Environmental Quality Incentives Program – Assistance Listing No. 10.912 Recommendation: We recommend the Organization implement a compensating control to formally document their review and approval over time & effort studies and allocations. This review would include comparing the payroll processed and allocated to the grant to the approved time and effort documentation by funding source to ensure payroll costs are not being overcharged. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Status of corrective action: This finding recurred in 2025 due to the timing of implementation, not because the corrective actions were ineffective. The corrective actions described below were fully in place by October 2025, after the start of the January 1 to December 31, 2025 audit period, so the controls were not in operation for the full year. The controls have been in operation since implementation, and the Organization expects this finding to be resolved in the audit for the year ending December 31, 2026, which will be the first audit period in which the controls operate for the entire year. Time and effort studies: Beginning in September 2025, the Organization conducts monthly time studies by position. Management reviews and approves each time study, and the approval is documented and dated by email to the Outsourced Accountant. When actual time spent deviates from the most recent time study, payroll allocations are adjusted so that charges to each funding source reflect actual effort. Payroll allocation reconciliation (compensating control): Each month, before payroll costs are included in a claim for reimbursement, the Director of Operations or a designee independent of payroll preparation compares the payroll processed and allocated to the Environmental Quality Incentives Program award to the approved time and effort documentation by funding source. Any difference is investigated and corrected in the general ledger before the costs are claimed, so that payroll charged to the award does not exceed the effort supported. Name of the contact person responsible for corrective action: Angie Sullivan, Director of Operations Planned completion date for corrective action plan: Implemented October 2025; expected to be resolved in the audit for the year ending December 31, 2026