgeted vs allowable time and effort. Names of the contact persons responsible for corrective action: Bryan Eleazar, CFO; Lisa Alexander, Direct of Grant Accounting; Jeanette Lysse, Controller Planned completion date for corrective action plan: October 29, 2021

Federally funded employees will have their timecards regularly evaluated to ensure amounts charged to federal programs are substantiated.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.559 Contact Person: Venessa Beecroft, Business Manager Anticipated Completion Date: June 30, 2023 Planned Corrective Action: The District will implement a tracking tool to ensure that all new hires return their work agreements as they are hired on throughout the year.