Corrective Action Plans

SPECIAL TESTS AND PROVISIONS – USING A SERVICER TO DELIVER TITLE IV CREDIT BALANCES TO A CARD OR OTHER ACCESS DEVICE Bluefield State University, Blueridge Community & Technical College, Concord University, Mountwest Community and Technical College, Shepherd University, West Virginia Northern Community College, and West Virginia University at Parkersburg Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93.342, 93.364 Bluefield State University (BSU) response BSU will submit the URL of their contract with their third-party servicer and cost information to the U.S. Department of Education for their publication in the Cash Management Contracts Database by Friday, February 23, 2024. BSU will also implement a detailed due diligence review over the fees assessed by the third-party servicer of Title IV credit balances. Blueridge Community & Technical College (BRCTC) response We acknowledge that BRCTC did not have internal controls in place to review the contract with our third-party servicer of Title IV credit balances or obtain and review the third-party servicer’s Title IV compliance audit to ensure compliance with federal regulations. By February 2024, documents will be requested and an annual due diligence review will be performed and documented of the third-party servicer contract and compliance audit as well as review of fees assessed by the third-party servicer. Concord University (CU) response CU agrees with this finding and due to changes in personnel, this regulation was not followed. CU will review and document the review of the Cash Management Database annually to ensure the link is posted. CU will review and document the review of other financial institutions charges compared against BankMobile’s fees annually. CU will annually review the servicer’s SOC report. CU will review BankMobile’s report, specifically looking for instances of noncompliance and internal control breaches. This will be documented annually. Mountwest Community and Technical College (MCTC) response Effective February 2024, MCTC will implement a review process to be conducted on an annual or monthly basis, as applicable, of all accounts opened with the Servicer during the specified timeframe. The "Activation & Preferences Report" available to management through the Servicers Administrator portal will be used to provide the data for review by management. The review process will consist of the following: • A request made of the servicer to provide a report of accounts opened with date/time stamp of consent to opening. Frequency: Monthly • Review of "Activation & Preferences Report" validated against Servicer "Accounts Opened" report. Frequency: Monthly • Generate a follow-up email to applicable students confirming the opening of the Servicer Account which will include an attachment of the Servicer "Terms and Conditions" and "Fee Schedules". Frequency: Monthly • Review the Servicers' Client Contract and Profile site for accuracy and completeness of information. Frequency: Annually • Review the Servicers' System and Organization Controls (SOC) and Compliance audits. Frequency: Annually • Management will incorporate as part of its "Due Diligence and Attestation" copies of comparable banking institution fee schedules that are date/time stamped to serve as evidence of review. Shepherd University (SU) response By April 2024, SU will develop and maintain a checklist that will be periodically reviewed and signed off related to this finding, specifically: Annually, SU will be submitting the URL to the Department of Education related to the contracts between SU and BankMobile, reviewing compliance audits and SOC reports for BankMobile, recording areas of risk, and noting ways to mitigate the potential risk moving forward. West Virginia Northern Community College (WVNCC) response Beginning June 2024, during the annual review meeting between WVNCC and BankMobile (the servicer that delivers Title IV credit balances to students), WVNCC will obtain a copy of the BankMobile compliance audit. This will be kept on file within the Business Office for reference if needed. In addition, the budget committee will review annual the fees charged by BankMobile and attempt to compare them to other providers of similar services. West Virginia University at Parkersburg (WVU-P) response WVU-P has submitted a URL to the US Department of Education of our contract and cost information with our third-party servicer. This submission should correct this portion of the finding although it was done after the end of the fiscal year under audit but serves to correct the finding in subsequent periods. WVU-P will ensure compliance with the remaining items noted by creating a written internal control policy requiring the following: • Verification of the required submission of the third-party contract with the Department of Education. • Documentation of a due diligence review of the fees assessed by the third-party servicer. • Obtain a copy of the annual compliance examination of the Title IV Programs. The 2022 report dated June 29, 2023, was received and reviewed by us for compliance with eligibility, systems, and internal controls, disbursements, Return of Title IV funds, and administrative requirements. • Obtain a list of students whose refunds were disbursed by the third-party vendor and cross-reference it with a list of the students processed and sent to the third-party vendor by WVU-P. For those students who elected to open a checking account, WVU-P will review supporting documentation to indicate that the student gave proper consent. These policies and procedures will be effective February 2024.

INTERNAL CONTROLS OVER CASH MANAGEMENT Bluefield State University, Fairmont State University, Mountwest Community and Technical College, and West Virginia Northern Community College Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Bluefield State University (BSU) response By June 2024, BSU will ensure that if a drawdown approval occurs in person with the Director of Financial Aid, the approval signature will be obtained during the meeting. Fairmont State University (FSU) response Effective February 2023, FSU has added a second level review control and it was put into place to address the inadequate internal controls identified. Mountwest Community and Technical College (MCTC) response Effective February 2024, MCTC will make the appropriate effort to obtain "inked" approvals prior to initiating drawdown requests through G5/G6 to serve as proof of double verification. However, MCTC does note that single reviews are completed prior to any drawdown request as evident of the relationship between the requestor and initiator of the drawdown in G5/G6 to ensure accuracy and completeness. West Virginia Northern Community College (WVNCC) response Beginning April 1st, 2024, WVNCC will establish an electronic repository specifically designated for the retention of evidence that a review and approval of all drawdown requests occur. The repository will be reviewed internally on a quarterly basis by the CFO and any anomalies will immediately be brought to the attention of staff and resolved.

CORRECTIVE ACTION PLAN Hermitage Homes for Elderly, Inc., Stanford Place Apartments respectfully submits the following corrective action plan for the year ended September 30, 2023. Purkey, Carter, Compton, Swann, & Carter, PLLC P.O. Box 727 Morristown, Tennessee 37815 Audit period: October 1, 2022 - September 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAMS AUDITS Finding No. 2023 – 001: Failure to remit excess residual receipts to HUD by the date required, ALN #14.157 The Project did not remit excess residual receipts in the amount of $525 to HUD by the date required. Criteria: Excess residual receipts are required to be remitted to HUD by the PRAC renewal of expiration date. Cause of Condition: The management agent did not have systems in place to ensure timely remittance of the excess residual receipts funds. Recommendation: Auditor recommends management remit the excess residual receipts in the amount of $525 to HUD and implement systems to ensure future excess residual receipts are either remitted to HUD or requested to be withdrawn for approved expenses no later than the respective PRAC renewal or expiration date. Action Taken: Excess residual receipts in the amount of $525 have been remitted to HUD. The Program Director and Assistant Program Director will track any excess residual receipts that need to be remitted against the contract renewal date. If the Accounting Manager has not remitted the funds or has not submitted a request to withdraw the funds for an approved expense before the Project’s contract renewal submission is due (120 days before the contract renewal date), the Program Director or Assistant Program Director will ensure the Form HUD-9250 to remit the excess residual receipts to HUD is submitted at that time. If the Department of Housing and Urban Development has questions regarding this plan, please call Megan Barnard at 423-587-4500. Sincerely yours, Megan Barnard Executive Director Douglas-Cherokee Economic Authority, Inc.

CORRECTIVE ACTION PLAN Aztex Homes for Elderly, Inc., Pleasant Hill Apartments respectfully submits the following corrective action plan for the year ended September 30, 2023. Purkey, Carter, Compton, Swann, & Carter, PLLC P.O. Box 727 Morristown, Tennessee 37815 Audit period: October 1, 2022 - September 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAMS AUDITS Finding No. 2023 – 001: Failure to remit excess residual receipts to HUD by the date required, ALN #14.157 The Project did not remit excess residual receipts in the amount of $731 to HUD by the date required. Criteria: Excess residual receipts are required to be remitted to HUD by the PRAC renewal of expiration date. Cause of Condition: The management agent did not have systems in place to ensure timely remittance of the excess residual receipts funds. Recommendation: Auditor recommends management remit the excess residual receipts in the amount of $731 to HUD and implement systems to ensure future excess residual receipts are either remitted to HUD or requested to be withdrawn for approved expenses no later than the respective PRAC renewal or expiration date. Action Taken: Excess residual receipts in the amount of $731 have been remitted to HUD. The Program Director and Assistant Program Director will track any excess residual receipts that need to be remitted against the contract renewal date. If the Accounting Manager has not remitted the funds or has not submitted a request to withdraw the funds for an approved expense before the Project’s contract renewal submission is due (120 days before the contract renewal date), the Program Director or Assistant Program Director will ensure the Form HUD-9250 to remit the excess residual receipts to HUD is submitted at that time. If the Department of Housing and Urban Development has questions regarding this plan, please call Megan Barnard at 423-587-4500. Sincerely yours, Megan Barnard Executive Director Douglas-Cherokee Economic Authority, Inc.

FINDING 2023-006 Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: The School Corporation did not submit annual reports in a timely manner during the first year of the audit period. Reimbursement requests included invoices which had been reimbursed previously and some request did not agree with supporting documentation. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are submitted timely and supporting documentation is used and retained for reimbursement requests. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reporting – The Treasurer and Deputy Treasurer will review and approve all grant reporting with Komputrol reports and grant approval. All deadlines will be submitted prior to due dates. The Superintendent, Treasurer, Deputy-Treasurer and/or Grant Writer will review all grant reimbursement requests prior to submission for accuracy. Anticipated Completion Date: Completed March 2023 – February 2024 INDIANA STATE

February 28, 2024 Audit Response to Finding 2023-001 to Uniform Guidance Audit - Enrollment reporting to National Student Clearinghouse Analysis: During the spring 2023 graduate only submission to the National Student Clearinghouse (NSC), Robert Morris University (University) incorrectly queried the wrong student population of graduates from Banner (student information system) as a result of human error, which resulted in the untimely reporting of spring 2023 graduates to the NSC. There were also exceptions found attributable to off-cycle graduates who had degrees conferred but the University had not updated their status to “graduated” in the NSC in a timely manner. Upon further review, the University determined extenuating circumstances (i.e. completion of all paperwork, and assignments, incomplete grade(s) existed for these students’ and their graduation date fell outside of the normal graduation date of their peers for that semester cohort. Since the University only typically submits graduate only files to the NSC three times a year (Spring, Summer, and Fall), these students were not reported to the NSC in a timely manner. Based on the findings noted above - and in the prior year Uniform Guidance audit, Robert Morris University (University) voluntarily undertook an exercise to self-audit the accuracy of all clearinghouse data submissions dating back to the implementation of the Banner Student Information System (SIS) in Fall 2021. At the conclusion of the self-audit, 127 students were found to have records of enrollment at the University, but were excluded from clearinghouse submissions during the period (July 2021 - November 2023) under self-audit. The University determined the omissions to be a combination of several factors; including, initial limitations in reporting capabilities as result of the Banner SIS conversion in Fall 2021 and overall process regarding review and submission of clearinghouse data. Response: Graduate Reporting The spring 2023 graduate file submission error was identified internally by RMU in July 2023 and all spring 2023 graduates were reported to the NSC at that time - albeit untimely. The University deemed this to be an isolated incident. For the off-cycle graduate exceptions, the University is increasing the frequency of submissions to the NSC to include mid-term submissions in addition to the end of semester submissions as usual practice. By increasing the frequency of submissions, the University believes this will capture the off-cycle graduates in a timely manner. Expected completion prior to May 31, 2024. Lookback Analysis As of the date of this letter, RMU has corrected all but 15 of the 127 errors and is working directly with representatives from the National Student Clearinghouse (NSC) and National Student Loan Data System (NSLDS) to resolve the remaining 15 errors as soon as possible. Expected completion prior to May 31, 2024. As a result of the findings noted above, the University’s Office of Data and Analytics (UDA) independently reviews all NSC files/extractions (graduate only and monthly enrollment reporting) from Banner prior to submission to the NSC. A member of UDA cross references the NSC file’s/extractions with other Banner student enrollment information for that time period to make sure the file is complete and accurate. The Registrar only submits files to the NSC after approval by the UDA and reports submission results back to the UDA after they are processed by the NSC. Conclusion: The University deems that the correction action steps outlined above will sufficiently resolve the findings and prevent any future instances of untimely reporting of enrollment and graduate data to the NSC and the NSLDS. Regards, Keith A. Roeper Chief Financial Officer and Vice President for Business Affairs Responsible Party

Corrective Action Planned: Due to insufficient staffing, review of reconciliations was inconsistent. New permanent staff have been hired in all critical business office roles so that reconciliations are now regularly reviewed by a second staff member. Name(s) of Contact Person(s) Responsible for Corrective Action: Brian Braden, Controller Anticipated Completion Date: February 12, 2024

Finding 2023-002 IV-D Cooperation with Child Support Name of contact person: Corrective Action: Proposed completion date: Finding 2023-003 Inaccurate Resources Entry Name of contact person: For the Year Ended June 30, 2023 Corrective Action Plan Section III - Federal Award Findings and Questioned Costs Section II - Financial Statement Findings July 1, 2023 Stephen McNally, Finance Director The Finance Department will attempt to make all necessary transfers of funds between Forfeiture accounts in the current period. However, this correction notification from US Treasury was not sent to the Finance department until after the reporting period in which the transaction took place. Kim Grissom, Family and Children's Medicaid Supervisor and Shelia Morton, Family and Children's Medicaid Supervisor Family and Children Medicaid Lead Workers and Supervisors will conduct second-party reviews on caseworkers. The supervisors will go over errors found by second parties during their team monthly meetings. The supervisors will hold individual performance meetings if cited for the same error. Lead Workers and Supervisors will conduct 100% second parties on caseworkers in their probationary period of 6 months unless extended by Supervisors due to performance and 5 applications and redeterminations on all other caseworkers per month. The supervisors will also ensure that caseworkers are up to date on changes that may come up and ensure that they give proper instruction when needed. Supervisors and/or Leadworkers will conduct monthly meetings which including mini trainings on errors found in second parties. Refresher trainings will be held quarterly for indept training regarding policy areas in which the Supervisors identify the need for. The Human Service Planner Evaluator will help track of repetitive errors and suggest trainnings needed to Supervisors to ensure that policy/procedures are being implemmented accordingly. The Supervisors will schedule and hold a meeting to inform the Program Administrator of the errors found on second-party findings and provide a copy of the individual’s performance meeting held with the worker on any repetitive errors. Supervisors and or Lead workers will send training invites to Program Administrator, Staff Development, and Human Services Planner Evaluator, for monthly and at quarterly refresher trainings. To ensure that the caseworkers do not repeat these errors, the following will happen: policy training was held on November 30, 2022, for Family and Children Medicaid section MA- 3365. Documentation Template was last updated on November 3, 2023, which includes IVReferral reminder. Family and Children meeting will be held by November 30, 2023.

Condition: The School District’s controls did not prevent or detect and correct, in a timely manner, an employee’s time being charged to the Special Education Cluster that did not have adequate documentation. Additionally, the School District’s controls did not prevent or detect and correct, in a timely manner, updates to an employee status upon termination for employees charged to the Special Education Cluster and the Education Stabilization Fund. Planned Corrective Action: The School District concurs with the audit finding. The District has worked to strengthen internal controls to eliminate errors. The District will review its internal controls and provide additional training to staff. The School District is in the process of filling a Project Manager role on the Payroll Team who will be responsible for reviewing employee terminations and identifying potential overpayments. Until the role is filled, the Senior Director of Payroll and CFO will review employee exits quarterly to identify any potential overpayments and move funds to the general fund. New procedures for employee exit were rolled out in July in an effort to improve timely exiting of employees. Contact person responsible for corrective action: Jeremy Vidito, Chief Financial Officer Anticipated Completion Date: June 30, 2024

Due to a turnover in the office of Controller, the Interim Controller drew down SIP grant funds for qualified purchases prior to the funds being disbursed, which is not the normal University procedure. The Interim Controller is no longer with the University, and the current administration has returned to the established University practice of not drawing down grant funds until payments have been made to vendors for grant purchases.

Specific Steps to Correct: Management has already corrected how it records interest earned on CDBG cash on-hand. Management will review program income on-hand throughout the year to assess its responsibility to return funds to the line of credit. Anticipated Completion Date: Will incorporate the auditor's recommendation into year end processing for fiscal year 2024, which will occur around June 30, 2024. Name(s) and Title(s) of Responsible Person(s): James Wood, Finance Director

Island Park UFSD Corrective Action Plan in Response to Single Audit Report For The Fiscal Year Ended June 30, 2023 CURRENT YEAR FINDINGS AND RECOMMENDATIONS Federal Award Findings And Questioned Costs Finding # 2023-001 U.S. Department of Education-Passed-through the NYS Education Department Finding: During our audit, we noted that certain figures used as inputs to the annual performance report could not be reconciled to supporting documentation and therefore, we were unable to substantiate certain amounts reported to NYSED. The review of the annual performance report was not performed at an appropriate level of precision such that the incorrect and/or incomplete information presented would be identified and corrected prior to submission to NYSED. Recommendation: We recommend that the District reevaluate the system of internal control for the review and approval of the annual performance report prior to submission to NYSED, including the reconciliation of amounts included within the support to appropriate supporting documentation. District Response: The District will ensure that, prior to submission to NYSED, the annual performance report will be reviewed by an individual other than the preparer and reconciled to the supporting documentation in order to confirm the completeness and accuracy of information reported. Mr. Salvatore Carambia, Business Administrator, is the person responsible for the planned corrective action. The completion date for this action is February 16th, 2024.

Common Origination and Disbursement (C OD) Reporting Planned Corrective Action: We are working to put a double check process in place, and to understand which step in the internal aid process has the opportunity to ensure this date exactly matches the COD disbursement date. The team had not realized that the date must match exactly. We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of our disbursing of Title IV funds. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024

The Greater Washington Jewish Coalition Against Domestic Abuse (JCADA) is committed to a corrective action plan for the late reports we have submitted in the past to our granting agencies. Weezie Lauher, JCADA Grant Manager, will submit all required grant reports five (5) days before due dates to Amanda Katz, Executive Director for review and submission. We affirm that JCADA will submit grant reports timely as prescribed by each grant. The effective date is January 1, 2024.

The University’s Director of Financial Compliance will implement an additional step to email the University’s Controller for approval prior to drawdown of federal funds and will follow up with a screenshot of the actual drawdown for validation. Anticipated Completion Date: September 18, 2023 Person Responsible for Corrective action: Karen Robbins, Director of Financial Compliance Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu

Finding: 2023-001 Condition: In a sample of three of nine cash draw downs from PMS, each of the three transactions tested were drawn in a proportion in excess of the Federal Percentage Share as required by the terms and conditions of the award. Individual(s) Responsible for Corrective Action: Elidoro Primero, CFO Planned Corrective Action: Management will provide additional training to individuals for monitoring grant compliance, reinforcing the importance of grant provisions and implementing a system of processes and controls for tracking compliance with all specific grant terms and conditions. Management will also solicit guidance/best practice from designated HRSA grant management officer for voluntary correction action steps to resolve finding. Anticipated Completion Date: June 30, 2024

Condition: The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. There were three errors identified that attributed to this finding. 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates Planned Corrective Action: The errors have been corrected and the university has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings as well as all required cash management compliance issues. Contact person responsible for corrective action: Brian Bell, Director Student Account Services Anticipated Completion Date: 10/31/2023

The Staff Accountant, Kyle Winton, will ensure that the PSERS reimbursements are properly deducted from federal grant allocations by reconciling with the quarterly Act 29 Reimbursement report that identifies federally funded staff through the CSIU payroll module. The appropriate aide ratio from the Act 29 Employer Salary Report will be used to calculate the correct retirement amount based on the employees’ work history.

Finding 2023-003 Program: Federal Family Education Loans CFDA No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management University’s Response: The University has continued to ensure that these funds are not commingled and has protected them from being spent. Due to the discrepancies identified, it is necessary to review and compare each student's loan history between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation process has proven to be tedious but necessary to identify funds that were never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: With additional assistance, the University made further progress in identifying records with discrepancies. We reviewed the types of discrepancies identified with the DoE and, with their guidance, are detailing the individual student accounts to which funds need to be returned to correct the students' NSLDS loan records. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services Anticipated Completion Date: May 31, 2024

Finding 2023-001 Planned Corrective Action: The District’s management will evaluate the grant monitoring process and ensure all reporting for federal grant requirements is accurate and timely, with a planned implementation date by the Financial Officer of December 15, 2023.

The Home contacted the Office of Refugee Resettlement (ORR) and was instructed to keep the funds and submit a carry-over request for these funds.

FINDING 2023-002 Finding Subject: Emergency Connectivity Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The School Corporation completed reimbursement requests and submitted them online; however, there was no evidence of an oversight or review process to ensure that the reimbursement requests were for allowable activities, allowable costs, and within the period of performance. Contact Person Responsible for Corrective Action: Derek Coulombe, Director of Technology Contact Phone Number and Email Address: (317) 856-5265; dcoulombe@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The School Corporation will develop procedures to ensure disbursement requests are printed out and a representative from the Business Department documents review of them for allowable activity before final submission. Anticipated Completion Date: March 1, 2024

Finding #2023-002 Section 202 Supportive Housing for the Elderly – (Capital Advance) – AL No. 14.157 Recommendation: We recommend that management should deposit the required funds in the future into the residual receipts reserve account within the 90 day requirement. Action taken: St. David’s Housing Development Fund Company, Inc. agrees with the auditor’s recommendation and will implement procedures to ensure timely and accurate deposits in the future. For questions regarding this corrective action plan, please contact Kyle Lyskawa, Chief Financial Officer, at (315)424-1821.

Finding 2023-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Food Service Manager or Director of Food Service will prepare the reimbursement claim and the Director of Business Affairs and HR or Treasurer will review and initial the claims. This will ensure the accuracy of the reimbursement claim. Anticipated Completion Date: This Corrective Action was put into place in September 2022 following our prior audit. The Claim that was not signed for this Audit was from October 2021.

Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Action Taken: One City Schools is in the process of identifying a required training program for all staff members involved in the submission, review and/or approval of the schedule of expenditures of federal awards. This includes One City’s Executive Chef, Executive Director of K-8, COO and VP of Government Relations (who oversees compliance). Designated staff will take advantage of all DPI-provided training seminars and resources available, and we will track attendance of relevant staff members. This process will be in place by June, 2024.