Corrective Action Plans

U.S. Department of Treasury Program Name: Coronavirus state and local fiscal recovery fund Federal Assistance Listing Number: 21.027 Significant Deficiency, Nonmaterial Noncompliance - Procurement Finding 2023-003 Criteria or specific requirement: Per Section 200.318 of the Uniform Grant Guidance, a non-federal entity must use documented procurement procedures for the acquisition of services required under a Federal or State award. Condition: There was one instance out of 11 contracts tested where the County did not properly follow the Uniform Grant Guidance procurement standards for contracted services. Questioned Costs: None. Effect: By not having the required documentation in the files, the County could have improperly contracted with a vendor that was not considered eligible to be paid with grant proceeds. Cause: The County utilized an existing vendor contract that had not been previously procured in accordance with the Uniform Grant Guidance procurement standards. Recommendation: The County should consider utilizing the Uniform Grant Guidance procurement standards for all County contracts or at least ensure that when utilizing a previously issued contract, the necessary procurement standards are met or completed prior to utilizing the vendors contract for a Federal or State grant. 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: Procurement will incorporate the completion of a checklist entitled “Subaward versus Contractor Checklist” created by UNC School of Government to determine a vendor’s status as Contractor or Subrecipient. The form, its use and requirements will be included in Procurement’s Process and Procedure manual and all staff training. This checklist will be required as a supporting document for each appropriate procurement/contract record upon approval by a Procurement Manager. Person responsible: David Boyd, Chief Financial Officer Estimated date of completion: February 28, 2024 David Boyd Chief Financial Officer 1/10/2024

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 Non-Material Non-Compliance – Eligibility Finding 2023-002 Criteria or specific requirement: 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. 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) The caseworker should prepare and submit a DMA-5097 form in the case of noncooperation as described in the Eligibility Review Document. b) When the Social Security Administration (SSA) terminates social security income (SSI) eligibility, the county is required to make an ex-parte determination for eligibility. This determination is required to be made within 120 days after the termination of the SSI payment. c) An OVS inquiry must be completed and agreed to information reported in NC FAST. d) An AVS inquiry must be completed and agreed to information reported in NC FAST. e) When forcing eligibility, documentation explaining the reasoning for the forced eligibility is required to be maintained on file. Condition: The following are the results of non-material non-compliance noted for each criteria listed above out of the 122 program participants selected for testing: a) There were two instances where the non-cooperation with IV-D was identified but no DMA-5097 was sent. (93 and 105) b) There were two instances where the County did not complete the ex-parte review for a participant whose SSI benefits were terminated during the year. The County should have forced eligibility, due to the COVID-19 exemption, but did not force eligibility for these instances. (63 and 121) There was one other instance where the County did force eligibility, but they forced it to the wrong program. (47) c) There was one instance where the resources found through the register of deeds did not agree to the resources in NC FAST which affected the countable resource calculation. (68) d) There were two instances where the OVS query was not ran at the time of the determination. (92 and 93) e) There were two instances where eligibility was forced but no documentation explaining the reasoning for was documented at the time of the determination. (114 and 122) Lastly, there were 31 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 9 out of 122 unique participants tested with the errors noted above, in which one was determined to have been improperly determined eligible. Questioned Costs: We noted a total of $59,534 in benefit payment claims paid by the State of North Carolina based on an improper eligibility determination made by the County for which the State relied on; see item “c” above. As the County did not make the payment directly, it is not considered questioned cost for the County under Uniform Grant Guidance §200.516(a)(3); however, in accordance with NC general statutes §108A-25.1A, the County is financially responsible for the $59,534 of erroneous issuance of Medicaid benefits for an ineligible individual. 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 that 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 Quality and Training 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 including completing ex-parte determinations for eligibility when SSA terminates SSI eligibility, properly documenting and reacting to IV-D non-cooperation, correct and appropriate usage of forced eligibility, and performing the required electronic verifications to complete an application or review. This training will be delivered by the end of the third quarter of fiscal year 2024. Responsible Individual(s): Ellese Massey, ESD Quality & Training Manager Anticipated Completion Date: March 31, 2024 Process Improvement: The Economic Services Division (ESD) has begun training new hires in one function of the Medicaid program, for example, processing applications or recertifications/changes. This is to build a stronger foundation before they learn the second function of their assigned program. Our Quality and Training Team is adding additional time for training, as needed, to ensure our trainees receive the support they need while learning a new program. ESD has specific protocol for managing the recertification process for SSI terminations and will ensure this policy is followed moving forward. Responsible Individual(s): Kim Konior, Medicaid Program Manager and Ellese Massey, ESD Quality & Training Manager Anticipated Completion Date: March 31, 2024 Quality Sampling and Accountability: The Quality and Training Unit will complete monthly quality sampling for Medicaid. Error trends will be shared with the managers and their supervisors, who will work collaboratively with Quality and Training staff to coordinate appropriate strategies to train and coach staff to mitigate errors moving forward. Supervisors will review specific quality sampling results with their staff. The supervisor will, 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 will review quality sampling results with supervisors quarterly to follow up on errors addressed, trainings completed and progress with individual Corrective Action Plans. The Quality Assurance team in OSI/CFAS will 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 will report out to ESD Leadership quarterly on findings. Responsible Individual(s): Kim Konior, Medicaid Program Manager & Sonya English, Quality Assurance Supervisor Anticipated Completion Date: Currently Ongoing

Recommendation: We recommend management ensure that the data collection forms are submitted electronically to Sam.gov each fiscal year going forward. Action Taken: Management acknowledges that the submission of the data collection form and required reporting package to the Federal Audit Clearinghouse (FAC) was not completed for the year ended June 30, 2021 and was submitted late for the year ended June 30, 2022. Management will provide additional oversight to ensure that the submission of the data collection form and reporting package is completed by the required due date.

FINDINGS – FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Education Stabilization Fund Cluster Federal Assistance Listing Numbers: 84.425W, 84.425U, 84.425D Finding 2023-001 Recommendations: The District should have an employee compare the Board Clerk’s supporting documentation and the Education Stabilization Fund spreadsheet report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the report submitted should be printed, initialed by the secondary reviewer, stapled with the information used to compile the report and combined with all financial records for the fiscal year. Action Taken: We agree with the recommendation. Our targeted implementation date is March 2024. If the Kansas State Department of Education and/or Kansas State Department of Administration has questions regarding this plan, please call Rex Richardson at 620-675-2277.

As noted within the portal filing summary for the general reporting period 5, the Corporation’s consolidated cumulative lost revenues totaled $141,363,926. Through the period 5 report, $99,467,570 cumulatively, had been applied to lost revenues to date, leaving $41,896,356 in unreimbursed lost revenues. As a result, there were sufficient qualifying lost revenues to receive and earn all PRF funds received, regardless of the reporting error identified and described in the “Finding” section above. Therefore, management believes no repayment of PRF funds received would be required. Management is implementing a process to add additional review steps prior to finalizing future reporting submissions, if required. As of the date of this letter, PeaceHealth Networks has reported on all PRF funds received and has no future portal reporting obligations. Corrective Action Plan Completion Date: October 15, 2023

2023-001 – Cost of Attendance Calculation. Auditor Description of Condition and Effect. Two students out of the 40 tested had an incorrect COA recorded in PowerFAIDS. The error was isolated to the population of students enrolled half-time at the College. The College determined that they did not properly update COA for the year. Subsequent to initial testing, the College adjusted the COA for the half-time students whose COA was not updated for the year. This condition did not result in any students being awarded an incorrect amount of Pell. As a result of this condition, the College was exposed to an increased risk that incorrect information would be used to determine students' Pell Grant award amounts. Auditor Recommendation. We recommend the College implement procedures to ensure the COA used to calculate each student's Pell Grant is updated for each academic year and reviewed by an independent official. Corrective Action. The College will evaluate and implement controls that will ensure Pell Grant Budget Cost of Attendance requirements are met. The Financial Aid Office will determine Cost of Attendance budget component amounts and School Administration will approve these amounts prior to the financial aid system and school website being updated accordingly each academic year. Responsible Party. Financial Aid Office and School Administration. Anticipated Completion Date. September 27, 2023

This is no disagreement with the finding. Management immediately began to review policies and procedures.

CORRECTIVE ACTION PLAN October 23, 2023 Health Resources and Services Administration Care Resource Community Health Centers, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. ____________________________________________________________________________________ CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, Opioid STR (Assistance Listing Number 93.788) Finding 2023-001 – Reporting SIGNIFICANT DEFICIENCY We recommend that the Center strengthen their system of internal controls to ensure that all reporting requirements are monitored and met on a timely basis. Action Taken Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency. This deficiency has been corrected as of the current date. During the fiscal year, there was a data element change in the Carisk portal that required an “evaluation score” to be added to the performance outcome measures. This was not previously required. Although data was uploaded on a monthly basis to the Carisk portal, the change caused the data to be rejected as an “error” resulting in measures not being uploaded. This was discovered in the BBHC February 2023 desk review of July - December 2022 data. A corrective action plan was recommended, prepared, and accepted by BBHC. The “evaluation score” was not part of the template in the electronic medical record (NextGen) therefore data could not be uploaded and was rejected. Once discovered, the data element was added to the template within the electronic medical record and data uploads of performance outcome measures were able to be extracted and successfully uploaded to the Carisk portal. The screening tool to produce the “evaluation score” is being added to the electronic health record and will be included in the workflow of the Behavioral Health Providers so that it may be captured for performance outcomes and discharges. This process requires the Care Resource Data Analytics team and external data consultants and service providers to create the templates. During the fiscal year, invoices are due on the 10th of the month unless the tenth falls on a weekend or a holiday in which case the invoices are due the following business day. There are times where extensions are necessary due to portal uploads or data corrections. Approval is given by the contract manager of BBHC. Approvals have been granted verbally and in writing (email). In the case of the invoice for the month of May 2023, verbal approval was provided, however not documented. In the future, all requests if approved verbally, will be confirmed in writing (email) to ensure proper supporting documentation of the approval. If the Health Resources and Services Administration has questions regarding this plan, please call Keenan Karwan, Chief Financial Officer at 305 - 576-1234 x203. Sincerely yours, Keenan Karwan

Donovan CPAs 9292 N. Meridian St, Ste 150 Indianapolis, IN. 46260 Attn: Jacob Stephenson Re: Response to Audit - 7/1/22 - 6/30/23 Single Audit December 21, 2023 Regarding Finding 2023-001 Reporting Significant Deficiency occurred as a result of inadequate controls to ensure accurate reporting to eh DOE. Correct 1.Regarding Finding 2023-001 Reporting Significant Deficiency occurred as a result of inadequate controls to ensure accurate reporting to the DOE. Corrective Action Plan as Follows: a. Deborah Czmiel (CFO) will request grant reports which include total expenses for each federal grant from BPI for the reporting period. b. Deborah Czmiel (CFO), Deborah Snedden (Superintendent) and Jeff Wood (Asst Superintendent) will compare grant reports from BPI to financial statements. Any discrepancies will be addressed and resolved by Deborah Czmiel (CFO) prior to submission of final report. c. Deborah Czmiel (CFO) will complete and submit the final reports, after the expense totals have been confirmed and reconciled. With collaboration of the administrative team and the proper checks and balances as identified above any future inaccurate submissions will not occur. Respectfully, Deborah s. Czmiel CFO/Business Manager

Condition: The University had one of the minimum safeguards written down within its information security program during the fiscal year. Planned Corrective Action: The University does have information security controls in place. While we have implemented these controls and safeguards, we acknowledge they are not documented in our formal policies. Our corrective action is to have these controls formalized and documented in the coming year. Contact person responsible for corrective action: Linda L Height, VP Finance Anticipated Completion Date: June 30, 2024

Condition: The University did not report certain students' status to NSLDS in a timely manner during the fiscal year Planned Corrective Action: The University Team will review status updates for all students that continue enrollment from one semester to another (May to Summer) to be sure their previous and new status both appear in NSLDS. All the students that were identified had continued with a new degree program in the summer, so the corrective action plan we are implementing will catch any issue before their new enrollment information is updated to NSLDS. Contact person responsible for corrective action: Noreen Ferguson, Registrar Anticipated Completion Date: December 31, 2023

Finding Reference Number: 2023-001 Initial Fiscal Year: 2023 Summary of Finding: Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Entity’s Corrective Action Plan Due to turnover within the IT Department, GLBA requirements were not communicated well to incoming staff or to the organization. Once GLBA requirements were discovered, a plan was developed to begin implementing GLBA controls and revise our security plan. The plan to bring the organization into GLBA compliance was developed for the 2023-2024 school year and was not in effect before this audit. The IT Department, and key stakeholders within the organization, are working to ensure GLBA compliance within the next year.. Anticipated Completion Date: September 21, 2023 Name and Title of Responsible Person: Luke Edwards, Director of IT.

Finding Reference Number: 2023-006 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: Exit Counseling (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Entity’s Corrective Action Plan Corrective Action Plan Summary: Once IT was made aware of the issues, we implemented changes to the process. The action code was discontinued, and our database administrator developed a custom database table used only for tracking Financial Aid communications. This custom table tracks the student’s organizational ID number, email address, communication code (EXIT for exit counseling emails), date/time the email was processed, and the status returned by the process used to send emails. Please note that this status only checks whether the process succeeded, it does not check whether the email was successfully sent. The Financial Aid Department is still copied in all emails sent at their main email address (currently FinancialAidTN@Johnsonu.edu). The Financial Aid Department has the responsibility to alert the IT Department if they are not receiving emails as expected. Once the IT Department has been alerted of an issue, the IT Department can start working to resolve the issue. For long-term reliability of communications, Johnson University has purchased and is implementing a new Financial Aid software platform. This will give us an opportunity to work towards reliable communications, not just reliable logging of process failures or successes. Anticipated Completion Date: September 21, 2023 Explanation: The corrective action plan was taken to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Luke Edwards, Director of IT.

Finding Reference Number: 2023-005 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: Disbursement Notifications (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Entity’s Corrective Action Plan Corrective Action Plan Summary: Once IT was made aware of the issues, we implemented changes to the process. The action code was discontinued, and our database administrator developed a custom database table used only for tracking Financial Aid communications. This custom table tracks the student’s organizational ID number, email address, communication code (MAND for mandatory loan emails), date/time the email was processed, and the status returned by the process used to send emails. Please note that this status only checks whether the process succeeded, it does not check whether the email was successfully sent. The Financial Aid Department is still copied in all emails sent at their main email address (currently FinancialAidTN@Johnsonu.edu). The Financial Aid Department has the responsibility to alert the IT Department if they are not receiving emails as expected. Once the IT Department has been alerted of an issue, the IT Department can start working to resolve the issue. For long-term reliability of communications, Johnson University has purchased and is implementing a new Financial Aid software platform. This will give us an opportunity to work towards reliable communications, not just reliable logging of process failures or successes. Anticipated Completion Date: September 21, 2023 Explanation: The corrective action plan was taken to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Luke Edwards, Director of IT.

Finding Reference Number: 2023-004 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: The University Did Not Timely Complete Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268, Federal Pell Grant Program, ALN #84.063) Entity’s Corrective Action Plan Corrective Action Plan Summary: When processing the R2T4s for these three students the Director looked at the current date on the form and processed them according to the current date and not the date of withdrawal. For these students due to the date difference went from being in the greater than 60% category where a R2T4 was not necessary to now needing one processed. The university has implemented an audit process where by the date entered can be more easily verified to ensure accuracy. This date and the withdrawal date or LDA are now added to a withdrawal form that is shared between departments so that any variance will be easily identified. Anticipated Completion Date: September 21, 2023 Explanation: The corrective action plan was taken to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Rocky Christensen, Director of Financial Aid.

Finding Reference Number: 2023-003 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063) Entity’s Corrective Action Plan Corrective Action Plan Summary: When setting the R2T4 dates in the system we had failed to count the Saturday and Sunday preceding the break period of five days or more. The university has addressed the issue for the future POE periods and implemented a three step verification process moving forward. The three step verification involves two additional staff verifying the dates in the system to ensure accuracy. Anticipated Completion Date: September 21, 2023 Explanation: The corrective action plan was taken to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Rocky Christensen, Director of Financial Aid.

Finding Reference Number: 2023-002 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: Documentation Regarding Offer of a Post- Withdrawal Disbursement (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063) Entity’s Corrective Action Plan Corrective Action Plan Summary: The university was not documenting the PWD notification that happens with students as part of our exit process. While the university was completing this the lack of documentation has been addressed. The university now has the student verify receipt of this information on the withdrawal form. Anticipated Completion Date: September 21, 2023 Name and Title of Responsible Person: Rocky Christensen, Director of Financial Aid.

Coronavirus State and Local Fiscal Recovery Funds– Assistance Listing No.21.027 Recommendation: The Organization should implement internal controls to ensure documentation of approval for expenditures is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • All transactions need to be routed through our bill payment software to ensure a proper paper trail and approvals. • All Financial Transactions forms must be signed by supervisor before being processed. • All credit card transactions will be reviewed weekly/monthly to ensure Accounting has receipts for all transactions. Staff must include a Financial Transaction Form signed by their supervisor for each receipt. Name(s) of the contact person(s) responsible for corrective action: Susan Lucas Planned completion date for corrective action plan: 1/1/2024 If there are questions regarding this plan, please call Holly Henning at 651-726-5215.

Condition: A sample of 118 payroll-related expenditures were randomly selected for testing using a random sampling approach, of which included a total of 37 district employees paid & claimed under this grant. These payroll-related expenditures were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. Upon completing this testing, we noted the following discrepancies: -There were 4 employee salary & benefits claimed that were not included in the 22-4998-E3 grant budget detail. The budget specified teachers & paraprofessionals, and support staff were not included, resulting in known questioned costs of $4,857.50. -There were 11 employees where a portion of the claimed payroll & benefits were deemed allowable per the budget but $8,947.88 was deemed not allowable, resulting in known questioned costs of $8,947.88. -Additionally, there were $6,686.25 of the employee salary & benefits that was not deemed allowable per the budget as the pay period dates did not align with “loss of learning” related pay dates or other approved activities. Plan: The District will review its policies and procedures to ensure that potential expenditures are approved are deemed to be allowable before spending federal funds. In addition, the District will consider implementing a monitoring process to ensure that control procedures are being followed. Anticipated Date of Completion: 6/30/2024 Name of Contact Person: Dr. Dwayne E. Evans, Superintendent of Schools Management Response: The District is currently strengthening internal control procedures over grant reporting and monitoring.

Finding 2023-003 Department of Agriculture Federal Financial Assistance Listing #10.766 Communities Facilities Loans and Grants Cluster Finding Summary: The System does not have an internal control system designed to provide for the preparation of the schedule of expenditures of federal awards (the schedule. We requested our auditors to assist with the preparation of the schedule. Responsible Individuals: Teresa Mallett, Chief Financial Officer Corrective Action Plan: Due to cost considerations, we will continue to have Eide Bailly LLP prepare our draft schedule of expenditures of federal awards and accompanying notes to the schedule of expenditures of federal awards. Anticipated Completion Date: Ongoing

Auditor’s Recommendation: The auditor recommends the District implement controls to ensure student files are complete and accurate and conduct training to for Title I personnel and school sites over the appropriate level of written documentation required for different situations. Views of Responsible Officials of Auditee: The district will continue to strengthen current controls and implementnew controls to ensure student files are complete and accurate. This will include training registrars to enhance documentation that is obtained to support the student records for all situations in which a student may be removed from designated cohort.

Management’s Corrective Action Plan Management takes its responsibility to maintain effective internal control over the federal award that provides reasonable assurance that the agency is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the award seriously and gave significant consideration to what additional controls would be effective to ensure the proper amount of indirect costs are charged to all federal grants. To prevent another occurrence, the organization will: On October 17, 2023, the agency refunded the indirect costs that were overbilled in error. By December 31, 2023 and annually thereafter, the Director of Grants Management will provide training and technical assistance to all Grant Specialists and Grant Accountants on allowable costs, including detailed training on proper determination of indirect costs for each grant. This training will also be incorporated into the onboarding process for any new grant staff. Continue its current policy that the Director of Grants Management complete a detailed review of each grant reconciliation monthly, to ensure all costs charged to the grant are reasonable and necessary for the performance of the award. This review will include appropriate tests of indirect costs including ensuring the appropriate indirect cost base is used, all items required to be excluded from the indirect cost base are excluded, and the appropriate indirect cost rate is applied to the indirect cost base. Continue its monthly analytical review to test the reasonableness of grant revenue relative to grant-funded expenditures. At least twice annually, the Controller will complete a second detailed, documented review of each grant reconciliation to ensure all costs charged to the grant are reasonable and necessary for the performance of the award, which will also include appropriate tests of indirect costs. At the end of each award cycle, the CFO will complete a third detailed, documented review of each grant reconciliation to ensure all costs charged to the grant are reasonable and necessary for the performance of the award, which will also include appropriate tests of indirect costs. Going forward, should indirect rates or methodologies change for any award, the CFO will review the grant reconciliation the first month following the effective date of the change to ensure the change has been properly implemented.

Responsible Official’s Response and Corrective Action Plan Management has added a more experience accountant and hired a BDO Field Accountant firm to expedite processes within the Organization. Management is creating new policies and procedures and tightening internal control to address issues related to timeliness of reporting. New procedures were implemented within the fiscal year 2023. Planned Implementation Date of Corrective Action Date: 04/01/2022 Person Responsible for Corrective Action Rosemarie Bizune Title: Director of Finance

Corrective Action Plan The District will implement procedures to ensure planned capital expenditures, using Elementary and Secondary School Emergency Relief Funds, receive approval by either the U.S. Department of Education or the Texas Education Agency prior to the actual purchase. Person(s) Responsible Assistant Superintendent of Business & Finance Anticipated Completion Date Fiscal year 2023-2024

The Office of the Registrar recognizes the importance of both timely and accurate reporting of enrollment status changes for lenders and servicers of student loans to determine in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Through our own data reporting and, in conjunction with the NSC, we are working to identify the affected students to correct their enrollment record statuses to graduated. We expect to make these corrections no later than January 12, 2024. Individuals with reporting responsibilities will engage in training through the NSC. An office audit will be conducted to assess areas for improvement. These actions will be completed by March 1, 2024. The College recently instituted additional conferral dates where graduated students will be submitted to NSC as batch files, thereby, substantially lessening the need to report as individual online updates.