Corrective Action Plans

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.

2025-002: Eligibility Determination Not in Place or Consistently Applied Across all Programs Issue: Eligibility documentation for TANF-funded services was incomplete, inconsistently applied, or missing required verification of residency, citizenship, income, resources, or other eligibility factors. Documentation was not always collected, reviewed, or signed before services were provided, and eligibility determinations were not supported by a uniform process. Corrective Actions: Porter-Leath will implement a standardized eligibility checklist that incorporates all TANF eligibility requirements, including verification of residency, identity, citizenship, household composition, income, resources, and work participation when applicable. 1. Staff must complete the checklist and compile all supporting documents before any TANF-funded benefits are provided. 2. When allowed under governing regulations, the Organization will also accept and retain documented eligibility determinations from other qualified programs, including SNAP, TANF acceptance letters or other qualifying documentation to determine eligibility, as part of the verification packet. 3. Each eligibility packet will require supervisory review and signature confirming that all required elements are present, accurate, and complete prior to approving eligibility. 4. The final approved packet will be maintained in accordance with DHS documentation and retention requirements. Responsible Personnel: Program Managers, Family Services Staff, Supervisors Timeline: Checklist finalized within 10 days; training within 30 days; full training and implementation immediately thereafter. Monitoring: Quarterly file reviews will confirm that eligibility checklists are correctly completed, include required documentation or accepted verification from other programs when applicable, and contain supervisory approval.

Moving to Work Demonstration Program -Assistance Listing No. 14.881 Recommendation: We recommend that management assign a designated individual to ensure rent reasonableness, income verification, and recertifications are completed accurately and on time, in accordance with HUD guidelines and the Authority's administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Director of HCV Program Administration and Ass istant Director of HCV Program Administration will be in charge of reviewing all Rent Reasonableness. Name(s) of the contact person(s) responsible for corrective action: Teresa J. Gonzalez, and Darrell Mciver. Planned completion date for corrective action plan: Effective immediately.

2025-002 – Child Nutrition Cluster – Eligibility – The District is aware of the missing eligibility documents for the Child Nutrition program and will implement new procedures and a plan to reduce the missing documentation. Responsible Officials – Heidi Engel, Enrollment & Transportation Coordinator, and Jessica Christensen, District Food Service Manager Anticipated Completion Date – The District will correct this in the subsequent fiscal year.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Will need to meet with academic records and determine if Doctorate program Dissertation 1-hour course can be coded and reported as full time to NSLDS Person Responsible for Corrective Action Plan: Academic Records / Regina Bolding Harned - Registrar / Allison Sullivan – Director of Financial Aid Anticipated Date of Completion: 12/5/25

RCAP Solutions and the Rental Assistance Division is committed to ensuring our administration of the Housing Choice Voucher program is timely and accurate. The department recently implemented a new voucher management software which maintains improved tracking and management tools. Additionally, the department management is looking forward to utilizing the new software for improved communication with participants and owners and to utilize the integrated participant portal to reduce the time it takes for documentation to be processed. In addition, the department management is committed to working with the team to answer questions, improve performance, and decrease the time it takes for program representatives to administer the program all while maintaining accuracy and customer service.

Below you will find our corrective action plan to address the one finding in our FY 2025 Federal Single Audit, which received an unmodified opinion from our auditor Audit Finding #: 2025-1 Eligibility Determination Grantor: Department of Health and Human Services Federal Program Name: Low Income Home Energy Assistance (LIHEAP) Federal Assistance Listing (CFDA#): 93.568 Description: During the audited year July 2024 – June 2025, Access paid benefits for one individual whose income was over the threshold of 60% of the CT state median income. The income was documented, but incorrectly calculated. Statement of Concurrence: Access management concurs with the audit finding: Corrective Action: Access has put in place written procedures as follows: ○Access will provide additional training support and resources to staff to ensure that all LIHEAPapplications are certified in an accurate manner. ○Access will expand its internal file audit process to continue maintining a master log of all filesreviewed and also note any major findings so a timely response can be made.

Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding. This was an unusual circumstance where a student was withdrawn from the college before they were awarded any federal aid. The director has put in place procedures to review the eligibility for federal aid of any student who withdraws to determine whether a post withdrawal disbursement is appropriate. Anticipated Completion Date: January 1, 2026

Date: October 16, 2025 To: Angela Baker, Finance Director From: Melissa Johnson, Early Education Director CC: Candy Scott, Executive Director Subject: NC Pre-K Audit • Purpose: To provide information on the requested review documentation for 40 child files for an NC Pre-K audit. • Details: While gathering requested information for an NC Pre-K audit, it was discovered that 11 of the 40 requested children’s files did not have review information in our online application portal, Survey Apply. The applications were processed following all guidelines and procedures, and supporting documentation is available. These documents include income spreadsheets, scorecards, and the date entered in the APP system. The review information, however, is not available in the online application database, and the reason for this has not been determined. Jennifer Williams, Office Manager, and I have both tried to recover this information without success. The requested files missing this information are Kever Pinto, Jackson Millsap, Brixton Beale, Zoey Matthews, Amir Salimov, Nolan McCowan, Rex Klein, Caleb Bernabe, Joseph Holland, Ocean Davis, and Bryson Bunch. • Outcome/Action Taken: Discovery of this possible glitch in the online application system has led us to put additional processes in place to ensure that this information is available upon request in the future. In addition to maintaining a saved copy of the income spreadsheet and scorecard on our internal server, we will now begin saving a copy of the review for each application that is processed. We are in the process of updating our NC Pre-K guidelines. This change will be reflected in these guidelines.

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022 and 34 CFR 682.610) Condition Found Of the 16 students selected for enrollment reporting testing, seven students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Upon further inquiry, there were an additional 206 students included in the same batch reported to NSLDS that were not reported timely. Views of Responsible Officials and Planned Corrective Actions NELB is revising the use of the customized report to more accurately reflect student records and will leverage the student information system, Jenzabar, to produce enrollment reports. The Office of the Registrar, the Office of the Controller, and Office of Financial Aid will review the file for NELB graduates in the month of May and ensure 100% compliance with graduating reporting after submission. As part of the NELB year-end closing procedures, there will be an additional review in the month of June every year to ensure that the file of NELB graduates provided to the National Student Loan Data System is consistent and accurate. This year-end closing procedure will be initiated by the NELB Chief Financial Officer and will coordinate with the Office of Financial Aid, Office of the Registrar and the Controller’s Office. Names of Contact Persons Responsible for Corrective Action: Office of Financial Aid (Jenny Aquiar), Office of the Registrar (Max Brodsky) and the Controller’s Office (Sean Bendall). The NELB Chief Financial Officer (James White) will work collaboratively to ensure that the corrective action plan is completed by each of these three NELB departments by June 30, 2026. Anticipated Completion Date: June 30, 2026

Income Eligibility Audit Finding Response: Over-Income Eligibility Determination Finding: During the audit review, it was identified that the Authority erroneously assigned a unit to a potential tenant whose initial income exceeded the program's income eligibility threshold. Although the applicant's income subsequently decreased prior to move-in, the Authority acknowledges that eligibility should have been confirmed and properly documented before final unit assignment. The tenant vacated the unit within six (6) months of occupancy. Authority Response: The Meridian Housing Authority (MHA) acknowledges the error in processing the applicant's income eligibility determination and recognizes that the assignment did not fully comply with HUD's established income verification and eligibility requirements. The Authority has reviewed the circumstances surrounding this incident and has determined that the error resulted from a timing and documentation oversight during the final verification phase. Corrective Action Taken: I. Immediate Case Review: The applicant's file was reviewed to verify all documentation and identify procedural gaps that led to the incorrect eligibility determination. 2. Staff Retraining: All occupancy and eligibility staff have been retrained on HUD income eligibility requirements, verification standards, and documentation retention procedures. 3. Revised Verification Protocol: The Authority has implemented an additional pre-move-in eligibility verification checkpoint to confirm applicant income status immediately prior to lease execution, and integration of a final income eligibility checklist into all applicant files. 4. Supervisory Review Requirement: A management-level review and approval is now required for all move-in certifications where an applicant's income falls near the program threshold. 5. Monitoring and Compliance Audit: Internal quality control reviews will be conducted quarterly to ensure continued compliance with HUD eligibility and verification standards. Anticipated Completion Date: Cunently in progress and will be completed by 3/31/2026 and ongomg. Contact Person: Ronald J. Turner, Sr. 2425 E Street, Meridian, MS 39301 601-693-4285

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University enhance system controls to ensure disbursements match awards. View of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office normally attempts to disburse aid within the term for which it is designated. However, unusual workloads brought about by FAFSA disruptions, staffing reductions, and duty changes led to delays in the disbursement of some aid for the 2024-2025 school year. A significant amount of Fall 2024 and Spring 2025 aid was not disbursed until August and September 2025. While this does not fall outside of rules set by the Department of Education, later disbursements caused extra challenges for the Accounting Team and meant a delay in receiving federal funds into the organization. As of September 30, 2025, All Pell Grant and Federal Supplemental Education Opportunity Grant Funds for 2024-2025 were been dispersed — and the matching amounts have been certified by the Department of Education. All federal loans for 2024-2025 have been dispersed, with the exception of 11 students. Nine of the students still have not accepted or declined their loans. They have been given until October 15, or the loans will be rescinded. Two more students had errors that stopped disbursement. This issue is being resolved by the team within the next week. Actions taken to resolve the issue: The Financial Aid team is taking the following actions to ensure that financial aid is disbursed in the term it is awarded. (Note: there are always a few exceptions due to highly unusual circumstances.) • Restructuring the awarding process to disperse funds soon after Census Date, before manually checking each record for anomalies. In 2024-2025, the manual checking process was completed first, which dramatically delayed disbursement. • Restructuring duties to spread out the awarding processing among more than one team member to allow for it to be completed more quickly. • Reviewing and enhancing financial aid policies governing the awarding and disbursing process to ensure that the amounts match at the end of the fiscal year (May 31) for spring and fall terms, and at the end of the award year (August 1) for the summer term. Name(s) of the contact person(s) responsible for corrective action: Tricia Harris, Financial Aid Director Planned completion date for corrective action plan: The Financial Aid Office has already begun implementation of this action plan and will complete implementation before the end of the current school term.

2025-001: Missing Exit Counseling Documentation - 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 four students out of forty did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be a instance of noncompliance with the Eligibility Compliance Requirement. This is a repeat finding, see Prior Year Audit Findings 2024-002. Corrective Action Plan LLCC has developed reports to identify students who require exit counseling. The Financial Aid Compliance Coordinator is responsible for overseeing and administering exit counseling process for students who are graduating, withdrawing, or dropping below half-time enrollment. Responsibilities include ensuring compliance with federal regulations, providing accurate loan repayment information, and maintaining proper documentation of completed counseling sessions. Responsible Person for Corrective Action Plan Alison Mills Implementation Date of Corrective Action Plan FY26

Corrective Action Plan (Management Response): The District acknowledges the finding and has initiated corrective measures:1. Policy Development: Draft comprehensive written policies and procedures addressing procurement, allowable costs, eligibility, reporting, and record retention for all major federal programs. 2. Approval and Adoption: Policies will be reviewed and formally adopted by the Board of Trustees prior to acceptance of further federal grants. 3. Training and Implementation: Staff responsible for federal program administration will be trained on the new procedures. Training materials will include checklists and step by step guides to ensure consistent application. 4. Monitoring: The District will conduct quarterly reviews of federal programs (if applicable) to ensure compliance. Exceptions will be documented and corrective action taken immediately.

Corrective Action MHA is now fully staffed with a current recertification reporting rate of over 96%. New staff members have been hired, trained and fully onboarded. An outside consultant was retained prior to staff hiring and processed all delinquent recertifications in the spring of 2025. Additional staff training is being scheduled. Increased quality control procedures are being designed and implemented in coordination with a consultant to ensure ongoing activities meet Authority standards as well as Federal requirements.

Tenant files have not regularly been reviewed for QC. Management will immediately set up regular reviewing of random files to be sure files are processed correctly and rents are being calculated according to HUD guidelines. Management agrees with the finding and takes the recommendations of the auditor to correct it.

Tenant files have not regularly been reviewed for QC. Management will immediately set up regular reviewing of random files to be sure files are processed correctly and rents are being calculated according to HUD guidelines. Management agrees with the finding and takes the recommendations of the auditor to correct it.