Corrective Action Plans

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.

The Government concurs with the auditor's findings and recommendations. DHS transitioned from a manual payroll process to the Government electronic Timeforce (STATS) system. All time and attendance are now vetted and approved through the various levels of applicable management, ultimately being approved by the Agency Head or designee. Payroll is generated based on the cost centers listed on the Notice of Personnel Action. Payroll is now reconciled by the Financial Analyst once it is posted by the Department of Finance to ensure that cost is applied appropriately. Additionally, a workflow is now established in the NOPA approval process to ensure the current org, objects and projects are listed on the Notice of Personnel Actions (NOPA) which is utilized for payroll purposes.

The Government concurs with the auditor's findings and recommendations. VIDE acknowledges the audit findings regarding Child Nutrition Cluster payroll and is committed to strengthening internal controls for federal compliance. VIDE will enhance timesheet management by developing clear policies for completion, submission, approval, and secure retention, ensuring accurate effort documentation. Federal Grants and Payroll staff will collaboratively verify employee authorization, accurate project coding, and consistent pay rates (NOPA vs. payroll register); this reconciliation will occur periodically and before key reporting deadlines. We will also improve payroll register completeness by adjusting reporting configurations to consistently include all mandatory employer-paid benefits (e.g., retirement, health insurance) and resolve individual instances where hours worked were inaccurate. Finally, mandatory training will be conducted for relevant staff and supervisors on new timesheet procedures, federal time and effort requirements, NOPA reconciliation, and accurate payroll documentation. This comprehensive approach, supported by ongoing monitoring from the Office of Fiscal and Administrative Services, will ensure sustained compliance and robust financial management for the Child Nutrition Cluster.

2022‐007 Payroll (Material Weakness) Recommendation: Procedures should be implemented to require appropriate contemporaneous documentation to support time and effort reporting under 2 CFR Part 200. In addition, procedures should also be implemented to require the review and approval of payroll. Action Taken (Unaudited): Management has updated its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. Dan Watkins is responsible for this corrective action. The Organization hired a Human Resource Manager June of 2024, moved to ADP for payroll in January 2025 and updated policies and process for review in May 2025. Procedures are in place for review and approval of each payroll.

Since the hiring of the Executive Director in March of 2022, we have implemented the following: Created A Human Resources Department, which did not exist at CRA before 2022. Hired a Human Resources Director to oversee department. Initiated a comprehensive HR information system where staff can review their pay, track their time, and review benefits. Initiated the process of uploading personnel information to our new system, while keeping backups secured in our Google workspace. This includes hiring documentation and change of status forms for employees.

View of Responsible Officials and Corrective Action Plan We acknowledge that the purchase of gift cards was not an allowable expense under federal grant guidelines. During the COVID-19 pandemic, our staff were tasked with responding to urgent and overwhelming public health demands, particularly as the New Mexico Department of Health became overextended. To recognize staff who went above and beyond to ensure timely case reporting and investigations for tribal communities, gift cards were used as a form of appreciation. Corrective Action Plan Timeline Moving forward, we will ensure full compliance with federal grant requirements. Specifically: 1. We will adhere strictly to the cost principles and allowability guidance outlined in federal regulations and the terms of each Notice of Award. 2. In instances where the allowability of an expense is unclear, we will proactively seek guidance and written approval from our Federal Grant Management Officer before incurring the cost. 3. We will provide refresher training to program and fiscal staff on allowable costs under federal awards to prevent recurrence of similar findings. These corrective actions will ensure future expenditures are fully compliant with federal guidelines and that staff recognition practices remain appropriate, allowable, and consistent with award terms. Corrective Action Plan Timeline • Immediate (Already in Effect): Ceased use of gift cards and other unallowable incentives. • Within 30 Days: Finance and program leadership will review current grant guidance and distribute a written summary of allowable/unallowable costs to all program managers. • Within 60 Days: Refresher training on federal cost principles (2 CFR 200) and Notice of Award guidance will be provided to all program and fiscal staff. • Ongoing: When ambiguity exists regarding allowable costs, staff will consult with the Federal Grant Management Officer prior to obligating or expending funds. Designation of Employee Position Responsible for Meeting Deadline Program Managers/Directors, Finance Officer, and Accounting Manager.

The HS program has established an internal process of requester/approver in place to review the transaction requested. Documents then get reviewed again by HR or Finance staff based on the transaction type before getting processed. Responsible party: Bonnie Foroudi, Finance Director Estimated completion date: December 31, 2025

Audit Finding Description: Documentation for exempt employees' hours was unavailable or incomplete. Corrective Action Plan: 1. Problem Statement: • During testing over payroll, the auditors noted exempt employee salary expense that was not supported with accurate time records. • Root cause: Management lacks policy over tracking time on the timesheet for the exempt employees. Since exempt employees are compensated monthly, it is not required for the exempt employees to record time in their timesheet. 2. Corrective Actions: • Review and Assessment: We have conducted a thorough review of the finding to understand its root cause and identify areas for improvement. • Policy and Procedure Enhancements: We will update relevant policies or procedures to strengthen systems and prevent recurrence. • Training and Education: Employees involved in the process will undergo additional training to ensure they fully understand compliance requirements and best practices. • Monitoring and Oversight: Management will implement regular monitoring and periodic internal audits to ensure continued compliance and effectiveness of the corrective actions. Name of responsible person: Andrea L. Jones, Chief Financial Officer Anticipated completion date: June 30, 2026

Audit Finding Description: Documentation for exempt employees' hours was unavailable or incomplete. Corrective Action Plan: 1. Problem Statement: • During testing over payroll, the auditors noted exempt employee salary expense that was not supported with accurate time records. • Root cause: Management lacks policy over tracking time on the timesheet for the exempt employees. Since exempt employees are compensated monthly, it is not required for the exempt employees to record time in their timesheet. 2. Corrective Actions: • Review and Assessment: We have conducted a thorough review of the finding to understand its root cause and identify areas for improvement. • Policy and Procedure Enhancements: We will update relevant policies or procedures to strengthen systems and prevent recurrence. • Training and Education: Employees involved in the process will undergo additional training to ensure they fully understand compliance requirements and best practices. • Monitoring and Oversight: Management will implement regular monitoring and periodic internal audits to ensure continued compliance and effectiveness of the corrective actions. Name of responsible person: Andrea L. Jones, Chief Financial Officer Anticipated completion date: June 30, 2026

Since the hiring of the Executive Director in March of 2022, we have implemented the following: Created A Human Resources Department, which did not exist at CRA before 2022. Hired a Human Resources Director to oversee department. Initiated a comprehensive HR information system where staff can review their pay, track their time, and review benefits. Initiated the process of uploading personnel information to our new system, while keeping backups secured in our Google workspace. This includes hiring documentation and change of status forms for employees.

Finding 2022-004 – Allocation of Program Effort by Employees In response to the finding, GEM will institute controls and processes to document and allocate personnel time and effort to NSF program GEM will allocate time and effort via approved time and expense personnel reports and reconcile these the accounting records and NSF program charges. Anticipated date of completion: Process was implemented on December 31, 2022. Responsible party: Jamie Hicks, Senior Accounting Manager

Finding 2022-001 Name of Responsible Individual: Carolina Liriano, Grant Manager; Holly Forester, Controller; Sheri Brady, VP and Chief Program Officer Corrective Action: CDF hired an Outsourced Grant Manager starting January 2025 to oversee compliance and internal control processes for federal awards, ensuring adherence to 2 CFR Part 200. The Outsourced Grant Manager will implement systems to accurately allocate salaries, wages, and other expenditures. Key actions include:  Payroll Expenditures: Establish procedures to approve payroll allocations based on actual time and effort reporting, requiring supervisor approval and periodic reviews for compliance.  Non-Payroll Expenditures: Develop approval processes for non-payroll expenses, ensuring detailed documentation and implementing checks to verify overhead allocations.  Documentation and Review: Implement a comprehensive filing system for approvals and supporting documents, with regular training for staff.  Ongoing Compliance Monitoring: Conduct periodic internal audits to ensure adherence to internal controls and federal regulations, addressing issues promptly. These measures will strengthen CDF’s internal controls, ensure compliance, and maintain the integrity of federal award management. Anticipated Completion Date: December 31, 2025.

FA 2022-002 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund, COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D210012 (Year: 2021) S425W210011 (Year: 2021) Questioned Costs: $58,415 Description: A review of expenditures charged to the Elementary and Secondary Emergency Relief Fund program revealed that the School District's internal control procedures were not operating to ensure that expenditures were appropriately documented to support allowability. Corrective Action Plans: District office will review payroll process and develop a procedure to ensure proper documentation is kept in an orderly manner. Estimated Completion Date: December 31, 2024 Contact Person: Terrance H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: SO10A200010 (Year: 2021) SO10A210010-21A (Year: 2022) Questioned Costs: $23,398 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Title I Grants to Local Educational Agencies program. Corrective Action Plans: District office has put procedures in action to make sure that all drawbacks are in line with expenditures. All draw down packets will be viewed and signed off by federal program director. This packet will included detail expenditure sheet for the month, year to date expenditure report and a cover sheet. Estimated Completion Date: December 31, 2024 Contact Person: Terrance H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

Finding 2022-004 – Allocation of Program Effort by Employees In response to the finding, GEM will institute controls and processes to document and allocate personnel time and effort to NSF program GEM will allocate time and effort via approved time and expense personnel reports and reconcile these the accounting records and NSF program charges. Anticipated date of completion: Process was implemented on December 31, 2022. Responsible party: Jamie Hicks, Senior Accounting Manager

Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation. Corrective Action Plan: The HR and payroll policies will be updated to incorporate the above recommendations. Planned Implementation Date: March 2025 Responsible Person(s): City Manager

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. This cost transfer process was implemented on April 1, 2023. A further enhancement of automating a portion of the related journal entry posting upon final approval by the Research Accountant or Associate Controller was implemented in June 2023. In light of the repeat finding, the University engaged an outside firm, Bowers and Company CPAs PLLC in May 2023, to conduct an internal review evaluation of the Payroll Department with a focus on reviewing assessing current internal controls and processes from employees set up through issuance of compensation and filing of state and federal forms relating to payroll procedures and transactions. The outcome of this review was to identify areas of potential weakness, process improvement, and current utilization of existing financial systems and tools. The results of this review evaluation were received in August 2023. In the limited scope review they identified no reportable findings and provided several recommendations to improve University-wide payroll processes. The implementation of these recommendations improved University-wide payroll processes. Additionally, we carried out an internal audit encompassing all federally funded research payroll transactions involving students, staff, and research faculty for the fiscal year 2022. We compared payroll authorizations against the actual payroll amounts for a total of 231 faculty, staff and students. We identified 6 findings, in addition to the findings from KPMG during the initial audit, between payroll authorizations or graduate appointments and the actual amounts charged to federal accounts, which is an overall error rate of 5.6%. Clarkson’s Payroll Department is conducting monthly review of allocations in payroll to proactively identify errors, aiming to facilitate prompt corrections. In addition to the monthly review, Sponsored Research Services will continue in processing cost transfers whenever errors are identified, necessitating adjustments to the allocation of payroll to federal awards.

Recommendation: The Association follow its own documented controls to ensure it prepares adequate time-and-effort documentation to support payroll costs charged to the federal grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Containment Supervisors have had long-time systems in place to review activity logs and their alignment with electronic time sheets. OCCDA policy changes in 2020 are documented in the staff handbook, which states that timesheets are submitted and approved electronically in EWS. In October 2023, a statement was added to the timekeeping system that states, “Submission of this electronic form constitutes your signature on the form. By electronically signing this form you are attesting to the accuracy of the information contained therein and the submission is authorized by you.” Root Cause Due to a lack of knowledge of the new system, fiscal staff could not pull reports out of the timekeeping system. Action Taken Upon implementation of the new timekeeping system in previous years, the staff handbook was updated to reflect the procedure of electronic submission of timesheets, but the fiscal policy will be updated to accurately reflect procedures by February 2024. Beginning in 2023, the staff allocations have been uploaded on a shared document where the Fiscal Manager and payroll both have access. Allocations are reviewed whenever there are any changes in duties or funding and at a minimum of quarterly. When there are changes, a formal status change is completed by HR and sent to payroll for processing and updates in the spreadsheet and the software. Beginning in January 2024 timesheets will be entered into the timekeeping system by staff indicating the number of hours spent in each funding program allowing for real time, accurate allocation of time. Time entry will continue to be reviewed by supervisors or the next in the chain of command when the supervisor is unavailable and paid based on the entered time. Quarterly allocations will be reviewed in the payroll system to ensure that we are staying within the budget. Electronic submission of timesheets was implemented in 2024. The staff allocations have been uploaded on a shared document where the Fiscal Manager and payroll both have access. Allocations are reviewed whenever there are any changes in duties or funding and at a minimum quarterly. When there are changes, a formal status change is completed by HR and sent to payroll for processing and updates in the spreadsheet and the software. Beginning in January 2024 timesheets have been entered into the timekeeping system by staff indicating the number of hours spent in each funding program allowing for real time, accurate allocation of time. Time entry will continue to be reviewed by supervisors or the next in the chain of command when the supervisor is unavailable and paid based on the entered time. Name(s) of contact person(s) responsible for corrective action: Fiscal Manager Planned completion date for corrective action plan: March 2024 (Q1)

2022-019 U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2201KSOAHD Management’s Response: Management will work with Aging to make sure they are tracking and reporting time correctly in accordance with the award parameters. Views of Responsible Officials and Corrective Action: Department personnel will need training on how to report time correctly in the payroll system to adhere to award parameters. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

Views of Responsible Officials The Organization agrees with this finding. Corrective Action Plan The Organization has strengthened its internal controls over payroll transactions in order to comply with laws, regulations, and grant agreements. Additionally, the pass-through entity has increased its documentation requirements which helps the Organization ensure that it possesses compliant payroll documentation. Further, the Organization plans to review its personnel files to ensure that adequate documentation exists to support approved rates of pay. Name(s) of Responsible Individuals Lacy Kimes, Board President Anticipated Completion Date Partially implemented. Personnel file review anticipated completion December 31, 2024.