Corrective Action Plans

Corrective Action Plan: SOR II grant leadership evaluated its process for preparing and reviewing time tracking for this award and has implemented procedures to ensure appropriate documentation of personnel costs are complete and accurate. Coordination with Payroll staff begin and was validated with current pay period ending 9/23/23. Hourly staff are clocking into appropriate cost center and salaried staff are submitting hours to payroll to ensure appropriate time tracking Contact Person(s): Heather Hintz/Kathy Dams Anticipated Completion: 12/31/2023

FINDING NUMBER: 2022-002 Condition: The Organization is either lacking or has non-conforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial Management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 5. Competition ? 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Planned Corrective Action: Management agrees with the finding and plans to review Uniform Guidance, modify and create policies and procedures where necessary to meet administrative Uniform Guidance requirements. The adopted policies and procedures will be reviewed and approved by the School Board of Directors at the organization?s next scheduled Board meeting. School Representative Responsible for Corrective Action: Carlos Perez, Executive Director Anticipated Completion Date: June 14, 2023

Identifying Number: 2022-002 Finding: The following discrepancies and inconsistencies were identified: administrative procedures and requirements of the grantor were not followed; there were no proper review or approval of required reporting prior to submission. Contact person responsible for corrective action: Kevyn Harmon, Senior Director of Finance & Administration Corrective Action: All personnel involved with the Title programs undergo training on the all the processes and requirements to administer the programs, and management will perform proper review of all claims for reimbursement. In additional, an annual update on the procedures and the requirements to ensure propriety and accuracy. Proposed Completion Date: EPIC Academy will complete implementation of the above procedures by November 30, 2022.

Finding: 2022-004 Corrective Action Plan: The District?s payroll process is significantly lacking proper control procedures. With the hiring of a new financial manager, policies, procedures and controls will be implemented immediately, including the proper tracking of time and effort for employees charged to federal grants as required. Anticipated Completion Date: September 1, 2023 Contact Person: Amanda Raymond, Director of Finance

Finding Number 2022-005 Education Stabilization Fund: Elementary and Secondary School Emergency Relief (ESSER) Assistance Listing Number 84.425D Allowable Costs/Cost Principles ? Documentation of Employee Time and Effort Immaterial Noncompliance Criteria: Per Federal regulations 2 CFR section 200.430(i)(1)(vii), the School District must maintain time and effort distribution records for an employee who works in part on the consolidated administrative cost objective and in part on a federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources. Condition: The School District did not maintain time and effort distribution records for employees who were partially funded with ESSER Federal funds. Cause: Oversight. Effect: Time and effort reports were not completed. Questioned Costs: None. Recommendation: Time and effort reports should be completed throughout the year listing the employees name, position or job title, and percentage of time spent on each Federal award and signed by the employee?s supervisor. Management's Response and Corrective Actions: The Director of Finance and Superintendent completed time and effort reports for the ESSER funds expended for fiscal year ending June 30, 2022 and will continue to complete time and effort reports going forward. Person Responsible for Corrective Action: Justin Weston, Director of Finance, and Amiee Erfourth, Superintendent Completion Date: November 21, 2022.

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with some Public Assistance Cost Allocation Plan requirements. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 93.659 93.659 COVID-19 Status: Corrective action complete Corrective Action: The Random Moment Time Study (RMTS) is a federally approved cost allocation methodology to claim allowable federal funds. The Department?s use of the RMTS is included in its Public Assistance Cost Allocation Plan (PACAP) with the federal grantor. The Department maintains that the sampling universe is accurate and complete and complies with federal requirements. There is no known deficiency with the integrity of the RMTS, nor are unallowable costs allocated to federal programs. Effective October 2022, the Department contracted with the University of Massachusetts (UMass) for the design and implementation of the RMTS mechanism. UMass has updated the RMTS instructions for the new quarterly process, which remains in compliance with federal law while alleviating the department-imposed restrictions. It also addresses the auditor?s concerns regarding the internal controls applicable to the RMTS worker types included in the sampling universe. The Department has also taken additional actions to address system limitations caused by high staff turnover rates within the cost pools. These include: ? The Headquarters (HQ) RMTS Coordinator pulls an InfoFamLink worker list report that shows all workers with access to the FamLink system. The list is then reviewed by job class to verify the accuracy of RMTS group assignment and to identify the workers that are eligible to be included in the sample. ? The Cost Allocation and Grants Management Unit pulls a job classification report from the Human Resource Management System (HRMS) at the end of every pay cycle. The HQ RMTS Coordinator compares the HRMS report to the InfoFamLink worker list report to verify if they are eligible to be sampled and properly allocated in HRMS. The HRMS has additional information related to job class to assist in sample eligibility determination and strengthen the internal controls around RMTS samples pulled. ? The HQ RMTS Coordinator pulls a workload report from InfoFamLink to view worker caseloads and primary assignments. This is an additional tool to determine if a worker is eligible and assigned to the correct RMTS sample pool. The Department will continue to maintain internal controls over the monthly update process to ensure the RMTS sampling populations are complete. The Department will also work with the federal partners to ensure continued compliance with the PACAP. The conditions noted in this finding were previously reported in finding 2021-042, 2020-044 and 2019-044. Completion Date: October 2022 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

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. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.

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.