Corrective Action Plans

Finding 2024-001 Eligibility Management agrees with the summarized findings. Management has reviewed the current policies and procedures to ensure that the steps to be performed are clearly stated for the underwriting and disbursement staff. Management has discussed the findings with staff members and will provide additional training as deemed necessary.

U.S. Department of Health and Human Services Program Name: Maternal and Child Health Services Block Grant Federal Assistance Listing Number: 93.994 Significant Deficiency, Nonmaterial Noncompliance - Reporting Finding 2024-006 Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per 2 CFR 200.334 the recipient must retain all Federal award records for three years from the date of submission of their final financial report. Condition: During the audit we tested 13 reports and noted the following: a) There were four (4) instances out of 13 reports tested where the submitted reports were unable to be provided, including the date of submission for the reports. b) There were 10 instances out of 13 reports tested where the County was unable to provide evidence the report was reviewed prior to submission. Questioned Costs: None. Effect: By not having the required documentation and underlying support, the County is not able to demonstrate compliance with the applicable requirements. Cause: The County did not have a formal policy to ensure documentation was retained to evidence review and submission of all reports. Recommendation: The County should consider creating a formalized policy to require all submitted reports and underlying data are retained in accordance with the Uniform Grant Guidance requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: See Corrective Action Plan prepared by the County. The Health Department will create and adopt a policy to ensure that federal award reports and data are retained in accordance with Uniform Guidance. The Health Department will also collaborate with NCDHHS to develop a procedure to address circumstances when the required report consists of answering a NCDHHS survey or form that does not have “save” or “download” capability, making it difficult to retain the required documentation. In addition, the Health Department will develop a standard operating procedure whereby program managers document that they have reviewed federal award reports prior to submission. While review of grant reports is common, the Health Department did not have adequate documentation to demonstrate completion of this step. Completion Date: April 30, 2025 Responsible Person(s): Jana Harrison, Business Operations Director

U.S. Department of Agriculture Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Material Weakness – Eligibility Finding 2024-003 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: For the WIC program, we were unable to obtain evidence to corroborate the review of the Senior Quality Training Specialist eligibility determinations. Questioned Costs: None Effect: By not having the required documentation to support the review by the Senior Quality Training Specialist, the County is unable to support their assertion the cases are properly reviewed by an individual other than the preparer. Cause: County does not have a formal policy for documenting evidence of the review by the Senior Quality Training Specialist. Recommendation: We recommend the County implement a policy to ensure the review by the Senior Quality Training Specialist is properly documented and retained. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: See below Corrective Action Plan prepared by the County. Program leadership will collaborate The Total Quality Team i.e. Compliance Coordinator and Quality Assurance Coordinator to revise current internal monitoring policies and procedures. Internal monitoring tools will be created to align with state and federal guidelines. Following review with Total Quality, staff will be trained on revised monitoring processes, policy, and procedures. WIC Policy A-19 mandates the use of the State Agency's WIC program monitoring tool for conducting record audits. To ensure proper implementation, this policy will be reviewed with the Senior Quality and Training Specialist. The WIC Senior Quality Training Specialist and WIC leadership will maintain audit documentation in accordance with Policy A-13, Retention of Administrative Documents, established by Mecklenburg County Health Department. The following the phases of the corrective action plan will be completed by March 31st, 2025. Phase1: Review of Federal Guidelines Phase 2: Review Of State Guidelines Phase 3: Internal Policy Review Phase 4: Creation and Implementation of new internal monitoring processes. Phase 5: Staff Training Completion Date: March 31, 2025 Responsible Person(s): WIC Director, Ali Raza and Senior Quality and Training Specialist, Tamika Moore

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Medical Assistance Federal Assistance Listing Number: 93.778 Material Weakness and Nonmaterial Noncompliance – Eligibility Finding 2024-001 – Repeat Finding Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria: a) Self-attestation wages should be compared to information in NC FAST. b) All countable resources should be confirmed and recalculated and ensure they are computed accurately in NC FAST. c) An OVS inquiry must be completed and agreed to information reported in NC FAST. d) An ex parte review is required every six (6) to twelve (12) months. e) Forced eligibility cases should maintain the proper documentation within NC FAST to support the determination for the required forced eligibility. f) For Aged, Blind, or Disabled cases or MQB programs the Register of Deeds is required to be verified and documented in the case file g) The caseworker should prepare and submit a DMA-5097 form in the case of incompatible income verification and self-attestation income as described in the Eligibility Review Document. h) For countable earned and unearned income, income conversion and computation was done in accordance with policy manuals, and have to agree to amounts in NC FAST. Condition: The following are the results of nonmaterial noncompliance noted for each criteria listed above out of the 122 program participants selected for testing: a) There were four instances where the participants self-attest wages did not agree to the wages entered into NC FAST. b) There were three instances where the countable resources were inaccurate within NC FAST. c) There was one instance where the OVS query was not run at the time of the determination. d) There were two instances where the ex parte review was not completed timely. e)There were two instances where the support for the forced eligibility was not properly maintained in NC FAST. f) There was one instance where the Register of Deeds support was not maintained in NC FAST. g) There were five instances where the income was incompatible between the income verification and self-attestation income but no DMA-5097 was sent. h) There were two instances where countable income was not properly included in NC FAST. Lastly, there were 6 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely. Context: There were 14 out of 124 unique participants tested with the errors noted above. Questioned Costs: None noted. Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: The County will take a multi-faceted approach to mitigating such errors in the future. Training: The Staff Development Unit within the Economic Services Division (ESD) will review the findings and create and deliver training to staff that determine Medicaid eligibility and their supervisors and managers to address the specific errors identified. This training will be delivered by the end of January 2025. Responsible Individual(s): Staphon Snelling, Training and Development Manager Anticipated Completion Date: January 31, 2025 Process Improvement: The Economic Services Division (ESD) has trained new hires in one function of the Medicaid program, for example, processing applications or recertifications/changes. This has built a stronger foundation before they learn the second function of their assigned program. Our Supervisors and Quality and Training Specialists are working even more closely together to follow up on errors and help ensure identified challenges in training and mentoring are addressed before they are released from mentoring. Ex parte reviews are directly assigned for Family and Children’s Medicaid and for Adult Medicaid, renewals are placed into Current for workers to get next and work as soon as possible. Family and Children’s Medicaid will provide second-function training for current employees on recertifications. Adult Medicaid has 10 currently in mentoring for recertifications. Kim Konior is responsible for monitoring ex-parte review reports and MAGI cases are being assigned out by Supervisor Collin Smith and Jannicia Austin for Adult Medicaid. Each month the Medicaid managers Kim Konior and Lynn Martin review the progress and update the Assistant Division Director on the current status and plans to continually improve in this area. Supervisors will ensure that second party reviews are reviewed and corrected for any internal control and eligibility errors within 5 business days of receipt. Supervisors ensure that updates to the quality sampling tracking log are completed by the 20th day of the following month. Responsible Individual(s): Kim Konior and Lynn Martin Medicaid Program Managers and Staphon Snelling, Training and Development Manager Anticipated Completion Date: Will begin Family and Children’s Medicaid recertification training in third Quarter of FY25 (Jan 2025) and end by the end of 2nd quarter of FY 2025 (December 2025). Quality Sampling and Accountability: The Quality and Training Unit complete monthly quality sampling for Medicaid. Error trends are shared with the managers and their supervisors, who work collaboratively with Quality and Training staff to coordinate appropriate strategies to train and coach staff to mitigate errors moving forward. Supervisors review specific quality sampling results with their staff. The supervisor when necessary and appropriate, address continued errors using an individual Corrective Action Plan with the worker to include refresher training, additional second party review and/or initiating the formal documentation process. Managers review quality sampling results with supervisors quarterly to follow up on errors addressed, trainings completed and progress with individual Corrective Action Plans. Supervisors, front line, and Managers have quality measure on their workplan to ensure timely response and accountability is held. All levels are to achieve an average quality score of 80% quarterly. Note that this error was found at a much higher rate last year. We are continuing to reinforce this importance and expect the improvement that we have achieved within one year will continue to grow as we keep reinforcing quality into our everyday work culture. Protocol for second party reviews provided 08/2024 in place for ESD. Cases will be checked by Quality and Training by the last day of each business month. Quality and Training will check and provide feedback to workers within 2 business days of the case being checked. Corrections of errors and rebuttals for QS errors should be submitted within 5 business days of feedback being provided and a response will be received within 3 business days of receipt. The Quality Assurance team in OSI/CFAS conduct an independent evaluation and review the second party review process at the divisional level to ensure review was accurate and errors were corrected timely. This team reports out to ESD Leadership quarterly on findings. Responsible Individual(s): Kim Konior and Lynn Martin, Medicaid Program Managers & Julio Rosales, Quality Assurance Supervisor, Staphon Snelling Training and Development Manager Anticipated Completion Date: Currently Ongoing

Management Response: The College acknowledges the finding and agrees with the recommendation to proactively obtain the waiver to ensure compliance with federal matching requirements. For the fiscal year 2025, we have already verified and obtained the waiver letter, ensuring that the College qualifies for the matching exemption. To prevent future occurrences, we have added the waiver verification process to our compliance tracking spreadsheet. This ensures that the waiver is requested and obtained from the appropriate department each year and documentation is presented to management to verify it has been obtained. We are committed to maintaining accurate oversight of matching requirements and will take all necessary steps to ensure full compliance moving forward.

MATERIAL WEAKNESS 2024-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV and Enrollment Reporting Condition The College's official policy is to be an attendance taking institution. However, the date of the institution’s determinations for withdrawals does not fall within the required 14 day period, and it instead follows that of institutions that are not attendance taking. Additionally, during testing, it was identified that the College's quality control processes for Return to Title IV calculations were not completed within a timely manner, and that process determined that calculations needed to be adjusted for some of the students. Those corrections were not made within the required 45 day periods, and, as a result of the late corrections, the NSLDS enrollment reporting also had to be updated outside of its typical window. Recommendation We recommend that the College review and update its policies to ensure that all compliance requirements are met within the required timeframes associated with those policies, as well as recommend that the College review its controls to ensure that accurate Return to Title IV calculations are completed in a timely fashion. Comments on the Finding Recommendation Barton County Community College understands the finding. Action Taken Barton’s Director of Financial Aid has informed the following Barton personnel of the finding: • Vice President of Instruction, • Vice President of Student Services, • Dean of Academics, the Dean of Workforce Training and Community Education • Dean of Military Programs, Technical Education, and Outreach Programs • Associate Dean of Instruction The Vice President of Instruction is initiating a project to involve these parties in the implementation of a procedure to report unofficial withdrawals by 14 calendar days to ensure Return of Title IV is completed within the regulatory timeframes and reported to NSLDS within the regulatory timeframe. Date of Implementation: This will be implemented for the spring 2025 term.

Finding: 2024-003 – Federal Award - Internal Control Over Compliance Auditor Recommendation: Cary should implement a review process over the reimbursement request prior to the submission to NCDOT where staff prepares, and a manager reviews the request. Evidence of performance and review of these requests should be maintained. Corrective Action: Cary will establish a documented review process where staff prepares and manager reviews reimbursement requests prior to the submission to any federal or state grantor. Responsible Parties: Finance and Respective Departments Date of Implementation: July 1, 2025

Condition: Not all Graduate status changes were updated in the NSLDS system. Criteria: The College is responsible for reporting student status changes to the NSLDS. Cause: Miscommunication between the Clearinghouse and College on which file is used to update the degree status. Effect: Loan repayment status was not started on time. Perspective: College reports using the National Student Clearinghouse. The College believed the Clearinghouse was using the Degree Verify file to update the status, but the Clearinghouse was using the Enrollment File in mid-May. Recommendation: We agree with the College’s plan of action below.ures and catching up submissions.

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 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 15 students selected for enrollment reporting testing, one student within the sample was reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Upon further inquiry, there were an additional 7 students included in the same batch reported to NSLDS that were not reported timely. Views of Responsible Officials and Planned Corrective Actions The School concurs with the finding. The School intends to report student status changes at year end. Names of Contact Person Responsible for Corrective Action: Andy Vidal, Chief Financial Officer, and Daniel Miller, Director on Financial Aid Anticipated Completion Date: December 31, 2024 Summary Schedule of Prior Audit Findings None

Finding A: Verification V1 Corrections. The college during a verification review process did not send a tax paid correction to FSA. The correction was made in the system, but was not flipped to (send) out to FSA. The financial aid office will at new procedure that will pull all pending corrections to double check to ensure any corrections made in the Financial Aid System will be sent. This process will rely on a weekly query to identify any correction made to an ISIR and provide a report for financial aid officer to review and confirm correction was completed thru FSA. Finding B: Verification V4 & V5 missing date. The financial aid process requires all students selected for V4 and V5 verification to complete Identity verification form in person. Staff are required to sign and date the documents in front of the students upon confirmation of identity. The office staff signed the forms, but did not date document. All documents had student signature and date student signed in front of staff, staff signature was completed as well, but in these cases the date verification occurred was not noted. The financial aid office completed a self-audit on 101 files selected for verification to confirm all signatures and dates were completed. Based upon additional review the financial aid team did not find any other documents that were missing signatures or dates. The financial aid office will review verification trainings on FSA and develop a business process that requires a second reviewer to confirm the documents are complete prior to closure of the file. Finding C: NSLDS last date of reporting. The financial aid office completed an internal audit reviewing all student withdraws to ensure reporting was accurate with clearinghouse and NSLDS. If last date of attendance did not match institutional records, the financial aid office updated correct values on NSLDS and Clearinghouse. No errors were found pertaining to fall 2023 enrollment. The errors found pertaining to the spring 2024 term including noted findings were updated and records office was notified to ensure data reported on rosters reflecting last date of attendance is reflected in the student enrollment tables. The financial aid office is working with institutional research to develop a process that will check to tables to ensure data is correct prior to submittal to clearinghouse and/or NSLDS. The process will query data from enrollment, midterm grade rosters and Clearinghouse report to make sure data matches. Incorrect data will be updated prior to submittal to clearinghouse and NSLDS. Person(s) Responsible: Director of Financial Aid Timing for Implementation: New procedures have already been implemented.

Return of Title IV Funds for Failure to Begin Attendance Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to ensure compliance with Return of Title IV Funds for Failure to Begin Attendance. • The University’s Title IV Aid Committee convened on November 18, 2024, to address strategies for ensuring that appropriate documentation related to the unofficial withdrawal process is accurately collected by the Student Financial Aid Office. • To enhance the process, in addition to contacting professors via email for all students receiving zero credits in a term, two additional fields will be incorporated into the university's grading system. These fields will enable professors to indicate whether a student never attended the course and to record the last date of attendance. Amount Returned to the United States Department of Education: $5,071 • $5,071 was returned for the questioned student identified during the audit on November 20, 2024. It was determined that the student never started the course, and the entire amount of the loan was returned. Person Responsible for Corrective Action Plan: Colby Benefield, Director of Student Financial Aid Anticipated Date of Completion: January 01, 2025

Return of Title IV (R2T4) Calculations Planned Corrective Action: Calander was set using prior year information it was not until notification in April 2024 from the DOE Audit Resolution Group that the error was made known to Financial Aid Director. Prior year R2T4 was handled by 3rd party vendor. The calendar for 2023-2024 was updated immediately and all calculations were processed and adjustments made. The ABU director has now taken NASFAA R2T4 Specialist training and is in charge of updating and maintaining the calendar. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: ABU started working on partnering with the National Clearing House in the fall 2023 for NSLDS reporting. Due to a system conversion at the time this process took longer than anticipated. However, the first error free report was uploaded 09/01/2024. ABU now has a schedule with set reminders from the clearinghouse to ensure timely and regular reporting. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

U.S. Department of Education 2024-001 Special Tests and Provisions – NSLDS Program-Level Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: After being made aware of the NSLDS calculation for programs reported that aren’t reported in years, we looked into solving the issue. We learned that there is a screen within our student information system that sets the default time to years rather than months. Our degree programs prior to 2017 were entered into that screen but degree programs after that time and all of our certificate programs, needed to be calculated as years and entered into our SIS. We did a small trial sample of adjusting three programs in the spring to make sure the changes did not cause any issues with the Clearinghouse and NSLDS. When the data proved to be transmitted and corrected in both systems without issue, we tackled the rest of the programs at the start of this fall. We worked with the Clearinghouse to notify them that we were going to be adjusting a large number of programs that were effecting many student records. They did some alignment of our programs on their end to make the data transition go smoothly to the NSLDS. Issues with reported program lengths having the additional calculation should no longer. We have built in processes to make sure this step will be taken for any new programs. Name(s) of the contact person(s) responsible for corrective action: Greg Bricca, Director of Institutional Effectiveness

Finding Number: 2024-002 Condition: During the audit, it was determined that there is no control function in place by the Airports staff to ensure that wage rate compliance with weekly certified payrolls is occurring. Planned Corrective Action: N/A - corrective action detailed above was implemented during February 2024 in full. Contact person responsible for corrective action: Karen Honda, Fiscal Management Officer Anticipated Completion Date: February 1, 2024

2024‐001 Special Tests and Provision – Wage Rate Requirements Person Responsible for Corrective Action: Jeff Barben, Business Administrator Correction Action Planned: The District will review, update and train staff on the processes and internal controls related to construction contracts to ensure compliance with the Wage Rate Requirements as published in 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction when applicable. Anticipate Completion Date: November 30, 2024

To address this finding, we will implement a documented system of controls for all Title IV refund calculations. This will include: Each R2T4 calculation will undergo a documented review by a secondary individual. This review will be recorded via either a signature and date on the worksheet or an email confirmation. Name(s) of Contact Person(s) Responsible for Corrective Action: Federico Peña Jr. (Fred), Financial Aid Director Anticipated Completion Date: November 6, 2024

The ESSER III 2024 Fall Report submitted to the California Department of Education on October 15, 2024, reflected the correction made to include the credit not reported on the prior ESSER III quarterly report. The Business Department has been added as an additional reviewer prior to submission.

Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Contact: Laura Meloy, VP, Finance Completion Date: June 30, 2025 Corrective Action: The ChildFund Management team has taken immediate action to discuss the importance of proper period end cut-offs with the Accounting and Grants Teams. Moving forward, the Grants and Project Management team will discuss expense cut-offs during the kick-off meetings and the importance of year-end accruals. The Accounting Department will also provide additional training and reminders around year-end cut-offs and the importance of reviewing invoice dates for accruals that are under our normal threshold of $1,000 USD for grants.

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar's Office partnered with IT to automate the transmission of enrollment and graduation files to the National Student Clearinghouse to avoid late submissions or confusion about which branch the transmission is reporting. They have been set up to be sent on the same day each month, rather than being sent manually by a staff member. Several staff members met with our NSC representative to review the transmission schedule to ensure the selected dates will lead to timely submissions. Name of the contact person responsible for corrective action: Kerri Vickers, Registrar Planned completion date for corrective action plan: December 2024

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: One instance was identified where there was no documented return of Title IV calculation, and fourteen instances were identified where there was no documented review of the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid Director recently completed R2T4 process training with the Controller. This added expertise will enhance the secondary review process, providing an independent assessment by a reviewer not involved in daily operations. This additional oversight will strengthen quality control through sampled calculation reviews. Furthermore, expanded attendance and withdrawal reports will support comprehensive control processes for this cluster. Anticipated Completion Date: Commenced December 1, 2024

Higher Education Institutional Aid-Assistance Listing No. 84.031S Recommendation: We recommend the University adhere to their existing internal control policy regarding scholarship awards made from federal award funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Title V Grant personnel will submit awards to the Financial Aid Office for official award letter notice, adhering to existing internal control policy regarding scholarship awards. Name(s) of the contact person(s) responsible for corrective action: Connie Owens and Dasha Smith Planned completion date for corrective action plan: January 31, 2025

Higher Education Institutional Aid-Assistance Listing No. 84.031S Recommendation: We recommend the University review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Time and effort reports will be reviewed and submitted monthly. Name(s) of the contact person(s) responsible for corrective action: Elizabeth McMurphy Planned completion date for corrective action plan: January 31, 2025

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar reviews an error report each month, resolves the errors, and then submits the report to NSLDS. NSLDS responds with an error resolution report, which is then used to resolve any further issues, and confirm the final reporting to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: December 15, 2024

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.269Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid will update the unofficial withdrawal process with successful completion definition to be inclusive of requiring a passing grade. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: December, 15 2024