FINANCIAL STATEMENT FINDING Finding No. 2022-002: Indirect Costs ? Significant Deficiency in Internal Control Over Financial Reporting Recommendation5 We recommend that ZERO TO THREE enhance its internal control policies to ensure indirect costs are calculated based on the most recent indirect cost rate agreement. Indirect costs should be billed at the lower of the negotiated rates or the actual charges. Action Taken ZERO TO THREE has recently undergone major technological upgrades involving multiple accounting systems. We received the NICRA letter with our new indirect cost rate eight months into the 2022 fiscal year. The late receipt of this letter, combined with challenges of our then antiquated accounting software, made it very difficult to retroactively apply the NICRA rate changes with consistent accuracy. Our new, robust accounting system, implemented October 1, 2022, is designed to easily handle these types of accounting changes going forward. Management is adjusting the cost reimbursements on the federal agreements to reflect the audit adjustment. Contact Person Responsible for Corrective Action Pia C. Valdivia, Chief Financial and Administrative Officer Expected Completion Date: March 31, 2023 FEDERAL AWARD FINDING Finding No. 2022-003: Indirect Costs ? Significant Deficiency in Internal Control Over Compliance ? Assistance Listing No. 93.600 Finding 2022-002 is also a finding with respect to the major federal program. See response above.