Corrective Action Plans

SPECIAL TESTS AND PROVISIONS – VERIFICATION Fairmont State University (FSU) Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93.342, 93.364 Effective February 2024, controls were put into place to address the additional review of the verification compliance requirement process once the initial review was completed. A weekly review with a comprehensive monthly review will be implemented to ensure no students are missed through the review process.

SPECIAL TESTS AND PROVISIONS – SATISFACTORY ACADEMIC PROGRESS Blue Ridge Community and Technical College, Bluefield State University, Fairmont State University, Marshall University, New River Community and Technical College, West Liberty University, West Virginia Northern Community College, West Virginia School of Osteopathic Medicine, and West Virginia University at Parkersburg Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264, 93.342, 93.364 Blue Ridge Community and Technical College (BRCTC) response BRCTC agrees with the auditor’s comments that the internal control process regarding the Satisfactory Academic Progress (SAP) Policy can be improved by maintaining documentation of an annual formal review of the SAP policy and its publication on the website, internal policy manuals and the student catalog. Effective January 2024, BRCTC’s website has been updated to appropriately reflect the SAP policy. Bluefield State University (BSU) response Effective January 2024, internal controls are in place to perform the Review of the Standards of Satisfactory Academic Progress Policy to comply with federal regulations 2-CFR 200.303, 34 CFR 668.16 (e) and 34 CFR 668.34. The current SAP policy was reviewed in June of 2023, but a signature was not maintained. The SAP policy will be reviewed annually prior to the new academic year that begins each August. The review will consist of the Director of Financial Aid, Chief Financial Officer and Provost reviewing all aspects of the current policy at first and then maintaining any changes annually along with retaining signatures of the annual review. The policies and procedures will be given a new review date each year to reflect the process.   Fairmont State University (FSU) response Effective January 2024, the following has been placed into the Satisfactory Academic Progress policy and will go into effect in Spring 2024 - Institutional Documentation Retention. Prior to the Satisfactory Academic Progress policy being applied to students at FSU, the Director will be responsible for the following: 1. Download the most current Satisfactory Academic Progress regulations from studentaid.gov. This documentation will be retained on the M drive under the appropriate aid year file folder for SAP. 2. Review, compare, and update the current Satisfactory Academic Progress policy at FSU with the most current federal regulations. The most current version of the policy will be signed off and dated by the Director of Financial Aid & Scholarship. This documentation will be retained on the M drive under the appropriate aid year file folder for SAP. 3. The Director of Financial Aid & Scholarships will provide any updates to the policy to the Information Systems Specialist by email in order for the Banner system to be updated with the updates. Email documentation will be retained on the M drive under the appropriate aid year file folder for SAP. 4. The Information Systems Specialist will update the Banner system in TEST. 5. The updates will be ran in TEST by running the ROPSAPR process for the future fall and future summer terms. 6. The TEST data will be reviewed and evaluated to ensure all policy updates have been captured and the students have been appropriately evaluated according to federal regulations. 7. The Information Systems Specialist will notify the Director of Financial Aid & Scholarships by email the status of the TEST system to determine if additional updates need to be made. 8. If the Director approves the data from the TEST system, they will notify the Information Systems Specialist by email that the updates are ready for production. Email documentation will be retained on the M drive under the appropriate aid year file folder for SAP. 9. Updates will be applied to the production system by the Information Systems Specialist and the ROPSAPR process will be run on all current students for evaluation. 10. The Information Systems Specialist will notify the Director of Financial Aid & Scholarships by email once the process is complete for one final review of the data to ensure all federal regulations are being met and the students have been evaluated accordingly. Email documentation will be retained on the M drive under the appropriate aid year file folder for SAP. 11. The Director of Financial Aid & Scholarships will sign off on the completed process by email to the Information Systems Specialist. Email documentation will be retained on the M drive under the appropriate aid year file folder for SAP. Marshall University (MU) response MU updated the website in February-March which included a review of SAP Policies and Procedures. MU did not update the Revision Date as there were no updates to Satisfactory Academic Progress federal regulations for the 2023-24 aid year. The policy did not change but was reviewed when updates were made to the website. This policy was updated and also added to the website. Effective February 2024, MU will document and retain all reviews and approvals for compliance with federal regulations. New River Community and Technical College (NRCTC) response NRCTC will continue to review policies and procedures at least once, and sometimes twice a year when the catalog is reviewed. NRCTC will continue doing this review and maintain documentation to ensure compliance with federal regulations. West Liberty University (WLU) response Effective January 2024, to comply with internal control over federal awards, WLU will ensure that SAP policies are compliant with the US DOE standards and retain evidence of the review before the SAP procedures are completed annually. If there are no changes, the policy will be approved to move forward. A signed sheet of the SAP policy approval will be retained in the office and an email of no updates will be sent to others in the Financial Aid Office. If changes are necessary, a financial aid committee would meet to make the appropriate updates. Once the policies and procedures are updated, a signed copy of the update will be retained in the FA Office and an email of the updates will be sent to the Financial Aid Office and communicated to all faculty, staff and students. West Virginia Northern Community College (WVNCC) response Effective December 2023, a new internal control process has been added to validate WVNCC’s processes (including SAP) with any changes to the Dept of Ed regulations, as available for the upcoming school year. WVNCC begins creating the new policy and procedure manual as the new year financial aid setup begins. The Director of Financial Aid will be creating a task force which meets two times per year to review the procedures. As WVNCC’s policy and procedure manual is a live working document, updates will be made as needed with a revision date denoted where applicable. WVNCC had an initial conversation with NASFAA on their policy and procedure information available and has created a sign off form to verify the review of the policy each academic year. This process is being implemented during the 2023-2024, prior to this year, as with the 2022-2023 documents, changes in regulations or college policy changes were made in the policy and procedure manual but may not have had a revision date as it done during the manual creation. This process will be fully implemented for the new 2024-2025 policy and procedure manual as it is being created. The new control will formalize this process, a review of applicable review is in process. West Virginia School of Osteopathic Medicine (WVSOM) response WVSOM did not have adequate internal controls in place surrounding the satisfactory academic policy (SAP) policy. A new SAP policy will be written and published to the public website to include reasonable standards for measuring whether eligible students are maintaining SAP in the educational program in our published SAP policy. The new policy will provide notification to the students of the results of an evaluation that impacts the students’ eligibility for title IV program funds. WVSOM will retain sufficient documentation that the procedures are performed and reviewed by the Financial Aid Director and a second review performed by the Associate Director of Financial Aid. The review will provide two signature sign-offs. West Virginia University at Parkersburg (WVU-P) response Financial Aid employees review all financial aid policies and procedures at minimum once per academic year. The Satisfactory Academic Progress (SAP) policy was reviewed and updated by financial aid staff throughout the spring and was approved by the Executive Vice President in June 2023, the updated SAP policy was forwarded to the President’s office to be filed and posted in the appropriate places, including online. WVU-P agrees that the updated and most recent SAP policy was not posted to the website prior to June 30, 2023. There was a college-wide policy review this spring, and the volume of that caused a delay in the policy’s posting. The resolution for this issue is to complete our policy review process earlier, and ensure if updates are necessary then the Marketing and Communications staff are aware of a deadline prior to June 30 to post the updated policy. WVU-P believes that there is sufficient documentation to show that the review of the SAP policy occurred within the academic year. The policies themselves have footnotes to document that Heather Skidmore reviewed the policies, and then the secondary review completed by Alice Harris before submission to the President. WVU-P will retain all communication that occurs related to future review processes to avoid a repeat finding on this issue.

SPECIAL TESTS AND PROVISIONS – NOTIFICATION OF CHANGES TO KEY PERSONNEL Division of Highways (the Division) Assistance Listing Number 20.933 Due to staff turnover, WVDOT recipient contact/key personnel had changed for some of the BUILD Transportation Discretionary Federal Grants. The USDOT representatives noted in the federal grants were not notified of these changes. The USDOT will be notified of all recent recipient contact/key personnel changes. Effective February 2024, when there are recipient changes, the USDOT will be notified within 30 days of the occurrence.

REPORTING Division of Highways (the Division) Assistance Listing Number 20.933 Effective January 2024, procedures have been put in place where pre-project performance management and quarterly progress reports on federal award projects will be compiled by WVDOT recipient/key personnel indicated in the BUILD Transportation Discretionary Federal Grants and submitted to USDOT by the 20th day after each calendar year quarter has closed as required by the grants. Prior reports that were not submitted to the USDOT as identified by the fiscal year 2023 audit will be sent.

REPORTING Workforce West Virginia (WWV) Assistance Listing Number 17.225 WWV updated reporting procedures in April 2023 and provided training to appropriate staff regarding the ETA 9050, 9052, and 9055 reports that did not have proper reviews documented prior to submission. That training is reflected in the reports selected after May 2023 that show proper documented reviews prior to submission.

INTERNAL CONTROLS OVER INFORMATION TECHNOLOGY Workforce West Virginia (WWV) Assistance Listing Number 17.225 WWV will create policies and procedures to be effective March 2024 which documents the process for periodic review of administrative access and user access for the ABPS and UI Tax systems. Appropriate staff will be trained once the policies and procedures are implemented. The wvOASIS SOC audit report for 2023 was completed in September 2023 and WVV is in the process of reviewing the report at this time. Disaster Recovery testing was conducted with WV Office of Technology and the mainframe vendor Ensono October 16-19, 2023.

REPORTING Department of Environmental Protection (DEP) Assistance Listing Number 15.252 Effective March 2024, DEP will implement the following steps to correct the finding: 1. Review the Office of Surface Mining Federal Assistance Manual for information and instructions in regard to preparing the required financial reports for periodic and annual submissions. The information obtained from the Federal Assistance Manual will be compared to 2 CFR 200.328 and 329 to ensure all required information is included in the financial reports. 2. Review the Federal Notice of Grant Award documents to ensure that reporting period dates and the submitted reports reconcile and are in agreement. 3. Create and implement written narrative that agrees with the requirements set forth in the Federal Assistance Manual. 4. Develop and implement standard operating procedures to ensure timely, accurate reporting that involves a review and approval process prior to submission. 5. Create a checklist of required items, and signature lines to show that reviews/approvals have taken place.

TRANSPARENCY ACT REPORTING West Virginia Community Development Block Grant Program (CDBG) Assistance Listing Number 14.228 The CDBG program has experienced turnover in staff during the last year. While CDBG knows the FFATA report was submitted, a physical copy of this report could not be provided, and it cannot be verified if it was submitted on time. In the FSRS system, only the person who creates the original report can view, edit, and pull the actual report, and since the employee who was responsible for submitting this report is no longer with the agency, it cannot be determined when it was originally submitted. CAD staff have since recreated the report in the FSRS system so there is a copy of the report. To ensure this doesn't happen in the future, CAD staff has completed FFATA training for the personnel involved in the reporting process. CAD staff is creating a calendar with due dates for the programs reporting requirements to ensure the dates are not missed. Once the report is submitted in the FSRS system, staff is required to save a copy of the report in shared files. CAD is also looking to implement a system where a centralized person is responsible for submitting the FSRS reports to ensure all processes are completed and documents saved correctly.

SPECIAL TESTS AND PROVISIONS – ADP SYSTEM FOR SNAP Department of Health and Human Resources (DHHR) Assistance Listing Number 10.551, 10.561, COVID-19 10.561 Management within the DHHR, Bureau for Family Assistance (BFA), appreciates and shares the auditors’ concern with SNAP program integrity as it relates to the Recipient Automated Payment and Information Data System (RAPIDS) ADP system. The BFA notes that 7 CFR § 272.10 begins with, “(1) Purpose. All state agencies are required to sufficiently automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. Sufficient automation levels are those which result in effective programs or in cost effective reductions in errors and improvements in management efficiency, such as decreases in program administrative costs...” Within the RAPIDS ecosystem for SNAP administration, this automation includes data matching measures undertaken, in compliance with related federal rules as specified in 7 CFR § 272.8, 7 CFR § 272.16, etc., to automate the validation of client-provided, worker-input information while mitigating the additional administrative burden of secondary review for all worker interactions with a client’s case. Policy regarding state and federal data matching is laid out in Chapter 6 of the State’s Income Maintenance Manual (IMM) at https://dhhr.wv.gov/bfa/policyplans/Documents/ Binder4.pdf. The primary data exchange system detailed in IMM Chapter 6 that is applicable to SNAP is the Income and Eligibility Verification System (IEVS) required by 7 CFR § 272.8. Systems mandated federally for inclusion in the IEVS include those operated by WorkForce WV, the Internal Revenue Service (IRS), and the U.S. Social Security Administration (SSA). A variety of other sources may also be queried for the purpose of validating client-provided information entered into RAPIDS by a worker, including Veterans Affairs (VA), Beneficiary and Earnings Data Exchange (BENDEX), Beneficiary Earnings and Exchange Record System (BEERS), National Directory of New Hires, and Prisoner Matching with the Department of Corrections as well as the Federal Data Services Hub (FDSH). IMM Chapter 6, page 2 describes the purpose of data matching through the IEVS thusly: Information obtained through IEVS is used for the following purposes: • To verify the eligibility of the assistance group (AG). • To verify the proper amount of benefits. • To determine if the AG received benefits to which it was not entitled. • To obtain information for use in criminal or civil prosecution based on receipt of benefits to which the AG was not entitled. IMM Chapter 6, pages 2-3 further detail the points at which a match with the IEVS must take place: A data exchange in the eligibility system occurs: • When a new case is created; • When a new person is added to a benefit; • When a person’s demographic information is changed; and, • On a periodic basis for all individuals in the eligibility system, depending on the type of benefit being received. Requirements for independent verification of information when automated data matches fail or report a discrepancy with client-provided, worker-input information are spelled out in IMM 6.4.4. The BFA believes that these automations, while perhaps not foolproof, are in keeping with both the word and intent of 7 CFR § 272.10, 7 CFR § 272.8, 7 CFR § 272.16, etc., which aim to automate processes in order to reduce administrative burden and associated costs, such as those that would be associated with a secondary review of all worker interactions with a client’s case. Furthermore, page 4-10.551-9 of the Compliance Supplement 2023, which lays out the suggested audit procedures for this topic, recommends the use of the USDA-FNS SNAP System Integrity Review Tool (SIRT) to ensure that the State’s ADP system is in alignment with USDA-FNS requirements and ensure that automated processes within RAPIDS continue to comport with federal requirements for ADP systems. To our knowledge, the auditors neither utilized that tool to guide their work nor requested verification from the State that the SIRT had been completed and previously employed. To support this response, management advocates a review of the SIRT submitted to FNS on October 26, 2023 in preparation for the go-live stage of the West Virginia People’s Access to Help (WV PATH) Family Assistance pilot program; as there is no significant difference in system functionality between the Family Assistance module of WV PATH and the existing eRAPIDS system, the responses/comments/replies from both FNS and the State that are included in this version of the SIRT generally apply both to eRAPIDS and to PATH. Throughout 2023, the BFA Division of Performance and Quality Improvement continued its ongoing SNAP case reviews, as well as its efforts to report compliance with monthly requirements for expanded supervisor case reviews conducted and tracked through the Rushmore case review system, as mandated in a December 7, 2022 memorandum to supervisors and made available to the auditors last year. Furthermore, the BFA developed additional worker training, including the reinstatement of face-to-face Statewide Payment Accuracy Conferences (held throughout the summer of 2023), with the aim to ensure that client information is accurately captured in RAPIDS so the APD can perform its automated functions with integrity.

DHHR INFORMATION SYSTEM AND RELATED BUSINESS PROCESS CONTROLS Department of Health and Human Resources (DHHR) Assistance Listing Number 10.551, 10.561, COVID-19 10.561, 93.558, COVID-19 93.558, 93.568, COVID-19 93.568, 93.575, 93.596, COVID-19 93.575, 93.658, 93.659, 93.767, 93.775, 93.777, COVID-19 93.777, 93.778 The DHHR is currently phasing in a new information technology system for determining eligibility, making payments, maintaining documentation, etc. The name of the new system is WVPATH (West Virginia People's Access to Help). The WVPATH system will replace the Family and Children's Tracking System (FACTS) and the Recipient Automated Payment Information Data System (RAPIDS), which are currently referenced in the finding. The WVPATH system will have additional controls and levels of review as compared with the FACTS and RAPIDS systems. Due to the timing of the phase-in process, the DHHR anticipates the finding will be resolved for the year ended June 30, 2024.

On a weekly basis, the Registrar will download the Registration Status Report from the student information system and review the report for accuracy. A copy will be provided to the Director of Financial Aid and the Accounts Receivable Coordinator to ensure all withdrawn students have been communicated in a timely fashion and all R2T4s are processed timely.

On a monthly basis, the Registrar will download the Registration Status report from the student information system and review the report for accuracy to ensure all enrollment changes are captured. Once the review is complete, the information will be uploaded to the National Student Clearinghouse.

Finding 2023-001: Special Test and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, 6 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the University review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal Requirements. Persons Responsible for Corrective Action: Liz Force, University Registrar & Director of Records; Pam Barrett, Associate Vice President & Director of Financial Aid Planned Corrective Action: Brenau University contracts with the National Student Clearinghouse (NSC) to perform routine enrollment reporting required by Title IV Federal Student Aid regulations. The University's student information system contains a program designed to compile enrollment data for transmission to NSC in accordance with specifications provided by the National Student Loan Data System (NSLDS). We conducted a detailed review of the November 2022 NSLDS Reporting Guide and engaged the University's student information system vendor, who reviewed the current software logic and installed the modifications necessary to become compliant in this area. Anticipated Completion Date: November 7, 2023

Finding 2023-002 - Employee Record Retention and Health and Safety Training Federal Program: CCDF Cluster: AL# 93.575 - Child Care and Development Block Grant AL# 93.596 - Child Care Mandatory and Matching Funds of the CCDF U.S. Department of Health and Human Services MATERIAL WEAKNESS NONCOMPLIANCE Special Tests and Provisions Name of Contact Person: Juanita GreggCorrective Action: • Upon hire and through the SWCDC onboarding process for new child care center employees, Center Directors will review the attached Health and Safety Training document as part of the orientation process. Tablets are available for those individuals who do not have access to laptops. • New teachers will be directed to contact the Learning and Development Director with questions upon registration to SWCDC’s online training system which holds all required Health and Safety Trainings and is approved by NC DCDEE. All courses are approved by DCDEE, meet hourly requirements and are CEU worthy. Electronic certificates are submitted to the individual electronically through a personal email address. The following link is a list of Health and Safety courses: H&S Training Course List • Upon completion of Health and Safety courses, the employee will document their completion on the appropriate SWCDC orientation documentation and submit to the Center Director via email. • The Center Director will be responsible for ensuring receipt of the certificate, maintain in the staff file, and then document accordingly for annual compliance monitoring. • As onboarding continues for the new employee, periodic monitoring from Direct Services Manager, Child Care Resource and Referral, and other identified individuals will review staff files and monitor timely completion and compliance for Health and Safety Trainings. We have hired a position into Workforce Development to provide this service and serve as a resource to our Center Directors. This individual will do spot checks for these trainings on-site. For those child care center employees who maintain in good standing with successful completion of Health and Safety Trainings, he/she will be eligible for incentive based awards quarterly. Such as: quarterly drawing for classroom supplies, gift cards, self-care resources, etc. • For those child care center employees who are challenged with successful completion, those individuals will be targeted to create an action plan to meet the requirements. Resulting in opportunities to discuss technology needs, limitations or content area concerns, or other areas of concern that administration may be unaware of at the time of hire. • SWCDC created Orientation Notebooks for each center director. These notebooks contain all SWCDC documents needed for successful onboarding and training for new staff. These notebooks contain the updated forms attached. During orientation, new center staff are now required to create an online learning account through ON24, which SWCDC manages. This training account gives new staff access to the H&S trainings they need, as well as, provides additional resources and access to other trainings not owned by SWCDC to complete the H&S requirements as well. • SWCDC Hired a Fidelity Coach through Workforce Development. While this is a new position for SWCDC, part of her job duties will be to randomly check employee files for H&S training completion. These random checks will be in conjunction with each center’s annual compliance visit. Completion Date: January 22, 2024

FINDING 2023-007 Subject: COVID-19 – Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls to prevent, or detect and correct, noncompliance. Recommendation We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation will create and implement an effective system to prevent, or detect and correct, noncompliance. We will create an oversight or review process to obtain the required certified payrolls. Anticipated Completion Date: Completed as of January 2024

FINDING 2023-006 Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: The School Corporation did not submit annual reports in a timely manner during the first year of the audit period. Reimbursement requests included invoices which had been reimbursed previously and some request did not agree with supporting documentation. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure reports are submitted timely and supporting documentation is used and retained for reimbursement requests. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Reporting – The Treasurer and Deputy Treasurer will review and approve all grant reporting with Komputrol reports and grant approval. All deadlines will be submitted prior to due dates. The Superintendent, Treasurer, Deputy-Treasurer and/or Grant Writer will review all grant reimbursement requests prior to submission for accuracy. Anticipated Completion Date: Completed March 2023 – February 2024 INDIANA STATE

FINDING 2023-005 Subject: COVID-19 – Education Stabilization Fund – Equipment Summary of Finding: The School Corporation utilized Education Stabilization Funds to pay for equipment. The equipment was not included in the capital asset records. The capital asset listing provided did not identify which assets were purchased with federal dollars. Recommendation: We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure asset records include all the necessary information and new assets are added. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Our corporation has a company that updates our fixed assets every two years. Between the two years our Deputy-Treasurer with the assistance of the Treasurer will work in an excel document to track all additions/deletions, identification, location, etc. All assets regarding equipment will be identified if purchased with federal grant funds. Anticipated Completion Date: February 2024

FINDING 2023-004 Subject: COVID-19 – Education Stabilization Fund – Earmarking Summary of Finding: Only 9% of the required 20% minimum earmarking requirement was spent. The remaining set aside amount that was requested for reimbursement was spent on activities that were not a part of the earmarking requirement. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure required earmarking requirements are met. Contact Person Responsible for Corrective Action: Casey Howard Contact Phone Number: 574-842-3364 x806 Views of the Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Superintendent, Treasurer, Deputy-Treasurer and/or Grant Writer will review all grant reimbursements prior to submission for all earmarking. Earmarking will be reviewed for implementation of evidence-based learning loss and accelerated learning. A grant amendment has been requested in January 2024 to include additional allowable expenses. Anticipated Completion Date: February 2024

FINDING 2023-002 Finding Subject: Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: Reports submitted were not substantiated by the ledgers. Contact Person Responsible for Corrective Action: Kellie Romer (Corporation Treasurer/Finance Director) Contact Phone Number and Email Address: 765-653-9771 Ext. 1010, kromer@greencastle.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school corporation will establish a proper system for internal controls and develop procedures to ensure reports are supported by the financial records. Anticipated Completion Date: Immediately 2/8/2024

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: We recommend the University evaluate its procedures and policies around reporting Direct Loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We disburse aid weekly and we have implemented a plan to review the reported disbursements in COD to ensure they are being reported accurately. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: June 30, 2023

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: We recommend the Institute review its reporting procedures to ensure that 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 has implemented a review to help identify students who may not be returning the following semester so they can be reported in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: June 30, 2023

Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University's policies and federal requirements related to monthly reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A policy has been implemented to have a review of reconciliations. The Director of Financial Aid will perform the reconciliations and the Assistant Director of Financial Aid will review and approve the reconciliation. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: June 30, 2023

2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.033, 84.007, 84.063, 93.264 Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPN’s are retained for at least 3 years after payment in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The missing Perkins MPNs were from loans that were over 25 years old. I have ensured that our remaining Perkins Loans have MPNs and will be retained for the 3 year period after a loan is paid in full. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: June 30, 2023

Corrective Action Plan For the Year Ended May 31, 2023 Finding 2023-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster. Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tests. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately and timely reporting significant data elements under the Campus- Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk. Statement of Condition: Management implemented controls that specifically addressed the circumstances surrounding prior year finding 2022-001. Management's review of the enrollment reporting did not detect other errors on certain student data elements or timely reporting. Certain student records within the NSLDS were identified with inaccurate data elements and not timely reported. Questioned Costs: Questioned costs could not be determined. Context: 10 students were identified with inaccurate data elements and not timely reported out of a total of 25 students tested. Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's effective date and status into NSLDS resulting in inaccuracies in significant Campus- Level and Program-Level enrollment data elements that DOE considers high risk. Effect: The Institute incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the Institute’s internal controls over compliance did not detect and correct the errors. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting. Status: Completed February 2024 Corrective Action: Management agrees with the finding. Through internal investigation, it was determined that there was a procedural issue with the manual entry of two date fields which both need to be the same when submitted to National Student Clearinghouse (NSC). Human error during these manual checks caused one data field to be correct, and the other incorrect. This error has been fixed so that both fields will always be the same and accurate. We have also updated our enrollment reporting procedures to have the registrar log into NSLDS monthly to confirm that the prior month NSC status changes are properly recorded in NSLDS. Contact Jean Weimer Registrar 414-847-3272 jeanweimer@miad.edu Submitted Feb 23, 2024

Finding - The organization did not submit the audit and data collection form within the nine-month due date for the fiscal year 2022. • The Fiscal Director position has not been continuously filled, and since COVID 19 it has proven difficult to hire qualified staff at the rate of pay offered by the Agency. The Fiscal Director is responsible for providing training and supervision to staff, and for completing such tasks as working with our Auditors and scheduling the annual audit. The Organization has hired a CFO for hire however, there are still sometimes difficulty in maintaining steady work flow, meeting deadlines and ensuring year end closing entries and reconciliations are completed timely. In addition, the Auditors contracted with the Agency have begun their reviews much later than they had pre-Covid, also lending to difficulty in meeting deadlines. • Community Action of Greene County Inc. has implemented a 9 day pay period and is considering a 4 day work week pilot in effort to attract and retain staff. The Agency will continue to take such actions to improve employee retention and engagement. • Community Action of Greene County Inc. will continue to incorporate automated accounting and payroll processes to improve the efficiency and accuracy of fiscal reporting. • A year end closing checklist and calendar will be developed and utilized by the fiscal staff as of Spring 2024. The completed checklist will be shared with the Executive Director following the close out period. • The Executive Director will schedule the Auditors to begin their reviews withing 90 days of year end as a condition of their contract. • The Executive Director is responsible for ensuring this corrective action plan is implemented.