Management recognizes that the payroll software transition and the absence of formally documented procedures governing payroll data preservation and time-and-effort reporting resulted in gaps in compliance. Specifically, legacy payroll and timesheet data were not fully preserved prior to system migration, and payroll allocations were, for a period, based on budgeted estimates rather than actual time worked. Management started implementing corrective actions to address both the immediate documentation gaps and the underlying internal control weaknesses. 1. Time-and-Effort Documentation System CPA transitioned to a new standardized payroll and time-reporting system in early 2024, which requires all employees whose compensation is charged in whole or in part to federal awards to document actual time worked, as follows: o Currently employees record time by department and program activity. o In December 2025, management is configuring the payroll system to allow employee time allocations down to the individual contract level. o Time reporting will be based on actual hours worked, not budgeted or estimated percentages and replace prior budget-based allocation methodologies. o Timesheets are reviewed and approved by supervisors on a bi-weekly basis and are maintained as part of CPA’s official payroll and accounting records. Management will establish guidelines and document formal procedures to ensure full data preservation prior to any future system migrations, including payroll, HR, or financial systems. These procedures include: o A mandatory pre-migration data inventory and archival checklist, approved by Finance and IT leadership o Secure retention of legacy payroll, timesheet, and personnel records in accordance with CPA’s record-retention policy o Verification testing to confirm data completeness and accessibility before decommissioning any legacy system o Written approval by the Chief Financial Officer prior to system cutover