Corrective Action Plans

Management will continue to accumulate proper supporting documentation to support their compliance with the eligibility compliance requirement and to provide such documentation, when legally possible. Responsible party: Cynthia Amodeo, CEO Myra Ricard, Program Director Anticipated Completion Date: uncertain at this time due to existing New York State law.

Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies in procedures for the Financial Aid office, including the area of enrollment reporting, which is also done by Institutional Research, to provide appropriate updating of the NSLDS records. This will include creating checks and balances to be sure that enrollment reporting is working and being updating timely. The Federal Student Aid website offers many resources in the form of training, including access to on-demand resources which provide a documented learning assessment. Our objectives will be that all current and incoming Financial Aid staff, along with Institutional Research staff, will be required to undergo training in the area of enrollment reporting, including the supervisor with whom the Financial Aid office reports to. This training will be annually and periodically throughout the year. In addition, daily add and drop reports are generated which would allow more frequent updating of the NSLDS system. Objectives will be to put in place to provide checks and balances to be sure that enrollment reporting is timely. Measurable targets will be achieved by documenting the training within a shared electronic drive between the supervisor and the Financial Aid office. The Financial Aid office shall be responsible for monitoring that the enrollment reporting is being done timely. In addition, periodic and monitored checks-ins of staff in Institutional Research with whom the responsibility to update NSLDS is with.

Due to a sudden and unanticipated staffing shortage, R2T4 calculations were performed beyond the required timeframe. In the case where a student receives all F’s on their transcript, we cannot determine the students’ last date of attendance or academic activity, since F grades do not include this information (unlike W grades) and the college is a non-attendance taking institution. In this case, federal guidelines allows schools to use the midpoint of the payment period for the calculation. In these cases, all calculations would be based on the same date each term. In review of FA22 records, the calculations were performed in March 2023, but the withdrawal dates used to calculate eligibility were 10/21/22, the FA22 term midpoint. All policies and procedures relating to R2T4 processing have been reviewed and updated, and a review of all prior year calculations will be performed as well, to ensure compliance. Additional staff have been trained in the process, and calculations are being performed. Adequate and trained staff will ensure that all required calculations are performed accurately, and according to required timelines. In addition, the Financial Aid Office is transitioning from the SAM to the Colleague Financial Aid System (starting in 2024-25) which will provide a more automated and integrated process, with enhanced internal controls.

Corrective action plan: • On the first Friday of each month, the Housing Choice Voucher Program staff meets to discuss program policies and procedures for training purposes. At each meeting, specific aspects of administering the program are reviewed, along with the related HUD policies. Staff members are given the opportunity to ask any questions on any procedures or policies they may not understand. Activities from the Nan McKay Rent Calculation training are passed out to staff to complete individually. After staff completes the activity, the answers are reviewed as a group. Other activities take place which involve the staff answering questions regarding various case studies of situations that may occur in the daily activities of administering the HCV Program. • January 9th – 11th, all HCV and PBV Specialist received Combo HCV/LIPH Rent Calculation training with HOTMA updates from Nan McKay and Associates. • Review and update Administrative Plan/SOP with Policies and Procedures to ensure all staff is familiar with policies and procedures. • Staff restructuring • In-service meetings with Compliance Specialist as staff challenges some write ups of deficiencies to ensure that there are mutual understandings of policies. • HCV/Occupancy Specialists have been instructed to triple check all certifications for accuracy to mitigate the possibility for careless errors PERSONS INVOLVED HCV Case Management Staff Asset Manager RAD Project Based Voucher Community Manager Compliance Specialist Compliance Supervisor HCV Program Director Occupancy Specialist MONITORING The Compliance Supervisor and Specialist will continue to monitor files. The Compliance Supervisor and Specialist will begin adding the CFR Regulation and or Administrative Plan Policy and page number to each deficiency write-up to assist staff in understanding the error so that staff will not make consistent errors. The Compliance Supervisor will provide to staff recommendations for improvement. It is hopeful that a greater number of participant files will be audited throughout the year for both the HCV Program and for the PBV communities. On the first Friday of each month, the Housing Choice Voucher Program staff meets to discuss program policies and procedures for training purposes. During these meetings specific aspects of administering the program are reviewed, along with the related HUD policies. Staff members are given the opportunity to ask any questions on procedures or policies they may not understand. During many meetings, activities from the Nan McKay Rent Calculation training are passed out to staff to complete individually. After staff completes the activity, the answers are reviewed as a group. Staff also answers questions regarding various case studies that may occur in the daily activities of administering the HCV Program. We also have NRHA’s Compliance staff provide training to review common errors and to discuss any areas staff may have that are gray with audited files. Staff has also gone through an intensive training on the common errors per NRHA’s Compliance Department. Quarterly Quality Control trainings are held with caseworkers lead by the NRHA Compliance Department to address concerns and common errors. The Admission and Continued Occupancy Policies (ACOP) and Administrative Plan policies and procedures are reviewed to ensure that all staff has a clear understanding of the proper ways of calculating income, applying allowances, using proper payment standards, and approvals of lease ups and completion of certifications. A departmental quality control team was established to ensure there is consistency of policies and procedures and that when new procedures are implemented the processes are properly documented and disseminated to all staff. A departmental quality control sub-team was formed after the audit to include the actual custodians of program participant files comprised of:  1 Tax Credit PBV Property Manager  1 LIPH Property Manager  1 Compliance Specialist  1 Occupancy Specialist  1 Senior HCV Specialist  1 Tax Credit Administrative Assistant NRHA Caseworkers and Administrative Staff have been instructed to triple check all certifications for accuracy to mitigate the possibility for careless errors. The NRHA Compliance Department continues to audit files for the HCV Program to ensure that files are being processed properly; income calculated correctly, verifications are in the file, HAP payments issued are correct, and that units are inspected timely. Findings are noted and must be corrected by the Case Worker or Administrative Staff and the file is reevaluated by the Compliance Department to ensure findings were corrected. NRHA Caseworkers and Administrative Staff have been instructed to triple check all certifications for accuracy to mitigate the possibility for careless errors. The NRHA Compliance Department continues to audit files for the HCV Program to ensure that files are being processed properly; income calculated correctly, verifications are in the file, HAP payments issued are correct, and that units are inspected timely. Findings are noted and must be corrected by the Case Worker or Administrative Staff and the file is reevaluated by the Compliance Department to ensure findings were corrected. NRHA will continue to investigate the possibility of increasing the number of program participant files reviewed by the Compliance Department. NRHA has begun contract negotiations with a new software vendor. It is the feeling of the agency that with a different software platform the errors being made will lessen as the information gathered to perform rent calculations will be in a more automated form. It is anticipated that this will lessen staff time needed to enter the information and thus allow for more time to be spent verifying accuracy of information. The timeline for implementation is for the software to be live at the beginning of the 2026 fiscal year. This over-riding strategy is to be done in conjunction with the steps outlined below to mitigate this situation.

FINDING NO. 2022-004 Statement of Condition: Management had developed activity level controls over compliance that included compliance review of all tenant certifications of income used in determining the amount of rent amounts due from eligible PRAC 202 participants (tenants) by the Coast compliance department. However, during our testing, management had no documentation evidencing such reviews had occurred; further, during our interview process of site staff (community managers), staff asserted that no such reviews had occurred, and that no feedback on tenant certifications was provided by the compliance department. Auditor Recommendation: Management should have a process to review and approve all tenant certifications being prepared by site staff (community managers). The approval process should include an approval stamp or some other evidence that each file has been reviewed by the compliance department and is approved for processing. Further, senior management should have an ongoing monitoring process to ensure that the compliance department is carrying out the review process. Action Taken: Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-300: Eligibility for the Children’s Health Insurance Program. This is the department’s Corrective Action Plan. Recommendation (2023-300): Eligibility for the Children’s Health Insurance Program We recommend the Wisconsin Department of Health Services work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate. Wisconsin Department of Health Services Planned Corrective Action: The Division of Medicaid Services (DMS) acknowledges that we maintained eligibility under the Children’s Health Insurance Program (CHIP) for individuals who had turned age 19, including SCHIP participants. It was our overarching policy to not terminate health care coverage upon certain changes in circumstances for Medicaid participants during the federal public health emergency (PHE). To comply with this policy, DHS made system changes at the beginning of the pandemic to maintain eligibility for all participants. After CMS provided additional information specific to SCHIP, DHS considered whether to make the necessary system changes to terminate SCHIP participants who turned 19 during the public health emergency. Because of the system limitation and DHS’s overarching goals to maintain continuous coverage, amongst other reasons, DHS decided to temporarily keep all CHIP participants enrolled until the public health emergency ended. DMS leaders met with CMS leaders on May 11, 2022, to discuss this compliance issue and related systems limitations. During that meeting, CMS indicated that they understood the system and communication challenges of having a single program that combines Medicaid and CHIP. CMS also acknowledged that the federal public health emergency was likely to end at any time, so making the required system changes would not be prudent. CMS said they would follow up with Wisconsin if they determined that further state action was needed, but they did not communicate to us after the meeting that they felt the compliance issue needed to be addressed. This confirmed the Medicaid Director’s decision to not pursue costly systems changes to support a change that might only be needed for a short period of time. After the PHE ended, DHS took proactive steps to identify aged-out CHIP participants and ensure that their eligibility was redetermined in the first two months of unwinding. In contrast to the rest of the CHIP and Medicaid population, whose renewals were distributed over a 12-month period from June 2023 through May 2024, these members’ renewals were accelerated to June and July 2023, so that their CHIP coverage would end as soon as possible after the end of the PHE. While we agree conceptually with the finding, the questioned costs identified do not consider that many (if not most) of the ineligible members would have been eligible for Medicaid as childless adults upon aging out of the CHIP program. We will discuss this likelihood with CMS and if necessary, use data available in our CARES eligibility system to assess how many of these members did retain eligibility as childless adults or in other categories of Medicaid after completing renewals in June and July. Anticipated Completion Date: March 31, 2024 Person responsible for corrective action: Jori Mundy, Director Bureau of Eligibility and Enrollment Policy, Division of Medicaid Services jori.mundy@dhs.wisconsin.gov. Rebuttal from the Wisconsin Legislative Audit Bureau - As stated in the finding, and as acknoledged by DHS, DHS maintained continous eligibility for SCHIP participants who were over age 19. This eligibility requirement continue through the public health emergency. Since CHIP and MEDICAID are separate programs, consideration of whether these participants could have been eligible for the Medicaid program would not have been part of our audit. Payments to providers for these participants were funded by SCHIP and not the medicaid program.

Finding 2023-104: Homeowner Assistance Fund—Documentation to Support Applicant Eligibility and Benefit Payments Auditor Recommendation: Revise its procedures to ensure the Department of Administration completes a sufficient review to ensure adequate supporting documentation is included in the Homeowner Assistance Fund program’s computer system prior to an approval of the benefit payment. Planned Corrective Action: The Wisconsin Department of Administration (Department) will revise its procedures to ensure it completes a sufficient review to ensure adequate supporting documentation is included in the Homeowner Assistance Fund program’s computer system prior to an approval of the benefit payment. Auditor Recommendation: Provide training or other technical assistance to the community action agencies on the adequacy of supporting documentation agencies are to obtain, evaluate, and enter into the Homeowner Assistance Fund program’s computer system. Planned Corrective Action: The Department will provide additional training and technical assistance to the community action agencies on the adequacy of supporting documentation agencies are to obtain, evaluate, and enter into the Homeowner Assistance Fund program’s computer system, the requirements for which are as contained in its Wisconsin Help for Homeowners (WHH) Program Manual. Training and technical assistance will be provided through communications with program administrators and during program monitoring. The Department further notes that, after providing nearly $70 million in assistance to help prevent foreclosure through mortgage, tax, and utility payments to more than 8,600 Wisconsin households facing pandemic-related financial hardship, the WHH Program closed to new applications on March 8, 2024.Anticipated Completion Date: June 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

Finding 2023-101: Homeowner Assistance Fund – Service Organization Controls Auditor Recommendation: Obtain the service organization audit report for the computer system used to administer the Homeowner Assistance Fund. Planned Corrective Action: The Wisconsin Department of Administration (Department) has requested and will obtain the service organization audit report for the computer system used to administer the Homeowner Assistance Fund. Anticipated Completion Date: Immediately following the issuance of the service organization audit report for the period ended May 31, 2024, which is anticipated to be received not later than September 30, 2024. Auditor Recommendation: Complete a review of the service organization audit report, assess the effectiveness of the internal controls on the computer system maintained by the service organization, and document its review. Planned Corrective Action: The Department will develop the means to inform and document its review of the service organization audit report and its assessment of the effectiveness of the internal controls on the computer system maintained by the service organization. The Department will utilize those means to evidence reviews and assessments it completed but did not document as reported to and by the auditors, and for future received service organization audit reports, including the report that will be obtained for the period ended May 31, 2024. Anticipated Completion Date: June 30, 2024, as related to the development and use of the means to evidence prior completed but undocumented reviews and assessments, and within thirty days of receipt of the service organization audit report for the period ended May 31, 2024, which is anticipated to be received not later than September 30, 2024. Auditor Recommendation: Complete a review of the complementary user entity controls at the Department of Administration that are required to be in place for it to rely on the service organization audit report, document its review, and implement user entity controls, if needed. Planned Corrective Action: The Department will develop the means to inform and document its review of the complementary user entity controls at the Department that are required to be in place for it to rely on the service organization audit report, and will implement user entity controls, if needed. The Department will utilize those means to evidence the review of complementary user entity controls it completed but did not document as reported to and by the auditors, and for complementary user entity controls contained in future service organization audit reports, including the report that will be obtained for the period ended May 31, 2024. Anticipated Completion Date: June 30, 2024, as related to the development and use of the means to document the prior completed but undocumented review, and within thirty days of receipt of the service organization audit report for the period ended May 31, 2024, which is anticipated to be received not later than September 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

Finding 2023-103: Emergency Rental Assistance Program—Subrecipient Monitoring Auditor Recommendation: Review its existing monitoring procedures and ensure adequate management oversight procedures are established, documented, and followed. Planned Corrective Action: The Wisconsin Department of Administration (Department) has reviewed its existing monitoring procedures, designed to ensure that subrecipients use the subaward for authorized purposes, take timely and appropriate action on all deficiencies detected through monitoring, and comply with the terms and conditions of the subaward, as required by 2 CFR s. 200.332 (d) through (f), and its own policies and procedures. The Department will improve the completeness and effectiveness of its monitoring program by ensuring that management oversight procedures are appropriately established, documented, and followed. Auditor Recommendation: Complete review and follow-up with the community action agencies or Energy Services, Inc. (ESI) identified by its existing monitoring procedures. Planned Corrective Action: The Department will complete review and follow-up with the community action agencies or Energy Services, Inc. (ESI) in accordance with its existing monitoring procedures.Auditor Recommendation: Consider if additional monitoring should be completed for the community action agencies or ESI for the months during FY 2022-23 when the Department of Administration paused monitoring for the Emergency Rental Assistance Program. Planned Corrective Action: To maintain the integrity of its Emergency Rental Assistance monitoring program, the Department will complete additional monitoring of the community action agencies and ESI during FY 2022-23, including during the period acceptance of new program applications was temporarily paused. Anticipated Completion Date: June 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

Finding 2023-102: Emergency Rental Assistance Program—Documentation to Support Applicant Eligibility and Benefit Payments Auditor Recommendation: Obtain required documentation for the four applicants we identified or seek to recoup improper benefit payments it made to these applicants. Planned Corrective Action: The Wisconsin Department of Administration (Department) requested and received from the auditors the four applicants they identified. The Department has reviewed available documentation in its eligibility and benefit determination system and will work with the responsible community action agencies and Energy Services, Inc. (ESI) to obtain required documentation supporting the applicants’ eligibility to receive Wisconsin Emergency Rental Assistance (WERA) Program benefits. Should the Department determine that it provided WERA Program benefits to ineligible recipients, it will seek to recoup the payments made. Auditor Recommendation: Provide additional training and technical assistance to the community action agencies and Energy Services, Inc. (ESI) on the adequacy of supporting documentation that is to be obtained and entered into Home Energy (HE) Plus by the community action agencies and ESI. Planned Corrective Action: The Department will provide additional training and technical assistance to the community action agencies and ESI on the adequacy of supporting documentation obtained and entered into Home Energy (HE) Plus, its eligibility and benefit determination system, based on its monitoring of accepted documentation. Anticipated Completion Date: June 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

The Director of Nutrition Services, hired August 2023, has been trained on the verification process and procedures along with timeline compliance requirements.

Identifying Number: 2023-001: Adjustments to Project Rental Assistance Payments Condition/Finding: During our review of eligibility testing support, we noted that for the tenant’s annual reexaminations and certifications under HUD Project Rental Assistance Contract Number FL29-S951-006, the incorrect amount of contract rent was being utilized on the forms to calculate the projects tenant assistance payment. The Project incorrectly double counted the utility allowance of $51 and was using a gross rent rate of $833 to calculate the tenant rental assistance payment when it should have only used a gross rent rate of $782 per the contact. This resulted in the Project requesting a tenant rental assistance payment that was $51 more than what it should have been for each tenant on the Housing Owner’s Certification and Application for Housing Assistance Payments (HAP) for 3 months of fiscal year 2023. Upon the Project’s analysis, it was determined that the total amount of the error, net of vacancies, was $14,724. Corrective Action Taken or Planned: Management has established procedures to ensure that there is a better process to check the amounts of contract rent being approved on the re-examinations and certifications of tenants. This includes, but is not limited to, an additional review step and control for confirmation of the correct contracted and billed amounts. These additional procedures also include processes with more closely reviewed monthly HAP forms by the appropriate personnel to ensure that the amounts being requested of HUD are in line with the appropriate contract rates. Corrective action has been implemented with all corrections approved by and reconciled with HUD. This has already been fully implemented at the organization as of the date of this letter. The primary designated official is the Chief Financial Officer. With our best regards, Paul Dennison Chief Financial Officer

2023-005 Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office designed a new process to coordinate with the academic office to review SAP status of students and ensure appropriate letters will be sent. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

2023-004 Eligibility – Assistance Listing No. 84.063 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate and timely disbursement dates to COD. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025.

2023-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 4 -- Missing documentation of landlord participation agreements, 1 -- Missing documentation of landlord participation agreements, due to incomplete record of transfer from WNCHS, 1 -- Missing documentation of lease contract, 2 -- Missing documentation of housing assistance form. Corrective Action: As outlined in previous year’s corrective action plan, WNCAP has implemented an eligibility checklist to ensure that client records are complete. The Housing Coordinator has shared the review checklist with frontline employees so they can use it as reference when completing intakes and recertifications, and she regularly reviews client files to ensure the records are complete. While the checklist was implemented in the first quarter of 2023, some of the records were created prior to implementation. Going forward, all records for the following audit period will have been created after implementation of the review checklist. Evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2021-22 audit: 2021-22 Total Deficient Eligibility Records: 30 2022-23 Total Deficient Eligibility Records: 8 WNCAP expects to see continued improvement in subsequent audits.

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Melissa Beadle, Deputy Director, will be responsible for implementing this corrective action by June 30, 2024. CMHA is aware that the HAB/MRI software does not store waitlist reports by date processed and since then, CMHA has been saving Excel files of the waitlist reports. The applicants that were selected for the audit were applicants that had preference points. All applicants with preference points were contacted at the same time to be informed that they were eligible for a voucher. The CMHA waitlists were ran by preference points and time/date of application. Once those applicants were pulled the waitlist was not saved to Excel. The preference point list was then sorted alphabetically for sign in purposes and tracking of applicant documentation. This is the list that was provided to the auditor.

The housing authority had instances of income, asset or medical miscalculation or insufficient verification and (1) instance of incorrect payment standard. Rockport Housing Authority (RHA) contracted with Newburyport Housing Authority (NHA) to manage the Section 8 program. They will be calculating income, assets and/or medical expenses based on HUD regulation. NHA is staffed with an experienced Section 8 Coordinator. In addition, NHA uses Rent O Meter to provide Rent Reasonableness Reporting that will then be entered into PHA web as a method of record .

The Authority will catalog and maintain all required tenant file documents in accordance with federal requirements and the Authority’s internal policies. Michael Simelton, Executive Director, has assumed the responsibility of executing strengthened controls over tenant file documentation maintenance as of April 30, 2024.

2023-002 ALN 14.871 – Section 8 Housing Choice Vouchers Program – Eligibility The Executive Director acknowledges the finding and is following the auditor's recommendation as listed in the Schedule of Findings and Responses. Person Responsible for Correction of Finding: N. Lee Staton, Executive Director Projected Completion Date: June 30, 2024

FINDING 2023-004 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Summary of Finding: One person was primarily responsible for compiling and uploading student data, including poverty status for Real Time reports. There was no additional review or verification being done to ensure that the numbers being pre-populated on the grant applications were correct. There was no internal control in place, such as an oversight, review or approval process to ensure eligibility was properly determined. There was no October 1 Real Time report presented for audit for either fiscal year 2020-2021 or 2021- 2022, which would have been used to pull in enrollment and poverty information for the 2021-2022 and 2022-2023 grants, respectively. Therefore, we were unable to verify if the amounts reported in the grant application were correct. Additionally, we were unable to verify if the correct socioeconomic status was properly reported for any of the students. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Superintendent will retain the Real Time reports and other supporting documentation. Superintendent will also start verifying the numbers pre-populated on the grant application to ensure correct reporting. Another person will start reviewing the application prior to submission to IDOE. Anticipated Completion Date: April 1, 2024

To correct the student reporting process in NSLDS and in addition to the actions already implemented, the following actions will be executed: 1. By June 30, 2024, achieve 100 % accurate reporting by performing a bi-monthly internal reconciliation (July, September, November, January, March, May): a. Bi-monthly the first day of the month of the reporting period, the IEO and Registrar offices will prepare the Enrollment Changes List (ECL). The list will include withdrawals, LOA, graduations, and other enrollment status changes. The ECL will be conciliated with each academic program leader within 24 hours. b. 2 calendar days after (a), the Registrar will certify and sign the list to assure the enrollment status is accurate. c. 3 calendar days after (b), the Registrar Office and IEO will do the data entry in the NSLDS platform. d. 1 calendar days after (c), the reconciled Enrollment Changes List will be revised by the Assistant Dean of Licensing and Accreditation for validation. e. 2 days calendar after (d), the reconciled and validated ECL be revised by Academic Dean and Vice-President for certification of the accurate NSLDS reporting. 2. By June 30, 2024, achieve 100 % of accurate reporting to the NSLDS by continuing the implementation of the monthly process of reconciliation of withdrawals and verification of attendance in the SharePoint. 3. By June 30, 2024, assure quality improvement through re-training of all Registrar Office staff and academic programs leadership in the processes and responsibilities regarding compliance reporting of student status in NSLDS and our internal policies and procedures.

2023-001 Program Eligibility—Significant Deficiency United States Department of Education - ALN 84.268 Federal Direct Student Loans Program Criteria: Students who receive federal student aid are required to be enrolled in an eligible program. Eligible programs must be included in an institution’s accreditation and authorized by the State and the US Department of Education. Condition: The Law School disbursed federal student aid to 63 students, totaling approximately $2,115,747, enrolled in an ineligible program; the LL.M. program. Context: The impact was to 63 students over a four-year period. Cause: The Master of Laws (LL.M) Program was included in the Law School’s ECAR which was approved by the Department of Education. The Law School’s accreditation by the American Bar Association does not cover programs outside of the Juris Doctorate program. As such, the LL.M program was not properly accredited and therefore not an eligible program. The ECAR was subsequently amended to remove this program. Effect: Federal student aid funds were inappropriately disbursed to students in an ineligible program which resulted in the Law School entering into a settlement agreement with the U.S. Department of Education pursuant to which the Law School reimbursed and paid a fine to the US Department of Education. Questioned Costs: $2,115,747 Recommendation: We recommend the Law School review new or modified programs to ensure program eligibility requirements are met. Corrective Actions Taken: Upon notification from Department of Education regarding this concern, the Law School discontinued disbursement of Title IV funds to students of the LL.M. program and will not disburse those funds to students of that program until it receives additional accreditation. The Law School is currently working on obtaining accreditation from the Middle States Commission on Higher Education for its existing LL.M. and future Master’s degree programs. Responsible Person: David D. Meyer, President and Dean, (718) 780-7901, david.meyer@brooklaw.edu

Finding No. 2023‐009 – Eligibility (Significant Deficiency) State Department of Labor and Industrial Relations AL Number: 17.225 Program Title: Unemployment Insurance Condition The audit identified two payments where the recipients did not make the minimum number of work search contacts. Current Status of Corrective Action Plan Concur. Hawaii UI issued a memo, dated September 22, 2023, reminding the local offices of the minimum work search requirements under Administrative Rule 12‐5‐35(c) and for the adjudication unit to conduct a fact‐finding as to the reasons for the claimant’s non‐compliance. Hawaii UI is currently working on a project to enhance the work search process and requirements using a grant awarded to UI by US Department of Labor. The project will allow expansion to the work search reporting requirement on the front‐end of the online weekly claim certification process to include employer job search details. The process entails the use of Behavioral Insight techniques to encourage accurate reporting of the work search requirement and provide a log of their work search efforts. These enhancements will help claimants better understand UI program requirements including: -What claimants should report and why, -The reporting expectations at various decision points throughout the certification process while they still have time to meet the requirements, -Convey the consequences of intentionally providing false information or making mistakes during reporting, and -Imposing a denial of benefits for weeks in which the claimant does not meet the work search eligibility requirement. Person Responsible Sheryl Maligro, UI Program Supervisor Anticipated Date of Completion The enhancements to the Work Search Process are anticipated to be completed in June 2024.

2023-004 Student Eligibility – Control Deficiency View of Responsible Officials Management agrees with the finding and provides more context regarding the finding. Participant eligibility procedures are based on USC §3272 and §3102 were created for Adult Education Family Literacy Act (AEFLA)-funded adult schools. The procedures were distributed, and training was provided on March 31, 2023 to address prior audit Finding No. 2022-03. The enrollment record that did not meet the criteria for eligibility in the Single Audit Fiscal Year Ending 06/30/23 had an intake date of September 15, 2022, approximately six months before the procedures were distributed and training provided. A corrective action has already taken place through the March 31, 2023 procedures distribution and training. The AEFLA-funded adult schools are aware that all participants reported in the AEFLA reporting system, known as the National Reporting System, including participants in workplace adult education and literacy activities as defined in United States Code, Title 29, Chapter 32 Workforce Innovation and Opportunity Act §3272, must meet AEFLA eligibility requirements. Corrective Action Plan Participant eligibility procedures for AEFLA-funded adult schools based on USC §3272 and §3102 will be reviewed annually with AEFLA-funded adult schools through a technical assistance session. The procedures inform the staff of the AEFLA-funded adult school of the following: • The Workforce Innovation and Opportunity Act • The Adult Education and Family Literacy Act • The relevant US Code and Code of Federal Regulations • A definition of AEFLA-eligible individuals • Categories of funding and their purpose • The role of the US DOE Office of Career Technical and Adult Education • The role of the Hawaii state director for adult education • The role of the AEFLA-funded local service providers Contact Person: Dan Miyamoto, TA Community Education Specialist Curriculum Innovation Branch Office of Curriculum and Instructional Design Anticipated Completion Date: August 31, 2024

Federal Agency Name: Department of Treasury Pass‐Through Entity: Equal Justice Wyoming and Wyoming Department of Family Services Assistance Listing Number: #21.023 Program Name: Emergency Rental Assistance Program Finding Summary: The Medical Center was not able to provide supporting invoices for two of the testing selections. An additional selection contained a keying error. Responsible Individuals: Amy Spieker, Director Community Health and Analysis, and Erika Novick, Operations Manager Corrective Action Plan: The Program Director and Operations Manager will ensure all invoices are properly submitted and approved prior to including the expenses in the reimbursement requests. Program Director/Director of Community Health and Analysis will review draws/invoices to ensure amounts on supporting documents agree to the amounts submitted in the reimbursement requests. Finance will also revise Corporate Card Policy by June 30, 2024, to include expense reports being submitted in a timely manner. Finance will review open expense reports with card holder and their supervisor monthly. Anticipated Completion Date: April 1, 2024