Corrective Action Plans

The Financial Aid Office concurs with the audit finding of the monthly SAS reconciliation requirement to be done internally was not in compliance. Whittier College Financial Aid Staff failed to send the SAS files monthly to our Accounting Department for reconciliation. As of September 2023, Whittier College Financial Aid Office has calendared a monthly reconciliation report to be sent to the Accounting Department to meet the guidelines set forth by the Department of Education. This reconciliation report will be sent monthly through out the calendar year. In the summer months of June and July we may not have any funds to reconcile, however, a report will be sent regardless for compliance. Person Responsible: Jesse Marquez, Associate Director and Information Specialist of Financial Aid Anticipated Completion Date: Implemented as of September 2023

FINDING 2023-003 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): SY22, SY23 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Eligibility, Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP), Special Tests and Provisions - Non-Profit School Food Service Accounts Audit Finding: Material Weakness Condition and Context The School Corporation had not established effective internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. Eligibility The School Corporation's policy is to have the Treasurer review and initial paper applications processed by the individual school treasurers to ensure that the eligibility determination was correct. However, six of the ten applications tested lacked documentation of this review. In addition, there was no internal control in place over applications submitted online. INDIANA STATE BOARD OF ACCOUNTS 18 BORDEN-HENRYVILLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) The Treasurer performed the verification of free and reduced price applications without a documented review or oversight process in place to ensure that applications selected for verification were in compliance with requirements related to the program. Special Tests and Provisions - Non-Profit School Food Service Accounts The School Corporation did not have an internal control in place to ensure that reimbursements for meals served were properly credited to the School Lunch fund. The lack of internal controls for Eligibility and Special Tests and Provisions - Verification of Free and Reduced Price Applications (NSLP) was isolated to the second year of the audit period. The lack of internal controls over Special Tests and Provisions - School Food Accounts was systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls was not designed by management of the School Corporation, which would include segregation of key functions. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 19 BORDEN-HENRYVILLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that management of the School Corporation design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING NO. 2023-002 - TRANSFER OF FUNDS BEYOND THE REQUIRED TIME LIMITS CONDITION During our field work in the cash management area, we noted funds that were requested to G-5 but not disbursed by UPM to minimize the time elapsing between the transfer of funds and disbursement as follows: Descriotion Dates Amount Funds received from G-5 on June 8, 2022 6/8/2022 $610,710.35 Funds disbursed during 2022-2023 Fiscal vear 2022-23 (525,362.27) Available balance from funds received in 6/8/2022 6/30/2023 $75,348.08 Funds received from G-5 on June 22, 2023 6/22/2023 $319,251.71 Funds disbursed at the end of fiscal year 2022- 2023 6/30/2023 (45,000) Available balance from funds received in 6/22/2023 6/30/2023 $274,251.71 RECOMMENDATION The University should reinforce the procedures the draw down of funds to comply with the regulation applicable for the transfer of funds through the G-5 system. Corrective Action Plan: "Corrective Action Plan: UPM acknowledges that recommendation 2023-002 by Mr. Santiago is correct; however, the Dean of Administration and Finance, who assumed this position on February 21, 2023, wishes to explain the reasons behind this occurrence. UPM managed the HEERF funds without prior experience and knowledge of their administration. The officials at that time were unclear about the rules and procedures for managing these funds because the contract details were not received by UPM, preventing them from establishing spending and disbursement policies. Additionally, UPM was without a president for 6 months, and after appointing a president, it operated for approximately a year without a permanent Dean of Administration and Finance. The employees in the Dean's office were not authorized for this level of decision-making, while time continued to pass. Furthermore, there were several changes in the members of our Higher Education Council. As soon as the Dean of Administration and Finance was appointed, consultations with the president were held to make decisions regarding the disbursement and expenses of these funds, which were implemented in June 2023. As a corrective action plan for the future, we will review all certifications related to federal funds management, prepare a comprehensive folder, and administer these funds while adhering to each of these measures. We will proactively identify our needs and align them with the award, clearly defining each process and protocol with the intention of compliance." During the last fiscal year. the Council of Theological Education approved new regulations for: 1. Regulation for the Acquisition of Equipment, Materials, and Non-Personal Services at UPM. 2. Regulation for the Administration of Movable Property (Equipment) at the UPM. hese new regulations complement the existing rules to ensure the integrity, preservation, accessibility, legibility, and legality of our financial actions. We will continue to work together to standardize our processes and address any non-compliance on our part.

Management agrees with the finding. The Organization will enhance internal control policies to ensure all employee timecards are reviewed and approved prior to payment to ensure that all payments are necessary and correct.

Management agrees with the finding. There was turnover in staff and the prior CFO did not keep a record of his review over cash management and reporting. In the future, management will ensure that documentation of the approval process for reimbursement and reporting is kept.

EF is strictly enforcing a policy that AMEX receipts from staff are due three days after the statement is posted. With this clear policy in place, the period end is accurate with drawdowns reflecting the activity incurred in that period. All supporting schedules are being saved.

Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Federal Financial Assistance Listing #93.498 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Costs Principles and Reporting Finding Summary: Winneshiek Medical Center claimed expenses that had been reimbursed by another source. The Medical Center is a critical access hospital which means that a portion of their expenditures are covered by Medicare. The Medical Center did not decrease their expenses for the portion that was reimbursed by Medicare. The Medical Center’s special report submitted to the Department of Health and Human Services for Period 4 TIN #420680487 reported these expenses that were reimbursed by other sources which made the report inaccurate as well. Responsible Individuals: Ben Stevens, CFO Corrective Action Plan: Management agrees with the finding. The Medical Center created a “Federal Reporting Review Policy” dated March 9, 2023 as a result of working with HRSA and the 2021FY audit. This policy was approved and is now in process. Anticipated Completion Date: No future reports are anticipated to be filed under this program.

CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Finding There is no disagreement with the finding. 2. Actions Planned in Response to Finding The District's internal controls related to payroll will continue to improve. 3. Official Responsible for Ensuring CAP Linh Phan, Manager, Accounting and Finance, Grants Accounting 4. Planned Completion Date for CAP The planned completion date for the CAP is June 30, 2024. 5. Plan to Monitor Completion of CAP The Finance Department management will be monitoring the corrective action plan.

CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Finding There is no disagreement with the finding. 2. Actions Planned in Response to Finding The District's internal controls related to payroll will continue to improve. 3. Official Responsible for Ensuring CAP Linh Phan, Manager, Accounting and Finance, Grants Accounting 4. Planned Completion Date for CAP The planned completion date for the CAP is June 30, 2024. 5. Plan to Monitor Completion of CAP The Finance Department management will be monitoring the corrective action plan.

Finding 2023-003 – Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Laura Hubinger, CFO-Greater Clark County Schools lhubinger@gccschools.com Beverly Woodring, GM Student Nutrition-Aramark bwoodring@gccschools.com Jennifer Cato, Deputy Treasurer-Greater Clark County Schools jcato@gccschools.com Contact Phone Number: 812-288-4802 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The FSMC Food Service Director will ensure that they obtain a secondary review signature by the Deputy Treasurer to ensure accuracy of the reimbursement claim. Anticipated Completion Date: Immediately

Contact Person: Traci Veyl, Associate VP of Student Financial Services Corrective Action: The College acknowledges the findings. Corrective action has occurred. The Financial Aid Office has updated policies and procedures to include a new report of all federal student aid to be sent to the Finance Office after any disbursements or adjustments of student aid. This report will include Direct Loans, Pell and SEOG. Anticipated Completion Date: March 11, 2024

Contact Person - Brenda Sem Corrective Action Plan - Minnkota Power Cooperative, Inc. will implement policies and procedures that will ensure all federal funds that Minnkota Power Cooperative, Inc. is entitled to is being received and reports are reviewed and approved before they are submitted. Completion Date- Immediately

The District incorrectly reported patient revenue figures submitted via the HHS Provider Relief Fund (PRF) portal. Personnel Responsible for Corrective Action: Mike Leone, Chief Financial Officer Anticipated Completion Date: Change is in process and full adoption is anticipated by June 30, 2024 Corrective Action Plan: While this did not lead to any additional lost revenues being made available to the District, the District is going to conduct detailed reviews to ensure reported amounts are properly tied out to the audited financial statements.

Significant Deficiency 2023-001. Allowable Costs/Cost Principles United States Federal Communications Commission: COVID-19: Emergency Connectivity Fund Program ALN: 32.009 Condition: Subpart E, 2 CFR §200.404 of the Uniform guidance requires that any monies charged to the Emergency Connectivity Fund Program be reasonable costs allowable under the approved grant application, including the grant requirement that reimbursed costs for devices or equipment are only eligible for a one-per user limitation. During the current year, we noted that the District purchased and was reimbursed for additional devices or equipment beyond the unmet need and the one per-user limitation. Planned Corrective Action: The District agrees with the recommendation, and the Assistant Superintendent for Finance and Management Services will contact the federal agency to determine the appropriate action for the reimbursement of the excess funds received. Responsible Contact Person: Jennifer Segui Assistant Superintendent for Finance & Operations South Country Central School District 189 N. Dunton Avenue East Patchogue, NY 11772 Anticipated Completion Date: June 30, 2024

Condition - The School District incorrectly reported expenditures on its reimbursement requests and final expenditures reports to the State. This resulted in the School District not providing accurate information to the State that is used to determine if grant money was expended in accordance with the original or amended grant application. Recommendation - That the School District should review their internal controls and establish procedures to ensure that reports comply with 2 CFR section 200.328 and ensure proper reporting by ESSER Subgrant fund, expenditure category, and object code. Method of Implementation - Accounts Payable will review all purchase orders (P.O.s) on a monthly basis for accuracy, using a checklist provided by the Business Administrator. Person Responsible for Implementation - AP Specialist / ABA / SBA Implementation Date - April 1, 2024

The newly hired CFO will update the policies and procedures and oversee the Finance Department and will develop procedures to ensure there are proper segregation of duties over key cycles, taking into consideration the size and complexity of the Organization. These procedures will strengthen the expense and accounts payable processes to ensure compliance with the provisions of 2 CFR § 200.302.

As a result of the growth in the Organization and corresponding growth in the number and complexity of its state and federal contracts, the Organization has hired an experienced CFO to ensure the Organization remains in compliance with federal and state laws and regulations related to its contracts. The newly hired CFO will seek to strengthen internal controls by updating written internal control and compliance policies and procedures and will ensure that the finance department adheres to the policies in place. The updated policies and procedures will develop controls to prevent the any further overbillings from occurring. These updated controls and policies, in part, will include developing a plan to track monthly revenues against expenses for its cost reimbursement contracts and to ensure that actual indirect costs billed for do not exceed actual indirect/overhead costs which could result in overbillings. The updated internal control and compliance policies and procedures will be in place to comply with 2 CFR Part 200 Subpart D § 200.303 and to comply with cost principles set forth in 2 CFR Part 200 Subpart E.

The System has contacted the Texas Department of Transportation requesting instructions on refunding the amounts. In addition, they will implement new procedures and controls surrounding the calculation of their request for reimbursement and the handling of insurance proceeds to prevent this from happening moving forward.

FINDING 2023-003 Finding Subject: Child Nutrition Cluster – Activities Allowed or Unallowed Summary of Finding: Material Weakness A cash reimbursement is provided to the School Corporation based on meals served under the School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children. The cash reimbursement is to be used for the benefit of the food service program. The School Corporation did not have internal controls in place over payroll disbursements charged to the food service program. Payroll disbursements were paid without evidence that the detailed report of payroll disbursements was reviewed and approved by another person not involved in the original payroll process. Contact Person Responsible for Corrective Action: Benjamin Mann Contact Phone Number and Email Address: 765-536-0008 bmann@mgusc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The CFO now reviews the Org Charge report and signs off before the payroll batch being released to the bank. This report is generated by Payroll and Benefits. Also, this entire report is now included with board claims for board approval rather than a final summary sheet. Anticipated Completion Date: February 2024

Corrective Action Plan: Management concurs with the Auditor’s recommendation and will review with the third-party North Central Illinois Council of Governments (NCICG) to establish appropriate City monitoring and review. City will also review with prior City Auditors to ensure proper overall procedures are in place to ensure all grants in the aggregate are monitored. Person(s) Responsible (Name, title): Donald Harris, City Treasurer and Shelly Munks, City Clerk Timing for Implementation: 7/31/2024

2023-005 – HEERF lack of compliance at one campus - (Significant deficiency) Cluster: Not applicable Sponsoring Agency: Department of Education (ED) Award Names: COVID-19 Education Stabilization Fund Award Numbers: P425E200430 and P425F201596 Assistance Listing Titles: COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and Institutional Aid Portion Assistance Listing Numbers: 84.425E and 84.425F Award Year: 2022-2023 Pass-through entity: Not applicable Cash Management Interest in the amount of $172,641.83 was remitted to DHHS on December 8, 2023. Effective June 2022, a new standard operating procedure (SOP) was implemented requiring a full reconciliation of costs prior to drawdowns to ensure only actual costs are drawn. The reconciliation must also be reviewed and approved by the Project Portfolio Financial Management Supervisor prior to the draw. The SOP applies to all Federal draws and therefore would apply to any “ad hoc” emergency programs moving forward. Eligibility In the event of any future “ad hoc" emergency federal programs with eligibility requirements, our policy has been updated as of 2/13/2024 to require two approvals and to document the approvals. • The reports used to determine student eligibility will be written and implemented by the Assistant Director of Financial Aid Systems. • The Deputy Director will then direct the awarding of direct grant payments which is executed by the Financial Aid Systems team. • Payments awarded to cover balances will be awarded by various members of the Financial Aid team during the processing of special circumstance appeals. Period of Performance As a result of the unallowable cost, the University took the following action in February 2024: • The Vice Chancellor for Student Affairs (VCSA) conducted a comprehensive review of current financial management policies and processes with specific attention to grant expenditure guidelines and timelines and provided training and educational resources to VCSA office staff since they do not ordinarily have responsibility for federal funding. Specifically, VCSA office staff have been trained on federal cost principles and now have responsibility for reviewing expense requests for allowability and allocability. Policies, training documents, and all resources developed as a result of this effort have been saved to a shared location for future reference. • Additionally, the unallowable charge identified in the audit was reversed and HEERF balance instead used for lost revenue previously accrued but not claimed. Reporting The Office of Financial Aid and Scholarships (OFAS) conducted a comprehensive review of the reporting process for HEERF and in October of 2023, established and documented a more systematic approach to reconcile the reports to the underlying data. At this time, updates to the 2022-2023 quarterly HEERF reports were also made. For inquiries regarding this finding, please contact Amanda Preston-Nelson at anelson10@ucmerced.edu who is responsible for the corrective action.

Additional controls related to reporting will be implemented by management.

Action taken in response to finding: Esperanza reviewed the current year’s HRSA drawdown sheet and updated all personnel salaries. We will also revise the draw down sheet so each person’s current salary is visible each month, and apply conditional formatting to highlight any person making in excess of the salary cap. Name(s) of the contact person(s) responsible for corrective action: Ryan Gadia Planned completion date for corrective action plan: May 31, 2024. If there are any questions regarding this plan, please call Ryan Gadia at (773) 640-5792.

FINDING 2023 004 Finding Subject: Child Nutrition Cluster – Allowable and Non allowable Activities and Costs Summary of Finding: Material Weakness FCSC did not have a review process in place to ensure that food service program funds were being used for allowable activities and allowable costs. Contact Person Responsible for Corrective Action: Tina Smith Contact Phone Number and Email Address: (765) 825 2178 tlsmith@fayette.k12.in.us Views of Responsible Officials: We concur with this finding. However, it has never been a past practice to audit the costs and activities of the food service program. This has been a recent change in audit requirements that began with the beginning of this audit period. Description of Corrective Action Plan: The Deputy Treasurer will randomly and periodically request receipts from the food service director in order to conduct a “mini audit” to ensure that all costs and activities are, in fact, allowable. Anticipated Completion Date: A new procedure is in place effective February 2024. The documented oversight will be available and provided for review with the 2025 audit.

FISAP Reporting Planned Corrective Action: Corban will work collaboratively with the Department of Education to investigate FISAP reporting and resolve any inconsistencies appropriately. Additionally, independent of the individual who prepares the FISAP, Corban will appoint a knowledgeable individual to review the completed FISAP for quality assurance (QA). These actions will ensure a diversity of accountability and prevent reoccurrence. Person Responsible for Corrective Action Plan: Jordan Lindsey, Associate Vice President for Enrollment Management and Marketing Anticipated Date of Completion: April 30, 2024