Corrective Action Plans

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and processes the R2T4 calculations. The Director will reassess R2T4 calculations and verify that only aid with signed promissory notes are being included in R2T4 calculations. Internal policies and procedures have been updated to ensure accurate calculations. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024

Recommendation: We recommend that management ensures policies and procedures are in place to verify college eligibility for matching fund requirements and to confirm that waivers are obtained in future years. Management Response: Management concurs with the finding. It was assumed the college would be auto-designated as an eligible institution based on Integrated Postsecondary Education Data System (IPEDS) data. New procedures have been implemented. The college will submit the Title III/V application annually regardless of the IPEDS status.

Inaccurate Packaging of Federal Direct Loans (FDL) Planned Corrective Action: Shorter University will provide additional training to Financial Aid Staff regarding the importance of reviewing students financial aid offers after manual adjustments are made. The training will include practice scenarios. In addition to training staff, Shorter University's Director of Information Technology is creating a quality control report that will identify students who may be eligible for a subsidized Stafford loan but have not received one. The report will be monitored by the Assistant Director of Financial Aid Systems who will review the students' financial aid. The quality control report will ensure the proper subsidized and unsubsidized Stafford loan allocation. A manual adjustment error was made to a student's financial aid offer, after financial aid was accepted resulting in an under awarding of a Stafford loan. A $3,500 unsubsidized loan to subsidized loan swap will be completed to hold the student harm less and correct the manual adjustment error. Person Responsible for Corrective Action Plan: Colleen Lassiter Anticipated Date of Completion: Training will be completed November 8, 2024 and Quality Control Report will be completed by December 15, 2024.

JUBILEE SENIOR HOMES, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Jubilee Senior Homes, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2023, to June 30, 2024 The findings from the June 30, 2024, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FINANCIAL STATEMENT AUDIT None noted. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2024-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.157. Program - Section 202 Supportive Housing for Elderly Persons Significant Deficiency Recommendation: Jubilee Senior Homes should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Senior management now recognizes that additional resources must be utilized during periods of progressive discipline with a frontline employee, to ensure the timely completion of recertifications. A new Manager was hired for Jubilee Senior Homes through an internal transfer and this individual is in the process of catching up on all needed paperwork as a top priority. The John Stewart Compliance Department will perform a 100% file audit upon completion of the outstanding certifications. Additionally, the assigned Regional Manager is performing monthly spot checks on files and reviewing a recertification status report for monitoring of progress and ongoing compliance. The property management company has implemented a roving support team that will assist managers who are struggling to meet their deadlines, ensuring compliance and helping to maintain performance standards moving forward. The roving support team was established in 2024, partly due to our commitment to ensure HUD deadlines are met. The property management company has also implemented monthly monitoring at their corporate office by the Property Management Document Information Specialist and HUD Secure Coordinator. This individual is monitoring monthly submissions to TRACs by all properties, and flagging underperformance on annual recertifications in addition to other HUD key performance metrics. The report of data from TRACs is circulated to Regional Managers, Directors, and senior leadership every month. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

3250 SACRAMENTO HOUSING, INC. 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN October 30, 2024 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2023, to June 30, 2024 The findings from the June 30, 2024, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FINANCIAL STATEMENT AUDIT None noted. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2024-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.157. Program - Section 202 Supportive Housing for Elderly Persons Significant Deficiency Recommendation: 3250 Sacramento should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Senior management now recognizes that additional resources must be utilized during periods of progressive discipline with a frontline employee, to ensure the timely completion of recertifications. A new Manager was hired for 3250 Sacramento through an internal transfer and this individual is in the process of catching up on all needed paperwork as a top priority. The John Stewart Compliance Department will perform a 100% file audit upon completion of the outstanding certifications. Additionally, the assigned Regional Manager is performing monthly spot checks on files and reviewing a recertification status report for monitoring of progress and ongoing compliance. The property management company has implemented a roving support team that will assist managers who are struggling to meet their deadlines, ensuring compliance and helping to maintain performance standards moving forward. The roving support team was established in 2024, partly due to our commitment to ensure HUD deadlines are met. The property management company has also implemented monthly monitoring at their corporate office by the Property Management Document Information Specialist and HUD Secure Coordinator. This individual is monitoring monthly submissions to TRACs by all properties, and flagging underperformance on annual recertifications in addition to other HUD key performance metrics. The report of data from TRACs is circulated to Regional Managers, Directors, and senior leadership every month. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: An incorrect satisfactory academic progress tracking status was assigned to a single student, which resulted in the one student receiving federal aid for the spring semester when they should have been marked as ineligible. The spring disbursement was corrected promptly when uncovered and funds have been returned to ED. An enhanced system is now in place to more clearly track the satisfactory academic progress of students who take a leave of absence from the university and return without demonstrating satisfactory academic progress at a different school. Anticipated Completion Date: 11/1/2024

Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process. 3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign. 3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal. 2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members. Anticipated Completion Date: 11/1/2024

Management’s Response- New Management has taken over responsibilities as of May 2024 and will review and implement stronger policies and procedures pertaining to tenant files

Contact Person Nichole Bristlin, Executive Director. Corrective Action Plan Management plans on adding a signed lease step to the quality control worksheet to ensure signed leases are included in all files. Planned Completion Date for CAP June 30, 2025

The Board of Trustees has designated the responsibility of overseeing the accounting and financial reporting to the District’s superintendent, Jeff Byrd. See the District’s responses to this finding in the letter provided by the District on page 103. Finding 2024-002 - Significant Deficiency - Verification of Eligibility for Free or Reduced Price Meals The District has reviewed the findings and identified areas of improvement for Child Nutrition. The district will audit the Child Nutrition information after verification each year to ensure that the correct changes have been made in the software. Internal Controls will be reviewed and strengthened to ensure proper coding moving forward.

The District Corrective Action Plan is to follow the corrective action plan set forth in the site review by the State of Alaska Child Nutrition Program to have intense staff meetings with cooks and meal counters to make sure point of service meal counts in the cafeteria or in the classroom are clear and accurate for reporting. School sites visits, discuss counting at point of service, claiming, reimbursable meals, production records, ordering, safety and hygiene. Attend monthly zoom with School Meals Program (Dept. of Education).

The Lac Courte Oreilles Ojibwe University (LCOOU) has currently implemented an admissions procedure to guarantee that all self-identified United States (US) federally recognized American Indian/Alaska Native (AI/AN) students’ documentation of tribal enrollment is verified, collected, and secured. All students that apply to the institution who self-identify and are affiliated with a US federally recognized tribe, band or nation must provide verification of tribal enrollment to be fully admitted as an LCOOU student. If this documentation is not provided, students can still register; however, will not be included in the annual Indian student count submitted to the Bureau of Indian Education. All continuing students who have matriculated to the institution with a self-identified tribal affiliation will be reviewed to confirm that all tribal enrollment documentation is collected and securely stored. The LCOOU Registrar’s office will closely monitor student’s files throughout the academic year to make certain all files are completed.

Eligibility Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has reviewed its current procedures for awarding Title IV funds and modified edit reports to find Pell-eligible students who had previously been inactivated or not yet awarded for an aid period to be reviewed and awarded accordingly. Name(s) of the contact person(s) responsible for corrective action: James Martin, Director of Financial Aid and Jody Finnegan, Associate Director of Financial Aid Planned completion date for corrective action plan: 09/18/2024

Finding 2024-001 - Moving To Work Demonstration Tenant Files - Eligibility - Internal Control over Tenant Files- Noncompliance and Significant Deficiency Moving To Work Demonstration – subsidy ALN14.881 Corrective Action Plan: Effective November 1, 2024, the Authority will implement a Compliance Coordinator position for the review of tenant files on a regular basis. The Compliance Coordinator will be under the immediate direction of the Finance Director, so as to be independent of the public housing and voucher programs. Person Responsible: Alan Zais, Executive Director Anticipated completion Date: March 31, 2025

Finding: 2024-004 Eligibility Federal agency: U.S. Department of Agriculture Federal program Title: Child Nutrition Cluster Federal Assistance Listing Number: 10.553 and 10.555 Federal Award Identification Number and Year: 212MN061N1199- 2024 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-213-000 Award Period: June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend that District management and financial personnel have internal controls designed to ensure proper documentation of eligibility for Child Nutrition. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will continue to work at ensuring there is a second person to review applications. Name of the Contact Person Responsible for Corrective Action Plan: Justin Dahlheimer, Superintendent Planned Completion Date for Corrective Action Plan: June 30, 2025

Student Financial Assistance Program Cluster - Department of Education Federal Financial Assistance Listing #84.063 Federal Pell Grant Program P063P222212,P063P232212 Eligibility Significant Deficiency in Internal Control over Compliance Finding Summary: One student was not awarded Pell assistance during the summer term as the student's FAFSA was not completed at the time the financial aid office was determining award eligibility. The student later completed the FAFSA within the award year and became eligible for a retroactive disbursement of Pell assistance; however, the financial aid office did not provide the student a retroactive disbursement of Pell. Responsible Individuals: Karrie Morgan, Director of Financial Aid Corrective Action Plan: Management will review procedures and control processes over monitoring retroactive disbursements. Anticipated Completion Date: October 31, 2024.

2024-001 Name of Contact Person: Anita Ramachandran, Interim PH Director and Victor Isler, Assistant County Manager - Successful People Corrective Action: Management promptly provided training to staff that teen clinic services are billable based on income and eligibility requirements. Proposed Completion Date: Management has already addressed this with staff.

FINDING 2024-007 Corrective Action Plan The Organization addressed the necessity of implementing a system of internal controls that would properly document the eligibility requirements set forth in the SSVF program during its most recent program audit (scope period January 1, 2022 – December 31, 2023) with the U.S. Department of Veterans Affairs. Subsequent to the program audit, the Organization instituted a corrective action plan to follow that process. In a letter dated August 21, 2024, the U.S. Department of Veterans Affairs stated and confirmed that “corrective actions were taken in response to recommendations issued by the Office of Business Oversight (OBO) in its SSVF Grant Programmatic Review.” Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: August 21, 2024

Memo: Audit Findings 2023-2024 Submitted by: Karson Kent, University Registrar Date: 9/13/2024 Below is a description of and explanation for the 3 findings from the 23-24 audit pertaining to the Registrar’s office. Also included is an explanation of how the findings have been addressed, and the action that has been taking to prevent them from happening in the future. ETBU uses the National Student Clearinghouse for enrollment reporting to the National Student Loan Data System. Case 1 – Student 1 withdrew from the spring term on 1/29/2024, but withdrawal was reported as end of fall 2023. Case 2 – Student 2 withdrew from the spring term on 1/31/2024, but withdrawal was reported as end of fall 2023. Error: The enrollment report was being pulled and sent to the National Student Clearinghouse (NSC) after the census date when roster certifications and withdrawal requests, up to that point, had been processed. Students 1 and 2 both withdrew during the roster certification period, which was before the census date, but after late registration had ended. Their withdrawals were processed in the Registrar’s office before the initial enrollment report was pulled, and since they received W’s for the term, they should have been reported for the term to the NSC. In researching the finding, it was discovered that the system is set up to only include students in the enrollment report who are enrolled as of the date that the first report is pulled. This means that students 1 and 2 were never included in the initial enrollment report for spring 2024, and therefore weren’t captured on any of the subsequent of term reports that notify the NSC of enrollment changes throughout the semester. This made it look like they never attended ETBU in the spring, which is why the NSC showed their withdrawal to be the end of the fall term. Action Taken: Students 1 and 2 enrollments for the spring 2024 term have since been corrected with the NSC. Additionally, since learning how the report is set up, the Registrar has been in discussion with the Director of Financial Aid and Institutional Research, to figure out the best timeline for processing the enrollment report moving forward. It has been determined that the initial enrollment report needs to be submitted as soon as late registration ends, so that everyone who is registered for the term is captured on the report. Once the roster certification period is over, students who have been reported as not attending will be dropped, and any University withdrawal request will be processed. Once those things have been done, the Registrar will submit the first subsequent of term enrollment report to the NSC. This will ensure that any enrollment changes that have happened after registration ended up to census date get reported within the time frame needed by Financial Aid. Case 3 – Student 3 was reported as withdrawn after the fall 2023 term, but actually graduated. Error: Student 3 should have been reported to the NSC as a fall 2023 graduate, but was not included on the graduation report. In investigating it appears student 3’s degree was conferred after the fall graduation report had already been submitted, and the Registrar was not made aware of the discrepancy. Since student 3 was not reported as graduated for fall 2023, and was not enrolled in the spring 2024 term, they were considered withdrawn through the the NSC. Action Taken: Student 3’s status has been changed from withdrawn for the fall 2023 term to graduated, with the NSC. To prevent this from happening in the future, the Graduation Certification Officer has been made aware to notify the Registrar anytime a degree is conferred outside of the normal time frame, so that it can promptly be reported to the NSC. As an added measure moving forward, after degrees have been conferred for a standard term, the Records Assistant will double check all the degrees conferred to help ensure that nobody was missed.

Students in the Pell Grant Verification Status (PGVS) file will be reviewed by a Financial Assistance Advisor for Pell and another Financial Assistance Advisor for Verification to make sure all appropriate flags are set correctly in the system. Once this review is complete, Pell will be re-originated. If students persist in the PGVS file, a help desk ticket will be filled with our Information Technology department to investigate why the record is still showing as not verified. This new review process will provide additional oversight in the verification process.

The College acknowledges that a submission error occurred in Spring 2023, resulting in several students not being included in the routine semester enrollment submissions to the National Student Clearinghouse (NSC). Beginning in Spring 2024, our Institutional Research department initiated a comprehensive process to resubmit corrected enrollment files to the NSC, covering Spring 2023, Summer 2023, and Fall 2023. In collaboration with NSC, we followed their established process to rectify the error, which required reloading each submission one at a time in succession from the original submission with the error. This process caused delays in our subsequent submissions until the corrections were fully completed. To prevent recurrence, we have implemented enhanced checks and controls prior to each submission to review the file and file size to ensure the correct number of students are submitted to NSC. Additionally, all submissions post-Spring 2023 have been reviewed, and we have confirmed that this was an isolated incident.

Finding Summary: One instance was identified in which the student was over-awarded Federal Pell assistance. The Watertown location does not use the auto package tool within Anthology for awarding students; rather, awarding student assistance is a manual process. The incorrect line item was read on the PELL chart resulting in the student being over-awarded Pell assistance in the summer of 2023. Responsible Individuals: Lauren Svanda, Director of Financial Aid Corrective Action Plan: When implementing the FAFSA changes for 2024, the SIS was configured to utilize the Auto Packaging function for the Watertown location which significantly reduces the likelihood of a student being awarded the incorrect amount of PELL. After each student is Auto Packaged, it is reviewed to ensure accuracy of the PELL calculation. Anticipated Completion Date: Resolved – Spring 2024

The Housing Manager will complete quality control file reviews from a random sampling of applicant files to ensure that they contain all required documentation for eligibility determination. An external agency will be hired to conduct a complete a full file audit of active files.

Planned Action: Family Pathways Food Access and Finance staff will communicate the audit finding to the appropriate authoritative TEFAP bodies: the Minnesota Department of Human Services, as administrator of Minnesota’s TEFAP program and issuer of Minnesota’s TEFAP Policy and Operations Manual, as well as Second Harvest Heartland, as pass-through agent and contractor of TEFAP food distribution. In addition to communicating the audit finding, Family Pathways will confirm what authorities exist for Family Pathways, as a TEFAP provider, to implement additional internal controls, including but not limited to: modifying current DHS TEFAP forms and applications, and/or requiring additional client application forms. Family Pathways would like to note that the current DHS TEFAP Policy and Operations Manual 2023, effective for the audit period indicated above, states that “additional eligibility criteria cannot be imposed on participants” and that “TEFAP Providers agree to make it as easy as possible for those in need to access food.”

Recommendation: We recommend that a review is implemented which compares enrolled credits to Pell award to ensure all Pell funds are awarded at proper amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With our new student information system, Anthology Student, there are regulatory controls in place that ensure that the Pell awards are awarded at proper amounts per enrolled credits. All undergraduate students are packaged Standard Academic Year (SAY) beginning with the 2024-2025 academic year. This packaging method will ensure that all Pell eligible students will receive their entire Pell award amount for the year. Name(s) of the contact person(s) responsible for corrective action: Andrea Padilla-Rosas Planned completion date for corrective action plan: August 2024