Corrective Action Plans

The Office of Vice President of Research and the Controller?s Office will collaborate to ensure effort verification reports are returned no later than 30 calendar days after they have been distributed, including escalating noncompliance to appropriate University leadership. These improvements are expected to be completed by December 2023. The Controller?s Office will review its indirect costs configurations within the grants module of Workday to ensure the automated calculation of indirect costs is correct. In addition, the Sponsored Programs Accounting team will manually reconcile indirect costs periodically at the grant level. These improvements are expected to be completed by December 2023. The University continues to have cost transfers in fiscal year 2023 as it reconciles its grants. However, to limit cost transfers in the future, the Office of Vice President of Research and the Controller?s Office worked with the University?s Workday Finance team to configure its accounting system with an automated control that prevents general (non-payroll) expenditures from being charged to the grant after the period of performance end date, one root cause of cost transfers. In addition, for payroll expenditures, the above teams updated grant labor costing allocations in its accounting system to contain an end date that coincides with the period of performance end date which restricts labor costs from being charged after the period of performance. The post award specialists will begin reviewing the labor costing allocations on a periodic basis. Also implemented in fiscal year 2023, before each payroll is processed by the Director of Payroll within the accounting system, grants that have ended are identified by the Assistant Controller and Director of Sponsored Program Accounting and the payroll expenditures are removed from the feed and not charged to the grant. The University has also hired individuals whose sole responsibility is to review general (non-payroll) expenditures charged to grants. Further, the University?s post award specialists are continually trained on the importance of allowed and unallowed expenditures and are now reviewing grant level budget versus actual reporting on a periodic basis to identify noncompliance. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.

2022-017 Finding: - ALN 93.914 ? HIV Emergency Relief Project Grants (Non-Major) / Department of Health and Human Services / Award Number: H89HA00027-28-00, H89HA00027-28-01/ Award Year: 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding. The review of personnel costs that are not 100% allocated to the grant will be reviewed annually as a part of the annual budget planning process. Allocation decisions will be documented and attached to budget planning documents. Person(s) Responsible for Implementing: DDPHE ?Tristan Sanders, Robert George Implementation Date: October 2023

SIGNIFICANT DEFICIENCY 2022-010 Education Stabilization Fund ? Higher Education Emergency Relief Fund ? 84.425 ? Allowable Costs or Cost Principles Condition Admin expenses reported under the program did not have proper supporting documentation to reflect the salary or wages associated with the specific grant activities. Recommendation We recommend that the College review its controls and ensure that controls are implemented that meet Federal requirements related to payroll documentation. Actions Taken As of March 23, 2023, all personnel working on federal grants whose salary or wage expenses will be paid wholly or in part by the federal funding will be required to prepare a Personnel Activity Report to track time spent on grant vs non-grant activities.

2022-001 MATERIAL WEAKNESS Condition: The District's internal control system did not prevent or detect material errors in the financial accounting records, which are utilized to prepare the District's financial statements. The District failed to transfer dedicated maintenance and operation millage revenues of $725,843 from the general fund to the capital projects fund which is included in the other aggregate funds. The financial statements were subsequently corrected by adjusting entries during audit fieldwork. District Response: The District concurs with this finding. The District has debriefed internally and established a plan complete with appropriate action steps and safeguards to ensure that the dedicated maintenance and operation millage revenues are transferred from the general fund to the capital project fund in a timely manner. The District will ensure due care is exercised to ensure accurate and reliable financial reporting. The point of contact for this would be Kelvin Gragg, Rose Smith, and Ashley Granberry. This Correction should be corrected on or before June 30, 2022. 2022-002 PAYROLL EXPENDITURES Condition: In our sample of payroll expenditures, we identified undocumented compensation of $7,685 and improperly awarded incentive pay of $4,700 paid from Federal funds without proper documentation or requirements. District Response: The District acknowledges the finding and would take this opportunity to explain the circumstances surrounding this material weakness. While not an excuse, it in part explains the conditions under which these instances of undocumented compensation occurred. The District has been impacted by multiple staff changes in the Business Office. The District has employed and/or contracted for payroll services with four (4) persons and for the role of Business Manager with three (3) persons just during this calendar year alone. The District has taken steps to stabilize the workforce in the Business Office. In addition to addressing the human capital issues, the District will provide additional monitoring support to ensure the implementation of the existing internal controls over program expenditures. The district has already taken steps to recoup compensation that was improperly awarded and paid. As recommended, the district will contact the Arkansas Division of Elementary and Secondary (DESE) for guidance regarding this matter. The district began addressing these is July 2022 and have since made the necessary changes as of September 2022. The point of contact for this would be Rose Smith, Ashley Granberry, Lucretia James and Kelvin Gragg.

Restore noted that 3 out of the 19 timesheets that were dated after Restore implemented its new process (i.e., after May of 2022) were missing documented supervisory reviews. This oversight was due to role changes and administrative transitions. To further strengthen the internal controls supporting time tracking, in addition to executing against the corrective action plan note in the prior year findings, in FY23 Restore also created a checklist to track all grant funded timesheets to ensure documented approvals and accurate time tracking.

Individuals Responsible for Corrective Action Plan: Jason Penegar, Vice President - Controller Nisha Eberhart, Accounting Manager Blanca Ramos, Sr. Manager, Compensation and Benefits Accounting Corrective Action Plan: Management will implement a new quality review process to ensure that correct default fund codes are assigned to staff for the DOL WPY grant. In addition, Management will implement a complete oversight review of all grant time charges in advance of the execution of a drawdown of DOL funds. Anticipated Completion Date: June 30, 2023

Corrective Action Plan Fiscal Year Ended December 31, 2022 Finding: 2022-1 Contact: Duane Landon, CFO duane@byrdbarr.place 206.812.4947 Finding: Timesheets did not support payroll allocations for ERAP versus LIHEAP. Corrective Action: Time will be allocated based on the number of files processed per program and timesheets will be completed to reflect this allocation. Proposed Completion Date: This has already been implemented for 2023.

Corrective Action: Management, in the immediate term, will review its oversight and controls on the manual process Grants Accounting implemented for obtaining Time & Allocation Excel Sheet and calculating payroll and benefits costs accurately onto the Request for Reimbursement (RFR). Furthermore, management plans to collaborate with its Payroll Service Provider to capitalize on software upgrades, aiming to enhance the accuracy of Time & Allocation to grants and reduce errors by designing straight-through-process improvements. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: April 2024

Corrective Action: Management, in the immediate term, will review its oversight and controls on the manual process Grants Accounting implemented for obtaining Time & Allocation Excel Sheet and calculating payroll and benefits costs accurately onto the Request for Reimbursement (RFR). Furthermore, management plans to collaborate with its Payroll Service Provider to capitalize on software upgrades, aiming to enhance the accuracy of Time & Allocation to grants and reduce errors by designing straight-through-process improvements. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: April 2024

Corrective Action: Management, in the immediate term, will review its oversight and controls on the manual process Grants Accounting implemented for obtaining Time & Allocation Excel Sheet and calculating payroll and benefits costs accurately onto the Request for Reimbursement (RFR). Furthermore, management plans to collaborate with its Payroll Service Provider to capitalize on software upgrades, aiming to enhance the accuracy of Time & Allocation to grants and reduce errors by designing straight-through-process improvements. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: April 2024

Corrective Action: Management is in the process of updating its written procedures to ensure that allowable costs and cost principles comply with 2 CFR 200.403. This includes Grants Accounting implementing a manual process that empowers program employees to submit and approve Time & Allocation Excel Sheets. These sheets include attestations certifying actual labor costs on a monthly basis. This information is then taken to inputted by the grants accounting team into the Request for Reimbursement (RFR). This measure ensures that labor costs are accurately reflected and compliant with regulatory requirements. In addition, Management will implement policies and procedures regarding regular review of allocations for workers compensation and other similar expenses to ensure accuracy. Finally, Management is committed to optimizing the efficiency and accuracy of its Time & Allocation to Grants by leveraging its Payroll Software Technology to strengthening its accounting process and internal controls. Name of Responsible Individual(s): Jason Brenier, CFO Anticipated Completion Date: April 2024.

Action Taken/to be Taken: Accounting staff is implementing a new process for payroll to record employee payroll expense based on the department that the employee works in. The last payroll in 2023 reflects a change in the time reporting process, and accounting staff will continue to ensure compliance with Uniform Administrative Requirements.

Views of Responsible Officials: We agree with the auditor's findings. We have corrected our methodology for deriving allocated dollars based on hours worked such that they agree.

2022-003 – Payroll Time Approval – Significant Deficiency in Internal Controls over Compliance Recommendation: The Auditor recommends LIFE implement controls for documenting and retaining information to indicate the Entity follows the requirements over 2 CFR section 200.430(i), and that all time charged to the grant are reviewed for approval. Action Taken: LIFE Management will: • Review, update and adhere to established policies/procedures that align with the compliance of 2 CFR, 200.430(i). • Implement LIFE’s newly customized timekeeping system that enables accurate recording of time spent on grant-related activities and that ensures capabilities for supervisory review and approval. • Conduct training sessions for all staff to educate them about any updated policies regarding timekeeping procedures, the new online timekeeping portal and adherence to federal regulations. • Schedule internal audits and reviews, at minimum, once a fiscal quarter to ensure that the new timekeeping system is being used correctly and that all time charged to grants is appropriate and compliant with LIFE’s policies/procedures and federal regulations. Due Date of Completion: January 31, 2023 Responsible Official: Executive Director

Finding Reference # 2022-002, Material Weakness in internal control over compliance and instance of immaterial noncompliance. Compliance Requirement: Allowable Costs Auditor’s Recommendation: We recommend management return to the previous process for recording payroll costs to grants and programs by which individual employee salaries and wages are allocated based on actual time spent on various activities and are directly charged to the respective activity cost centers benefited. Corrective Action: In 2022, we began outsourcing our payroll processing to Paychex, Inc. During that transition, we changed our process for entering payroll into our accounting software and began using aggregation of total employee hours. Management will return to the practice of allocating payroll per employee instead of using aggregate totals, effective immediately. Management will also contact grantors to resolve any errors in cost reimbursements resulting from 2022 payroll allocation corrections.

A policy will be developed and submitted for board approval outlinging the payroll internal control processes as it relates to timesheets, payroll service reports, and approval process. Newly adopted written procedures will be developed to align with the newly adopted board policy. The following district office staff members will participate in training provided by a private consultant ont he newly adopted policy and procedures along with the required process for documenting all personnel services charged by Title I Grants: CSFO, Federal Programs Bookkeeper, Federal Programs Secretary, Centralized LSA Bookkeeper, State Funds Bookkeeper 2, Accounts Payable Clerk, and Payroll Clerk. The CSFO will develop a turn-around training and trail all school level staff to include bookkeepers and principals on the following topics: Completing and documenting time and effort sheets, properly documenting and affirming salaries of Title I employees, checks and balances for payroll and timesheets, adhering to board approved policies and procedures for completing timesheets, signing timesheets, and balancing timesheets against payroll service reports. An internal audit team will be developed to periodically check compliance to newly adopted policies and procedures. All time and effort sheets will be submitted at the onset of employment for review and compliance with a follow up mid-year certification of time and effort on the federal programs.

A policy will be developed and submitted for board approval outlinging the payroll internal control processes as it relates to timesheets, payroll service reports, and approval process. Newly adopted written procedures will be developed to align with the newly adopted board policy. The following district office staff members will participate in training provided by a private consultant ont he newly adopted policy and procedures along with the required process for documenting all personnel services charged by Education Stabilization Fund: CSFO, Federal Programs Bookkeeper, Federal Programs Secretary, Centralized LSA Bookkeeper, State Funds Bookkeeper 2, Accounts Payable Clerk, and Payroll Clerk. The CSFO will develop a turn-around training and trail all school level staff to include bookkeepers and principals on the following topics: Completing and documenting time and effort sheets, properly documenting and affirming salaries of Education Stabilization Fund employees, checks and balances for payroll and timesheets, adhering to board approved policies and procedures for completing timesheets, signing timesheets, and balancing timesheets against payroll service reports. An internal audit team will be developed to periodically check compliance to newly adopted policies and procedures. All time and effort sheets will be submitted at the onset of employment for review and compliance with a follow up mid-year certification of time and effort on the federal programs.

Personnel Responsible for Corrective Action: This initiative was a collaboration between the Finance Grants Team, Brandie Hall and Bobby Morris-Culp, and the COO, Jennifer Johnson, representing the programs side of the contract. Anticipated Completion Date: A proper Time Activity Report was implemented October 1, 2022. Corrective Action Plan: Although Foster Adopt Connect did not receive the results from the 2021 Independent Audit conducted by other auditors until November of 2022, due to the close time proximity, was able to design a compliant Time Activity Report and have staff utilize said reports to track time beginning October 1, 2022, which was the beginning of the FFY/Contract funding period. This would indicate that this is not in fact, a repeat finding.

Finding 2022-004 - Strengthen controls surrounding program-related record keeping including increasing the frequency of reconciliation's and program wage allocation procedures to match the payroll cycle. Program Affected Under the U.S. Department of Health and Human Services - Award Year October 1, 2021 - September 30, 2022: Assistance Listing 93.262 Occupational Safety and Health Program Corrective Action The Organization agrees with the finding. The Organization has implemented both time and effort reporting by pay period and wage reconciliations as part of a monthly close process. Responsible individual - JJ Bartlett Completion 9/30/2023

Finding: The Organization allowed payroll related costs to be submitted for reimbursement under the grant for time that did not match approved timesheets. This is not in compliance with program allowable cost requirements. The amount of payroll and related costs discovered to be incorrect was a net amount of $25, which when projected onto the remaining payroll and related costs that were not tested, amounted to $1,038. Corrective Action Taken or Planned: The Organization will review audit findings and ensure accurate future reimbursements, develop a comprehensive process for verifying time sheets against service delivery, and implement a paper timesheet system in which supervisors must enter time based on timesheets, ensuring 1:1 reimbursement. Name of Contact Person: Jacob Ducey, Grants Manager Phone Number of Contact Person: (540) 907-4555 Projected Completion Date: October 31, 2023

Item: 2022-003 Assistance Listing Number: 84.425U Programs: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Federal Agency: U.S. Department of Education Pass-Through Agencies: Arizona Department of Education Pass-Through Grantor Identifying Number: Unknown Award Year: April 19, 2022 to September 30, 2024 Criteria: In accordance with 2 CFR § 200.430 – Compensation – the entity’s system of internal controls should include a process to review after-the-fact interim charges made to federal awards based upon budget or allocation estimates. Condition: The entity’s system of internal controls did not include a process to review after-thefact interim payroll charges made to federal awards based upon budget or allocation estimates. Name of Contact Person: Doug Taylor, CFO Phone Number: (602) 230-1116 Anticipated Completion Date: December 31, 2023 Views of Responsible Officials and Corrective Actions: Special Olympics Arizona, Inc. will revise its policies and procedures to require that actual time be recorded on timesheets for the actual efforts spent on Federal awards. Management will utilize actual time and effort when charging expenditures to Federal awards going forward.

Item: 2022-002 Assistance Listing Number: 21.027 Programs: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agencies: Arizona State Office of the Governor; Maricopa County Pass-Through Grantor Identifying Number: Unknown Award Year: January 1, 2022 to December 31, 2024; January 28, 2022 to June 30, 2023 Criteria: In accordance with 2 CFR § 200.430 – Compensation – the entity’s system of internal controls should include a process to review after-the-fact interim charges made to federal awards based upon budget or allocation estimates. Condition: The entity’s system of internal controls did not include a process to review after-thefact interim payroll charges made to federal awards based upon budget or allocation estimates. Name of Contact Person: Doug Taylor, CFO Phone Number: (602) 230-1116 Anticipated Completion Date: December 31, 2023 Views of Responsible Officials and Corrective Actions: Special Olympics Arizona, Inc. will revise its policies and procedures to require that actual time be recorded on timesheets for the actual efforts spent on Federal awards. Management will utilize actual time and effort when charging expenditures to Federal awards going forward.

Assistance listing number and program name: 12.401 National Guard Military Operations and Maintenance (O&M) Projects Agency: Department of Emergency and Military Affairs (DEMA) Name of contact person and title: Jensen Forde, CFO Anticipated completion date: April 30, 2024 Agency’s Response: Concur DEMA HR anticipates having this completed by April 2024 at the latest. All employee records will be audited, corrected and maintained per the finding. HR staff has received a copy of the Department’s Record Retention Schedule and effective immediately will adhere to the policy.

Response. Agreed. Where feasible, the Housing Trust will aim to improve management of all federal grants. A process of documentation verification prior to any requests made for financial draws will include employee, supervisor, business operations manager, and executive director level approvals to ensure compliance and availability of funds. A monthly federal request for reimbursements with all grantee information will be used and reconciled monthly with QuickBooks. This report will mirror the SEFA form so auditors will receive the information in a timely manner. For any quarterly reports, the three months of reporting will again be reconciled prior to submission. All new processes and compliance will be updated in the policies and procedure manual. As the Executive Director prepares the 2024 budget, a reorganization of the business operations department will be sought. A new position to prepare and work on all federal grant tasks will be hired and report to the Business Operations Manager. In the meantime, the Business Operations Manager has started to develop checks and balances. Corrective Action Plan Timeline: Immediately Designation Of Employee Position Responsible For Meeting Deadline: Business Operations Manager

Views of Responsible Officials: When SAMU commenced operations at the end of June 2022, the Welcome Respite Project (funded by FEMA) was SAMU's only active project. The HR platform/timekeeping software, Gusto, was implemented prior to the project start date (i.e. employees offer letters and onboarding materials were sent via the platform). Incoming staff were provided with an overview of how to use Gusto during onboarding, one-on-one meetings with supervisors, and staff meetings. Employee time was remunerated according to the rates authorized. During 2022, staff entered their hours in Gusto and were not engaged in outside, non-project-related activities. In 2022 we had only one project and therefore, some salaried staff were instructed that the completion of a timecard was not needed. However, that changed in 2023 as the new Managing Director requested that all staff, including salaried staff, complete timecards appropriately. Additional project codes were implemented in January 2023 and October 2023. SAMU provided updated guidance on timekeeping and use of project codes during the course of several staff meetings and one-on-one meetings. In 2023, SAMU developed a Gusto training and continues to reinforce timekeeping policies and expectations during meetings. Rate and position changes were and continue to be communicated to staff via official HR letters and stored in program files.