Action Taken in Response to Finding: In 2023, invoices were submitted using a format aligned with initial guidance from the Colorado Department of Human Services (CDHS), reflecting a per-learner, activity-based approach. Beginning in October 2024, updated guidance required invoices to be based on actual costs incurred, including the use of supporting documentation such as timesheets and receipts to substantiate costs. As of October 2025, CDHS updated reimbursement requirements to no longer require supporting documentation at the time of invoice submission. However, complete supporting documentation is maintained and provided upon request for monitoring or audit purposes. Standardized Excel-based tools provided by CDHS are utilized for reimbursement submission (Invoice and Ledger). Transaction-level cost tracking was implemented to ensure allowable and eligible costs are recorded and supported. Financial and grant-related policies were previously maintained and were subsequently standardized and incorporated into Financial Policies and Procedures in 2023, with a comprehensive Grant Management framework implemented in May 2026. Control Enhancement: Beginning in 2025, all costs applied toward matching requirements are recorded and tracked at the transaction level within the accounting system and are fully supported by source documentation. Matching contributions must: • Be based on actual, allowable, and allocable costs • Be verifiable from accounting records • Not include estimated or budgeted amounts A standardized approach has been implemented to ensure that matching costs are derived from the same underlying financial data used for reimbursable costs. Monitoring & Review: • Matching costs are reviewed by the Senior Accountant prior to inclusion in reimbursement requests • A secondary monthly review is performed by the Director of Finance & Operations to validate accuracy, allowability, and compliance with matching requirements • Any discrepancies between recorded costs and matching allocations are identified and resolved prior to submission Testing & Validation: • Beginning June 2026, quarterly internal reviews will be conducted to test a sample of matching costs for compliance with documentation and allowability requirements • Testing will confirm that matching costs are fully supported and traceable to accounting records • Results will be documented and tracked, and any identified deficiencies will require corrective action Documentation & Evidence: • Supporting documentation for matching costs is maintained in Microsoft Teams • Matching calculations and supporting detail are retained and available for audit or monitoring • Review and approval are evidenced via email approval and retained as part of the audit record Control Owner(s): • Director of Finance & Operations • Finance Team Responsible Party: Helen Young Hayes, Founder / Chief Executive Officer, in coordination with the Director of Finance & Operations and Finance Staff Anticipated Completion Date: All corrective actions will be implemented by June 30, 2026. Ongoing monitoring, quarterly testing, and policy updates will continue. Status: • Transaction-level tracking of matching costs: Implemented 2025 • Updated invoicing methodology: Implemented October 2024; revised October 2025 • Cost Sharing policy: Implemented May 2026 • Grant Management framework; Incorporated in Financial Policy and Procedures on May 2026. • Quarterly internal reviews will be conducted to test a sample of matching costs for compliance with documentation and allowability requirements: June 2026