Finding 554456 (2024-001)

Date: March 27, 2025 Cognizant or Oversight Agency: U.S. Department of the Treasury Public Counsel respectfully submits the following corrective action plan for the year ended August 31, 2024. Name and address of independent public accounting firm: Armanino, LLP 11766 Wilshire Blvd. 9th Floor Los Angeles, CA 90025 Audit period: August 31, 2024 The finding from the August 31, 2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS-FINANCIAL STATEMENT AUDIT SIGNIFICANT DEFICIENCY 2024-001 The Uniform Guidance Cost principles require consistency in treatment of costs and, specifically, that compensation costs be consistent. In addition, the Uniform Guidance requires that there be a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated and conform to the established accounting policies and practices of the Organization. Recommendation: The process implemented by management during the year appears to have addressed the ongoing variances satisfactorily, and management should continue with its new process. Action Taken: We agree with the auditors' recommendations, and we have already taken the following actions during the fiscal year ended August 31, 2024: We have updated the payroll allocation methodology to ensure that we are making allocations for employees on a fully pro rata basis and that there is a validation process to ensure that 100% of an employee’s time is appropriately allocated across Federal and non-Federal funding sources. The supporting documentation is saved in our shared network folders and attached to the journal entries within our financial system. For any future process or system changes, we will ensure that we have thoroughly assessed the impact of any change before we implement it and vet it in through our internal grant compliance team. We have already made changes to involve our Legal Data Manager to implement a reporting process to ensure that we have complete timeslips that reflect both employee and supervisor approvals for every pay period. We will maintain this approach in Legal Server, the Organization's case management and timekeeping system, and will attach these timeslips as support for each of our allocation entries. We will continue to assess our procedures and internal controls relevant to our Federal funding to ensure compliance with the requirements of Uniform Guidance. We will do a thorough review of our internal control system and update it as necessary to align with best practices as recipients of Federal funding. The Finance team will continue to actively seek training related to Uniform Guidance updates and other Federal rules and requirements. We will share and discuss this information across departments to maintain organization-wide compliance. Name of responsible person: Steven Godoy VP, Finance & CFO Anticipated completion date: August 31, 2025 If the U.S. Department of Treasury has questions regarding this plan, please call Steven Godoy, VP, Chief Financial Officer at (213) 393-1055. Sincerely yours, Steven Godoy VP, Chief Financial Officer