Corrective Action Plans

U.S. Department of Housing and Urban Development: The Housing Authority of the County of Contra Costa respectfully submits the following corrective action plan for the year ended March 31, 2025. Auditor: Novogradac and Company, LLP Certified Public Accountants 1144 Hooper Avenue Suite 203 Toms River, New Jersey 08753 The findings from the March 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Federal Award Program Audit Finding 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 11,032 units. Of a sample size of sixty-nine (69) tenant files, the following was noted: - Declaration of Section 214 Status form was missing in one (1) file - HUD-9886 Authorization for Release of Information was missing in six (6) files - Lead based paint form was missing in one (1) file - HUD-50058 Form applicable to the audit period was missing in seven (7) files Our sample size is statistically valid. Known Questioned Costs: $168,325 Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement.. Views of responsible officials and planned corrective action: We agree with the Auditor’s observations on the inspection of the tenant files and will implement internal control procedures that will ensure compliance of federal regulations. HACCC identified two primary causes of the deficiency and has outlined corrective measures to address them. Firts, HACCC recognized the need for improved training on supervisory tools used to monitor recertification deadlines. Management was retrained in November 2025 on the use of WorkQueue oversight tools and on conducting daily team stand-up meetings to reinforce production goals. Key performance indicators from these meetings flow to management reports and executive leadership for ongoing monitoring. Second, HACCC'S HCV program partnered with Paul Edwards Management and Consulting (PEM) on May 1, 2024. This partnership provided HACCC's HCV program with technical assistance and coverage of positions which had remained vacant from 2021 until recently. Ingrid Layne, Director of Assistance Housing, will be responsible to implement this corrective action by March 31, 2026.

Finding 2025-001. The management company is required to use the Enterprise Income Verification for eligibility determination per the compliance supplement. There are numerous reports required to be created and reviewed by management on a periodic basis. (1) Recommendation: The management company should acquire access to the HUD EIV, and begin producing and reviewing the required reports within required timeframes. The organization should further establish procedures that will ensure ongoing compliance. These procedures should include training and monitoring of responsible staff. (2) Actions Taken: Management has worked with HUD to obtain access and will begin performing this responsibility. The appropriate reports will be produced and reviewed once management has access to the HUD EIV system. Procedures are being implemented to assure that this process is taking place.

Finding 2025.002 - Sliding Fee Scale Discount Recommendation The Organization should strengthen internal controls in place to effectively ensure that patients receive the correct sliding fee discount. Action Taken • Monthly Audits o The Front Office Coordinators at each location will routinely audit sliding fee verification on a monthly basis to verify that information has been captured and recorded correctly and all proof of income documentation is received. These monthly audits will be adopted as standard protocol and procedure for front office operations, effective January 2025. Any findings through the audit process will be reported to the COO. At least five patient charts will be audited monthly. o In addition, the Revenue Cycle Manager will also review audit findings or summaries to ensure adequate adjustment to patient accounts to correlate with the patient's eligibility status. • Staff Training o Although Heartland has offered periodic sliding fee scale procedure training, administration will be scheduling additional training with a focus on required documentation and proper analysis and implementation of sliding fee discounts. o COO and Revenue Cycle Manager will review, implement and update standard operating procedure for sliding fee scale verification. o Employees will receive a copy of the sliding fee scale policy and sign that they have read the material. o Front office employees at all locations will complete a sliding fee schedule competency check-off sheet that will be reviewed by the Front Office Coordinators and Revenue Cycle Manager.

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Temporary Assistance for Needy Families (TANF) Assistance Listing Number: 93.558 Contact Person: Elise Lopez – Vice President, Organizational Operations Anticipated Completion Date: January 31, 2026 Planned Corrective Action: The TANF Cash Assistance eligibility for each client served is one of the dozens of data points that Emerge tracks as part of our requirements for the Arizona Department of Economic Security (ADES) funding. The categorization of whether clients are eligible for TANF Cash Assistance, while a reporting requirement, is not tied to our contract billing. In other words, the accuracy of this categorization does not affect Emerge’s funding in any manner, and reporting errors regarding this categorization has not – and cannot – result in over‐billing for service units within the contract. Nevertheless, Emerge takes its reporting obligations very seriously and strives to always provide the most complete and accurate data to funders and the community. In regard to determining a client’s eligibility for TANF Cash Assistance or other government benefits, Emerge collects information and assesses eligibility for two reasons: 1) as a means of supporting our case management services and efforts to connect clients with appropriate resources, and 2) in order to comply with ADES requests to report whether or not we serve TANF‐eligible clients. While Emerge and its employees are not trained by ADES in determining individual’s eligibility for TANF Cash Assistance or other government benefits that we do not administer, we do provide our own internal training to employees about the factors that go into determining eligibility. Historically, this information has been provided as a stand‐alone document and noted during new hire training. In researching the client files which were selected for audit, it was determined that, in some instances, clients were categorized incorrectly, or that qualifying information was not sufficiently documented as it pertains to the client’s TANF Cash Assistance eligibility. Overwhelmingly, this was a result of one or both of the following factors: (1) clients whose TANF eligibility changed during the year, but whose status was not updated in our system, and/or (2) inconsistencies in how a client’s children had been documented in our client information system (eg. clients whose children are not enrolled in Emerge’s services do not appear in this system, but staff may have marked the client eligible for TANF based on verbal information without documenting the children in their notes). Our internal inquiry into this issue also revealed that TANF income eligibility charts were not correctly updated in all areas of the client information system, which may have led to confusion among staff regarding client eligibility status changes throughout the year. To mitigate future errors, we have taken immediate steps to begin the process of updating our client information system to ensure the correct TANF eligibility charts are reflected in the appropriate areas. We also have a plan to update TANF eligibility chart updates annually, which will include a quality assurance check by the Vice President of Operations to ensure the information has been updated in all appropriate areas of the client data managements system. As of November 28, 2025, we have developed an internal performance improvement plan. This plan includes conducting an internal audit of our client information system files for 2025 to ensure accuracy, re‐training staff on TANF eligibility and documentation, and conducting monthly quality assurance checks through the end of FY26. Additionally, greater time and focus related to the details surrounding the TANF assessment process will be built into the curriculum for new hire trainings moving forward. These corrective actions, while ongoing, are expected to be fully implemented by 01.31.2026

Management will monitor utility allowances on a monthly basis to ensure they are applied to tenants correctly.

The tenant recertifications will be monitored by the owner to ensure they are being completed in a timely manner.

Finding 2025-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Catalog Numbers: 14.850 Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material weakness in Internal Control over Compliance for Eligibility Finding 2025-003 (continued) Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit and the Authority failed to properly calculate the tenant's rent payments using documentation from third party income verification. Context: There are approximately 834 units. Of a sample size of twenty three (23) tenant files, the following was noted: Original Applications were missing in thirteen (13) files. Citizenship Declarations were missing in five (5) files. Verification of income was missing in eight (8) files. The Authority also failed to properly calculate the rent payments of four (4) tenants by not utilizing documentation from third party income verification. Our sample size is statistically valid. Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files and the calculation of rent. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure eligibility compliance with the Uniform Guidance and the compliance supplement. Authority's response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2026.

Finding 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Number: 14.871 & 14.EHV Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). Finding 2025-001 (continued) Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit and the Authority included income that was miscalculated during the annual recertification. Context: Of a sample size of thirty-seven (37) tenant files, the following information was unavailable for examination at the time of audit: • Original application was missing in one (1) file • Citizenship declaration was missing in one (1) file • Signed lease was missing in one (1) file • Verification of income was missing in four (4) files • HUD form 50058 was not timely filed for one (1) file In addition, three (3) tenants' annual recertifications (HUD-50058 form) included income that was miscalculated. Our sample size is statistically valid. Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered and designed a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure eligibility compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster Program to ensure that established internal control policies are being followed on a timely basis. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2026.

Corrective action has been completed. The Institute determined at the start of Academic Year 24-25 that transitioning to a third-party provider of financial aid solutions would be in its best interest. This engagement provides a team of professional financial aid operations and student service specialists, allowing for enhanced loan counseling and processing services, implementing additional checks and balances, and mitigating the potential for errors such as this incident. The error resulting in the finding was actually identified by the third-party provider, following which AFI immediately returned the erroneously awarded federal funds to G5. Individuals responsible for corrective action: Lang Fredrickson, Chief Financial Officer 323.856.8429

Immediate Corrective Action Taken: • Fiscal Services reviewed the Title I allocations to confirm that no improper fiscal impact occurred as a result of the reporting discrepancy. • The district documented the finding and communicated the error internally to Fiscal Services and Educational Services staff. • Roles and responsibilities for ConApp enrollment data review have been clarified to prevent future manual errors. Preventive Measures to Avoid Recurrence: 1. Dual Verification of ConApp Enrollment Data • The Accountant in Fiscal Services will now compare and confirm the ConApp enrollment counts to certified CALPADS Fall 1 data before submission and certification. • A second-level review by the Coordinator of Teaching and Learning Department certifying the ConApp. 2. Documentation & Recordkeeping • Any adjustments to pre-populated enrollment numbers will require written justification and supporting documentation (e.g., CALPADS reports, email confirmations). Responsible Parties: • Fiscal Services Accountant – Responsible for matching the ConApp enrollment counts to CALPADS Fall 1 and maintaining backup documentation. • Coordinator, Teaching and Learning Department – Support in verifying site-level data. Completion Date: • Immediate clarification and assignment of review responsibilities were completed in October 2025.

Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2025 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action:  Scanning Applications: o CSFP staff scan applications daily. These applications are then stored in SharePoint. We have 2-3 volunteers weekly who rename applications based on Client ID, Name, and Expiration Date, then file them electronically based on their expiration date. This ensures that we are always up to date on having an electronic version of our CSFP applications. o Before shredding any applications that have been scanned, we confirm that the application exists in the system (done by CSFP staff).  If an application is missing: o Confirm that application information is in ClientTrack and document through a generated printed application. o Send application to distribution site for next distribution, to ensure participant signs new application before they receive another CSFP box. Anticipated Completion Date: This process was fully implemented at the end of May 2024. It should be noted that the applications have a 3-year certification period, so the full effect of the new process won’t be realized until spring of 2027.

Identifying Number: 2025-001 - Eligibility Finding: Under the Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and Grants for New and Expanded Services Under the Health Center Program, eligible individuals receive a sliding fee discount on amounts owed for health center services based on family size and income levels in comparison to the federal poverty guidelines. The Organization should maintain records providing evidence that the patients included under this program are eligible. However, during the compliance testing of 43 sample items, there were two instances where the patients had properly submitted their forms, but the Organization applied the incorrect sliding fee category. There is no known monetary impact, improper expenditure of funds or questioned costs identified. However, if the Organization does not strengthen the internal controls in regard to the eligibility determination process, there is a possible effect on the ability of the Organization to obtain additional funding under this program if ineligible patients are being treated with grant funding. Corrective Action Plan: The Operations and Social Work leadership met to determine a corrective action plan to address the audit findings for sliding fee scale eligibility. The leadership, under the direction of Alice Sliwka, Chief Operating and Quality Officer, will re-educate all appropriate staff who complete all eligibility ensuring standardization of naming convention for all documents received. The leadership will also review and edit the policy as the frequency of review has changed from every six months to annually. Monthly audits will continue to be completed to address any individual issue of non-compliance. Monthly follow-up and review of all findings will be shared with the Quality Excellence Committee until full compliance is maintained. Chase Brexton anticipates completion of this by March 31, 2026.

2025-001: Exit Counseling Notification Not Performed Timely Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period – Year Ended June 30, 2025 Condition Found During our student file testing, we noted one student out of forty was not sent exit counseling notification within thirty days after the student withdrew. We consider the exit counseling notification not being performed in a timely manner to be an instance of noncompliance with the Eligibility Compliance Requirement. Corrective Action Plan The College has implemented two new procedures that query data to identify financial aid recipients that have withdrawn from classes. The first query identifies new loan borrowers that have dropped below half-time status and the second query identifies previous loan borrowers that have dropped below half-time status. These queries will be run bi-weekly to identify students that must be sent exit counseling notifications within thirty days of withdrawal. Responsible Person for Corrective Action Plan Jeffrey A. Heap, Sr. Director, Financial Services & Controller Deanna Hogan, Director, Financial Aid Implementation Date of Corrective Action Plan October 3, 2025

Condition: The School District charged an expenditure to the grant which was incurred in a school building that was not an eligible school building under the award. Planned Corrective Action: Associate Accountant will ensure the Assistant Superintendent’s signature is on all invoices charged to federal grants including the Regional Assistance Grant. The Finance Director will ensure this during the invoice approval process. Finance Director and Assistant Superintendent meet monthly to discuss federal grants which includes the Regional Assistance Grant. Part of this meeting is to discuss known expenditures for federal grants so far this year to ensure they are properly coded and expended. Finance Director will run a general ledger analysis every two months to compare posted grant expenditures to approved grant budgets. Expenditures in question will be discussed at monthly meetings. Any determined to be incorrect will be moved to non-grant accounts via journal entry most likely prepared by Finance Director and approved by Associate Accountant. Contact person responsible for corrective action: RJ Wiersema and Jill Ansel Anticipated Completion Date: 12/31/2025

Assign supervisors responsibility for ,specific program related timeliness and compliance reports to improve accountability and avoid duplicative monitoring. Require supervisors to conduct and document monthly review of assigned reports and take corrective action as needed. Upon filling the vacant manager position, require agency-wide review of supervisory reports. Incorporate handson exposure to Medical Assistance screens in VACMS during SNAP processing for new staff. Reinforce expectations for simultaneous processing of SNAP and Medical Assistance combination cases.

Finding 2025-001 Name of Responsible Individual: Noemi Sarrion, Director of Financial Aid Corrective Action Plan: Management agrees with the finding that the estimated Cost of Attendance (COA) for the summer term was calculated incorrectly for five students. Because the summer term includes multiple sessions, the COA multi-step programming process in PowerFAIDS, the College’s financial aid management software, including the review of COA selection metrics, are manual. In April 2025, the College migrated its ERP software and PowerFAIDS to cloud-based platforms. This transaction required significant time from Office of Financial Aid (OFA) staff to test system functionality and validate migrated data to ensure a smooth go-live. As these efforts coincided with summer COA programming, the capacity for thorough review and comprehensive functional testing of summer COA setup was reduced. Going forward, the OFA will assign a staff member, separate from the individual handling COA programming, to review the COA selection metrics. In addition, the OFA will evaluate the potential of automating COA programming processes. Anticipated Completion Date: May 1, 2026

Pathways executive management team will provide at least quarterly trainings on any changes in state of federal funding guidance and ensure implementation of this guidance is clear through regular contact with state and federal agencies.

Finding 2025-002: Student Financial Aid Cluster – Reporting View of Responsible Officials and Planned Corrective Action: Root Cause Errors occurred because the data file transmitted from Anthology to COD did not consistently include the correct student information. It is not yet clear whether the issue arises from configuration problems, system design limitations, or both. Planned Corrective Action and Responsible Officials • Procedure review and update. The Financial Aid Office will review and revise procedures to ensure accurate, timely, and complete reporting to COD, including pre-submission and post-submission checks. • System-to-COD file analysis with Anthology. In partnership with Anthology's support and managed services teams, the College will: o o o Analyze how COD reporting files are created within Anthology. Identify why certain student data elements are not being transmitted correctly. Implement configuration changes or other system-level fixes to ensure accurate and complete reporting. • Enhanced manual validation until issues are resolved. If the file creation process is determined to be working "as designed" but still does not meet regulatory expectations, Financial Aid staff will perform manual review and correction of COD files prior to submission, and will monitor error and rejection reports from COD for follow-up. As with Finding 2025-001, the Vice President for Student Affairs and the Director of Financial Aid share responsibility for ensuring these corrective actions are implemented and sustained commencing on the date set forth above.

Contact Person – Randal Bergquist, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure students are receiving a reduced meal and the appropriate rate. Completion Date – January 31, 2026

Finding 2025-002: In order to ensure proper compliance with the student refund and return process, the CFO, Controller, and Student Accounts Coordinator will establish clear departmental responsibilities for initiating and approving financial aid batches and create an internal processing timeline shorter than the 14-day federal limit. Additionally, the CFO, Controller, and Student Accounts Coordinator will obtain training on the timing and documentation requirements under 34 CFR §668.164(h).

The initial issue was resolved. We determined that a transposition error occurred during the entry of the student count numbers into the CARS system. Importantly, this data entry error did not affect the funding allocation received. In accordance with the auditor's recommendations, we will continue to utilize the CalPads 1.17 report for reporting student counts for each school. Moving forward, we will implement a dual-verification process, requiring a second person to confirm data accuracy during the entry of numbers into CARS, thereby mitigating the risk of future data entry errors.

Finding 2025-003 – Section 8 Project-Based Cluster Tenant Files – Eligibility – Rent Calculations Noncompliance & Significant Deficiency Section 8 Housing Choice Voucher Cluster – ALNs 14.195 and 14.249 Corrective Action Plan: Finding: Somerville Housing Authority (SHA) received the authority’s Single Audit for the year ended March 31, 2025, indicating that SHA received a finding of Significant Deficiencies. Auditors identified two files missing proper income verification, and seven files missing the EIV report. Extrapolation of errors to the population found the potential misstatement to be immaterial to program HAP expense. Auditors note that all income-related discrepancies were found in files selected from a HAP register dated earlier in the fiscal year, indicating improvements in compliance as the year progressed. Auditors recommend that SHA should enhance its quality control procedures to ensure compliance with HUD income verification regulations and EIV review requirements. Regular internal reviews and staff training should be conducted t oaddress these compliance issues effectively. PHA Response: The SHA has implemented a corrective action plan to address noted deficiencies. The SHA has had significant staffing turnover in the last year. While vacant positions were filled, the SHA contracted with Nan McKay Associates (NMA) to complete all Annual Recertifications. NMA assigned four full-time staff to complete all recertifications and assigned one additional full-time staff person to conduct a monthly Qualify Control Review of all recertifications completed by NMA. During NMA’s contract, SHA focused on hiring and training new staff. SHA has hired a new Director of Leased Housing, a new Leased Housing Supervisor, three Leasing Coordinators, and a Tenant Selector. The Director and Supervisor have been providing one-on-one training and support. New staff have also been enrolled in training opportunities provided by outside vendors such as the Nan McKay Rent Calculation Class. As of 7/31/2024, SHA has resumed program management from NMA. SHA has also increased the agency’s internal quality control audits. The Director of Leased Housing has increased monthly SEMAP review from 40 to 50 files. Monthly feedback is provided to staffers individually and systemic issues are addressed to the entire department. The Supervisor also conducts a monthly review of the Income Verification Tool, following up with staffers to assist them in addressing discrepancies with their client’s records. Additionally, SHA has fully implemented an electronic file storage system, utilizing PHA Web’s online system to better organize, track, and maintain client files. Since implementation of the corrective action plan, 97% of reviewed files have appropriate third party documentation, 94% have appropriate adjusted income, and 97% were found to have appropriate Utility Allowances. Corrective action has been taken on all errors, and guidance has been provided to staff. SHA will continue conducting file audits, as well as following up with staff. PHA Goal: Based on the SHA’s monthly quality control sample of tenant files: (A) The SHA obtains third party verification of reported family annual income, the value of assets totaling more than $5,000, expenses related to deductions from annual income, and other factors that affect the determination of adjusted income, and uses the verified information in determining adjusted income, and/or documents tenant files to show why third party verification was not available; (B) The SHA properly attributes and calculates allowances for any medical, child care, and/or disability assistance expenses; and (C) The SHA uses the appropriate utility allowances to determine gross rent for the unit leased in accordance with 24 CFR 982.505. PHA Strategies: Target Completion Date: 1) The SHA will review its current quality control tracking system to record the results of random sampling of files as required in 985.2. The SHA will revise this system on an ongoing basis if necessary. 3/31/2026 2) Confirm that 90% or more files sampled contain proper third party written verification (or equivalent) of income and assets, proper calculation of appropriate deductions and allowances and that appropriate utility allowance were used in the calculation of tenant rent. 3/31/2026 Persons Responsible: Matt Lincoln, Director of Leased Housing David Hospedales, Leased Housing Supervisor

2025-004 – Child Nutrition Cluster - Eligibility - The District is aware of the student’s receiving benefits that are not eligible for benefits and will implements new procedures and a plan to update eligibility. Responsible Official – Austin Moore, Business Manager Anticipated Completion Date – The District will correct this in the subsequent fiscal year.

The Institution has reviewed the details of the finding and determined the error to be due to human error and the responsibility of the Institution. Subsequent to the audit, the Institution refunded $350 in 2023-2024 Federal Pell Grant program funds on behalf of student #20 (VR). In addition the Institution refunded $419 in 2024-2025 Federal Pell Grant program funds on behalf of student #2 (EL). These two students over-award was due to a schedule or grade change that took place after the start of student’s term or payment period. The Institution will implement reporting from our SIS to monitor schedule or grade changes that take place after the start of a student’s term or payment period.

2025-003: Inaccurate Eligibility Classification and System Entry Issue: Eligibility classifications in CACFP were entered incorrectly due to manual processes and inconsistent verification. In some cases, the eligibility category recorded in the system did not match the approved paper application. Documentation of income verification and classification checks was incomplete or not retained. Corrective Actions: Porter-Leath will strengthen controls over eligibility determination by requiring a complete review of all eligibility documents before system entry. 1. Applications will first be checked by administrative or Family Services staff to verify household size, income documentation, and appropriate eligibility category. 2. Site Managers will review the classification for accuracy and ensure the approved determination is entered consistently into ChildPlus or ProCare. 3. A final review by the Preschool Coordinator will confirm that the eligibility classification on the application matches the classification stored in the system prior to claim submission. 4. A reconciliation step will be built into the monthly workflow so discrepancies between documentation and system data are identified and corrected promptly. Responsible Personnel: Family Services Liaisons, Site Administrative Staff, Site Managers, Preschool Coordinator, CACFP Coordinator Timeline: Revised procedures implemented within 15 days; staff training completed within 30 days. Monitoring: Periodic quarterly reviews of at least 25 percent of eligibility files will be conducted to confirm proper classification and system accuracy, with results reported to management.