Corrective Action Plans

Condition: Semi-annual time and effort certifications were not maintained for a grant employee whose salaries and wages were not supported by detailed time records. Corrective Action Planned: Management is aware of the missing time and effort certifications for the single grant employee. This error was in part due to the transition of both the Payroll Coordinator and Budget Analyst positions within Canton Public Schools. Controls have been put in place to ensure all time and effort certifications are completed and submitted to the business office in a timely manner. Anticipated Completion Date: Completed Contact: Stephen Marshall, Assistant Superintendent of Finance & Operations

1. Accounting Controls team will continue to coordinate with Central Office/program coordinators to: a) Communicate the impact of questioned cost resulting from current year’s audit findings. b) Follow through on the sample testing performed on payroll documentations as a secondary control twice a year; and c) Provide feedback and training to the schools based on the result of sample testing. 2. The Accounting controls team will continue to collaborate with the MyPLN team to ensure effective monitoring and timely completion of the annual Mandatory Time and Effort Training. This essential training is mandatory for administrators, timekeepers, and supervisors. Successful completion involves answering review questions at the conclusion of the course, with a 100% correct response rate necessary to obtain certification. 3. Each July, the LAUSD organizes the Principals' Leadership Institute, during which the Accounting Controls team and Central Office/program coordinators will present to principals and assistant principals the significance of completing Time and Effort documentation in a timely and accurate manner. 4. The Accounting Controls team will work with Organizational Excellence and Central Office/program coordinators to present to School Administrative Assistants at their scheduled meetings/trainings, at least once a year. Name: Bryant Gonzalez Title: Deputy Controller Email: bryant.gonzalez1@lausd.net

Views of Responsible Officials: Educare DC is an educational non-profit organization. We have consistently used weekly timesheets to document the total time spent by teaching and administrative staff. However, considering that it is difficult for teaching and administrative personnel to accurately charge time to specific awards, management has consistently used estimates based on the role of each employee. These estimates are reconciled and updated regularly based on after-the-fact effort in consultation with staff. Management will make sure this process is officially documented going forward. Management has noted the auditor’s recommendation and will ensure documentation of its allocation process to support time charged to federal program is strengthened. In addition, a formal policy and procedure will be documented and include responsible parties for preparing, reviewing, approving, and adjusting any noted variances between estimates and actuals incurred on a regular basis. Name and Title of Responsible Official: Barbara Ledyard, Vice President of Finance and Administration Anticipated Completion Date: January 31, 2024

Finding 2023-002: Special Education Cluster Semi-Annual Certification Procedures Recommendation: The School District should provide training to educate all employees working in federal programs of the requirements for documenting personnel expenses under Uniform Grant Guidance, and the School District should require proper time-and-effort documentation to be timely reviewed and approved by the appropriate program supervisor. Action Taken: Trainings will be provided to all directors of federally funded programs regarding the semi-annual certification process. Certifications will be performed by all federally funded staff two times each year. The first certification is due to the Director of Fiscal Services no later than January 15 of each year. The second certification is due to the Director of Fiscal Services office no later than July 15 of each year. Certification records will be verified and maintained by the Director of Financial Services. Responsible Person and Anticipated Completion Date: Director of Financial Services, November 2023. If the Michigan Department of Education has questions regarding this plan, please call Jesse Rickard at (231) 767-7209.

Corrective Action: The District has communicated with all departments that pre-filled forms should not be utilized when documenting salaries and wages charged to federal awards. Additionally, the District has reviewed all employees with recurring federal time and effort requirements to ensure the proper forms are completed. Monitoring will occur at the beginning of each semester to ensure all required time and effort documentation has been completed and collected. Responsible Officials: Kevin Caskey, CPA - Chef Financial Officer - (843) 680-6013 Anticipated Completion: Immediately

The Hingham Public Schools’ general weekly payroll is approved on a weekly basis by Management. In the case of our summer programs a similar control has been put in place by Management to ensure all payroll records are approved before processing.

Hingham Public Schools has circulated training guides and templates to grant writers on the requirement to have time and effort reporting completed in a timely manner for staff assigned to specific grants. Grant accounting associates have also been provided with the training material to ensure that there is an additional review of time and effort reports as part of the grant accounting, review and finalization process.

Time & Reporting - Corrective Action Plan In order to strengthen the internal controls surrounding time and effort reporting, the Organization has modified its policies and procedures relating to time and effort reporting to align with any changes in payroll processes and any changes in personnel at the Organization to ensure that appropriate support is maintained at all times at the Organization. Further, the Organization plans to implement regular internal inspections of records to ensure completeness and adherence to the policies in place.

Finding #2023-001 – Allowable Costs relating to Time and Effort and Internal Controls Contact – Suzanne Tobin, Chief Financial Officer Telephone Number – (301)-832-3810 Completion Date – First Quarter of 2024 Information on the Major Federal Program: U.S. Department of Health and Human Services Name of Program: Substance Abuse and Mental Health Services Assistance Listing Number: 93.243 Grant Award Number: 1H79TI085239-01/6H79SM080760-03M001/1H79TI084237-01/ 1H79SM080760-01 Grant Award Period: September 30, 2022 to September 29, 2027, November 30, 2018 to November 29, 2023, September 30, 2021 to September 29, 2026/November 30, 2018 to November 29, 2023 U.S. Department of Veterans Affairs Name of Program: Veterans Supportive Housing Per Diem Program Assistance Listing Number: 64.024 Grant Award Number: VOAQ754-1291-558-PD-21, VOAQ754-2080-558-CM-22, VOAQ754-2286-565-CM-22 Grant Award Period: October 1, 2022 to September 30, 2023 Corrective Action Plan: Effective immediately, the Organization will strictly enforce its policy for employees to properly complete their timesheets and for supervisors to properly review and approve employees’ timesheets. To do this, the Organization will conduct a training for all employees and supervisors about how to properly complete and review timesheets. To ensure compliance with the policy, the Organization will conduct random checks of timesheets every pay period to verify that supervisory approval is performed. Appropriate disciplinary action will be implemented for non-compliance.

The Institute has implemented procedures to ensure all documents to support the salaries and wages charged to federal programs are prepared in accordance with the SCDE requirements.

The Institute has implemented procedures to ensure all budget estimates used for salaries and wages are reviewed quarterly and adjustments will be made to reflect actual cost for the activity performed in accordance with the SCDE requirements.

The School District recognizes the issue identified during the audit and has made all necessary adjustments to ensure compliance with spending down the remaining ESSER III funding.

The Assistant Superintendent of Curriculum & Instruction will work with the Business office and the Human Resources department to ensure that the Certification of Federal Awards forms accurately reflect the employee's time charged to the grant. The forms will be reviewed to ensure the costs are allowable and properly documented.

The District will implement a system of internal controls to ensure that all certifications are completed timley. Additionally, the District will ensure that time being charged to the grant agrees to actual time spent working in the grant for each employee.

Ashley Community Schools will immediately implement procedures to ensure documentation of distribution of salaries and wages is regularly completed, reviewed, authorized and maintained. The direct supervisor of all staff providing services under federal awards will ensure documentation is compiled, reviewed and authorized no less than quarterly. Original documentation will be maintained by the direct supervisor and copies of fully executed documentation will be shared with the superintendent’s office for storage for a minimum of five years.

View of Responsible Officials: Management response and corrective action Personnel responsible for corrective action: Evan Heath, CFO Anticipated completion date for corrective action: April 30, 2026 In response to Finding No. 2022-SA3, management agrees with the finding. Corrective actions will be implemented in subsequent fiscal years. Unallowable costs will be identified and documented in the Accounting Policies and Procedures Manual and communicated to the Finance Department and the Organization’s employees. The CFO will regularly communicate these requirements to directors and staff through weekly and monthly meetings to ensure a clear understanding of allowable versus unallowable costs. In addition, quarterly budget-to-actual analyses will be prepared and reviewed to monitor expenditure and ensure costs remain within approved budget limitations.

Department of Housing and Urban Development and Department of Veterans Affairs 2022-008 Federal Program Name: Emergency Solutions Grant Program and VA Homeless Providers Grant and Per Diem Program Assistance Listing Number: 14.231 and 64.024 Recommendation: We recommend the Organization develop a system of internal controls to ensure that salaries and related payroll expenses are tracked to reasonably reflect the actual time spent working on the programs. In addition we recommend that management retain all documents including evidence of review and approval for all expenditures of federal funds until the latter of the legally required retention period or completion of required audits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented internal control procedures to strengthen payroll allocation practices and documentation retention for federally funded expenditures. The Organization has established a process to ensure that salaries and payroll-related costs charged to federal programs are supported by appropriate time tracking and allocation documentation that reasonably reflects actual time worked on each program. Supervisory review and approval requirements have been implemented to validate payroll allocations and supporting documentation. Additionally, the Organization has reinforced documentation retention standards by requiring retention of all federal expenditure support, including invoices, approvals, reconciliations, and evidence of review, in accordance with federal retention requirements and audit availability standards. Name(s) of the contact person(s) responsible for corrective action: Ryan Ross, Executive Director Planned completion date for corrective action plan: March 31, 2026

Item 2022.003 - Activities Allowed or Unallowed Recommendation We recommend that the Center consistently enforce its internal controls over payroll to ensure that the timesheet and payrates are reviewed and approved by the appropriate supervisor. Additionally, we recommend that the Center consistently reinforces its internal controls over nonpayroll expenditures to ensure all expenditures were approved by the appropriate supervisor. Repeat Finding Yes Action Taken Island Health Care will take the following actions to address this recommendation: Timesheet and Payrate Review and Approval: • Standardize timesheet submission and approval process • Utilize an electronic timesheet system to document the verification of employee payrates and ensure there is a detailed audit trail that records all submissions, reviews, and approvals by supervisors • Conduct regular audits to verify timesheets and payrates are reviewed and approved by supervisors NonPayroll Expenditures: • Evaluate and improve upon existing processes to ensure internal controls over nonpayroll expenditures are working. This includes enforcement of approval policies with mandatory documentation and regular monitoring throughout the process for a clear audit trail • Conduct regular audits to verify nonpayroll expenditures have been reviewed and approved by supervisors

During this period, Hope the Mission experienced rapid organizational growth in which our internal infrastructure had not yet caught up to support the significant growth in programs and funding. Since then, management changed our 3rd party payroll provider in order to better support our payroll and reporting needs. As part of this transition, we worked closely with our new payroll provider to implement job-costing functionality that will accurately track time across grants funded programs. In addition, we have established a process requiring department leads to review and approve all timesheets prior to submission. We also partnered with our new 3rd party payroll provider to set up time allocation for salaried employees.

Re: Corrective Action Plan - Audit Finding 2022-02 - Improve Controls and Documentation over Payroll Planned Corrective Action: The District will enhance payroll documentation controls by standardizing processes for verifying pay rates, retaining payroll support documents, and documenting/approving transfers and allocations. Cross-department procedures between Payroll, HR, and Business Office will be formalized. Staff involved in payroll and federal grants will receive training. Planned Implementation Date of Corrective Action: Already following corrective action Person Responsible for Corrective Action: Lisa Gibbons; Director of Finance & Operations ___Lisa Gibbons__________________________ Signature Ms. Emilys Peña Assistant Superintendent Dr. Deanne Galdston Superintendent of Schools Ms. Lisa Gibbons Director of Finance and Operations Dr. Ceronne Daly Director of Diversity, Equity, Inclusion, and Belonging Dr. Kathleen Desmarais Director of Student Services Ms. Amanda Owens Director of Human Resources

Planned Corrective Action(s): SIG-NAL will enhance internal controls by implementing formal review and approval processes for payroll, expenses, and financial reporting. The organization will require documented evidence (digital or written) of all reviews and approvals and will maintain these records in a standardized, centralized system. The Finance Team will ensure that all controls are performed and documented in accordance with 2 CFR Part 200 requirements. Updated internal control policies and procedures adopted in 2025 address these requirements and are being fully implemented. Anticipated Completion Date ● March 2026 Responsible Party ● Director of Operations, with support from the Finance Team and Executive Director

Corrective Action Plan The documentation deficiencies identified were largely due to the absence of a dedicated internal Human Resources (HR) department and the absence of formalized HR procedures. During the audit period, HR services were outsourced to a third-party provider; however, the services provided were not comprehensive nor su􀆯iciently tailored to the agency’s operational and compliance needs. Additionally, the scope and deliverables under that contract were not clearly defined, resulting in incomplete documentation practices and potential risk exposure.

The Government concurs with the auditor's findings and recommendations. The Division of Human Resources is now adjusting the Notice of Personnel Actions to reflect the requisite Project code at the beginning of each Fiscal year.

The Government concurs with the auditor's findings and recommendations. DOH fully acknowledge and accept the auditor’s finding regarding DOH’s inability to reconcile the payroll expenses listed in the SEFA with those documented in the payroll register. This discrepancy arose because payroll adjustments were not completed in time to reflect accurately in the FY2022 SEFA. To address this, DOH team has received thorough training, and staff members now have the necessary access to make payroll adjustments in the Government Financial Management System as of FY2024. Moving forward, DOH will strengthen our SOPs by conducting monthly reconciliation meetings with all relevant program teams to ensure timely adjustments and continuous monitoring. Additionally, DOH will update procedures to guarantee that all new fiscal staff are granted complete financial system access and are trained on reconciliation and adjustment processes within two weeks of starting.

The Government concurs with the auditor's findings and recommendations. VIDE acknowledges the audit finding related to payroll activities and recognizes the need for stronger internal controls to ensure full compliance with federal regulations. To address the identified discrepancies and prevent future occurrences, VIDE will enhance timesheet management and strengthen rate verification processes. To improve timesheet management, VIDE will implement a system to ensure all timesheets are submitted and readily available. This will include electronic timesheet submission, mandatory supervisor review and approval before payroll processing, and secure electronic storage and archiving of timesheets. VIDE will also strengthen its rate verification process by implementing a standardized procedure that includes a checklist for comparing NOPA rates with payroll system rates. Payroll staff will be required to complete this checklist at the start of each pay cycle and maintain a tracker to flag any discrepancies. To ensure all employees and supervisors understand the new policies and procedures, VIDE will conduct mandatory training sessions. These sessions will cover proper timesheet completion and submission, rate verification requirements, and the importance of adhering to the new guidelines.