Corrective Action Plans

Finding 2022-046 CCDF Cluster, ALN 93.575 and 93.596 - Provider Health and Safety Requirements Management Views MDE and the Department of Licensing and Regulatory Affairs (LARA) agree with the finding. Planned Corrective Action For part a., the Child Care Licensing Bureau (CCLB) within LARA has updated its internal policies to clarify how it manages workflow operations, while ensuring CCLB meets federal compliance requirements. In June 2022, the Child Care Organizations Act was amended and the language in Michigan Compiled Law 722.113h was changed to allow for inspections to be conducted in accordance with the State plan. The State plan specifies the annual licensing inspection requirement, at 45 CFR 98.42(b)(2)(i)(B) for unannounced inspections, must be performed ?not less than annually.? According to guidance from the Federal Office of Child Care Region V, this does not mean that inspections must be performed at exact 12-month intervals; therefore, the lead agency has flexibility to schedule the inspections within each calendar year. CCLB has subsequently completed the annually required renewal and/or interim inspections for the licenses identified in the audit sample. The applicable health and safety requirements were reviewed during the inspections conducted. For part b., CCLB is currently creating a new licensing system that will automate letters being sent to licensed child care providers. The new system will generate and store inspection reports directly in the system instead of creating the report in a separate location and then manually moving it to other locations (network drive, SharePoint). This allows the inspection reports to be maintained digitally and be accessible at a later date, while ensuring proper documentation to support renewal inspections is maintained. For part c., in June 2022, CCLB implemented a new process to save all extension letters mailed in PDF format and stored in the current system to be accessed and available upon request. In addition, CCLB will incorporate refresher trainings regarding documentation and storage of inspection reports at its biannual all-staff trainings. The current process of documentation creation and storage will be phased out after the new licensing system is implemented and processes are no longer manually done by CCLB staff. Anticipated Completion Date a. Completed b. October 1, 2023 c. October 1, 2023 Responsible Individual(s) Emily Laidlaw, LARA Lisa Brewer-Walraven, MDE

Finding 2022-045 CCDF Cluster, ALN 93.575 and 93.596 - Child Care Stabilization Grants Management Views MDE agrees with the finding. MDE?s written procedures for the fall 2021 grant round required manual verification of the number of subsidy eligible children, increasing the risk for human error in documenting the appropriate number of subsidy eligible children on the provider?s application. The exceptions noted by the auditors were found in the fall 2021 grant round before procedures were modified in the spring of 2022. Planned Corrective Action MDE revised procedures in March 2022 for the spring 2022 grant round to prepopulate applications based on the number of subsidy eligible children directly from Bridges for specified pay periods, also allowing the providers to dispute the number of subsidy eligible children included in the prepopulated application. Anticipated Completion Date Completed Responsible Individual(s) Lisa Brewer-Walraven, MDE

Finding 2022-043 Aging Cluster, ALN 93.044, 93.045, and 93.053 - AIS FIRST User Access Management Views Although MDHHS thoroughly reviewed the access forms, MDHHS agrees that the final approval was not documented. Planned Corrective Action MDHHS has instructed staff that all forms must either contain a handwritten or electronic signature. MDHHS will also develop and implement an internal process for staff to ensure all future security forms contain the required approvals. Anticipated Completion Date July 1, 2023 Responsible Individual(s) Jen Hunt, MDHHS Cindy Masterson, MDHHS

View of responsible officials and planned corrective action The Association will conduct reconciliation of payroll allocation twice each year at the end of the second quarter and at the end of the third quarter to actual time recorded to ensure salary expense allocated to the federal awards is supported by actual time worked. A budget revision based on actuals will be implemented effective the fourth quarter.

Finding 2022-041 Homeowner Assistance Fund, ALN 21.026 - Eligibility Determinations Management Views MSHDA agrees with the finding. Planned Corrective Action For parts a. and b., MSHDA will implement further training of both Case Managers and Case Manager Assistants to address the cited items. This will include additional training on documentation of the homeowner?s hardship and detailing calculations in the case notes. For part c., MSHDA will provide additional training to staff making sure that all fields on the checklist are answered correctly. The checklist now has a system failsafe that all fields must have an answer prior to allowing the file to be conditionally approved in the online application portal. Anticipated Completion Date Completed Responsible Individual(s) Dawn Hengesbach, MSHDA Glenn Ross, MSHDA Raul Escobedo, MSHDA Krysta Smith, MSHDA

Finding 2022-039 Formula Grants for Rural Areas and Tribal Transit Program, ALN 20.509 - PTMS Security Management and Access Controls Management Views MDOT agrees with the finding. Planned Corrective Action MDOT?s Office of Enterprise Information Management (EIM) and Office of Passenger Transportation (OPT) will collaborate and provide oversight to ensure there is properly approved access for Public Transportation Management System (PTMS) users and that PTMS user access is reviewed semiannually for privileged accounts and/or annually for all other accounts. MDOT EIM and OPT will do this by reviewing security management and access control procedures and making any necessary updates, providing training on the process and documentation requirements, and designating a PTMS system security administrator(s) and back-up(s) as needed. Anticipated Completion Date August 1, 2023 Responsible Individual(s) Kyle Nelson, MDOT Andy Esch, MDOT OPT Business area system administrator(s)

Finding 2022-065 Unemployment Insurance, ALN 17.225 See Department of Labor and Economic Opportunity, Unemployment Insurance Agency, Unemployment Administration Fund, Report on Expenditure of Federal Awards, Year Ended September 30, 2022, Corrective Action Plan, Finding 2022-001.

Finding 2022-064 Unemployment Insurance, ALN 17.225 See Department of Labor and Economic Opportunity, Unemployment Insurance Agency, Unemployment Compensation Fund, Report on Expenditure of Federal Awards, Year Ended September 30, 2022, Corrective Action Plan, Finding 2022-003.

Finding 2022-062 Unemployment Insurance, ALN 17.225 See Department of Labor and Economic Opportunity, Unemployment Insurance Agency, Unemployment Compensation Fund, Report on Expenditure of Federal Awards, Year Ended September 30, 2022, Corrective Action Plan, Finding 2022-001.

Midland County Hospital District Single Audit Report FY2022 Corrective Action Plan Finding 2022-002 - Management agrees with the finding. We have developed policies and procedures over financial reporting to ensure patient service revenue includes Medicaid supplemental payments in all lost revenue that fall under the Federal assistance guidelines and ensure that total revenues are reconciled to the general ledger account balances and supporting information. net revenue was corrected for this issue dure the PRF Reporting Period #3 that was submitted September 29, 2022. Internal controls have been enacted and the Executive Director of Fiscal Services/Controller, Rebbecca Richey will be responsible to ensure all future periods will accurately reflect the lost revenues for the Hospital District. This corrective action plan was implemented on September 29, 2022.

Midland County Hospital District Single Audit Report FY2022 Corrective Action Plan Finding 2022-001 - Management agrees with the finding. Period 2 Provider Relief Fund (PRF) report included certain expenses that were also subsequently submitted to another funding source as a request for financial assistance. Even if these amounts were excluded, our expenses and lost revenue reported exceeded the amount of PRF funding received. These expenses were removed and corrected in the Period 4 PRF report submitted on March 30, 2023 by the Executive Director of Fiscal Services/Controller, Rebbecca Richey. The Executive Director of Fiscal Services/Controller, Rebbecca Richey will be responsible to ensure that future PRF reporting periods will not have overlapping funding source requests. The corrective action plan was implemented on March 30, 2023.

Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: David Felix, Chief Financial Officer Anticipated Completion Date: May 18, 2023 Planned Corrective Action: When the City received notification of the award of CSLFRF funds, the CFO and City Attorney reviewed the law and, based on how it was written, felt that we could apply it to the Fire Department?s salary expenses as over 80% of their calls are for emergency medical services, they are the first responders to a 911 EMS call, and they usually transport the patients to the hospital. Neither in the initial law documentation, nor in the initial application, was there an option to select a $10M de minimus revenue loss option. If this was available, the City would have chosen that up front. We completed the interim report based on data created by inquiries run in our General Ledger on the date we submitted the report. We believed the data was saved on our system, but we can not find the electronic copy of it. As adjustments have been made to the data since then, we are unable to recreate a report that matches the data on the interim report. We can get within $800, but not the exact amount. Going forward, we will ensure the data is saved and put in a place that it is easier to retrieve.

Contact Person Jill Blair Planned Corrective Action June 30, 2023 Planned Completion Date The Superintendent and business manager will work together to ensure all purchases match up with purchase orders and receipts.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Barbara Fought Contact Phone Number: 260-260-3191 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: West Noble School Corporation will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to member schools during the writing process of the IDEA 611 and 619 grants in order for each member school to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to each cooperative school. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the fiscal agent?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by all cooperative schools to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of a member school, will be paid directly by that member school. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to the member school. For any expenses for a category outside of salary and benefits, a member school will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, the member school must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer and NEISEC in order to complete the grant reimbursement requests. INDIANA STATE BOARD OF ACCOUNTS 29 TELEPHONE (260) 894-3191 - 5050 N US HIGHWAY 33 - LIGONIER, IN 46767-9606 - FAX (260) 894-3260 - 1-800-488-3191 - WNSC@WESTNOBLE.K12.IN.US At the end of the grant period, any school with remaining proportionate share money will be required to complete a waiver. As of this date (2/10/2023) DeKalb County Eastern CSD and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

2022-006 Special Tests and Provisions ? Internal Control and Compliance over Obligation, Expenditure, Payment Requirements City?s Corrective Action Plan: When invoices from subrecipients are received, they are reviewed thoroughly by staff. Documentation sent may range from a few pages to several hundred pages. The larger the packet submitted, the longer the review process. In the review process, it may be determined that the information sent is not sufficient to support the claim/amount for reimbursement. This initiates a back and forth between staff and the subrecipient that could take up to several weeks to resolve. The department continuously holds workshops with all vendors/subrecipients on best practices, and invoicing procedures to cut down on the time spent reviewing invoices. The department makes great effort in working with all subrecipients to expedite documentation review and payment process and continues to make great improvement in this area. Staff will also maintain records of any delays in processing as a result of insufficient documentation submitted by the subrecipient. Responsible Person: Julisa Villalobos (Program Admin), Raquel Chavarria (Fiscal) Expected Implementation Date: July 2023

Finding 2022-001 Federal Agency Name: U.S. Department of State Program Name: Refugee Admissions - Reception and Placement CFDA # 19.510 Finding Summary: In connection with the audit procedures performed over the Refugee Admission - Reception and Placement program, we noted instances when indirect cost calculations included an insignificant amount of ineligible costs. Responsible Individuals: Rose Olivas, Contract Compliance Director and Dawn Miera, Finance Director Corrective Action Plan: Contract Compliance and Finance will meet every time we receive a new type of grant. The two teams will go over allowable costs and which costs are allowed to be applied to the de minimis rate. All applicable spreadsheets will be updated separately for each new contract and training for billing preparers and reviewers will be ongoing. Anticipated Completion Date: Ongoing

2022-003 Accuracy of Federal Reports Throughout the Single Audit process, management discovered that the pandemic caused issues concerning the organization of cash disbursement receipts. In lieu of this finding, management has decided to develop and implement the following procedures: 1. Management will develop a written policy and procedure for a cloud-based document saving subscription, that will be utilized to scan and to upload all invoices/statements/bills/receipts into specific grantor, vendor, and program folders. 2. Management will create a unique email address strictly used as a landing site for pay request, vendor invoices, and receipts. 3. Management will train all current staff and provide training to new hires as a part of orientation in use of the system. 4. Management will monitor the site on a weekly basis, at which time request, payments and receipts will be allocated to the appropriate budget lines.

2022-002 Indirect Cost Allocation Methodology In order to comply with 2 CFR Part 200 subpart E, Appendix IV requirement that NPOs have a policy and procedure that meets the Uniform Guidance for cost principles with specific focus on charging indirect costs, Cleveland UMADAOP will execute the following. 1. Management will develop a written policy that establishes the method for allocating both direct and indirect costs. 2. Management will develop a procedure that outlines the day-to-day execution of the policy and facilitates the documentation to adherence to the policy. This will include identification of a specific role/person responsible for to maintain the policy and procedure. 3. Management will train employees who are responsible for the delivering the programs. In addition, Management will conduct periodic training for those employees that are responsible for the audit function which will include the Business Manager and Executive Director. 4. Management will develop and periodic audit schedule that will allow for monitoring of adherence to the policy and procedures. 5. Management will provide the policy, procedure and audit process to its retained accounting service provider to assist in the execution of the development of the policy, procedure, training and audit process. 6. Management will review allocations monthly and document changes, if applicable.

2022-003: Supporting Documentation Recommendation: We recommend the organization design controls to ensure an adequate review process is in place to review costs charged to grants are properly supported by documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will better enforce a policy that expenses must be sufficiently supported by documentation before payment is made. Name(s) of the contact person(s) responsible for corrective action: Joseph Ferlo, President & CEO Planned completion date for corrective action plan: June 30, 2023

FINDING 2022-001 ? Material Weakness and Material Noncompliance ? Budget Variances / Allowable Costs Corrective Action Plan: Analyze actual expenditures monthly, review the budget to actual numbers monthly and use data from this review to prepare a more accurate final budget revision. Responsible Parties: Rod Livingston, Business Manager Anticipated complete date of June 30, 2023 Rod Livingston Business Manager

Finding Reference Number: SA2022-001 Charging Eligible Program Costs to the Correct Category Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP2014 ? Name(s) of the contact person: Marsha Ley ? Corrective Action Plan: City Finance staff will scrutinize the costs charged to the Coronavirus State and Local Fiscal Recovery funds program and based on the expenditure description and support documents will select an appropriate category when coding the costs in the Project and Expenditure Report. When the cost cannot be classified under the following four categories: ?support public health?, ?address negative economic impacts?, ?premium pay to essential workers?, and ?investment in water, sewer and broadband infrastructure?, then Finance staff will include it under ?replace lost public sector revenue? category. Finance staff will notify Budget Team about the amount and the specific expenditures that were classified under lost revenue category, to ensure we are not exceeding allowable amount of $10 million assigned under the ?replace lost public sector revenue? category. Additionally Accounting Manager and Senior Accountant will review the expenditure categories selected on the Project and Expenditure Report. City staff will correct $249,999 taser certification plan expenditure category during the next reporting window on the Department of the Treasury reporting portal. ? Anticipated Completion Date: June 30, 2023

Compliance requirement ? Allowed Cost /Cost Principle Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the referenced transaction was below the "Micro-purchase" threshold and does not require a quotation. The FAR increase the "Micro-purchase" threshold for natural disasters and national emergencies, among others. The invoice amount of $5899 was a continuation of an initial project under this contractor which have the unique security passwords, IT protocols and other IT requirements for the uniform implementation of intelligent classrooms for remote distance education. Accordingly, the institution does not request a quote. The institution followed the referenced guidelines in the determining the allowability of costs. Additionally, an external consultant reviewed the transaction and costs prior to request reimbursement. The 2 CFR Part 200, Appendix XI Compliance Supplement guide, issued April 2022, makes referenced to the FAQ's and Other Guidance containing information pertinent to the compliance requirements described in the document and encouraged auditor to regularly check the HERF Websites for updated FAQ's and other pertinent guidance and reporting information. The institution followed those referenced FAQ's and guidelines, among other sound administration practices, in the use of the grants. The referenced Compliance Supplemental, under "Activities Allowed or Unallowed" states: "Institutions must demonstrate that costs incurred are allowable under the relevant statutory provision and consistent with the purpose of the ESF "to prevent, prepare for, and respond to coronavirus"". The institution used $5,899 paid to the guidelines as indicated to contractor, to continue enhancing the distance learning program in preventing the spread and contamination of the coronavirus among professors and students by enabling remote distance education. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 2. The institution does not concur with the auditor finding because of what is discussed in No 1 above. In the two cases mentioned, the cost quote may not agree with the invoice, because of some additional services requested, but the amount of the invoice was the correct amount paid and actual cost used to draw the HEERF funds. These invoices were for furniture and partitions divisions, to enable the remote distance education, avoiding physical contact of students and professors, to prevent, prepare for and respond to the COVID-19 emergency. Once again, these incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines. 3. The institution does not concur with the auditor finding. The referenced three cases may not have a specific or expressed "acknowledgement of receipt" statement, but the acknowledgement was validated by UTC management and with the signatures when the check was issued. Nevertheless, the costs incurred in these invoices were authorized and incompliance with HEERF program and ESF purpose. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 4. Institution does not, firmly, concurs with the auditor finding. This should not even be a finding because the institution strictly followed the FAQs published on March 19, 2021 to calculate the lost revenue and using a comparison between FY-20 and FY 21. That guideline described "Loss of Revenue" as "...those revenues and institution of higher education otherwise expected but were reduced or eliminated as a result of the novel coronavirus 2910 (COVID-2019) pandemic. As such, lost revenues can only be estimated". Nerveless, the result would have been relatively the same if we have use FY21 audited financials. Given the many factors and complexities of the unusual process, the institution followed a conservative approach and reduced those revenue items that have an increase between fiscal year from those with a loss of revenue. Therefore, the institution netted the potential amount of lost revenue to claim. Accordingly, the net amount resulted in $280,929.84. The potential loss of revenue amount could be greater but the institution decided to only claim the referenced estimated amount. These calculations and analysis were further discussed and evaluated by an officer of the Department of Education, with no recommendation on claiming a higher amount because the amount claimed was less than the estimated potential. The guideline indicates: "Reimbursement for lost revenue is allowable for the Institutional Portion program...". The institution claimed this loss of revenue amount from their institutional portion, complying with the HEERF guidelines and the authorized use of the funds. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. a. The institution used unaudited figures for FY21 because the audited financial statements were not completed at the time of the calculation. The institution revised the calculations with the audited financial statements, and the results were the same and the claimed estimated amount did not changed. Once again and in accordance with the guidelines, we were estimating the lost revenue with the data available at the moment. b. The institution followed the recommended HEERF guidelines for this complex and novel exercise. The institution considered under the analysis; those revenues otherwise expected but that were reduced as a result of the novel COVID-2019. The contributions as "Support Revenue" from related entities, which were a significant source of revenue for the institution, was not claimed as loss of revenue. The institution specifically claimed those lost revenue items as authorized in the guidelines. Therefore, once again, the UTC was in compliant with the lost revenue referenced guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. c. As explained above, the institution followed a conservative approach and only claimed a net amount of all lost revenue items. The institution only claimed those estimated revenue items, as authorized in the guideline, that suffer a loss between the two fiscal years considered in the evaluation. This was further evaluated by an officer of the DOE. As the guidelines described, since the lost revenues can only be estimated, the institution correctly, analyzed and calculated the best conservative/reasonable estimate of loss revenue with the available data at the moment. Even if we used the auditors' recommended items, the results would have been the same and no revenue item was claim out of the authorized or allowable costs from the guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. Actions Taken or Planned: The institution understands that the incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines and no further was required.

1. The institution does not agree, nor concurs, with the auditors on this finding because the institution used the reimbursement payment method. This method was the preferred one when the non-federal entity, as our institution, cannot meet the requirements in 2 CFR, section 200.305(b)(1) for advance payment and the federal awarding agency sets a specific condition for use of the reimbursement. Title 2 of the CFR Part 200.305(b)(1), establish among others: "The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part". Furthermore, 2 CFR Part 200.305(b)(3) states: "Reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. " Since our institution was not able to meet 2 CFR, section 200.305(b)(1), and the HEERF guidelines has specific condition on how to use the funds; we choose the reimbursement method in the execution of the funds. Our institution adopted all HEERF instructions and guidelines as their policies to comply with the HEERF requirements, in addition to the CFR's regulations. Below some of the guidelines, instructions ad FAQs we adopted followed" a. Higher Education Emergency Relief Fund III, Frequently Asked Questions, American Rescue Plan Act of 2021, Published May 11, 2021, Questions 7 and 11 updated May 24, 2021, Question 36 updated September 30, 2021 b. US Department of Education, Notice of Proposed Institutional Eligibility Criteria, February 25, 2021 c. Federal Register Notice of Interpretation (NOI), regarding Period of Allowable Expenses for Funds Administered under HEERF Program, March 22, 2021 d. HEERF Notice of Interpretation for Period of Allowable HEERF Expenses (March 22, 2021) e. HEERF Lost Revenue FAQs (March 19, 2021) f. HEERF Period of Allowable Expenses Grant Records Notice (March 19, 2021) g. HEERF Grant Program Auditing Requirements (March 8, 2021) h. CRRSAA HEERF II Section 314(a)(1) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) i. CRRSAA HEERF II Section 314(a)(2) Frequently Asked Questions (January 14, 2021) j. CRRSAA HEERF II Section 314(a)(4) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) k. HEERF I and HEERF II Comparison Fact Sheet (Published January 14, 2021 and Updated: March 19, 2021) 1. HEERF Lost Revenue FAQ's, Published March 19, 2021 m. HEERF II, Public and Private Nonprofit Institution (a)(2) Programs (CFDAs 84.425K), FAQ's, Published January 14, 2021 n. HEERF II, Proprietary Institution Grant Funds for Students (CFDA 84.425Q) ((a)(4) Program), FAQ's Published January 14, 2021, Updated March 19, 2021. o. HEERF II, Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F), FAQ's Published January 14, 2021, Updated March 19, 2021. p. CAREST Act HEERF Rollup FAQs (issued October 14, 2020 and revised November 20, 2020) q. CARES Act HEERF Round 3 FAQs (Issued October 14, 2020 and revised November 20, 2020) r. CARES Act HEERF Supplemental FAQs (Issued June 30, 2020 and revised September 08, 2020) s. CARES Act HEERF Student FAQ's (Issued May 15, 2020) t. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) u. CARES Act HEERF Emergency Financial Aid Grants to Students under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) v. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, Issued April 9, 2020 w. COVID-19 FAQ's for Title III, IV, V and VII Grantees, June 16, 2020 x. COVID-19 Letter to HEP Grantees on Flexibilities Available Under CARES Act Section 3518, July 1, 2020 2. The institution does not agree, nor concurs, with the auditors on this finding because, as we mention in number 1 above, the institution adopted and followed the federal award and HEERF guidelines in the execution of the funds. The HEER funds were provided during the special national emergency caused by COVID-19. The DOE and HEERF officials issued many written guidelines, instructions, and FAQ's (Frequently Asked Questions) documents, due to the nature and novel of the national emergency situation. The institution adopted, followed, and relied on the many referenced guidelines and exercise extreme judgment to ensure compliance with the federal requirements and use of the funds. The institution belief this referenced guidelines and instruction were very specific and sufficient to execute the use of the funds. All direct charges to federal awards were for allowable costs under the guidelines and instructions from the Department of Education. Some of the allowable costs were verified and validated by an officer of the Department of Education and reviewed by an independent consultant. 3. The institution concurs with the auditor finding. Actions Taken or Planned: The institution begins in addition to the adopted HEERF guidelines, instructions, and CFRs; to develop additional procurement policies and are in the process of completing those policies. The institution expects to have those completed by May 31, 2023.

Below is the corrective action plan for the federal compliance audit finding from our 21-22 financial audit report. FINDING #2022-002: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CORRECTIVE ACTION Staff were trained on timekeeping policies and procedures in the summer of 2022. The Director of State and Federal programs created the PowerPoint Presentation and presented it to staff. Additionally, the district?s website was updated to include the training presentation, training video, sample semi-annual and monthly forms, duty statements, work assignments, and frequently asked questions. The district expects to be in compliance with federal timekeeping requirements for the next audit cycle.

2022-001 Significant Deficiency: Internal control over maintenance of documentation of procedures performed Planned Corrective Action: Management will implement additional procedures to maintain documentation of the review and approval of expenses allocated to federal programs. Anticipated Completion Date: March 31, 2023 Responsible Party: Hasan Suzuk (Executive Director)