Corrective Action Plans

Research and Development Cluster – Assistance Listing Numbers 47.070, 47.076, 47.084, and 93.846 Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Midway through the fiscal year, we introduced a new process involving multiple layers of approval before a drawdown is executed. The drawdown calculation is done either by the Senior Accountant or Grant Manager and sent to either the Grant Manager (if prepared by the Senior Accountant), or Controller (if prepared by the Grant Manager) for review and approval. If additional information is needed, the approver sends the request back for updating and recalculation. Name(s) of the contact person(s) responsible for corrective action: Mutale Sokoni, Associate Vice President for Finance, 703-284-1496 Planned completion date for corrective action plan: Action taken during April 2024

Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-008 Name of contact person: Stephanie Williams, Budget and Finance Director Corrective Action: Proposed Completion Date: May-25 Corrective Action Plan for Finding 2024-004, 2024-005, 2024-006, and 2024-007 also apply to State Awards findings. The County Manager has instituted a Grant approval process so that she, Department Heads, Offices and the Finance Department are aware of grants prior to receipt or spending of them. This process will allow time for receipt, BoCC approval, if necessary, and to be coded and tracked separately from the General Fund. Section IV - State Award Findings and Question Costs 146

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $528,450 to $1,238,306, from November 13, 2023, to December 18, 2023. While the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the amounts were not returned within the seven-day period as required. Summary: The College draws a portion of funds for student stipends while award reconciliation is in progress to ensure timely disbursement. An administrative oversight led to excess cash being held longer than allowed. Specifically, the prior stipend drawdown was not netted out when calculating subsequent fund requests, resulting in excess cash being held for 24 business days. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure compliance with the seven-day return requirement. 2. Process Change: Going forward, the College will refrain from drawing funds for student stipends until reconciliations have been fully completed. This will ensure that funds are drawn in alignment with actual disbursement needs, reducing the risk of excess cash. 3. Internal Control Strengthening: The College will enhance internal controls around cash management to ensure that excess cash instances are identified and corrected promptly. 4. Staff Training: All relevant staff will undergo training on revised cash management procedures and the importance of timely reconciliation and returns. 5. Improved Monitoring: The College will implement a more robust monitoring process to track excess cash and ensure compliance with Federal regulations, including daily checks during peak disbursement periods. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $1,335,590 to $4,774,182, from September 6, 2023, to September 13, 2023. The excess cash exceeded the one-percent tolerance of prior year drawdowns, and the funds were not posted to students' ledgers within the three-business-day period as required. Summary: The College draws a portion of funds early to ensure the timely disbursement of stipends to students, while the reconciliation process is still underway. However, the funds were not posted to students’ ledgers within the required three days, leading to a violation of the federal cash management requirements. The issue was related to administrative oversight in the processing of the drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure funds are posted to students’ ledgers within the three-business-day requirement. 2. Process Change: The College will refrain from drawing funds early to cover stipends until all necessary reconciliations are completed, ensuring compliance with the required disbursement timeline. 3. Internal Control Strengthening: The College will strengthen internal controls by implementing more rigorous checks to ensure timely posting of funds to students' accounts after drawdowns. 4. Staff Training: Relevant staff members will undergo training on the updated procedures and the importance of timely posting of funds to student ledgers. 5. Improved Monitoring: The College will institute enhanced monitoring and tracking of funds after drawdowns to ensure that the required posting timeframe is consistently met. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

The District will reduce net cash resources by investing in capital equiment where necessary and allocating direct cost overhead expenditures.

Recommendation: Request reimbursement of loans throughout the project.

Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had one instance of excess cash for the Federal Direct Student Loan program, ranging from $172 to $10,314, from March 25, 2024, to April 5, 2024. Although the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the funds were not returned within the required seven-day period. Summary: The College inadvertently retained excess cash for the Federal Direct Student Loan program beyond the seven-day tolerance period due to administrative oversight. The delay in returning the excess cash was attributed to the reconciliation process taking longer than anticipated. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure excess funds are returned to the Secretary within the seven-day tolerance period. 2. Process Change: The College will enhance its reconciliation process to expedite the identification and return of excess cash within the required timeframe. 3. Internal Control Strengthening: The College will implement more rigorous internal controls, including automated alerts and checks, to ensure compliance with cash management requirements. 4. Staff Training: Relevant staff will receive additional training on updated cash management procedures and the importance of timely returning excess cash. 5. Improved Monitoring: The College will introduce enhanced monitoring and tracking mechanisms to ensure that excess cash is promptly identified and returned within the mandated period. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

2024-004 FINDING Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – March 31, 2025

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: Kansas Health Science University (KHSU) had excess cash for the Federal Direct Student Loan program, including $268,278 from July 12, 2023, to July 19, 2023, and amounts ranging from $2,204 to $13,385 from April 8, 2024, to April 23, 2024. For the first period, the excess cash exceeded the one-percent tolerance of prior year drawdowns and was not returned within the three business-day period. For the second period, although the excess cash did not exceed the one-percent tolerance, amounts were not returned within the seven-day period as required. Summary: KHSU identified two instances of excess cash due to delays in returning unused funds. The Funds were not returned to ED withing the required number of days, leading to a violation of the federal cash management requirements. The issue was related to an administrative oversight related to the timing of the return of drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: KHSU will update its cash management procedures to ensure compliance with both the three-day and seven-day return requirements for excess cash. 2. Process Change: KHSU will implement a process to immediately review and reconcile drawdowns with disbursement needs. Drawdowns will be based strictly on reconciled disbursement schedules to prevent excess cash. 3. Internal Control Strengthening: Internal controls will be enhanced to include automated alerts for identifying excess cash and triggering prompt corrective actions. 4. Staff Training: Financial aid and accounting staff will undergo targeted training on Federal cash management regulations, focusing on the prevention and timely resolution of excess cash. 5. Improved Monitoring: KHSU will establish daily monitoring of cash balances during peak disbursement periods and periodic reviews to ensure ongoing compliance with Federal regulations. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

Corrective Action/Management Response: We will have another Accounting Technician II audit to be sure all checks and requisitions match. Proposed Completion Date: 12/1/2024; we will check weekly

Finding 2024-003 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District has already begun evaluating current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Greg Johnson, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date The planned completion date is June 30, 2025. 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

Management Response: Due to the size of LDSC’s administrative staff, complete segregation of duties is not economically feasible. We will ensure the areas recommended above are added to our current policy to the extent it is economically feasible.

Auditor recommendation: We recommend that the City establish policies and procedures for requesting reimbursement of grant expenditures on a monthly basis, including reconciliation of the expenditures and reimbursements under each grant. Views of Responsible Officials and Planned Correc􀀁ve Ac􀀁on: The City agrees with this finding. Vacancies in key posi􀀁ons including the Airport Manager and the Transit Director of Administra􀀁on meant that there was not sufficient exper􀀁se in the program areas to ensure that reimbursement requests were prepared and submi􀀂ed 􀀁mely. These key posi􀀁ons have now been filled. The City now has an Airport Manager with substan􀀁al experience managing municipal airports and overseeing federal funding for airports. The City also hired a Transit Director of Administra􀀁on with extensive federal and state grant management experience, and exper􀀁se in Transit programs. The Accoun􀀁ng Officer, Grants Manager and Accoun􀀁ng Financial Analyst posi􀀁ons in the Finance Department have been filled, and the Grants Division is now fully staffed. More robust staffing is allowing Finance to perform more oversight in addi􀀁on to working more closely with Transit and Airport program staff. Filling these key posi􀀁ons and retaining qualified staff is essen􀀁al to establishing a process for 􀀁mely requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursement under each grant. The Transit Division is working with a contractor provided by the FTA on establishing policies and procedures to ensure compliance with federal grant requirements. This contractor is also providing training and technical assistance to the Transit program. The scope of this work includes ensuring requests for reimbursement of grant expenditures are submi􀀂ed 􀀁mely, and reconcilia􀀁ons of grant expenditures and reimbursements are completed 􀀁mely and accurately. The Airport Department is in the process of contrac􀀁ng with a vendor to assist with federal compliance and provide training for Airport staff on relevant Uniform Guidance requirements. The vendor’s scope of work will include helping with developing and documen􀀁ng policies and standard opera􀀁ng procedures for requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursements. Addi􀀁onally, the Airport Department plans to create a Grant Accountant posi􀀁on which will be responsible for reconciling grant expenditures monthly and processing reimbursement requests quarterly. In CY25 the City plans to provide Uniform Guidance training for staff which will include internal controls related to cash management. Responsible Official:Emily Oster, Finance Director, James Harris, Airport Manager, Airport Heavy Equipment Mechanic, Gabrielle Chavez, Transit Director of Administration, Matthew Bonifer, Accounting Officer, Erika Lujan, Grants Manager Timeline and Es􀀁mated Comple􀀁on Date: June 30, 2025

Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention. To further stabilize and formalize these improvements, a Certified Public Accountant will be added as a consulting CFO. This role supports the ongoing development of fiscal operations. Additionally, it is recognized that the payroll vendor, ADP, was initially slow to address issues with uploaded data when notified by CAPNC, responded officially after CAPNC alerted repeatedly that it had now elevated to an audit issue. This issue has since been remedied. Staff have shown marked improvement over previous legacy staff in documentation, accountability, and monitoring. Payroll services in general are able to provide real-time features and accountability for time, resulting in more accurate, reliable, and allocable time recording. Payroll records are reviewed, and time studies are performed for all staff to ensure the allocation methodology is appropriate, consistent, and aligned with staff performance. Wipfli Consulting is providing technical assistance over an additional contract period to update policies and procedures for the fiscal area, in accordance with Uniform Guidance, and allow for advance reporting, as well as provide CPA support. The curriculum includes comprehensive training for all administrative leadership staff, covering fiscal oversight, grants management, and compliance. Allocations are regularly reviewed by the leadership team to ensure appropriate methodology and consistency with grant expectations and regulations. Board members have access to the accounting software through a Board portal for further oversight, enhancing transparency and accountability. Review of finance in conducted monthly by Board of Director’s Finance Committee.

Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention. To further stabilize and formalize these improvements, a Certified Public Accountant will be added as a consulting CFO. This role supports the ongoing development of fiscal operations. Additionally, it is recognized that the payroll vendor, ADP, was initially slow to address issues with uploaded data when notified by CAPNC, responded officially after CAPNC alerted repeatedly that it had now elevated to an audit issue. This issue has since been remedied. Staff have shown marked improvement over previous legacy staff in documentation, accountability, and monitoring. Payroll services in general are able to provide real-time features and accountability for time, resulting in more accurate, reliable, and allocable time recording. Payroll records are reviewed, and time studies are performed for all staff to ensure the allocation methodology is appropriate, consistent, and aligned with staff performance. Wipfli Consulting is providing technical assistance over an additional contract period to update policies and procedures for the fiscal area, in accordance with Uniform Guidance, and allow for advance reporting, as well as provide CPA support. The curriculum includes comprehensive training for all administrative leadership staff, covering fiscal oversight, grants management, and compliance. Allocations are regularly reviewed by the leadership team to ensure appropriate methodology and consistency with grant expectations and regulations. Board members have access to the accounting software through a Board portal for further oversight, enhancing transparency and accountability. Review of finance in conducted monthly by Board of Director’s Finance Committee.

Audit Finding Number: 2024-002 – Cash Management Agency: Public Housing Capital Fund Responsible Person, Title: Stephanie Schmutzer, Accountant Completion date: 7/1/2024 Agency Response: Concur Corrective Action Plan: Management concurs with the recommendation to implement timely LOCCS fundings that coincide with our normal accounting cycle and when directed by HUD to circumvent the rules to get that in writing not just verbal.

Finding 2024-005 Non-cooperation with IV-D Referrals Name of contact person: Corrective Action: July 1, 2024 Section II - Financial Statement Findings (continued) Kim Grissom, Family and Children's Medicaid Supervisor and Shelia Morton, Family and Children's Medicaid Supervisor Error discovered was that there was no IV-D Referral sent to Child Support Services. Family and Children’s Medicaid leadership updated the Recertification Documentation template on 11/20/2024 to ensure that workers are documenting the necessary IV-D Referral process (including when it is not required) on every case. The AP section of the template has been updated to allow caseworkers to provide detailed information on IV-D Referrals. All Family and Children’s Medicaid caseworkers have been advised to utilize the updated Recertification Documentation Template effective immediately. Currently, the Division of Health Benefits (DHB) have advised that during the Public Health Emergency and the Continuous Coverage Unwinding period, IV-D Referrals are not required and are only sent at the request of the client. This policy will be in effect until further notice from DHB (Admin Letter 13-23). Although IV-D Referrals are currently suspended per DHB, Family & Children’s Medicaid leadership will review this policy with staff by conducting a refresher training by 12/31/2024. The Family and Children Medicaid Supervisors created and utilizes an Error Trends Data log that went into effect on 10/1/2024. The Error Trends Data log will provide Family and Children’s Medicaid leadership with data regarding errors that are repetitive. This will help leadership conduct monthly or quarterly refresher training as well as individualized training for staff who continue to have repetitive errors. Staff who fail to utilize the updated Recertification Documentation Template and continue to have repetitive errors will be placed on a corrective action plan.For the Year Ended June 30, 2024 Corrective Action Plan Proposed completion date: Finding 2024-006 Inadequate Request for Information Name of contact person: Corrective Action: Proposed completion date: Finding 2024-007 Inaccurate Information Entry Name of contact person: Refresher training will be held by December 31, 2024 on effective documentation and record keeping. “Vehicle Status Documentation” template will be created and implemented by December 31, 2024. Error Trends Data log was implemented October 1, 2024. Adult Medicaid Lead Workers will monitor this by conducting a random selection of second party reviews each month. Adult Income Maintenance Supervisor II (pending vacancy), Delta Elliott, Income Maintenance Lead Worker III, and Michelle Ogle, Income Maintenance Lead Worker III Error discovered where vehicle status was not clearly documented in the case record caused by ineffective record keeping and incomplete documentation. Refresher training will be held by 12/31/2024 to review appropriate documentation and record keeping in NC FAST and will be conducted by Adult Medicaid leadership. Adult Medicaid Supervisor will create a “Vehicle Status Documentation” template that will be utilized by all Adult Medicaid caseworkers at every application and recertification. Completion and uploading of this template will be required in NC FAST. Adult Medicaid Lead Caseworkers will monitor the use of the template during monthly second party reviews of each caseworker. Adult Medicaid Supervisor created and utilized an Error Trends Data log effective 10/1/2024. The Error Trends Data log captures monthly errors to identify trends among staff. This log also provides Adult Medicaid leadership with data regarding errors that are repetitive to help leadership conduct monthly or quarterly refresher training as well as individualized training for staff who continue to have repetitive errors. Staff who fail to utilize the “Vehicle Status Documentation” template and continue to have repetitive errors will be placed on a corrective action plan. Policy refresher training will be held before 12/31/2024 that will cover the IV-D Referral process with specific advisory that the policy is currently suspended until further notice per DHB (Admin Letter 13-23). The Recertification Documentation template was updated on 11/20/2024 and went into effect immediately to be used by all Family and Children’s Medicaid caseworkers. The Error Trends Data log was implemented on October 1, 2024. Family and Children’s Medicaid leadership will monitor this by conducting a random selection of second party reviews each month. Section III - Federal Award Findings and Questioned Costs (continued) Kim Grissom, Income Maintenance Supervisor II; Taylor White, Income Maintenance Supervisor II; Lisa Kornegay, Income Maintenance Lead Worker III; and Sherry Stainback, Income Maintenance Lead Worker III 176

Although the Project does not currently use an interest-bearing account for project funs, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action.

Although the Project does not currently use an interest-bearing account for project funs, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action.

U.S. Department of Housing and Urban Development 2024-001 Home Investment Partnerships Program – Assistance Listing No. 14.239 Recommendation: To ensure accountability with the required reporting, we recommend management review and update the procedure to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PHFA will implement electronic time tracking, this will replace the current manual process of preparing timesheets that are entered into a database used to accumulate administrative expenses charged to federal programs. This will ensure the invoices submitted for reimbursement of program administration expenses are accurate. PHFA is currently in the process of implementing a Human Capital Management system that will allow employees to track the time they work on federal programs. Name of the contact person responsible for corrective action: Adrianne Trumpy, Director of Accounting Planned completion date for corrective action plan: July 1, 2025 If there are any questions regarding this plan, please call Adrianne Trumpy at 717.780.3823.

CONDITION: During the course of the audit, auditors noted 10 of the 25 (40%) quarterly expenditure reports required by the Illinois State Board of Education were not submitted timely. Seven of the quarterly expenditure reports were submitted between 2 and 4 days late, one quarterly expenditure reports was submitted between 10 and 20 days late, and two quarterly expenditure report were submitted between 80 and 100 days late. For the federal program, auditors noted 3 of the 4 (75%) quarterly expenditure reports required by the Illinois State Board of Education were not submitted timely. One of the quarterly expenditure reports was submitted 2 days late, one of the quarterly expenditure reports was submitted 4 days late, and one of the quarterly expenditure reports was submitted 89 days late. PLAN: The Regional Office of Education #3 will submit timely expenditure reports. A system of calendar reminders as well as written procedures have been implemented. In addition, Regional Office of Education #3 has employed an additional bookkeeper to help spread the work load more evenly. ANTICIPATED DATE OF COMPLETION: Ongoing CONTACT PERSON: Ms. Julie Wollerman, Regional Superintendent

2024-004: Material Weakness and Noncompliance – Written Policies Required by the Uniform Guidance Statement of Condition/Criteria: The City does not have written policies and procedures to implement the requirements of 2 CFR section 200 for the administration of federal awards. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. Planned Corrective Action: City was in the process of developing written policies and procedures related to federal awards during the year, but was unable to obtain board approval for the policies until April 2024. Contact person responsible for corrective action: Vicki Schroeder, Treasurer, and Eric Buckman, City Manager Anticipated Completion Date: April 2024

WHPCA has hired a third-party accountant as well as implemented additional monitoring and review and approval procedures to strengthen its financial management.

Federal Single Audit for the Period Ending June 30, 2024 Corrective Action Plan February 5, 2025 ➢ The major program the finding pertained to: 2024-001. Internal Control Over Compliance, United States Department of Agriculture, Passed-through New York State Department of Education: Child Nutrition Cluster, School Breakfast Program ALN: 10.553, National School Lunch Program ALN: 10.555 ➢ Condition: The District has not yet updated its existing policies and written procedures to conform to the Uniform Guidance requirements. ➢ Planned Corrective Action: The District has already updated its policy and related procedures in order to comply with the requirements of Uniform Guidance. The Board of Education adopted its policy in May 2024. ➢ Name, Title and Contact Info of Responsible Person: Sam M. Schneider Assistant Superintendent for Business East Hampton Union Free School District 4 Long Lane East Hampton, NY 11937 (631) 329-4106 sam.schneider@ehschools.org ➢ Anticipated Completion Date: Already implemented on May 21, 2024.

Condition: The School’s policy regarding allowable cost recognition and requests for reimbursement follow those requirements set forth by the federal program. Questionable Costs: During testing, it was determined that vision benefits had been double counted for reimbursement requests during the year ended June 30, 2024. Context: Vision benefits selected for testing had been double counted for reimbursement. Effect: The School obtained reimbursement funding over allowable amount. Cause: The School did not adequately monitor and review reimbursement submission and reporting. Identification as a Repeat Finding: Not a repeat finding Recommendation: All federal program reimbursement requests should be reviewed for accuracy and appropriateness. Response: Our management team has acknowledged the finding and has immediately implemented a review process for all federal program reimbursement submissions. The error has been fixed and the HR team has added additional controls for the calculation / review of the bi-weekly benefit deduction amounts. Contact Person Responsible for Corrective Action: Denise Alyeshmerni, Director Completion date: December 31, 2024