Finding: 2025-002 Reportable finding considered a material weakness-Expenses incurred outside of the period of performance Effect: The organization claimed and was reimbursed for unallowable costs under 2 CFR 200.458. Failure to maintain effective controls over cost allowability increases the risk of noncompliance questioned costs, and potential repayment of federal funds. Questioned costs: Known questioned costs of $403,805 were identified by reviewing each transaction prior to the date and for the month after the award began to ensure there are no likely questioned costs. Recommendation for the organization from the auditor: • Formalize and implement written policies and procedures governing identification, approval, and accounting for pre-award costs. • Require documented written approval from the federal awarding agency prior to charging any pre-award costs to federal awards. • Provide training to program and finance personnel on Uniform Guidance cost allowability requirements, including 2 CFR 200.458 and 2 CFR 200.403. • Implement supervisory review controls to ensure costs charged to federal awards are incurred within the approval period of performance or have documented prior approval. Corrective Action Plan for Pre-award costs Management acknowledges the audit finding that pre-award costs were charged to multiple federal awards for expenses incurred before the approved period of performance beginning October 1, 2024. The costs were incurred without the required written prior approval from the Maryland Department of Labor (MD DOL), the pass-through entity. As a result, unallowable costs were reimbursed and later removed from the Schedule of Expenditures of Federal Awards (SEFA). Management determined that the issue resulted from insufficient internal controls, the absence of formal written procedures for pre-award costs, and gaps in staff understanding of Uniform Guidance requirements. To address these root causes, the organization adopted a formal written policy governing the identification, approval, documentation, and accounting of pre-award costs. The policy requires written prior approval from MD DOL before any pre-award costs may be incurred or charged to a federal award and establishes documentation, retention, and accounting standards to support compliance with 2 CFR 200.458 and 2 CFR 200.403. Third, the organization also implemented a mandatory written approval workflow requiring program and grants staff to prepare and submit a formal request to MD DOL whenever pre-award costs are anticipated. No costs may be incurred until written approval is received. Approval documentation must be retained in both the official grant file and the accounting system. This workflow is now part of the grant start-up process for all federal awards. Fourth, the organization strengthened supervisory review controls to ensure that all costs charged to federal awards fall within the approved period of performance or have documented prior approval. These controls include a pre-posting cost allowability checklist, supervisory review and approval of all federal charges, and accounting system alerts that flag costs incurred outside the period of performance. Additionally, the Compliance Officer will conduct quarterly internal compliance reviews to verify adherence to federal requirements and internal policies. Finally, the organization implemented preventive measures to ensure long-term compliance. These include maintaining a centralized grant calendar with period-of-performance dates, requiring dual review of costs charged during the first 90 days of new awards, and conducting semi-annual internal audits of federal expenditures. Any discrepancies identified will be reported to senior leadership within five business days. Management is committed to ensuring full compliance with Uniform Guidance and MD DOL requirements. All corrective actions described above have been implemented or will be fully implemented by July 31, 2026. The organization believes these actions sufficiently address the audit findings and significantly strengthen internal controls over federal award management. Corrective Action Plan Summary Corrective Action Responsible Staff/Role Target Completion Date Evidence of Completion Develop and implement formal Pre-award Cost Policy Finance Director June 1, 2026 Final approved policy; distribution email; policy posted to shared drive Establish mandatory written prior approval workflow Finance Director June 30, 2026 Completed approval request template; sample approval documentation; updated grant file checklist Conduct Uniform Guidance training Compliance Officer July 31, 2026 Training materials; attendance logs; post-training assessments Implement supervisory review controls Finance Director June 30, 2026 Completed checklists; system screenshots; supervisor sign-offs Perform quarterly internal compliance reviews Compliance Officer Quarterly, ongoing Quarterly review reports; corrective action memos (if applicable) Maintain centralized grant calendar Director of Performance and Compliance June 30, 2026 Updated grant calendar; access logs or distribution email Conduct semi-annual internal audits Compliance Officer Semi-annual, ongoing Internal audit reports; follow-up documentation Dual review of early-period charges Finance Director; Grants Manager July 1, 2026 Dual-review sign-off forms; documented approvals