Corrective Action Plans

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Krystal Burnham, Food Service Compliance Coordinator/ Danny Robbins, Interim Director of Budget and Finance Anticipated Completion Date: July 31, 2023 Planned Corrective Action: The District will ensure that monthly counts are supported by documentation and verified by a second staff member and agree to the accuracy of the reimbursement claims prior to submission to the Arizona Department of Education. The District will also ensure that reimbursement claims are submitted within the required time period after month end and any identified issues with measures that prevent their recurrence.

2023-003 Lack of Support for Credit Card Charges for Former Employees Name of contact person – Laura Straw, Director of Finance Corrective action – Agate has re-instated the credit card receipt policy and has begun to enforce this policy. We are also taking action to review current policies and procedures surrounding employee credit cards and reimbursements. Completion date – Management and the Board of Directors implemented the above as of January 1, 2024.

Federal Program Title: Research and Development Cluster ALN: Various Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Boise State University continues to review and enhance its internal subrecipient payment processes to find ways to identify and prevent untimely subrecipient payments, and to reduce the potential for human error. The University will implement additional internal measures to address inefficiencies related to the current multi-department review, approval, and payment process. Name(s) of the contact person(s) responsible for corrective action: Jen Lutke, Assistant Director, Post Award: jenniferlutke@boisestate.edu Planned completion date for corrective action plan: February 2024

The District has taken remedial actions to reduce net cash resources the Food Service Fund including the purchase of updated cafeteria equipment, service vehicles and brand new cafeteria tables for the High School. Additionally, the District plans to request additional staffing and more diverse menu items to suuplement the food service program.

The District will implement processes and procedures for the timely liquidation of all POs to ensure that expenditures are captured and are in agreement with the final federal grant expenditure report.

To address Cost Efficacy, It Takes A Village To Feed One Chitd, Inc., we wilt imptement and utilize QBO moving forward, through obtaining an additionat license for QBO and taking onLine training classes to become more wetl versed and efficient through accredited and ticensed instructors. We witt use best practices for internat controts through showing more evidence of QBO approvat routing for alt transactions, accounts payabte & receivabte, credit card reconcitiations. We wilt improve overatt checks and batances for supervision and staff, white team ing how to operate on a futt accrual tevet.

Finding Number: 2023-001 Condition: Out of 28 payments to subrecipients that were tested, 12 were made after the 30 calendar day requirement. Planned Corrective Action: Accounts Payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, Accounts Payable will manually change the payment terms to 30 calendar days or less, to ensure compliance. Periodically, Accounts Payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable Offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by Accounts Payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and Principal Investigators (PIs) to highlight the need for prompt review and approval of Federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the university’s Fundamentals of Sponsored Administration training courses. Contact person responsible for corrective action: Accounts Payable: Erik Sager; Purchasing: Tom Guerin; Sponsored Research Services Accounting: John Ungruhe Anticipated Completion Date: Initial corrective action, including review of invoices, reminders and modifications to training, will be completed by 10/31/2023. Additional solutions to eliminate manual updates, if possible, will be completed within 12 months.

Condition: The District claimed $136,026 of capital expenditures between their March 31, 2023 and June 30, 2023 reimbursement claim submitted to the Illinois State Board of Education that could not be supported by documentation. Plan: The District is in the process of restructuring finance and operations to align roles and responsibilities. We will implement additional procedures for review and approval of reimbursement claims prior to submission to ensure that expenditures are claimed within a reasonable period of time in relation to when a reimbursement claim is submitted. Anticipated Date of Completion: 6/30/2024 Name of Contact Person: Sheila Johnson, Assistant Superintendent of Finance and Operations

Finding #2023-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Treasury, Assistance Listing #21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Passed through Harris County, Texas, Contract #220163, Contract year: 12/01/22 – 12/31/24, U. S. Department of Health and Human Services:, Assistance Listing #93.243, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Contract #5H79TI080624-03, Contract year: 09/30/21 – 09/29/22, Contract #5H79TI080624-04, Contract year: 09/30/22 – 09/29/23, Passed through the City of Houston Health Department, Contract #H79SP080300, Contract years: 11/01/21 – 10/31/22, 11/01/22 – 10/31/23 and 06/08/21 – 06/30/23, Assistance Listing #93.788, Opioid STR, Passed through the Texas Health and Human Services Commission, Contract #HHS000357900001, Contract years: 09/01/21 – 08/31/22 and 09/01/22 – 08/31/23, Passed through the University of Texas Health Science Center, San Antonio, Contract #HHS000561800001, Contract year: 09/01/21 – 08/31/22, Assistance Listing #93.959, Block Grants for Prevention and Treatment of Substance Abuse, Passed through the Texas Health and Human Services Commission, Contract #HHS000130500019, Contract years: 09/01/21 – 08/31/22 and 09/01/22 – 08/31/23. Condition and context: Houston Recovery Center is required to submit monthly reimbursement requests for five of its federal programs; one program requires reimbursement requests based on achievement of certain milestones rather than time. Out of a sample of 17 requests, we found six did not have evidence of review and approval as required by Houston Recovery Center’s policies and procedures. Recommendation: Training should be provided to ensure that policies and procedures regarding independent review and approval are followed. Planned corrective action: Houston Recovery Center will strengthen its internal control policies and procedures over independent review and approval of grant payment requests by shifting the primary review and approval process from the Chief Executive Officer (CEO) to the Chief Operating Officer (COO). The COO has full knowledge of allowable costs and has more availability than the CEO, which will make it easier to ensure that our policies and procedures are followed on a consistent basis. The CEO will continue in this role as backup to the COO to ensure immediate access for needed approval. We believe we have a strong system in place used by our accounting department to ensure all expenses underlying the grant payment requests are reviewed, checked for accuracy, and properly approved which further supports the reimbursement policies and procedures. Responsible officer: Leonard Kincaid, Executive Director. Estimated completion date: November 1, 2023.

Internal Control over Compliance- Cash Management Recommendation: Internal controls are designed to ensure an adequate review and approval process is in place before submission of any drawdown requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Response by management to the finding: Management has implemented appropriate controls to ensure drawdowns are reviewed and approved by staff familiar with the purpose and operations of the contracts before requests are processed in the payment management system. Name of the contact person responsible for corrective action: David Rivera-Garcia, Executive Vice President/CFO Planned completion date for corrective action plan: June 2024

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: A financial policy for managing receipt of federal awards is in the process of being created by the Financial Policies Committee Anticipated Completion Date: December 31, 2024 Contact: April Steward, Town Administrator

CORONAVIRUS STATE AND LOCAL RECOVERY FUNDS, ASSISTANCE LISTING 21.027 : INELIGIBLE COSTS / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATE "EXCEPT WHERE OTHERWISE AUTHORIZED BY STATUTE, COSTS MUST MEET THE FOLLOWING CRITERIA IN ORDER TO BE ALLOWABLE UNDER FEDERAL AWARDS: (F) NOT BE INCLUDED AS A COST OR USED TO MEET COST SHARING OR MATCHING REQUIREMENTS OF ANY OTHER FEDERALLY-FINANCED PROGRAM IN EITHER THE CURRENT OR PRIOR PERIOD. / THE CITY OF EAST PRAIRIE RECEIVED ARPA FUNDS THROUGH MISSISSIPPI COUNTY, MISSOURI FOR THE REMOVAL OF ASBESTOS AND DEMOLITION OF A HAZARDOUS SCHOOL STRUCTURE IN ORDER TO FACILITATE THE CONSTRUCTION OF A PUBLIC HEALTH FACILITY IN AUGUST AND SEPTEMBER, 2022. IN DECEMBER OF THE SAME YEAR, THE CITY RECEIVED WAS AWARDED AND ARPA GRANT AND FUNDS THROUGH THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION FOR THE SAME PROJECT. THIS WAS A DUPLICATION OF ARPA FUNDS DUE TO THE CITY NOT BEING FULLY AWARE OF THE COST STANDARDS OF UNIFORM GUIDANCE AND A MISCOMMUNICATION REGARDING ELIGIBILITY OF COSTS. / THE CITY OF EAST PRAIRIE HAS CONTACTED MISSISSIPPI COUNTY AND WILL BE RECEIVING AUTHORIZATION FROM THE MISSISSIPPI COUNTY COMMISSION TO RE-ALLOCATE THOSE FUNDS FOR THE SAME PUBLIC HEALTH FACILITY PROJECT. WE ARE ALSO DEVELOPING A WRITTEN POLICY AND PROCEDURE MANUAL CONFORMING TO UNIFORM GUIDANCE.

Finding 2023-004 Internal control deficiency and noncompliance over Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting related to expenses attributable to coronavirus reported in the provider relief fund reports. The entity has excess lost revenues to cover all payments received (excluding the expenses submitted). Therefore, no refund is required for any payments received. Since the program has ended, the management has implemented the following procedures for future grants: 1) An education session occurred on February 15, 2024, with the relevant parties across Huntington Health entities to formally implement a review process whereby the Controller will review the support files prior to filings being made related to grant applications/programs across any of Huntington’s entities. Documentation of this review will be retained in the central file repository. These steps and controls will be updated and documented in the departmental policy. 2) A central folder on the Huntington Hospital’s main accounting drive has been created. This folder will be populated with all support for filed figures related to grant applications/programs across the hospital’s various entities. The support will be validated as having been placed into this folder as part of the reporting out process by the accounting manager and Controller handling the reporting. Files will be retained in this central drive for a minimum of 7 years. These steps and controls will be updated and documented in the departmental policy. Contact Person: Byron Davis, Controller and Steven Mohr, Senior Vice President and Chief Financial Officer, Huntington Hospital Anticipated Completion Date: Completed

Finding 2023-001 Internal control deficiency and noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles related to salary cap limitation. In response to this finding management will implement the following: We are revising our internal controls to more frequently perform our salary cap reconciliation ensuring the appropriate sponsor invoicing for employees who are over the salary cap limitation. For the salary cap variances that were identified through the previous reconciliation process, they will be adjusted and posted by the close of our March 2024 accounting period. Lastly, we will offset our cash for the March 2024 letter of credit draw down process in the Payment Management System, and incorporate adjustments in our March 2024 invoices for federal pass-thru awards. In addition, the salary cap adjustment program in our new ERP system was designed to remove the defect experienced in our legacy system. Contact Person: Nicole Anderson Leonard, Vice President, Research and Vice Dean Anticipated Completion Date: March 31, 2024

Corrective Action Plan: Reimbursement of Department of Agriculture cash has been completed for year-end 2022-2023. District Administration will assess staffing needs to determine separation of duties and to determine additional staffing needs to meet the requirements of duty separation. Currently, the Finance Department consists of one Payroll/Benefits position, one Accounts Payable/Receivable Position, one Grants Specialist Position, and one Finance Director. In prior years, the Finance Department had two additional positions that have since been eliminated, causing position duties to be absorbed amongst the remaining staff. Journal postings to reimburse shown below. Anticipated Completion Date: March 29, 2024

SUBRECIPIENT CASH MANAGEMENT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.788 The West Virginia Department of Health and Human Resources, Bureau for Behavioral Health (BBH), analyzed this finding and hereby offers more details into the condition and cause of the finding. For the first noted exception, the grant was finalized on March 20, 2023. The BBH received the subrecipient’s first request for payment on April 12, 2023, at which point the reconciliation indicated that the subrecipient had incurred expenses of $118,186.21 to date. Although the reconciliation was not reviewed and approved by the BBH timely, it indicated that the subrecipient had not been reimbursed at all; therefore, the subrecipient had no cash on hand at the time of the request for payment. For the second noted exception, the BBH received the reconciliation on June 2, 2023. Although the reconciliation was not reviewed and signed by the BBH timely, it indicated $41,296.14 of cash on hand, which was under the 10% threshold established by the BBH when monitoring cash management for subrecipients of the Opioid program. For the third noted exception, the BBH received the reconciliation on March 14, 2023. Although the reconciliation was not reviewed and signed by the BBH timely, it indicated expenditures of $63,839.08 and cash on hand of only $18,070.92, which was less than the 10% threshold established by the BBH when monitoring cash management for subrecipients of the Opioid program. For the fourth noted exception, a processing error within the BBH caused the subrecipient to receive a payment that should have been held due to the subrecipient having sufficient cash on hand at the time of the payment. Nonetheless, after the period of performance, the subrecipient did not have excess cash on hand, or any cash on hand for that matter. The subrecipient returned $218,290.74 to the BPH on November 14, 2023 and $2,317.10 on November 29, 2023 in accordance with the closeout procedures referenced in 2 CFR 200.344(d). The total amount of $220,607.84 constituted the balance of unobligated cash that the BPH paid the subrecipient in advance and was not authorized to be retained by the subrecipient for use in other projects. In an effort to enhance internal controls, the BBH’s central level managers continue to work with internal and external parties to improve everyone’s understanding of the federal rules and regulations and the BBH’s existing policies, procedures, and overall expectations concerning subrecipient cash management.

SUBRECIPIENT CASH MANAGEMENT Department of Health and Human Resources (DHHR) Assistance Listing Number 93.323, COVID-19 93.323 The West Virginia Department of Health and Human Resources, Bureau for Public Health (BPH), will analyze the condition that led to this finding in an effort to determine if the subrecipient has any excess cash on hand to date. In an effort to enhance internal controls, the BPH has initiated mandatory retraining for all staff members who are responsible for reviewing subrecipient expenditure reports and processing invoices. The retraining effort has already begun and will be conducted on a monthly basis for existing employees and at the start of employment for new staff members. The BPH has also developed and implemented a Subrecipient Grant Expenditure Checklist and Subrecipient Grant Invoice Checklist. The checklists outline the steps to take when reviewing subrecipient expenditures and invoices; provide a means to verify whether the grantee is under the 10% threshold established by the BPH when monitoring cash management for subrecipients of the Epidemiology program, including a means to compare expenditures between reporting periods; and require the staff member to certify that the reviews were completed.

CASH MANAGEMENT Bluefield State University and West Virginia State University Assistance Listing Number 84.425J Bluefield State University (BSU) response Effective June 2024, BSU will draw down funds on appropriate expenditures that have already been disbursed to avoid any cash management violations. West Virginia State University (WVSU) response Currently all funds have been disbursed for HEERF awards P425E201113, P425F201736, and P425J200056. WVSU will reconcile the SEFA receipts and disbursements to internal data to locate the discrepancy and make the necessary corrections. Further, WVSU will review and update internal controls related to cash management rules to ensure compliance for drawdowns and disbursements.

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