Corrective Action Plans

Finding Number: 2024-001 Condition: The Organization failed to submit monthly reimbursement requests to the Hebrew Immigrant Aid Society by their due dates during the year ended June 30, 2024. Planned Corrective Action: The Organization has implemented system and process improvements to ensure timely submission. The Organization has and will continue to maintain appropriate staffing level and sufficient training to ensure timely submission. This plan does not account for circumstances beyond JFS’s control such as timing of funding approval from the grantor. Non-controllable delays will be documented by JFS and reports submitted in a reasonable amount of time following approval. Contact Person Responsible for Corrective Action: Justin Fisher, Director of Accounting Anticipated Completion Date: April 30, 2025

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of a lack of understanding of procedures involved in posting and reporting to COD. In April 2024 after the 2023 audit, we identified this as a gap in the Business Office process to ensure that dates disbursed matched the COD system. This process was rectified, and the business office staff was coached and trained. Unfortunately, these 2023-2024 findings occurred prior to the implementation and coaching of these new processes. Urban College of Boston (UCB) has contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year. Global FAS provides UCB with a monthly reconciliation report through our shared Secured File Transfer Protocol site (SFTP)and notifies us when one is ready to be reviewed. Once the file is received, the Business Office will conduct a secondary reconciliation using the Global FAS report. The Business Office will review the students ledger/billing and compare information with COD to ensure all disbursement information matches according to regulation. Urban College conducted a full reconstruction of COD dates to Ledger posting dates and ensured that all dates for this auditing period and current funding year disbursements are accurate. Urban College has also moved to a once-a-week disbursement schedule which will structure our reporting from our SIS system to COD and assist in the accuracy of our data review. Global Financial Services has been conducting a quarterly testing of our disbursement records to also ensure the accuracy of data. The Director of Financial Aid and Chief Finance Officer will continue to review procedures and update according to regulation and policy changes so potential gaps are discovered proactively. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

The District will work with the contractors to make sure the proper reports are submitted to meet the prevailing wage requirements agreed upon in the contract.

Finding 2024-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 We concur with the finding. Corrective Action plan: As of SY 24/25 when the High School Treasurer checks the 10% of the paper applications, she will make a list of the ones she checked and it will be located in the application binder. As of March 1st, 2025 The Food Service Director will run a copy of Direct Certs that Titan has in their file, she will then cross check it with the list that is send from IDOE. She will keep both list together in a file after initialing it. Anticipated completion Date: March 2025

Management recognizes the importanceof maintaining complete and accurate documenation for all expenditures, including credti card charges. While supporting documentation is collected and reviewed, we acknowldge the need to strengthen the review process for complete documenation, cost classification and recording. To address this, all relevant staff received additional training in January and February 2025 regarding identifying allowable and unallowable costs and properly documenting expenses in accirdance with federal cost principles. In addition, the new program director has scheduled quarerly meetings with the external accountant to implenet a revised system for classifying direct and indirect costs and to develop any additional staff training. These steps will help ensure that all costs are allowable, appropriately allocated, and accurately recorded in the general ledger.

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260-244-5771 fleetwoodta@wccsonline.com Views of Responsible Official: Whitley County Consolidated Schools Todd Fleetwood Director of Business and Operations INDIANA STATE BOARD OF ACCOUNTS 21 107 North Walnut Street  Columbia City, Indiana 46725 Phone (260) 244-5771  Fax (260) 244-4590  Website http://wccsonline.com The School Corporation concurs with the finding. Description of Corrective Action Plan: The business office inadvertently omitted the reviewer’s sign-off on one of the grant reimbursement forms. This oversight will be promptly corrected. Anticipated Completion Date: 04/01/2025

The deficiency was a result of prior management that was replaced in the current fiscal year. The new financial team found the deficiency during the audit, made all the necessary corrections, and self-reported it to the auditor before issuance. The rate is now correctly applied to all federal grants, and a review process is in place for current and future grants. The federal funds were returned and the FFR’s were amended before final reporting and issuance of the audit. The matter is corrected, and corrective action is complete.

2024-001: Approvals for expenditures Name of contact person: Stacey Holbrook, Executive Director Corrective Action: A member of management or the Board of Directors will review and authorize all disbursements. This authorization will be evidenced by the initialing of each disbursement reviewed. Proposed completion date: The Board will implement the above procedure immediately.

2022-001: Segregation of Duties Name of contact person: Stacey Holbrook, Executive Director Corrective Action: Duties and functions will be reviewed to determine where segregation needs to occur. The duties will be separated as much as possible and alternative controls will be implemented to compensate for lack of segregation. However, the risk of not segregating certain duties is not worth the additional costs. Nonfinancial employees will be trained and provide some assistance. Proposed completion date: The Board will implement the above procedure immediately.

Finding 2024-004 - U.S. Department of Education (USDE) - Higher Education Institutional Aid (Title III Programs) (Material weaknesses and Significant deficiencies): A. We observed the following questioned cost of $505,004 during our testing of Title III and Future Grant drawdowns (material weaknesses): a) Adequate supporting source documents and general ledger data was not readily on file to support three (3) of eleven drawdowns tested. The University subsequently supplied adjusting journal entries to reclass expenditures previously recorded elsewhere in the general ledger. However, the total amount of the questioned cost noted above was not substantiated, resulting in excess federal cash on hand. b) We noted two (2) drawdowns for payroll were drawn 20 days and nine (9) days before the actual payroll dates. B. Our testing of Title III cash disbursements revealed questioned cost of $55,525 as stated below (significant deficiency): a) Adequate supporting source documents, such as invoices, check request, and evidence of approval were not on file or provided for one (1) of eight (8) disbursements tested. b) One (1) check contained only one signature. C. We noted the following during our review of budget versus actual reporting. a) The University did not properly and accurately maintain budget vs actual schedules to adequately validate carryover and remaining balances. The budgets for Title Ill, Future grants appear to have been overspent; however, the reasonableness of under or over prior year remaining balances could not accurately be determined. D. We noted the following during our testing of time and effort reporting (significant deficiencies): a) The University subsequently provided corrected Time and Effort Reports for nine (9) out of 12 tested which we noted were previously missing employee signatures, signatures of approval by supervisor or next level of authority, salary distribution percentages, and grant funding codes. b) Personnel Action Forms originally provided for three (3) of four (4) employees tested did not contain salary allocations as evidence that salaries were to be allocated to the program. The University subsequently corrected the forms. c) The University also provided adjusting entries to reclassify salaries that were incorrectly recorded in the general ledger; however, we were unable to trace the salary distribution to the general ledger for two (2) of 12 tested. Auditor's Recommendation – 1) We recommend all drawdowns are approved by management prior to the request being made and reviewed to assure that drawdowns and supporting expenditures are accurately and timely recorded. Federal regulations require that funds drawn down are limited to the minimum amounts needed to cover immediate project cost and not made to cover future or budgeted expenditures. 2) We recommend the University require prior approval for all disbursements, including credit card, check, wires, and electronic funds transfer, and maintain supporting source documents in a manner that’s easily accessible when needed. Proper supporting source documents include invoices, approved expense/check request, payment advice copy, etc. 3) We recommend the University implement procedures for budget versus actual reporting to include allowable carryover budgets to accurately reflect remaining balances and to assure that the University is operating within the constraints of the grant budgets. 4) We recommend that the University maintain adequate supporting source documentation as evidence that time and effort reporting is accurately completed, reviewed and approved prior to seeking reimbursement for payroll expenses from the grantor. Federal regulations require that grant recipients provide reasonable assurance that charges are accurate, allowable, and properly allocated and that salary and wages charged to federal awards are based on actual rather than budget estimates. Corrective Action – The Vice President for Fiscal Affairs has implemented standard operating procedures to ensure the following: drawdown review and approval, centralize location for all grant related documents, award letters, invoices, etc. with accessibility for both Business Office and Sponsored Programs, and grant reconciliation completion date. The SOP will be included in the update Business Office Procedure document that will completed this fiscal year. The items identified in the 23-24 audit for grant were also contributed to the down-time of the ERP as well as having a new team in Sponsored Programs and Business Office reviewing and restoring the accounting records while trying to ensure accuracy and integrity in the recording of transactions. The institution disagrees with in-adequate approval of documents. The ERP is designed to not process purchase orders without appropriate approvals. All requisitions are approved by the area Vice President with any transactions $10,000 and over requires the signature of the President.

The department will develop a contingency plan and training procedures to ensure continuity of grant procedures and a review process to ensure reporting accuracy.

U.S. Department of State Services and Advocacy for Gay, Lesbian, Bisexual, and Transgender Elders, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 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. FINDINGS—FEDERAL AWARD PROGRAMS AUDIT SIGNIFICANT DEFICIENCY FA 2024-001 Internal Control over Compliance- Cash Management Recommendation: Based on our testing, we noted that the May and July 2024 drawdowns were approved prior to submission. We recommend management continue to maintain this process in order to maintain proper internal controls over compliance. 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 as of the May 2024 drawdown moving forward. Name of the contact person responsible for corrective action: Kris Mordecai, Chief Operating Officer. Planned completion date for corrective action plan: Corrected as of April 2024. If the U.S. Department of State has questions regarding this plan, please call Kris Mordecai at 212-741-2247.

2024-001 – Nonmaterial Noncompliance Over Cash Management Recommendation: Haley’s Park put procedures in place to ensure HAP Vouchers are submitted to HUD within the prescribed timeframe above. Corrective Action: We have already implemented procedures to ensure HAP Vouchers are submitted to HUD within the prescribed timeframe. Personnel Responsible for Corrective Action: David Langgle-Martin, Chief Housing Officer and Kyle Wilson, Property Manager Anticipated Completion Date for Corrective Action: The Corrective Action has already been implemented as of the date of this report.

2024-001 ALN 14.872 – Public Housing Capital Fund Program – Cash Management The CEO agrees with the finding and will follow the Auditor's recommendations as listed on the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Mr. Robert Dull, CEO Projected Completion Date: June 30, 2025

The University will move to have the funds placed into an interest bearing account. In addition, we will seek additional clarity from the program officer as it relates to the original guidance received and the steps to submitting interest to the appropriate agency.

We concur with the recommendation. The one (1) instance of drawdown that exceeded the three day rule for drawdowns was an oversight on the part fo the institution. In addition, we will revise the spreadsheet used to track cumulative program expenditures against drawdowns.

Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to improve segregation of duties where possible and follow the Committee of Sponsoring Organizations of the Treadway Commission best practices for small business. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025.

Uniform Guidance Corrective Action Plan Year ended June 30, 2024 Federal Finding #2024-001 Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Quinnipiac University agrees with the finding. For one student who withdrew during the 2023 – 2024 academic year, the Direct Loan funds awarded to that student were not returned to the student financial assistance account within 45 days after the University determined the student withdrew. For one student who withdrew during the 2023 – 2024 academic year, the Pell and Direct Loan funds awarded to that student were not returned to the student financial assistance account within 45 days after the University determined the student withdrew. The finding is attributed to programs previously being reconciled monthly or when enough authorized funds became available within G5. At the time the above students withdrew, there were not enough authorized funds to process the net total of draw downs and returns so a batch was held until more funds were available, which resulted in returns surpassing the 45 day threshold. In December 2023, Management implemented additional steps within the reconciliation process of Title IV awards in order to prioritize the return of any unearned Title IV awards so that they are remitted to the student financial assistance account within G5 in a timely manner. The students mentioned above withdrew prior to these additional steps being implemented. If the Office of Management and Budget have questions regarding this plan, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

Finding Number: 2024-003, Subrecipient Payments Condition: The University did not have adequate controls in place to ensure invoices to subrecipients were paid timely within the 30-calendar-day requirement. Planned Corrective Action: Penn State has created a new Subaward Administration and Compliance Office (SACO), which is part of the new Post Award Contractual Compliance Office. The SACO is led by its own director and will provide central oversight over key subaward compliance processes, such as subrecipient payments, and provide training to campus on subrecipient processes. This function has previously not existed in a central office at Penn State. The creation of this office demonstrates Penn State’s commitment to compliance for subaward activities. Contact person responsible for corrective action: John Hanold, Associate Vice President for Research; Director, Office of Research Administrative Services Anticipated Completion Date: June 30, 2025

YPIC will post the $194,602 audit adjustment to correctly reverse the overstatement of grants receivable and grant revenue in the accounting records by April 30,2025. YPIC will also implement a monthly reconciliation process to review grant expenditures and ensure that amounts reported align with actual expenditures. Additionally, YPIC will develop a Financial Reporting Checklist to ensure all adjustments are posted timely.

2024-003 H. Period of Performance Timely Payment of Financial Obligations Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: As the grant period has ended, we recommend that the Corporation works with the funding agency to remedy the period of performance noncompliance. In addition, we recommend that the Corporation reassess the design of its period of performance controls to identify where enhancement or additional controls are needed over liquidation of financial obligations subsequent to the end of a grant award. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendations. Action planned/taken in response to finding: The Corporation went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue to educate all grant managers on (1) the reporting capabilities within the system that can be utilized in the execution of monitoring payment status on individual invoices that have been submitted to granting agencies for reimbursement, and (2) the requirement to use their grant specific general ledger coding when orders are placed with vendors that are set up under the Corporation’s group purchasing process. For the specific vendor noted in Finding 2024-003, a grant number input field has been added to the group purchasing orders to allow for enhanced tracking and review of expenditures associated with grants and the monitoring of payment of those expenditures. The use of the accurate grant general ledger coding by grant managers when orders are placed, will reduce the time between placement of order and payment of the invoice. Additionally, management will develop a federal grant policy that covers all requirements for compliance and internal controls for federal grants. The grant manager responsible for oversight of BHSB grants will work with BHSB to remedy the period of performance noncompliance noted in Finding 2024-003. Anticipated Completion Date – June 30, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

2024-002 C. Cash Management; L. Reporting Evidence and Review and Approval of the Reported Expenditures and Timely Report Submission Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: Management should reassess the design of its controls to ensure submissions to BHSB are made timely within the required 15-day period and that documentation is retained that evidences the review and approval of expenditures submitted to BHSB for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendations. Action planned/taken in response to finding: The Corporation went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue educating grant managers on capabilities within the system that can be utilized in the execution of review and approval of grant expenditures prior to timely submission to the relevant granting agencies for reimbursement. Centralized repositories have been set up for grant managers to extract specific monthly financial reports for use in the execution of their controls, as well as to retain their review and approval evidence. Additionally, management will develop a federal grant policy that includes the requirements for compliance and internal controls for federal grants. The policy will acknowledge that for controls to be designed and operate effectively, there must always be a segregation of duties between the preparer of the control vs. reviewer and that clear documentation must be retained to evidence the execution of the controls. Anticipated Completion Date – June 30, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

Finding No. 2024-004: Segregation of Duties and Oversight – Material Weakness in Internal Control over Financial Reporting Contact for Corrective Action: Matt Bergheiser, President The finance department will institute a monthly financial reporting package to be sent to the President of the organization which will include the monthly financial statements, general ledger detail, a listing of all journal entries made, significant accounts reconciliations, aged payables and receivables, and any significant adjustments in the previous period. Report will also include an update to the Schedule of Federal Awards and other significant grant reporting done in conjunction with the development team. President will review and approve the packet monthly. Expected Completion Date: 3/31/2025

2024-002. Allowable Costs/Cost Principles: Final Expenditure Report for a Federal or State Project (FS-10-F) United States Department of Education, Passed Through New York State, Department of Education: Twenty-First Century Community Learning Centers ALN: 84.287 Condition: Testing of the expenditures charged to the grant, determined that costs were in excess of the adjusted budget amount because the actual number of students served was less than the target number of students to be served. Planned Corrective Action: The District should monitor performance indicators for the grant and review final expenditures charged to grants prior to submitting final cost reports to the New York State Education Department for reimbursement. Responsible Contact Person: Peter Daly Interim School Business Administrator Bridgehampton Union Free School District 2685 Montauk Highway Bridgehampton, New York 11932 Anticipated Completion Date: June 30, 2025.

The Controller will review the detailed information related ot the drawdown to ensure the amount charged to the specific grant is allowable, reasonable and properly supported prior to when the drawdown is requested.