EIN: 362166961
UEI: U43SP5TQJHD9
Data as of August 25, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 21, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by November 21, 2026 (88 days from today).
What is a management decision? →The Agency is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: None Context: This condition occurred in all 53 transactions selected for testing and represented 20 different employees. Cause: Procedures for the allocation of employee time in full compliance with the Uniform Guidance have not yet been fully implemented. Effect: Inaccurate payroll costs may be charged to federal programs if the Agency does not have procedures in place to monitor and record employee time devoted to federal programs. Repeat Finding: This finding is a repeat of finding 2024-002. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee woks on more than one federally funded program. Views of Responsible Officials: There is no disagreement with this finding.
Show full finding ▾Hide full finding ▴Allocation and Documentation of Payroll Costs Federal Agencies: Corporation for National and Community Services, U.S. Department of Labor, and U.S. Department of Housing and Urban Development Federal Program Names: AmeriCorps State and National Grants, WIOA Adult Program, and Community Development Block Grants/Entitlement Grants Cluster Assistance Listing Numbers: 94.006, 17.258, and 14.218 Pass-Through Agencies: Illinois Department of Human Services, Chicago Cook Workforce Partnership, City of Chicago Department of Family and Support Services, and City of Chicago Department of Housing Pass-Through Numbers: FCSDY07205, FCSDY07201, FCSDY07898; Adult-2021-2135, 177227, 177420, 178768, and 253064 Award Period: July 1, 2024 through June 30, 2025; October 1, 2023 through September 30, 2024; October 1, 2024 through September 30, 2025; and January 1, 2022 through December 31, 2025 Type of Finding: Other Matters Material Weakness in Internal Control over Compliance Criteria or Specific Requirement: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;(B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. Condition: The Agency is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: None Context: This condition occurred in all 53 transactions selected for testing and represented 20 different employees. Cause: Procedures for the allocation of employee time in full compliance with the Uniform Guidance have not yet been fully implemented. Effect: Inaccurate payroll costs may be charged to federal programs if the Agency does not have procedures in place to monitor and record employee time devoted to federal programs. Repeat Finding: This finding is a repeat of finding 2024-002. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee woks on more than one federally funded program. Views of Responsible Officials: There is no disagreement with this finding.
MATERIAL WEAKNESS Finding 2025-003 – Allocation and Documentation of Payroll Costs Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated and support the distribution of the employee’s wages among specific activities or cost objectives if the employee woks on more than one federally funded program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As corrective action, management implemented a new system to track time and effort effective July 1, 2025, using the Forms Assembly platform for federally funded DHS programs. For other grants, the Agency has continued to maintain supporting time and effort documentation through Excel-based records. Management recognizes that the implementation of the Forms Assembly system has presented operational challenges, particularly due to the need to reconcile information separately with the payroll system. As a result, since October 2025, management has been evaluating and vetting alternative systems that can fully integrate time and effort reporting with payroll processing. Beginning in fiscal year 2027, the Agency plans to implement a new integrated software solution that will record employee time, grant allocations, and payroll information within a single system integrated directly with payroll processing. Management believes this integrated approach will strengthen internal controls, improve the accuracy and timeliness of reporting, reduce manual reconciliation processes, and enhance compliance with federal time and effort requirements. Name of contact person responsible for corrective action: Margarita Rosas, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2026
2024-002
FAC accepted this audit on February 13, 2025 — management decision was due August 13, 2025.
The Agency is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: None Context: This condition occurred in all 47 transactions selected for testing and represented 14 different employees. Cause: Procedures for the allocation of employee time in full compliance with the Uniform Guidance have not yet been fully implemented. Effect: Inaccurate payroll costs may be charged to federal programs if the Agency does not have procedures in place to monitor and record employee time devoted to federal programs. Repeat Finding: This finding is a repeat of finding 2023-003. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee woks on more than one federally funded program. Views of Responsible Officials: There is no disagreement with this finding.
Show full finding ▾Hide full finding ▴Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Labor Federal Program Names: Block Grants for Community Mental Health Services and WIOA Adult Program Assistance Listing Numbers: 93.958 and 17.258 Pass-Through Agencies: Illinois Department of Human Services and Chicago Cook Workforce Partnership Pass-Through Numbers: 45CBB00060; 2021-2135 and 2022-2135 Award Period: July 1, 2023 through June 30, 2024; October 1, 2022 through September 30, 2023; October 1, 2023 through September 30, 2024 Type of Finding: Other Matters Material Weakness in Internal Control over Compliance Criteria or Specific Requirement: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;(B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. Condition: The Agency is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: None Context: This condition occurred in all 47 transactions selected for testing and represented 14 different employees. Cause: Procedures for the allocation of employee time in full compliance with the Uniform Guidance have not yet been fully implemented. Effect: Inaccurate payroll costs may be charged to federal programs if the Agency does not have procedures in place to monitor and record employee time devoted to federal programs. Repeat Finding: This finding is a repeat of finding 2023-003. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee woks on more than one federally funded program. Views of Responsible Officials: There is no disagreement with this finding.
OTHER MATTERS MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE Finding 2024-002 – Allocation and Documentation of Payroll Costs Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated and support the distribution of the employee’s wages among specific activities or cost objectives if the employee woks on more than one federally funded program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will develop and implement a process whereby payroll costs for staff are supported by a system of internal controls which will provide reasonable assurance that the charges are accurate, allowable, and properly allocated. Name of contact person responsible for corrective action: Juan Carlos Linares, President and CEO Planned completion date for corrective action plan: December 31, 2024
2023-003
FAC accepted this audit on February 23, 2024 — management decision was due August 23, 2024.
During the audit, 1) noted $103,547 in payments originally classified as a federal award until auditors' review of agreement identified that amount is not federal funding (ALN 93.958). 2) Noted $25,400 was omitted from the SEFA for grant as formula calculating total expenditures excluded an amount. A change to the SEFA was required to adjust the amounts reflected as federal awards. Questioned Costs: None Context: The initial SEFA provided overstated federal awards by $103,547 (ALN 93.958) passed-through the Illinois Department of Human Services and understated federal awards by $25,400 (ALN 17.258) passed-through the Chicago Cook Workforce Partnership. Cause: Lack of review of final calculations and passed through grant agreement. Effect: Amounts inaccurately reflected on the SEFA. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend the Agency establish controls to evaluate grant agreements to capture funds identified as federal accurately and perform review of final SEFA to avoid any calculation related errors. Views of Responsible Officials: There is no disagreement with this finding.
Show full finding ▾Hide full finding ▴2023 – 002: Preparation of Schedule of Expenditures of Federal Awards Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Labor Federal Program Names: Block Grants for Community Mental Health Services and WIOA Adult Program Assistance Listing Numbers: 93.958 and 17.258 Pass-Through Agencies: Illinois Department of Human Services and Chicago Cook Workforce Partnership Pass-Through Numbers: 45CBB00060; 2021-2135 and 2022-2135 Award Periods: July 1, 2022 through June 30, 2023; October 1, 2021 through September 30, 2022; October 1, 2022 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Agency must provide the Schedule of Expenditures of Federal Awards. The schedule must be complete and accurate to provide for the basis of testing by the auditors as well as for accurate financial reporting to primary and secondary funders. Condition: During the audit, 1) noted $103,547 in payments originally classified as a federal award until auditors' review of agreement identified that amount is not federal funding (ALN 93.958). 2) Noted $25,400 was omitted from the SEFA for grant as formula calculating total expenditures excluded an amount. A change to the SEFA was required to adjust the amounts reflected as federal awards. Questioned Costs: None Context: The initial SEFA provided overstated federal awards by $103,547 (ALN 93.958) passed-through the Illinois Department of Human Services and understated federal awards by $25,400 (ALN 17.258) passed-through the Chicago Cook Workforce Partnership. Cause: Lack of review of final calculations and passed through grant agreement. Effect: Amounts inaccurately reflected on the SEFA. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend the Agency establish controls to evaluate grant agreements to capture funds identified as federal accurately and perform review of final SEFA to avoid any calculation related errors. Views of Responsible Officials: There is no disagreement with this finding.
Action taken in response to finding: Management will implement a process to evaluate grant agreements and properly identify federal funding which will be reviewed to ensure the final SEFA is accurate and free of errors. Name of contact person responsible for corrective action: Juan Carlos Linares, President and CEO Planned completion date for corrective action plan: December 31, 2023
The Agency is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: None Context: This condition occurred in all 59 transactions selected for testing and represented 16 different employees. Cause: Procedures for the allocation of employee time in full compliance with the Uniform Guidance have not yet been fully implemented. Effect: Inaccurate payroll costs may be charged to federal programs if the Agency does not have procedures in place to monitor and record employee time devoted to federal programs. Repeat Finding: This finding is not a repeat finding. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee woks on more than one federally funded program. Views of Responsible Officials: There is no disagreement with this finding.
Show full finding ▾Hide full finding ▴2023 – 003: Allocation and Documentation of Payroll Costs Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Labor Federal Program Names: Block Grants for Community Mental Health Services and WIOA Adult Program Assistance Listing Numbers: 93.958 and 17.258 Pass-Through Agencies: Illinois Department of Human Services and Chicago Cook Workforce Partnership Pass-Through Numbers: 45CBB00060; 2021-2135 and 2022-2135 Award Period: July 1, 2022 through June 30, 2023; October 1, 2021 through September 30, 2022; October 1, 2022 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:(A) The system for establishing the estimates produces reasonable approximations of the activity actually performed;(B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. Condition: The Agency is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: None Context: This condition occurred in all 59 transactions selected for testing and represented 16 different employees. Cause: Procedures for the allocation of employee time in full compliance with the Uniform Guidance have not yet been fully implemented. Effect: Inaccurate payroll costs may be charged to federal programs if the Agency does not have procedures in place to monitor and record employee time devoted to federal programs. Repeat Finding: This finding is not a repeat finding. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee’s wages among specific activities or cost objectives if the employee woks on more than one federally funded program. Views of Responsible Officials: There is no disagreement with this finding.
Action taken in response to finding: Management will develop and implement a process whereby payroll costs for staff are supported by a system of internal controls which will provide reasonable assurance that the charges are accurate, allowable, and properly allocated. Name of contact person responsible for corrective action: Juan Carlos Linares, President and CEO Planned completion date for corrective action plan: December 31, 2023
In testing required reports, we noted a monthly expenditure report did not have documented review and approval. Questioned Costs: None Context: The Agency is required to report monthly expenditures to the funder. We noted one of three instances selected for testing did not have documented review and approval. Cause: The Agency did not follow established policies and procedures over the review and approval of the monthly expenditure reports. Effect: Monthly expenditure reports have a higher risk of error if review in accordance with established policies and procedures is not performed. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management update their policies and procedures to ensure all monthly expenditure reports have documented review and approval. Views of Responsible Officials: There is no disagreement with this finding.
Show full finding ▾Hide full finding ▴2023 – 004: Reporting Federal Agency: U.S. Department of Labor Federal Program Name: WIOA Adult Program Assistance Listing Number: 17.258 Pass-Through Agency: Chicago Cook Workforce Partnership Pass-Through Number: 2022-2135 Award Period: October 1, 2022 through September 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The internal control system should include policies and procedures to ensure that required reports have documented review and approval. Condition: In testing required reports, we noted a monthly expenditure report did not have documented review and approval. Questioned Costs: None Context: The Agency is required to report monthly expenditures to the funder. We noted one of three instances selected for testing did not have documented review and approval. Cause: The Agency did not follow established policies and procedures over the review and approval of the monthly expenditure reports. Effect: Monthly expenditure reports have a higher risk of error if review in accordance with established policies and procedures is not performed. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management update their policies and procedures to ensure all monthly expenditure reports have documented review and approval. Views of Responsible Officials: There is no disagreement with this finding.
Action taken in response to finding: Management will ensure authorizations are reflected on monthly expenditure reports. Policies will be updated to include alternative methods of documenting review and approval, such as an email to keep on file with the calculation. Name of contact person responsible for corrective action: Juan Carlos Linares, President and CEO Planned completion date for corrective action plan: December 31, 2023
FAC accepted this audit on December 6, 2021 — management decision was due June 6, 2022.
In testing cost reimbursement calculations we noted months that did not have documented review and approval noted on the calculation support. Questioned Costs: None. Context: The Agency utilizes monthly cost reimbursement calculations to determine grant revenue to record in the general ledger. We noted two of five instances selected for testing did not have documented review and approval. Cause: The Agency did not follow established policies and procedures over the review and approval of the monthly cost reimbursement calculations. Effect: Monthly cost reimbursement calculations have a higher risk of error if review in accordance with established policies and procedures is not performed. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management update their policies and procedures to ensure all monthly cost reimbursement calculations have documented review and approval. Due to increased remote working environments, we recommend including alternative methods of documenting review and approval, such as e-mail. Views of Responsible Officials: There is no disagreement with this finding.
Show full finding ▾Hide full finding ▴Finding 2021-001 ? Documentation of Review of Cost Reimbursement Calculations Major Program: Block Grants for Community Mental Health Services CDFA Number: 93.958 Federal Agency: U.S. Department of Health and Human Services Pass-Through: Illinois Department of Human Services Grantor Number: 22876440A Award Period: July 1, 2020 through June 30, 2021 Type of Finding: - Significant deficiency in Internal Control over Compliance. - Other Matters. Criteria: The internal control system should include policies and procedures to ensure that cost reimbursement calculations are accurate and based on actual program performance. Condition: In testing cost reimbursement calculations we noted months that did not have documented review and approval noted on the calculation support. Questioned Costs: None. Context: The Agency utilizes monthly cost reimbursement calculations to determine grant revenue to record in the general ledger. We noted two of five instances selected for testing did not have documented review and approval. Cause: The Agency did not follow established policies and procedures over the review and approval of the monthly cost reimbursement calculations. Effect: Monthly cost reimbursement calculations have a higher risk of error if review in accordance with established policies and procedures is not performed. Repeat Finding: This finding is not a repeat finding. Recommendation: We recommend management update their policies and procedures to ensure all monthly cost reimbursement calculations have documented review and approval. Due to increased remote working environments, we recommend including alternative methods of documenting review and approval, such as e-mail. Views of Responsible Officials: There is no disagreement with this finding.
Management?s Response and Corrective Action Plan: Management will ensure authorizations are reflected on monthly calculations. Policies will be updated to include alternative methods of documenting review and approval, such as an email to keep on file with the calculation. Person Responsible: Anthony Lopez, Chief Financial Officer Implementation Date: December 31, 2021
The Agency is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: None. Context: This condition occurred in 15 of 37 transactions selected for testing and represented three different employees. Cause: Procedures for the allocation of employee time in full compliance with the Uniform Guidance have not yet been fully implemented. Effect: Inaccurate payroll costs may be charged to federal programs if the Agency does not have procedures in place to monitor and record employee time devoted to federal programs. Repeat Finding: This finding is not a repeat finding. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee?s wages among specific activities or cost objectives if the employee woks on more than one federally funded program. Views of Responsible Officials: There is no disagreement with this finding.
Show full finding ▾Hide full finding ▴Major Program: Block Grants for Community Mental Health Services CDFA Number: 93.958 Federal Agency: U.S. Department of Health and Human Services Pass-Through: Illinois Department of Human Services Grantor Number: 22876440A Award Period: July 1, 2020 through June 30, 2021 Type of Finding: - Significant deficiency in Internal Control over Compliance. - Other Matters. Criteria: Uniform Guidance section 200.430(h)(8)(i) indicates that the standards for documentation of personnel expenses are such that (1) Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. Furthermore, subsection (viii) indicates: Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity are identified and entered into the records in a timely manner and (C) The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal award based on budget estimates. Condition: The Agency is allocating payroll costs to grants based upon budgeted amounts/percentages submitted to the funding agency and does not currently have a system for ensuring that the estimates used produce reasonable approximations of the activity actually performed. Questioned Costs: None. Context: This condition occurred in 15 of 37 transactions selected for testing and represented three different employees. Cause: Procedures for the allocation of employee time in full compliance with the Uniform Guidance have not yet been fully implemented. Effect: Inaccurate payroll costs may be charged to federal programs if the Agency does not have procedures in place to monitor and record employee time devoted to federal programs. Repeat Finding: This finding is not a repeat finding. Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated, and support the distribution of the employee?s wages among specific activities or cost objectives if the employee woks on more than one federally funded program. Views of Responsible Officials: There is no disagreement with this finding.
Management?s Response and Corrective Action Plan: Management will develop and implement a process whereby payroll costs for staff are supported by a system of internal controls which will provide reasonable assurance that the charges are accurate, allowable, and properly allocated. Person Responsible: Anthony Lopez, Chief Financial Officer Implementation Date: December 31, 2021
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