Findings Citing § 200.430

2024-001 Twenty-First Century Community Learning Centers – Assistance Listing No. 84.287 Material Weakness in Internal Control Over Compliance and Noncompliance – Inadequate Payroll Documentation B. Allowable Costs/Cost Principles Criteria: Per 2 CFR § 200.430(g), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and are supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. As part of the Organization’s internal controls, time and effort documentation—such as timecards—should be reviewed and approved by the employee to confirm accuracy. Condition and Context: We selected 40 individuals paid in randomly selected pay periods for testing. Our sample was not statistically valid. During our testing of payroll expenses charged to the federal program, we noted that 2 out of 40 of the employee timecards selected for review were not signed or electronically certified by the respective employee. Without employee attestation, the accuracy of the reported time cannot be verified in accordance with Uniform Guidance requirements. This resulted in total questioned costs of $763. Based on an error rate of 3.23%, the likely questioned costs for the full payroll population are projected to be $14,578. Additionally, we identified 10 instances where the number of hours reported on employee timecards did not match the hours recorded in the payroll system and charged to the federal award. The total questioned costs for these discrepancies were $569. Based on an error rate of 2.41%, the likely questioned costs for the full payroll population are projected to be $10,878. This is a repeat finding of 2023-003. Cause and Effect: The lack of employee signatures appears to be due to inconsistent enforcement of timecard approval procedures. The discrepancies in the number of hours charged to the federal award appear to be due to a lack of effective reconciliation procedures between timekeeping and payroll records. As a result of these items noted above, the Organization charged unsubstantiated payroll costs to the federal award. Recommendation: We recommend that management ensure all employee timecards are signed or electronically certified by the employee in a timely manner. We also recommend a process is implemented to reconcile time charge to federal award to underlying payroll report. Internal controls should be reinforced to verify that no payroll costs are charged to federal programs without appropriate documentation and approval. Views of Responsible Officials and Planned Corrective Action: We agree with the recommendation and updated our written policy in 2024. The policy was reviewed by the Finance Committee and approved by the full Board of Directors in December 2024.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

2024-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Funding Agency: Department of Agriculture ALNs: 10.565, 10.568 & 10.569 Criteria Internal controls and other compliance knowledge should prevent the incorrect coding of employee hours worked. Per 2 CFR 200.430(g)(1), "charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed" and "be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated." Condition Internal controls and adherence to compliance were not followed with regards to an appropriate level of approval of management that is charged to the Coronavirus State and Local Recovery Funds program and the Food Cluster Program. Questioned costs Total questioned cost of $2,822 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Coronavirus State and Local Recovery Fund grant (ALN 21.027). Total questioned cost of $3,475 based on three payroll transactions tested that were not approved at the appropriate level but were charged to the Food Cluster Program (ALNs 10.565, 10.568, & 10.569). Context During our payroll testing, of the six executive director timesheets tested, none of them indicated a review or approval from the board president. Cause The error was caused by not applying an adequate number of controls necessary for the executive director's timesheet. Effect The Coronavirus State and Local Recovery Funds program and Food Cluster program and other federal programs could be incorrectly charged with unreasonable wages.Repeat Finding No. Auditor's Recommendation We recommend that the board president or other board member designee review the executive director's timesheet prior to submitting the wages for reimbursement from federal grants.

Finding No. 2024-001: Allowable Cost/Activities (Time and effort) Federal Program Title: U.S. Department of Health and Human Services Awards: ALN 93.527 Health Center Program Cluster Criteria: 2 CFR 200.430 established that all salaries and wages charged to Federal awards must be supported by a system of internal controls that provides reasonable assurance that the personnel costs incurred are accurate, allowable, and properly allocated. This includes a system to demonstrate that total compensation paid to individual employees is reasonable according to work performed. Condition: During audit procedures, we tested 40 payroll costs charged to the ALN 93.527 Health Center Program Cluster. Time and effort reporting could not be located for the 7 employees that were charged to Grant H2E for the period September – December 2024 which documented the distribution of the employee’s salary and wages among specific grants by work performed. Cause: The Organization did not follow the policies and procedures in place related to obtaining time and effort certifications from employees. Effect: The federal award may be overcharged or undercharged if actual effort differs from time charged to the award. Questioned Costs: $122,765 Context/Sampling: A sample of 40 payroll transactions were selected for testing. For each transaction, a timecard was obtained for all selected transactions which verified that the employees worked the hours to support the charges to the grant. While all timecards documented total hours worked, none included documentation of the specific time allocated to the federal program. Additionally, time and effort certifications were obtained for 33 of the 40 sampled employees. However, the Organization did not obtain time and effort certifications for the remaining 7 employees whose salaries were charged to the H2E grant. The sample was selected using non-statistical sampling methods and was not intended to be, nor should it be considered, a statistically valid sample. Repeat Finding: No Recommendation: Management should strengthen its internal controls over payroll charges to federal awards by ensuring consistent adherence to its time and effort certification policies as well as conduct periodic reviews of payroll documentation to verify compliance with established policies and federal requirements. Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding.

2024-001 Allowable Compensation Costs Material Weakness in Internal Control Over Compliance 16.575 Crime Victim Assistance Criteria – 2 CFR Section 200.403 states that costs must be necessary and reasonable for the performance of the federal award. Costs must also conform to any limitations or exclusions set forth in the federal award as to types or amount of cost items. In addition, 2 CFR Section 200.430 states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition and Context – Through a financial review by a pass-through entity, compensation costs of $32,302 were identified as unallowed under the terms of the federal award for the budget period July 1, 2023 to June 30, 2024. These costs included $19,259 in calendar year 2023 and $13,043 in calendar year 2024. Cause – CCAHT did not have internal controls in place to ensure that salaries and wages claimed for reimbursement was accurate, allowable, and properly allocated. Effect – CCAHT submitted salaries and wages for reimbursement that were unallowed under the terms of the federal award. Questioned Costs – This resulted in known questioned costs of $32,302. Repeat Finding - No Recommendations – We recommend CCAHT implement internal controls to ensure all costs charged to the program are accurate, allowable, and properly allocated in accordance with the terms of the federal award, and that there is proper review and approval. Management’s Response – Management concurs with the audit recommendations. See Management’s Corrective Action Plan.

2024-001 Allowable Compensation Costs Material Weakness in Internal Control Over Compliance 16.575 Crime Victim Assistance Criteria – 2 CFR Section 200.403 states that costs must be necessary and reasonable for the performance of the federal award. Costs must also conform to any limitations or exclusions set forth in the federal award as to types or amount of cost items. In addition, 2 CFR Section 200.430 states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition and Context – Through a financial review by a pass-through entity, compensation costs of $32,302 were identified as unallowed under the terms of the federal award for the budget period July 1, 2023 to June 30, 2024. These costs included $19,259 in calendar year 2023 and $13,043 in calendar year 2024. Cause – CCAHT did not have internal controls in place to ensure that salaries and wages claimed for reimbursement was accurate, allowable, and properly allocated. Effect – CCAHT submitted salaries and wages for reimbursement that were unallowed under the terms of the federal award. Questioned Costs – This resulted in known questioned costs of $32,302. Repeat Finding - No Recommendations – We recommend CCAHT implement internal controls to ensure all costs charged to the program are accurate, allowable, and properly allocated in accordance with the terms of the federal award, and that there is proper review and approval. Management’s Response – Management concurs with the audit recommendations. See Management’s Corrective Action Plan.

2024-001 Allowable Compensation Costs Material Weakness in Internal Control Over Compliance 16.575 Crime Victim Assistance Criteria – 2 CFR Section 200.403 states that costs must be necessary and reasonable for the performance of the federal award. Costs must also conform to any limitations or exclusions set forth in the federal award as to types or amount of cost items. In addition, 2 CFR Section 200.430 states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition and Context – Through a financial review by a pass-through entity, compensation costs of $32,302 were identified as unallowed under the terms of the federal award for the budget period July 1, 2023 to June 30, 2024. These costs included $19,259 in calendar year 2023 and $13,043 in calendar year 2024. Cause – CCAHT did not have internal controls in place to ensure that salaries and wages claimed for reimbursement was accurate, allowable, and properly allocated. Effect – CCAHT submitted salaries and wages for reimbursement that were unallowed under the terms of the federal award. Questioned Costs – This resulted in known questioned costs of $32,302. Repeat Finding - No Recommendations – We recommend CCAHT implement internal controls to ensure all costs charged to the program are accurate, allowable, and properly allocated in accordance with the terms of the federal award, and that there is proper review and approval. Management’s Response – Management concurs with the audit recommendations. See Management’s Corrective Action Plan.

Finding No. 2024-001: Allowable Cost/Activities (Time and effort) Federal Program Title: U.S. Department of Health and Human Services Awards: ALN 93.527 Health Center Program Cluster Criteria: 2 CFR 200.430 established that all salaries and wages charged to Federal awards must be supported by a system of internal controls that provides reasonable assurance that the personnel costs incurred are accurate, allowable, and properly allocated. This includes a system to demonstrate that total compensation paid to individual employees is reasonable according to work performed. Condition: During audit procedures, we tested 40 payroll costs charged to the ALN 93.527 Health Center Program Cluster. Time and effort reporting could not be located for the 7 employees that were charged to Grant H2E for the period September – December 2024 which documented the distribution of the employee’s salary and wages among specific grants by work performed. Cause: The Organization did not follow the policies and procedures in place related to obtaining time and effort certifications from employees. Effect: The federal award may be overcharged or undercharged if actual effort differs from time charged to the award. Questioned Costs: $122,765 Context/Sampling: A sample of 40 payroll transactions were selected for testing. For each transaction, a timecard was obtained for all selected transactions which verified that the employees worked the hours to support the charges to the grant. While all timecards documented total hours worked, none included documentation of the specific time allocated to the federal program. Additionally, time and effort certifications were obtained for 33 of the 40 sampled employees. However, the Organization did not obtain time and effort certifications for the remaining 7 employees whose salaries were charged to the H2E grant. The sample was selected using non-statistical sampling methods and was not intended to be, nor should it be considered, a statistically valid sample. Repeat Finding: No Recommendation: Management should strengthen its internal controls over payroll charges to federal awards by ensuring consistent adherence to its time and effort certification policies as well as conduct periodic reviews of payroll documentation to verify compliance with established policies and federal requirements. Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding.

Finding 2024-001: Allowable Cost/Cost Principles – Enhanced Documentation of Cost Allocation (Repeat Finding) Criteria or Specific Requirements Per 2 CFR Part 200.430 (g)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition Description A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Of the 50 employee monthly reimbursements (10 for ALN 14.241; 40 for ALN 93.914) selected for allowable costs testwork, we noted 2 employee monthly reimbursements (1 for ALN 14.241; 1 for ALN 93.914) for where the hours reported per the timesheet did not agree with the hours reported in the related request for reimbursement invoices. The hours reported per the reimbursement invoices were greater than the hours reported per the timesheets. The Foundation subsequently provided documentation indicating that such differences had been properly corrected in the following month’s reimbursement invoice through an adjustment to the reported hours per the reimbursement invoice. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to the Grants We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-001. Per the CAP, the Foundation will perform regular reviews of tracked hours and reconciliations at least quarterly. Of the 18 payroll reimbursement months (for ALN 93.914), and 4 payroll reimbursement months (for ALN 93.940) selected for testwork, we noted a total of 2 months (1 for ALN 93.914; 1 for ALN 93.940) whereby the related reviews of tracked hours were performed more than 90 days after the respective reimbursement month. C. Timecard Lacking Employee and Manager Approvals In performing allowable costs testwork over payroll expenditures, we noted the following: Questioned Costs A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges None. The Foundation corrected the discrepancies in subsequent monthly reimbursements. This issue is considered an internal control finding. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to Grants None. This issue is considered an internal control finding. C. Timecards Lacking Employee and Manager Approvals None. This issue is considered an internal control finding. Cause and Effect A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Per the Associate Director of Contract Accounting, this was a one-time error in the month’s request for reimbursement invoice. This error was corrected within the grant period and did not result in overbilling the funder. However, since the correction occurred after the Foundation’s fiscal year-end, it resulted in an overstatement of expenditures reported on the SEFA for the year ended December 31, 2024. B. Improved Documentation of Routinary Reviews of Employees' Hours Charged to Grants. Per the Associate Director of Contract Accounting, the routinary review of employee hours occurred. However, there were still reclassifications that needed to be performed beyond the normal review process. The review process was not properly implemented. C. Timecards Lacking Employee and Manager Approvals The identified condition resulted from failure to follow formal procedures requiring both the employee and manager to sign off on the timesheets.

Finding 2024-001: Allowable Cost/Cost Principles – Enhanced Documentation of Cost Allocation (Repeat Finding) Criteria or Specific Requirements Per 2 CFR Part 200.430 (g)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition Description A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Of the 50 employee monthly reimbursements (10 for ALN 14.241; 40 for ALN 93.914) selected for allowable costs testwork, we noted 2 employee monthly reimbursements (1 for ALN 14.241; 1 for ALN 93.914) for where the hours reported per the timesheet did not agree with the hours reported in the related request for reimbursement invoices. The hours reported per the reimbursement invoices were greater than the hours reported per the timesheets. The Foundation subsequently provided documentation indicating that such differences had been properly corrected in the following month’s reimbursement invoice through an adjustment to the reported hours per the reimbursement invoice. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to the Grants We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-001. Per the CAP, the Foundation will perform regular reviews of tracked hours and reconciliations at least quarterly. Of the 18 payroll reimbursement months (for ALN 93.914), and 4 payroll reimbursement months (for ALN 93.940) selected for testwork, we noted a total of 2 months (1 for ALN 93.914; 1 for ALN 93.940) whereby the related reviews of tracked hours were performed more than 90 days after the respective reimbursement month. C. Timecard Lacking Employee and Manager Approvals In performing allowable costs testwork over payroll expenditures, we noted the following: Questioned Costs A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges None. The Foundation corrected the discrepancies in subsequent monthly reimbursements. This issue is considered an internal control finding. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to Grants None. This issue is considered an internal control finding. C. Timecards Lacking Employee and Manager Approvals None. This issue is considered an internal control finding. Cause and Effect A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Per the Associate Director of Contract Accounting, this was a one-time error in the month’s request for reimbursement invoice. This error was corrected within the grant period and did not result in overbilling the funder. However, since the correction occurred after the Foundation’s fiscal year-end, it resulted in an overstatement of expenditures reported on the SEFA for the year ended December 31, 2024. B. Improved Documentation of Routinary Reviews of Employees' Hours Charged to Grants. Per the Associate Director of Contract Accounting, the routinary review of employee hours occurred. However, there were still reclassifications that needed to be performed beyond the normal review process. The review process was not properly implemented. C. Timecards Lacking Employee and Manager Approvals The identified condition resulted from failure to follow formal procedures requiring both the employee and manager to sign off on the timesheets.

Finding 2024-001: Allowable Cost/Cost Principles – Enhanced Documentation of Cost Allocation (Repeat Finding) Criteria or Specific Requirements Per 2 CFR Part 200.430 (g)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition Description A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Of the 50 employee monthly reimbursements (10 for ALN 14.241; 40 for ALN 93.914) selected for allowable costs testwork, we noted 2 employee monthly reimbursements (1 for ALN 14.241; 1 for ALN 93.914) for where the hours reported per the timesheet did not agree with the hours reported in the related request for reimbursement invoices. The hours reported per the reimbursement invoices were greater than the hours reported per the timesheets. The Foundation subsequently provided documentation indicating that such differences had been properly corrected in the following month’s reimbursement invoice through an adjustment to the reported hours per the reimbursement invoice. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to the Grants We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-001. Per the CAP, the Foundation will perform regular reviews of tracked hours and reconciliations at least quarterly. Of the 18 payroll reimbursement months (for ALN 93.914), and 4 payroll reimbursement months (for ALN 93.940) selected for testwork, we noted a total of 2 months (1 for ALN 93.914; 1 for ALN 93.940) whereby the related reviews of tracked hours were performed more than 90 days after the respective reimbursement month. C. Timecard Lacking Employee and Manager Approvals In performing allowable costs testwork over payroll expenditures, we noted the following: Questioned Costs A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges None. The Foundation corrected the discrepancies in subsequent monthly reimbursements. This issue is considered an internal control finding. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to Grants None. This issue is considered an internal control finding. C. Timecards Lacking Employee and Manager Approvals None. This issue is considered an internal control finding. Cause and Effect A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Per the Associate Director of Contract Accounting, this was a one-time error in the month’s request for reimbursement invoice. This error was corrected within the grant period and did not result in overbilling the funder. However, since the correction occurred after the Foundation’s fiscal year-end, it resulted in an overstatement of expenditures reported on the SEFA for the year ended December 31, 2024. B. Improved Documentation of Routinary Reviews of Employees' Hours Charged to Grants. Per the Associate Director of Contract Accounting, the routinary review of employee hours occurred. However, there were still reclassifications that needed to be performed beyond the normal review process. The review process was not properly implemented. C. Timecards Lacking Employee and Manager Approvals The identified condition resulted from failure to follow formal procedures requiring both the employee and manager to sign off on the timesheets.

Finding 2024-001: Allowable Cost/Cost Principles – Enhanced Documentation of Cost Allocation (Repeat Finding) Criteria or Specific Requirements Per 2 CFR Part 200.430 (g)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition Description A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Of the 50 employee monthly reimbursements (10 for ALN 14.241; 40 for ALN 93.914) selected for allowable costs testwork, we noted 2 employee monthly reimbursements (1 for ALN 14.241; 1 for ALN 93.914) for where the hours reported per the timesheet did not agree with the hours reported in the related request for reimbursement invoices. The hours reported per the reimbursement invoices were greater than the hours reported per the timesheets. The Foundation subsequently provided documentation indicating that such differences had been properly corrected in the following month’s reimbursement invoice through an adjustment to the reported hours per the reimbursement invoice. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to the Grants We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-001. Per the CAP, the Foundation will perform regular reviews of tracked hours and reconciliations at least quarterly. Of the 18 payroll reimbursement months (for ALN 93.914), and 4 payroll reimbursement months (for ALN 93.940) selected for testwork, we noted a total of 2 months (1 for ALN 93.914; 1 for ALN 93.940) whereby the related reviews of tracked hours were performed more than 90 days after the respective reimbursement month. C. Timecard Lacking Employee and Manager Approvals In performing allowable costs testwork over payroll expenditures, we noted the following: Questioned Costs A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges None. The Foundation corrected the discrepancies in subsequent monthly reimbursements. This issue is considered an internal control finding. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to Grants None. This issue is considered an internal control finding. C. Timecards Lacking Employee and Manager Approvals None. This issue is considered an internal control finding. Cause and Effect A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Per the Associate Director of Contract Accounting, this was a one-time error in the month’s request for reimbursement invoice. This error was corrected within the grant period and did not result in overbilling the funder. However, since the correction occurred after the Foundation’s fiscal year-end, it resulted in an overstatement of expenditures reported on the SEFA for the year ended December 31, 2024. B. Improved Documentation of Routinary Reviews of Employees' Hours Charged to Grants. Per the Associate Director of Contract Accounting, the routinary review of employee hours occurred. However, there were still reclassifications that needed to be performed beyond the normal review process. The review process was not properly implemented. C. Timecards Lacking Employee and Manager Approvals The identified condition resulted from failure to follow formal procedures requiring both the employee and manager to sign off on the timesheets.

Finding 2024-001: Allowable Cost/Cost Principles – Enhanced Documentation of Cost Allocation (Repeat Finding) Criteria or Specific Requirements Per 2 CFR Part 200.430 (g)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition Description A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Of the 50 employee monthly reimbursements (10 for ALN 14.241; 40 for ALN 93.914) selected for allowable costs testwork, we noted 2 employee monthly reimbursements (1 for ALN 14.241; 1 for ALN 93.914) for where the hours reported per the timesheet did not agree with the hours reported in the related request for reimbursement invoices. The hours reported per the reimbursement invoices were greater than the hours reported per the timesheets. The Foundation subsequently provided documentation indicating that such differences had been properly corrected in the following month’s reimbursement invoice through an adjustment to the reported hours per the reimbursement invoice. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to the Grants We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-001. Per the CAP, the Foundation will perform regular reviews of tracked hours and reconciliations at least quarterly. Of the 18 payroll reimbursement months (for ALN 93.914), and 4 payroll reimbursement months (for ALN 93.940) selected for testwork, we noted a total of 2 months (1 for ALN 93.914; 1 for ALN 93.940) whereby the related reviews of tracked hours were performed more than 90 days after the respective reimbursement month. C. Timecard Lacking Employee and Manager Approvals In performing allowable costs testwork over payroll expenditures, we noted the following: Questioned Costs A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges None. The Foundation corrected the discrepancies in subsequent monthly reimbursements. This issue is considered an internal control finding. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to Grants None. This issue is considered an internal control finding. C. Timecards Lacking Employee and Manager Approvals None. This issue is considered an internal control finding. Cause and Effect A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Per the Associate Director of Contract Accounting, this was a one-time error in the month’s request for reimbursement invoice. This error was corrected within the grant period and did not result in overbilling the funder. However, since the correction occurred after the Foundation’s fiscal year-end, it resulted in an overstatement of expenditures reported on the SEFA for the year ended December 31, 2024. B. Improved Documentation of Routinary Reviews of Employees' Hours Charged to Grants. Per the Associate Director of Contract Accounting, the routinary review of employee hours occurred. However, there were still reclassifications that needed to be performed beyond the normal review process. The review process was not properly implemented. C. Timecards Lacking Employee and Manager Approvals The identified condition resulted from failure to follow formal procedures requiring both the employee and manager to sign off on the timesheets.

Finding 2024-001: Allowable Cost/Cost Principles – Enhanced Documentation of Cost Allocation (Repeat Finding) Criteria or Specific Requirements Per 2 CFR Part 200.430 (g)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition Description A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Of the 50 employee monthly reimbursements (10 for ALN 14.241; 40 for ALN 93.914) selected for allowable costs testwork, we noted 2 employee monthly reimbursements (1 for ALN 14.241; 1 for ALN 93.914) for where the hours reported per the timesheet did not agree with the hours reported in the related request for reimbursement invoices. The hours reported per the reimbursement invoices were greater than the hours reported per the timesheets. The Foundation subsequently provided documentation indicating that such differences had been properly corrected in the following month’s reimbursement invoice through an adjustment to the reported hours per the reimbursement invoice. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to the Grants We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-001. Per the CAP, the Foundation will perform regular reviews of tracked hours and reconciliations at least quarterly. Of the 18 payroll reimbursement months (for ALN 93.914), and 4 payroll reimbursement months (for ALN 93.940) selected for testwork, we noted a total of 2 months (1 for ALN 93.914; 1 for ALN 93.940) whereby the related reviews of tracked hours were performed more than 90 days after the respective reimbursement month. C. Timecard Lacking Employee and Manager Approvals In performing allowable costs testwork over payroll expenditures, we noted the following: Questioned Costs A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges None. The Foundation corrected the discrepancies in subsequent monthly reimbursements. This issue is considered an internal control finding. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to Grants None. This issue is considered an internal control finding. C. Timecards Lacking Employee and Manager Approvals None. This issue is considered an internal control finding. Cause and Effect A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Per the Associate Director of Contract Accounting, this was a one-time error in the month’s request for reimbursement invoice. This error was corrected within the grant period and did not result in overbilling the funder. However, since the correction occurred after the Foundation’s fiscal year-end, it resulted in an overstatement of expenditures reported on the SEFA for the year ended December 31, 2024. B. Improved Documentation of Routinary Reviews of Employees' Hours Charged to Grants. Per the Associate Director of Contract Accounting, the routinary review of employee hours occurred. However, there were still reclassifications that needed to be performed beyond the normal review process. The review process was not properly implemented. C. Timecards Lacking Employee and Manager Approvals The identified condition resulted from failure to follow formal procedures requiring both the employee and manager to sign off on the timesheets.

Finding 2024-001: Allowable Cost/Cost Principles – Enhanced Documentation of Cost Allocation (Repeat Finding) Criteria or Specific Requirements Per 2 CFR Part 200.430 (g)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition Description A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Of the 50 employee monthly reimbursements (10 for ALN 14.241; 40 for ALN 93.914) selected for allowable costs testwork, we noted 2 employee monthly reimbursements (1 for ALN 14.241; 1 for ALN 93.914) for where the hours reported per the timesheet did not agree with the hours reported in the related request for reimbursement invoices. The hours reported per the reimbursement invoices were greater than the hours reported per the timesheets. The Foundation subsequently provided documentation indicating that such differences had been properly corrected in the following month’s reimbursement invoice through an adjustment to the reported hours per the reimbursement invoice. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to the Grants We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-001. Per the CAP, the Foundation will perform regular reviews of tracked hours and reconciliations at least quarterly. Of the 18 payroll reimbursement months (for ALN 93.914), and 4 payroll reimbursement months (for ALN 93.940) selected for testwork, we noted a total of 2 months (1 for ALN 93.914; 1 for ALN 93.940) whereby the related reviews of tracked hours were performed more than 90 days after the respective reimbursement month. C. Timecard Lacking Employee and Manager Approvals In performing allowable costs testwork over payroll expenditures, we noted the following: Questioned Costs A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges None. The Foundation corrected the discrepancies in subsequent monthly reimbursements. This issue is considered an internal control finding. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to Grants None. This issue is considered an internal control finding. C. Timecards Lacking Employee and Manager Approvals None. This issue is considered an internal control finding. Cause and Effect A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Per the Associate Director of Contract Accounting, this was a one-time error in the month’s request for reimbursement invoice. This error was corrected within the grant period and did not result in overbilling the funder. However, since the correction occurred after the Foundation’s fiscal year-end, it resulted in an overstatement of expenditures reported on the SEFA for the year ended December 31, 2024. B. Improved Documentation of Routinary Reviews of Employees' Hours Charged to Grants. Per the Associate Director of Contract Accounting, the routinary review of employee hours occurred. However, there were still reclassifications that needed to be performed beyond the normal review process. The review process was not properly implemented. C. Timecards Lacking Employee and Manager Approvals The identified condition resulted from failure to follow formal procedures requiring both the employee and manager to sign off on the timesheets.

Finding 2024-001: Allowable Cost/Cost Principles – Enhanced Documentation of Cost Allocation (Repeat Finding) Criteria or Specific Requirements Per 2 CFR Part 200.430 (g)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives. Per Uniform Guidance Compliance Supplement part 6 – Internal Control, non-federal entities are required to establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition Description A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Of the 50 employee monthly reimbursements (10 for ALN 14.241; 40 for ALN 93.914) selected for allowable costs testwork, we noted 2 employee monthly reimbursements (1 for ALN 14.241; 1 for ALN 93.914) for where the hours reported per the timesheet did not agree with the hours reported in the related request for reimbursement invoices. The hours reported per the reimbursement invoices were greater than the hours reported per the timesheets. The Foundation subsequently provided documentation indicating that such differences had been properly corrected in the following month’s reimbursement invoice through an adjustment to the reported hours per the reimbursement invoice. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to the Grants We performed testwork over the Foundation’s implementation of the Corrective Action Plan (CAP) for Finding 2023-001. Per the CAP, the Foundation will perform regular reviews of tracked hours and reconciliations at least quarterly. Of the 18 payroll reimbursement months (for ALN 93.914), and 4 payroll reimbursement months (for ALN 93.940) selected for testwork, we noted a total of 2 months (1 for ALN 93.914; 1 for ALN 93.940) whereby the related reviews of tracked hours were performed more than 90 days after the respective reimbursement month. C. Timecard Lacking Employee and Manager Approvals In performing allowable costs testwork over payroll expenditures, we noted the following: Questioned Costs A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges None. The Foundation corrected the discrepancies in subsequent monthly reimbursements. This issue is considered an internal control finding. B. Improved Documentation of Routinary Reviews of Employee Hours Charged to Grants None. This issue is considered an internal control finding. C. Timecards Lacking Employee and Manager Approvals None. This issue is considered an internal control finding. Cause and Effect A. Improved Documentation for Basis of Cost Allocation for Employee Time Charges Per the Associate Director of Contract Accounting, this was a one-time error in the month’s request for reimbursement invoice. This error was corrected within the grant period and did not result in overbilling the funder. However, since the correction occurred after the Foundation’s fiscal year-end, it resulted in an overstatement of expenditures reported on the SEFA for the year ended December 31, 2024. B. Improved Documentation of Routinary Reviews of Employees' Hours Charged to Grants. Per the Associate Director of Contract Accounting, the routinary review of employee hours occurred. However, there were still reclassifications that needed to be performed beyond the normal review process. The review process was not properly implemented. C. Timecards Lacking Employee and Manager Approvals The identified condition resulted from failure to follow formal procedures requiring both the employee and manager to sign off on the timesheets.

Finding 2024‐002 Significant deficiency in internal controls over compliance related to allowable costs/cost principles compliance requirement. Federal Agency: Department of Treasury Program Title: Community Development Financial Institutions Fund Equitable Recovery Program (CDFI ERP) Federal Assistance Listing Number: 21.033 Award Number: 22ERP061530 Award Period: April 10, 2023 through December 31, 2028 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E require that personnel expenses allocated both directly and indirectly to federal awards be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, properly allocated and supported by adequate documentation based on an after the fact determination. Condition/Context for Evaluation During the year ended December 31, 2024, allocations of compensation expenditures were supported by a predetermined allocation created by a supervising manager responsible for overseeing all employees working on federally funded grants. The internal control system did not include a documented after the fact review of the actual activity conducted by the employee. Effect or Potential Effect HomeSight did not fully comply with the allowable cost principles as specified in 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E, Section 200.430. As a result, there may be charges to awards that do not have adequate allocation support. Questioned Costs Not determinable - HomeSight records lack established procedures of a documented after-the-fact level of activity. Accordingly, it is impossible to determine if there is a variance from pre-determined allocation levels. Cause HomeSight’s internal controls did not ensure that employees time allocated to federal awards was supported by adequate documentation. Repeat Finding Not a repeat finding. Recommendation We recommend that HomeSight implement the necessary internal control that includes processes to perform periodic after-the-fact reviews of charges made to a Federal award based on pre-determined allocation rates. View of Responsible Officials of Auditee Management agrees with the finding and has provided the accompanying corrective action plan.

2024-001: Allowable Costs Federal Agency: U.S. Department of Education Federal Program Name: Special Education – Special Olympics Education Programs Assistance Listing Number: 84.380W Pass-Through Agency: Special Olympics, Inc. Pass-Through Numbers: Y-16-24-800-12, Y-16-24-800-13 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Compliance Supplement requires that compensation for personal services be charged to the federal grant based upon approved actual time worked on the program and not based on an allocation or budget (2 CFR 200.430(i)). Condition: While performing audit procedures, it was noted that in one (1) of the eight (8) payroll expenses tested, wages charged to the grant did not match underlying payroll records. Questioned Costs: $101 Context: During the process of obtaining an understanding of internal controls and processing of payroll expenditures, we noted an instance where payroll was not charged to the grants based upon approved actual time spent in the program. Cause: Clerical error in summarizing grant expenditures. Effect: The Organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to salary expenditures charged to a program. Personnel need to reinforce policies and control procedures to ensure salaries charged to a grant are appropriately based on actual approved time worked in a program. Repeat Finding: No Recommendation: We recommend that the Organization ensure policies and procedures for reviewing and approving payroll expenditures for grant programs be strengthened to ensure mathematically accuracy. Views of Responsible Officials: There is no disagreement with the audit finding.

2024-001: Allowable Costs Federal Agency: U.S. Department of Education Federal Program Name: Special Education – Special Olympics Education Programs Assistance Listing Number: 84.380W Pass-Through Agency: Special Olympics, Inc. Pass-Through Numbers: Y-16-24-800-12, Y-16-24-800-13 Award Period: January 1, 2024 – December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Compliance Supplement requires that compensation for personal services be charged to the federal grant based upon approved actual time worked on the program and not based on an allocation or budget (2 CFR 200.430(i)). Condition: While performing audit procedures, it was noted that in one (1) of the eight (8) payroll expenses tested, wages charged to the grant did not match underlying payroll records. Questioned Costs: $101 Context: During the process of obtaining an understanding of internal controls and processing of payroll expenditures, we noted an instance where payroll was not charged to the grants based upon approved actual time spent in the program. Cause: Clerical error in summarizing grant expenditures. Effect: The Organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to salary expenditures charged to a program. Personnel need to reinforce policies and control procedures to ensure salaries charged to a grant are appropriately based on actual approved time worked in a program. Repeat Finding: No Recommendation: We recommend that the Organization ensure policies and procedures for reviewing and approving payroll expenditures for grant programs be strengthened to ensure mathematically accuracy. Views of Responsible Officials: There is no disagreement with the audit finding.

2024-001 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1640 2021 Pass-Through Agency: Not Applicable Pass-Through Number(s): Not Applicable Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR 200.430(g)(1)(iii) requires personnel expenses to reasonably reflect the total activity for which the employee is compensated by the recipient, not exceeding 100 percent of compensated activities. Condition: For one out of 60 selected payroll transactions, we noted the employee had hours charged to the award in excess of actual hours worked with 224 hours charged to the program and only 168 worked. Questioned costs: $2,028. Context: The County identified this issue prior to the audit and attempted to correct it, however an incorrect project code was applied in the correction, so the amount was not removed as intended and resulted in costs charged to the program above what was incurred. Cause: An error was made in the process of allocating costs to this award and another error was made in the process of correcting the error. These errors were not identified in the County’s review process. Effect: The County charged $2,028 to the award that was not based on employee compensation. Repeat Finding: Not a repeat finding. Recommendation: We recommend the County improve the review process over allocating payroll costs to ensure that payroll costs charged were for the proper amounts. Views of responsible officials: There is no disagreement with the audit finding.

2024-001 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1640 2021 Pass-Through Agency: Not Applicable Pass-Through Number(s): Not Applicable Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR 200.430(g)(1)(iii) requires personnel expenses to reasonably reflect the total activity for which the employee is compensated by the recipient, not exceeding 100 percent of compensated activities. Condition: For one out of 60 selected payroll transactions, we noted the employee had hours charged to the award in excess of actual hours worked with 224 hours charged to the program and only 168 worked. Questioned costs: $2,028. Context: The County identified this issue prior to the audit and attempted to correct it, however an incorrect project code was applied in the correction, so the amount was not removed as intended and resulted in costs charged to the program above what was incurred. Cause: An error was made in the process of allocating costs to this award and another error was made in the process of correcting the error. These errors were not identified in the County’s review process. Effect: The County charged $2,028 to the award that was not based on employee compensation. Repeat Finding: Not a repeat finding. Recommendation: We recommend the County improve the review process over allocating payroll costs to ensure that payroll costs charged were for the proper amounts. Views of responsible officials: There is no disagreement with the audit finding.

2024-001 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1640 2021 Pass-Through Agency: Not Applicable Pass-Through Number(s): Not Applicable Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR 200.430(g)(1)(iii) requires personnel expenses to reasonably reflect the total activity for which the employee is compensated by the recipient, not exceeding 100 percent of compensated activities. Condition: For one out of 60 selected payroll transactions, we noted the employee had hours charged to the award in excess of actual hours worked with 224 hours charged to the program and only 168 worked. Questioned costs: $2,028. Context: The County identified this issue prior to the audit and attempted to correct it, however an incorrect project code was applied in the correction, so the amount was not removed as intended and resulted in costs charged to the program above what was incurred. Cause: An error was made in the process of allocating costs to this award and another error was made in the process of correcting the error. These errors were not identified in the County’s review process. Effect: The County charged $2,028 to the award that was not based on employee compensation. Repeat Finding: Not a repeat finding. Recommendation: We recommend the County improve the review process over allocating payroll costs to ensure that payroll costs charged were for the proper amounts. Views of responsible officials: There is no disagreement with the audit finding.

2024-001 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1640 2021 Pass-Through Agency: Not Applicable Pass-Through Number(s): Not Applicable Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR 200.430(g)(1)(iii) requires personnel expenses to reasonably reflect the total activity for which the employee is compensated by the recipient, not exceeding 100 percent of compensated activities. Condition: For one out of 60 selected payroll transactions, we noted the employee had hours charged to the award in excess of actual hours worked with 224 hours charged to the program and only 168 worked. Questioned costs: $2,028. Context: The County identified this issue prior to the audit and attempted to correct it, however an incorrect project code was applied in the correction, so the amount was not removed as intended and resulted in costs charged to the program above what was incurred. Cause: An error was made in the process of allocating costs to this award and another error was made in the process of correcting the error. These errors were not identified in the County’s review process. Effect: The County charged $2,028 to the award that was not based on employee compensation. Repeat Finding: Not a repeat finding. Recommendation: We recommend the County improve the review process over allocating payroll costs to ensure that payroll costs charged were for the proper amounts. Views of responsible officials: There is no disagreement with the audit finding.

2024-001 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1640 2021 Pass-Through Agency: Not Applicable Pass-Through Number(s): Not Applicable Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR 200.430(g)(1)(iii) requires personnel expenses to reasonably reflect the total activity for which the employee is compensated by the recipient, not exceeding 100 percent of compensated activities. Condition: For one out of 60 selected payroll transactions, we noted the employee had hours charged to the award in excess of actual hours worked with 224 hours charged to the program and only 168 worked. Questioned costs: $2,028. Context: The County identified this issue prior to the audit and attempted to correct it, however an incorrect project code was applied in the correction, so the amount was not removed as intended and resulted in costs charged to the program above what was incurred. Cause: An error was made in the process of allocating costs to this award and another error was made in the process of correcting the error. These errors were not identified in the County’s review process. Effect: The County charged $2,028 to the award that was not based on employee compensation. Repeat Finding: Not a repeat finding. Recommendation: We recommend the County improve the review process over allocating payroll costs to ensure that payroll costs charged were for the proper amounts. Views of responsible officials: There is no disagreement with the audit finding.

2024-001 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1640 2021 Pass-Through Agency: Not Applicable Pass-Through Number(s): Not Applicable Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR 200.430(g)(1)(iii) requires personnel expenses to reasonably reflect the total activity for which the employee is compensated by the recipient, not exceeding 100 percent of compensated activities. Condition: For one out of 60 selected payroll transactions, we noted the employee had hours charged to the award in excess of actual hours worked with 224 hours charged to the program and only 168 worked. Questioned costs: $2,028. Context: The County identified this issue prior to the audit and attempted to correct it, however an incorrect project code was applied in the correction, so the amount was not removed as intended and resulted in costs charged to the program above what was incurred. Cause: An error was made in the process of allocating costs to this award and another error was made in the process of correcting the error. These errors were not identified in the County’s review process. Effect: The County charged $2,028 to the award that was not based on employee compensation. Repeat Finding: Not a repeat finding. Recommendation: We recommend the County improve the review process over allocating payroll costs to ensure that payroll costs charged were for the proper amounts. Views of responsible officials: There is no disagreement with the audit finding.

2024-001 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1640 2021 Pass-Through Agency: Not Applicable Pass-Through Number(s): Not Applicable Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR 200.430(g)(1)(iii) requires personnel expenses to reasonably reflect the total activity for which the employee is compensated by the recipient, not exceeding 100 percent of compensated activities. Condition: For one out of 60 selected payroll transactions, we noted the employee had hours charged to the award in excess of actual hours worked with 224 hours charged to the program and only 168 worked. Questioned costs: $2,028. Context: The County identified this issue prior to the audit and attempted to correct it, however an incorrect project code was applied in the correction, so the amount was not removed as intended and resulted in costs charged to the program above what was incurred. Cause: An error was made in the process of allocating costs to this award and another error was made in the process of correcting the error. These errors were not identified in the County’s review process. Effect: The County charged $2,028 to the award that was not based on employee compensation. Repeat Finding: Not a repeat finding. Recommendation: We recommend the County improve the review process over allocating payroll costs to ensure that payroll costs charged were for the proper amounts. Views of responsible officials: There is no disagreement with the audit finding.

2024-001 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP1640 2021 Pass-Through Agency: Not Applicable Pass-Through Number(s): Not Applicable Award Period: March 3, 2021 – December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: 2 CFR 200.430(g)(1)(iii) requires personnel expenses to reasonably reflect the total activity for which the employee is compensated by the recipient, not exceeding 100 percent of compensated activities. Condition: For one out of 60 selected payroll transactions, we noted the employee had hours charged to the award in excess of actual hours worked with 224 hours charged to the program and only 168 worked. Questioned costs: $2,028. Context: The County identified this issue prior to the audit and attempted to correct it, however an incorrect project code was applied in the correction, so the amount was not removed as intended and resulted in costs charged to the program above what was incurred. Cause: An error was made in the process of allocating costs to this award and another error was made in the process of correcting the error. These errors were not identified in the County’s review process. Effect: The County charged $2,028 to the award that was not based on employee compensation. Repeat Finding: Not a repeat finding. Recommendation: We recommend the County improve the review process over allocating payroll costs to ensure that payroll costs charged were for the proper amounts. Views of responsible officials: There is no disagreement with the audit finding.

2024 001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles U.S. Department of Homeland Security: Passed through the State of New Jersey, Department of Law and Public Safety: Disaster Grants – Public Assistance (Presidentially Declared Disasters) – ALN 97.036 Federal Grant Numbers and Years State of New Jersey pass through number: UH1WX Project #2365 – Award Year 2024 (Application 696220) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Findings: 2023-001 Criteria Compliance – Program Specific The Federal Emergency Management Agency (FEMA), as part of the U.S. Department of Homeland Security, evaluates the eligibility of all costs claimed by the applicant. Not all costs incurred as a result of the incident are eligible. (PAPPG v4) Chapter 4, page(s) 51 54; Chapter 6, page(s) 65 & 93 95. Cost must be: • Directly tied to the performance of eligible work; • Adequately documented (2 CFR section 200.403(g)); • Reduced by all applicable credits, such as insurance proceeds and salvage values (Stafford Act section 312, 42 USC section 5155, and 2 CFR section 200.406); • Authorized and not prohibited under federal, state, territorial, tribal, or local government laws or regulations; • Consistent with applicant’s internal policies, regulations, and procedures that apply uniformly to both federal awards and other activities of the applicant; and • Necessary and reasonable to accomplish the work properly and efficiently (2 CFR section 200.403). 1. Applicant (Force Account) Labor FEMA refers to the applicant’s personnel as “force account.” FEMA reimburses force account labor based on actual hourly rates plus the cost of the employee’s actual fringe benefits. FEMA calculates the fringe benefit cost based on a percentage of the hourly pay rate. Because certain items in a benefit package are not dependent on hours worked (e.g., health insurance), the percentage for overtime is usually different than the percentage for straight time. Compliance – General Per 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non federal entity, not exceeding 100% of compensated activities; (iv) Encompass federally assisted and all other activities compensated by the non federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non federal entity’s written policy; (v) Comply with the established accounting policies and practices of the non federal entity. Internal Control Per 2 CFR section 200.303(a), a non federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition and Context The New Jersey Turnpike Authority (the “Authority”), through the State of New Jersey, Department of Homeland Security (the State), administers the federal Disaster Grants – Public Assistance (Presidentially Declared Disasters) program and is reimbursed for eligible expenditures when a presidentially declared disaster occurs. For the Authority’s force account labor costs, the Authority utilizes manual Daily Worksheets (timesheets) as the official records for time and effort worked during an event by the Authority’s personnel. These timesheets are then entered into the Authority’s information system (PeopleSoft) for review and approval, reconciling back to the information entered on the respective timesheet. For thirteen of sixty timesheets selected for testwork, the Authority was unable to provide the timesheets as the official record for the time and effort charged to the federal program. However, the Authority successfully demonstrated through PeopleSoft system that the time and effort charged to the federal program was properly reviewed and approved and reconciled to the amounts of reimbursement requested from the State. The finding is recurring from the prior year as the corrective action plan developed by the Authority from the prior year finding was not implemented until December 2024, which is subsequent to when these expenditures were incurred by the Authority between fiscal years 2020 and 2022. Cause The Authority did not maintain and make readily available certain timesheets used as the official record for the time and effort charged to the federal program in accordance with the Uniform Guidance. Effect The Authority did not comply with 2 CFR Section 200.430 related to incorporating the physical timesheets into the official records of the Authority. Questioned Costs None as the time and effort amounts charged were determined to be allowable. Recommendation We recommend that the Authority strengthen its processes to ensure that all timesheets for disaster related events that are federally funded are maintained and are made readily available if subject to audit or other inspection in accordance with the Uniform Guidance. Views of Responsible Officials Management agrees with the finding. Beginning in December 2024, as a commitment to strengthen our processes and ensure that all physical timesheets related to FEMA-declared disaster events are properly maintained and readily accessible, management put a process in place to enhance procedures and controls for timesheets going forward to ensure full compliance with the Uniform Guidance requirements. This process was successfully implemented as of this date and for prospective periods. However, this process does not remedy the issue noted in the finding which relates to time worked from 2020-2022, which is before the process was in place. Therefore, the finding is repeated from the prior year.

Finding Number 2024-001: Represents a significant deficiency in internal control over compliance. Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control Over Compliance Description: Payroll Expenditures – Approval of Wage Confirmation Sheets Major Program: AL#93.569 - Community Service Block Grant – Award numbers CFS-24-7007 and CFS-25-7007 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of a sample of fourteen (14) payroll transactions (representing eight (8) individual employees), there were two (2) selections that did not have signed wage confirmation sheets. Criteria: 2 CFR 200.430(i) states that “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated”. Wage confirmation sheets, which document the employees rate of pay, must be signed indicating approval. Cause: Due to inadequate staffing, the Organization does not have the proper review process in place to ensure that the wage confirmation sheets are reviewed and approved prior to payroll being processed. Effect: Without proper review and approval of the wage confirmation sheets, it is possible that grants could be charged incorrectly, resulting in misstated financial statements. Recommendation: We recommend the Organization implement systems and procedures to ensure all wage confirmation sheets have been reviewed and approved, to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

2024-001. Allowable Costs/Cost Principles United States Department of Health and Human Services, Substance Abuse and Mental Health Services Administration Passed Through Vibrant Emotional Health: Substance Abuse and Mental Health Services Administration - 988 National Suicide Prevention Lifeline ALN: 93.243 Substance Abuse and Mental Health Services Administration - Disaster Distress Helpline ALN: 93.243 Passed Through New York State Office of Mental Health: Substance Abuse and Mental Health Services Administration - 988 S11MY1 ALN: 93.243 Criteria: Uniform Guidance 2 CFR 200.430, covers standards for documentation of compensation-personal services. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and time spent. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, these records should support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Time records prepared by employees reflect the total hours worked for the day, but do not reflect the actual time spent on programs funded by a federal award, rather they are based on budgeted hours. Cause: The Organization allocates payroll to programs funded by awards based on the contract supported budget, which is based on an estimate of the time that work will be performed by individuals. At the time of the audit, the true-up of budgeted hours to actual hours worked had not been completed. Effect: Without time records, which are based on time worked to support the proper allocation of payroll, errors could occur and result in the Organization reporting and receiving reimbursement for the incorrect amount of payroll expenses chargeable to an award. Identification of a Repeat Finding: This is a repeat finding from the prior year, 2023-001. Questioned Costs: Dollar amount undetermined, Personnel Activity Report details not available. Recommendation: The Organization’s use of Personnel Activity Report equivalent documentation, should allow each employee to accurately reflect the time work is performed for each federal award. Views of Responsible Officials and Planned Corrective Action Plan: The Organization agrees with the finding as indicated in the Organization’s corrective action plan, and has modified procedures to reflect actual time worked by employees on PAR equivalent documentation. The Organization’s new payroll and time keeping system should capture information, which will support personnel expenses funded by each federal award.

2024-001. Allowable Costs/Cost Principles United States Department of Health and Human Services, Substance Abuse and Mental Health Services Administration Passed Through Vibrant Emotional Health: Substance Abuse and Mental Health Services Administration - 988 National Suicide Prevention Lifeline ALN: 93.243 Substance Abuse and Mental Health Services Administration - Disaster Distress Helpline ALN: 93.243 Passed Through New York State Office of Mental Health: Substance Abuse and Mental Health Services Administration - 988 S11MY1 ALN: 93.243 Criteria: Uniform Guidance 2 CFR 200.430, covers standards for documentation of compensation-personal services. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and time spent. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, these records should support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Time records prepared by employees reflect the total hours worked for the day, but do not reflect the actual time spent on programs funded by a federal award, rather they are based on budgeted hours. Cause: The Organization allocates payroll to programs funded by awards based on the contract supported budget, which is based on an estimate of the time that work will be performed by individuals. At the time of the audit, the true-up of budgeted hours to actual hours worked had not been completed. Effect: Without time records, which are based on time worked to support the proper allocation of payroll, errors could occur and result in the Organization reporting and receiving reimbursement for the incorrect amount of payroll expenses chargeable to an award. Identification of a Repeat Finding: This is a repeat finding from the prior year, 2023-001. Questioned Costs: Dollar amount undetermined, Personnel Activity Report details not available. Recommendation: The Organization’s use of Personnel Activity Report equivalent documentation, should allow each employee to accurately reflect the time work is performed for each federal award. Views of Responsible Officials and Planned Corrective Action Plan: The Organization agrees with the finding as indicated in the Organization’s corrective action plan, and has modified procedures to reflect actual time worked by employees on PAR equivalent documentation. The Organization’s new payroll and time keeping system should capture information, which will support personnel expenses funded by each federal award.

2024-001. Allowable Costs/Cost Principles United States Department of Health and Human Services, Substance Abuse and Mental Health Services Administration Passed Through Vibrant Emotional Health: Substance Abuse and Mental Health Services Administration - 988 National Suicide Prevention Lifeline ALN: 93.243 Substance Abuse and Mental Health Services Administration - Disaster Distress Helpline ALN: 93.243 Passed Through New York State Office of Mental Health: Substance Abuse and Mental Health Services Administration - 988 S11MY1 ALN: 93.243 Criteria: Uniform Guidance 2 CFR 200.430, covers standards for documentation of compensation-personal services. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and time spent. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, these records should support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Time records prepared by employees reflect the total hours worked for the day, but do not reflect the actual time spent on programs funded by a federal award, rather they are based on budgeted hours. Cause: The Organization allocates payroll to programs funded by awards based on the contract supported budget, which is based on an estimate of the time that work will be performed by individuals. At the time of the audit, the true-up of budgeted hours to actual hours worked had not been completed. Effect: Without time records, which are based on time worked to support the proper allocation of payroll, errors could occur and result in the Organization reporting and receiving reimbursement for the incorrect amount of payroll expenses chargeable to an award. Identification of a Repeat Finding: This is a repeat finding from the prior year, 2023-001. Questioned Costs: Dollar amount undetermined, Personnel Activity Report details not available. Recommendation: The Organization’s use of Personnel Activity Report equivalent documentation, should allow each employee to accurately reflect the time work is performed for each federal award. Views of Responsible Officials and Planned Corrective Action Plan: The Organization agrees with the finding as indicated in the Organization’s corrective action plan, and has modified procedures to reflect actual time worked by employees on PAR equivalent documentation. The Organization’s new payroll and time keeping system should capture information, which will support personnel expenses funded by each federal award.

2024-001. Allowable Costs/Cost Principles United States Department of Health and Human Services, Substance Abuse and Mental Health Services Administration Passed Through Vibrant Emotional Health: Substance Abuse and Mental Health Services Administration - 988 National Suicide Prevention Lifeline ALN: 93.243 Substance Abuse and Mental Health Services Administration - Disaster Distress Helpline ALN: 93.243 Passed Through New York State Office of Mental Health: Substance Abuse and Mental Health Services Administration - 988 S11MY1 ALN: 93.243 Criteria: Uniform Guidance 2 CFR 200.430, covers standards for documentation of compensation-personal services. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and time spent. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, these records should support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Time records prepared by employees reflect the total hours worked for the day, but do not reflect the actual time spent on programs funded by a federal award, rather they are based on budgeted hours. Cause: The Organization allocates payroll to programs funded by awards based on the contract supported budget, which is based on an estimate of the time that work will be performed by individuals. At the time of the audit, the true-up of budgeted hours to actual hours worked had not been completed. Effect: Without time records, which are based on time worked to support the proper allocation of payroll, errors could occur and result in the Organization reporting and receiving reimbursement for the incorrect amount of payroll expenses chargeable to an award. Identification of a Repeat Finding: This is a repeat finding from the prior year, 2023-001. Questioned Costs: Dollar amount undetermined, Personnel Activity Report details not available. Recommendation: The Organization’s use of Personnel Activity Report equivalent documentation, should allow each employee to accurately reflect the time work is performed for each federal award. Views of Responsible Officials and Planned Corrective Action Plan: The Organization agrees with the finding as indicated in the Organization’s corrective action plan, and has modified procedures to reflect actual time worked by employees on PAR equivalent documentation. The Organization’s new payroll and time keeping system should capture information, which will support personnel expenses funded by each federal award.

2024-001. Allowable Costs/Cost Principles United States Department of Health and Human Services, Substance Abuse and Mental Health Services Administration Passed Through Vibrant Emotional Health: Substance Abuse and Mental Health Services Administration - 988 National Suicide Prevention Lifeline ALN: 93.243 Substance Abuse and Mental Health Services Administration - Disaster Distress Helpline ALN: 93.243 Passed Through New York State Office of Mental Health: Substance Abuse and Mental Health Services Administration - 988 S11MY1 ALN: 93.243 Criteria: Uniform Guidance 2 CFR 200.430, covers standards for documentation of compensation-personal services. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and time spent. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, these records should support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Time records prepared by employees reflect the total hours worked for the day, but do not reflect the actual time spent on programs funded by a federal award, rather they are based on budgeted hours. Cause: The Organization allocates payroll to programs funded by awards based on the contract supported budget, which is based on an estimate of the time that work will be performed by individuals. At the time of the audit, the true-up of budgeted hours to actual hours worked had not been completed. Effect: Without time records, which are based on time worked to support the proper allocation of payroll, errors could occur and result in the Organization reporting and receiving reimbursement for the incorrect amount of payroll expenses chargeable to an award. Identification of a Repeat Finding: This is a repeat finding from the prior year, 2023-001. Questioned Costs: Dollar amount undetermined, Personnel Activity Report details not available. Recommendation: The Organization’s use of Personnel Activity Report equivalent documentation, should allow each employee to accurately reflect the time work is performed for each federal award. Views of Responsible Officials and Planned Corrective Action Plan: The Organization agrees with the finding as indicated in the Organization’s corrective action plan, and has modified procedures to reflect actual time worked by employees on PAR equivalent documentation. The Organization’s new payroll and time keeping system should capture information, which will support personnel expenses funded by each federal award.

2024-001. Allowable Costs/Cost Principles United States Department of Health and Human Services, Substance Abuse and Mental Health Services Administration Passed Through Vibrant Emotional Health: Substance Abuse and Mental Health Services Administration - 988 National Suicide Prevention Lifeline ALN: 93.243 Substance Abuse and Mental Health Services Administration - Disaster Distress Helpline ALN: 93.243 Passed Through New York State Office of Mental Health: Substance Abuse and Mental Health Services Administration - 988 S11MY1 ALN: 93.243 Criteria: Uniform Guidance 2 CFR 200.430, covers standards for documentation of compensation-personal services. Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed and time spent. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, these records should support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities, which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Time records prepared by employees reflect the total hours worked for the day, but do not reflect the actual time spent on programs funded by a federal award, rather they are based on budgeted hours. Cause: The Organization allocates payroll to programs funded by awards based on the contract supported budget, which is based on an estimate of the time that work will be performed by individuals. At the time of the audit, the true-up of budgeted hours to actual hours worked had not been completed. Effect: Without time records, which are based on time worked to support the proper allocation of payroll, errors could occur and result in the Organization reporting and receiving reimbursement for the incorrect amount of payroll expenses chargeable to an award. Identification of a Repeat Finding: This is a repeat finding from the prior year, 2023-001. Questioned Costs: Dollar amount undetermined, Personnel Activity Report details not available. Recommendation: The Organization’s use of Personnel Activity Report equivalent documentation, should allow each employee to accurately reflect the time work is performed for each federal award. Views of Responsible Officials and Planned Corrective Action Plan: The Organization agrees with the finding as indicated in the Organization’s corrective action plan, and has modified procedures to reflect actual time worked by employees on PAR equivalent documentation. The Organization’s new payroll and time keeping system should capture information, which will support personnel expenses funded by each federal award.

2024-002 Compensation for Personal Services Coronavirus State & Local Fiscal Recovery Funds – Assistance Listing No. 21.027 – COVID-19 Funding Award Number: 24-IHFA 186302 – Award Period: October 1, 2023 through September 30, 2024 Award Number: Aurora ARPA – Award Period: April 1, 2024 through December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition: Hours spent working on different funding sources/cost objectives from payroll timesheets did not agree to hours entered into the payroll allocation spreadsheets for five pay periods for sampled employees #1 and #2. Additionally, total hours worked and logged on timesheets did not agree to hours paid for two pay periods for sampled employees #1 and #3. These errors were not detected and corrected after-the-fact. Criteria: According to 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.430(i)(1), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated Questioned Costs: Not determinable. Cause: The Organization’s established internal controls over salary and wage cost allocation did not operate as intended. Effect: Allowable costs could potentially be overpaid or underpaid or disallowed and required to be paid back to the Federal awarding agency (and/or pass-through entity). Recommendation: The Organization should strengthen their policies and procedures to support a system of internal control able to prevent and/or detect and correct errors timely ensuring costs are accurate, allowable, and properly allocated. Views of Responsible Officials and Planned Corrective Actions: Gateway Domestic Violence Services acknowledges there were errors made but can attest that the charges to funders were correct. See separately issued corrective action plan.