Corrective Action Plans

Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: The University has implemented a weekly COD maintenance file update that will report any change activity to a student’s COD funds. This process is ensured to take place by ongoing calendar reminders as well as progress checks between the Director and Assistant Director. Anticipated Completion Date: November 6, 2023

Management agrees with the finding and the recommendation. Management will implement an expanded centralized tracking process to include activity outside of the loan system, with a secondary, independent review of all loan maintenance activity. Responsible Party: Thad Richardson Chief Financial Officer Phone: (802) 828-5470 Anticipated Completion Date: December 31, 2023

Responsible Individual: Eric Gumm Registrar and Director of the First-Year Program and Academic Development Center Abilene Christian University Finding 2023-001 concerning Enrollment Reporting Agency Name: U.S. Department of Education Program Name: Federal Pell Grant, Federal Direct Student Loans October 13, 2023 Finding Summary: Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309) Institutions are required to report enrollment information. The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Out of the population of 1,079 students with student attendance changes required to be reported prior to July 19, 2022 or after February 28, 2023, a sample of 25 students were selected for testing. The University reported the incorrect Program Enrollment Effective Date for 10 students and did not timely report a status change for one student. Corrective Action Plan (CAP): After review, the University acknowledges and understands the findings associated with the reporting date of enrollment changes. ACU's official policy regarding recording the effective date of a status change is to designate the date reflected in the SFAREGS screen in Banner as the official date of determination. This is the date that will be reported to NSLDS for any student status changes. Anticipated Completion Date: Within the Fall semester, the University Registrar’s Office will implement sole use of the dates as shown in our Banner mainframe system’s SFAREGS screen for reporting enrollment statuses. This will afford the consistency of dates needed.

Responsible Individual: Thomas Ratliff Director of Student Financial Services Abilene Christian University Finding 2023-002 concerning Return of Title IV Funds Agency Name: U.S. Department of Education Program Name: Federal Pell Grant, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work Study Program, Teacher Education Assistance for College and Higher Education Grants October 13, 2023 Finding Summary: Return of Title IV Funds (34 CFR 668.173(b); 34 CFR 668.22€; 34 CFR 668.22(g) and 34 CFR 668.22(i) note that federal regulations state that the return of Title IV funds must be made in the proper amount and in a timely manner as well as apply the return of Title IV funds to federal programs as required. The University’s processes did not ensure the days in the semester were consistently calculated correctly to calculate the return of Title IV funds correctly. Out of the population of 266 students that withdrew during the year, 25 students were tested. Nine instances were noted in which the total days in the semester were not calculated correctly which resulted in the calculation of an incorrect refund amount. Corrective Action Plan (CAP): After review, the university agrees that the students identified had an incorrect number of days included in their Return of Title IV Aid calculations. There was an error in two of our standard academic calendars used for processing these calculations. The university has since manually reviewed every academic calendar for the 2023-2024 academic year to ensure all academic calendars are completely accurate for each possible enrollment variation. The Director of Student Financial Services reviewed these along with each individual who is responsible for processing Return of Title IV Aid calculations, so as to ensure all parties are in complete agreement about the calendar dates. Anticipated Completion Date: Our new manual confirmation assurance has been implemented for 2023-2024. Calendar reminders have been set for each semester of the coming years to ensure the calendars are reviewed again just before the terms begin, to ensure accuracy at the point that calculations are to start for new enrollment periods. We believe this finding will not be repeated due to our enhanced diligence.

Finding 2023-001 A. Comments on Findings and Recommendations: We agree with the finding and recommendation. B. Actions Taken or Planned: The Institution has reviewed the details of the findings and determined the errors to be due to human error. For student #13, the R2T4 in question was a refund which was returned on June 15, 2023, in the amount of $595 to the 2022-2023 Federal Pell Grant Program funds. The Institution should have recalculated the Federal Pell Grant funds to include in the R2T4 calculation. The Institution used $1,261 as Federal Pell disbursed, when we should have only used $420 (due to the student being less than ½ time). After recalculating the Federal Pell, the Institution should have returned $214 to 2022-2023 Federal Pell Grant program funds. This resulted in an under return of $460 in 2022-2023 Federal Pell program funds. In addition, the Institution used an incorrect number of days in the payment period in the R2T4 calculation, resulting in an incorrect percentage of aid earned. For student #AR1, the R2T4 in question was a refund which was returned on May 31, 2023, in the amount of $9 in 2022-2023 Federal Subsidized Direct Loan Program funds. The $9 was in the amount of R2T4 funds which was due to the student and not required to be returned by the Institution. The Institution did not have authorization from the student to return funds to the Federal Subsidized Direct Loan Program. This resulted in an over return of $9. For student #AR15, the R2T4 in question was a refund which was returned on October 24, 2022, in the amount of $929 to the 2022-2023 Federal Pell Grant Program funds. The Institution should have returned $1,431, which resulted in an under return of $502. The Institution used an incorrect number of days in the payment period in the R2T4 calculation, resulting in an incorrect percentage of aid earned. Subsequent to the audit, the Institution returned $962 to the Federal Pell Grant Program funds on behalf of student #13 and student #AR15. The Institution has planned the following immediate solutions to ensure accuracy for R2T4 calculations. • Share Corrective Action Plan (CAP) with accountable staff. • Create a scheduled hours chart for all programs to address the incorrect number of days being calculated in a payment period. Additionally, the Institution will standardize the usage of the automated calculations within the Institution’s Student Information System (Anthology) to help minimize potential human errors within our processes. • Evaluate and update R2T4 policies and procedures as necessary to incorporate these solutions. • Train staff on R2T4 calculations as well as conduct ongoing training on an annual basis. o This will also incorporate training on the Institution’s R2T4 policies, including covering the requirement that student files should be reviewed for appropriate student authorizations as well as the full-time/part-time status of a student. • Re-train staff on the Institution’s R2T4 peer review process. • Establish target dates to review CAP effectiveness. o The Institution will conduct a monthly review of the CAP’s effectiveness for the first six months after implementation of the CAP and then will conduct periodic reviews of the CAP thereafter.

Finding Number 2023-005 — Significant Deficiency in Internal Control/Non-Compliance — Appropriate Expense Period of Covid 19-ESSER II 23b — Credit Recovery Condition: During expense testing of ESSER funds, a journal entry that reclassed the cost of Edmentum, program licenses for Plato courses, had expensed the entire annual license fee. The period for eligible expenditures did not begin until October 1, 2022. This journal entry expensed the full cost of the invoice, $11,914.50, and the district did not prorate the costs to include only those expenses from October 1, 2022 through June 30, 2023. The District did not adhere to the proper period for expenditures. Responsible Person: Carl Seiter, Director of Business Services Implementation Date: December 31, 2023 Corrective Action: Develop a summary of all federal grants. This summary will detail the fiscal year it is associated with but more importantly, it will provide the proper period of eligible expenditures for each federal funding source. This summary may be used and readily available at the time approvals are granted for expenditures. If an expense does not fall within the eligible time period, the expense can be rejected by the approver. This summary will be shared with all administrators and staff. In addition, the process for reclass journal entries will also include a pause to check that each invoice associated with a federal grant, is falling within the proper period of expenditures. Sincerely, Carl Seiter Director of Business Services Shepherd Public Schools

Finding Number 2023-006 — Significant Deficiency in Internal Control — Covid 19-ESSER II 23b-Summer School and ESSER II-98C - Approval Process Condition: During expense testing of ESSER funds, a July 2022 expenditure for $24.95, payable to BMO, and an August 2022 invoice for $10,167, payable to IXL for math software licenses, were not approved by the Director of Business Services. During this time, the Director of Business Services position was vacant. Proper internal control procedures would ensure a proper approval process, for any position that is temporarily vacant. Responsible Person: Carl Seiter, Director of Business Services Implementation Date: December 31, 2023 Corrective Action: Develop an approval process workflow that would temporarily utilize another administrator for approvals in Munis if any key position is vacant. The district has two administrators per building. The administrators will have the other building administrator act as approver for that building in the event an administrative position is vacant. If both principal positions are vacant, an administrator in another building will be integrated into the approval process for the building with no administrator. At Central Office, the next key position for approvals would be Trina Smith, the Accounts Payable/Accounts Receivable Accountant. If this position is vacant, the llRlPayroll Accountant will assume those approval duties. The final step of approval is the Director of Business Services to approve items before the AP/AR position can process any items. These items include invoices, requisitions, purchase orders, payroll related items and journal entries. In the event the Director of Business Services position is vacant, the District Superintendent of Schools will be the final approver. Sincerely, Carl Seiter Director of Business Services Shepherd Public Schools

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.

The Vice President of Finance corrected the disbursement dates for the students in question in September 2023. Going forward, the Student Financial Aid Office and Business Office will coordinate the drawdown of funds, reporting to COD, and posting to student accounts. The personnel of the College understands that while on the cash advance method to disburse funds, they have three business days from the date the funds are received to post the funds to the student accounts. However, the disbursement date on the student account and in COD still must agree. Anticipated Completion Date: The corrective action was completed in September 2023. Contact Person: Stephanie Dickerson, Registrar/Financial Aid 910-323-5614

Wage rate requirements were discussed during the bidding process. However, the School District and engineers were not aware the specific language needed to be included in the bid and contract. The School District used two contractors that did pay at and above the required wage rates; however, certified payrolls were not required to be provided and the subcontractor agreements were not required to have prevailing wage language. The School District is aware of the written requirement for future projects.

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Macomb Community College Single Audit Act Compliance report for the year ended June 30, 2023, and corrective actions to be completed. 2023-001 Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. We noted that one out student of a testing population of two was not reported timely to NSLDS and did not have the correct status change reported. As a result of this condition, the College was exposed to an increased risk that incorrect and untimely information would be reported to NSLDS. Auditor Recommendation. We recommend that the College consistently apply their enrollment reporting procedures to prevent untimely status change reporting in the future. Corrective Action. This situation occurred because the student graduated during a term in which they were not enrolled. This is connected to our upload to the National Student Clearinghouse which did not mark the student as graduated (G Not Applied) in our degree verify file. There is a known defect in our student information system that causes this issue. We are currently working collaboratively with our information technology department to resolve this defect which will ensure that we capture students in this situation in the future. Responsible Person. Registrar/Director of Enrollment Services Anticipated Completion Date. June 30, 2024

Finding 2023-007 Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: We did not maintain all records as required under the program and as a result, subsequent to yearend, were required to buy back specific Perkins Loans that did not have proper documentation maintained. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: All loan documentation was provided to Department of Education as part of the liquidation process and any loans that did not have proper documentation were purchased back by the College in September 2023 and the Perkins Liquidation was complete with final reporting requirements completed. Anticipated Completion Date: September 30, 2023

Finding 2023-005 Special Tests and Provisions – Enrollment Reporting Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing of enrollment reporting, it was noted that 7 of 19 students tested were not reported to NSDLS with changes in effective dates and enrollment statuses; and the certification dates were not within 60 days of the changes and 8 of 19 students tested were reported to NSLDS with incorrect program begin dates. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The errors noted in tested were corrected when we were notified of the errors and additional review was taken to ensure that a final enrollment roster was submitted as required as part of the close audit process. Anticipated Completion Date: September 30, 2023

Finding 2023-004 Cash Management –Reconciliations (Direct Loan) Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans Finding Summary: When testing cash management related to reconciliations, the auditors noted 2 of the 12 monthly SAS reconciliations were not completed. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The Student Financial Aid Director completed a final reconciliation after final disbursements were made to students to ensure all aid awards was correctly reflected. Anticipated Completion Date: September 30, 2023

Finding 2023-003 Eligibility – Calculation of the Amount of Pell, Subsidized and Unsubsidized Direct Loan Assistance Awarded Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing over the eligibility requirements, the following deficiencies were noted: • 2 of 60 students were not awarded the correct amount of Pell. One student was under awarded by $2,773 and one was over awarded by $862. • 7 of 60 students were not awarded the correct amount of subsidized loans. 4 students were under awarded subsidized loans based on being awarded as the wrong academic year in school; and 3 students were over awarded subsidized loans as the student did not have financial need. • 5 of 60 students were not awarded the correct amount of unsubsidized loans. All 5 of the students with errors were under awarded unsubsidized loans based on being awarded as the wrong academic year in school. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The College has reviewed all students impacted by the errors noted above and made corrections to the students as needed. Anticipated Completion Date: September 30, 2023

Finding 2023-006 Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP). Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: In testing key line items as indicated in the compliance supplement, the auditors noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: Any errors that were required to be corrected were made for 2022 and resubmitted to the Department of Education prior to the 2023 report being completed. Anticipated Completion Date: September 30, 2023

Recommendation: We recommend the District include contract language which ensures vendor are not suspended or debarred as well as utilize sam.gov to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Procedures will be updated to include verification that a vendor has not been suspended or debarred. A record of this verification will be retained.

The Charter Holder will contact TEA to clarify if there is non-compliance with ESSER III funding requirements, and if needed, to determine any remedial steps related to this finding. For future construction projects or components thereof, the Charter Holder will not use federal funds. Had the Charter Holder been notified either during ESSER III training or the approval process that this project component would require provisions from the Davis-Bacon Act, Wage Rate Requirements, ESSER III funding would not have been requested. Based on the Charter Holder's financial condition, we would have been more than able to fully fund the minor HV AC remodeling with our local fund. The general contractor is aware of the Davis-Bacon Act requirements for federally funded projects, however, during the planning stage of the project, the RFP was not designed to include provisions on Wage Rate Requirements because the Charter Holder originally planned to utilize its local funds to cover the total construction cost. Anticipated completion date: By December 01, 2023 - contact TEA to clarify non-compliance and if needed, determine remedial steps. Ongoing: Future construction projects will not use federal funds.

Department of Education Macalester College respectfully submits the following corrective action plan for the year ended May 31, 2023. Audit period: June 01, 2022 – May 31, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.007, 84.063 Recommendation: We recommend the College evaluate the circumstances that delayed reporting disbursements to COD to ensure that it will not happen again. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We experienced a malfunction in our reporting software and were not aware of the issue until after the reporting deadline. We now have procedures in place whereby we confirm that COD has received the file once we have submitted it. Name(s) of the contact person(s) responsible for corrective action: Jenae Schmidt Planned completion date for corrective action plan: Implemented in November 2022. If the Department of Education has questions regarding this plan, please call Jenae Schmidt at 651-696-6214.

WGU has implemented the appropriate identification of the TPD comment codes with our new aid year configuration and will continue this course of action whenever the new aid year FAFSA is released. The comment code numbering changed in 2024‐ 2025 from 2023‐2024. WGU will review and match the new 2024‐2025 codes with its corresponding 2023‐2024 codes to ensure our system is configured to identify ISIR records that are flagged by FSA requiring further action accordingly. Auditee Contact Person(s) Responsible for Corrective Action: Patti Kohler Vice President, Financial Aid.

1780 Sloan Avenue Indianapolis, IN 46203 (317) 351-1534 To Whom It May Concern, This letter is in response to our Single Audit/Uniform Guidance Finding. We understand that we are to verify two items when ESSER funds are used for construction contracts over $2,000: 1. Verify that the required prevailing wage rate clauses are included in the contract—also known as Davis-Bacon Act compliance. 2. For each week in which work was performed under the contract, verify that the contractor submitted the required certified payrolls. Although we did state the contractor was to be compliant with all applicable laws and regulations, the contractor did not provide this information in a timely manner and we were subsequently unable to provide these requirements during the audit. Regarding Finding 2023-001, please know that our organization understands this requirement and will adhere to it moving forward. Our plan of action includes incorporating strict language of the requirement in both contract and bid documents, correspondence submitted weekly, and explicit penalties for a contractor if they are unable to comply, which could include withholding of payment or stopped work. In addition to the measures above, I will be responsible to ensure all contractors are following these requirements. If you have any questions, please do not hesitate to contact me. Best Regards, Luke Kahren Chief Operating Officer luke.kahren@vcpindy.org (317) 351-1534

The Financial Aid Director recalculated the “need” for each student in question. The Financial Aid Director agreed with the auditor’s calculations. The following corrections were made on August 8, 2023: For the first student, $2,000 of subsidized federal direct loans were reallocated to unsubsidized federal direct loans. For the second student, $382 of subsidized federal direct loans were reallocated to unsubsidized federal direct loans. For the third student, $1,649 of subsidized federal direct loans were reallocated to unsubsidized federal direct loans. For the fourth student, $1,145 of federal work study funds were returned to the Department of Education. The student had already worked for the University and earned the funds in question. He was treated as a regular employee of the University and paid with institutional funds instead of federal work study funds. Anticipated Completion Date: The corrective action was completed on August 8, 2023. Contact Person Shala LaTorraca, Director of Financial Aid 918-335-6260

November XX, 2023 Office of the Secretary of State Audits Division 255 Capitol St. NE, Suite #500 Salem, OR 97310 Plan of Action for Wheeler County, Oregon Wheeler County, Oregon respectfully submits the following corrective action plan in response to deficiencies reported in our audit of fiscal year ended June 30, 2023. The audit was completed by the independent auditing firm Solutions, CPAs PC, John Day, Oregon. The deficiencies are discussed below with the Action Plan listed for each. 1. Material Weakness – Financial Statement Preparation Criteria: The financial statements are the responsibility of the county’s management, including the prevention or detection of material misstatements in the presentation and disclosure of the financial statements. Non-attest services performed by the auditor in the preparation of the financial statements cannot be considered compensating controls. Condition: The county engages their auditors to provide non-attest services for the preparation of its financial statements. Although common for municipalities the size of the county, this condition represents a control deficiency over the financial reporting process that is required to be reported under professional standards as long as management makes all financial reporting decisions and accepts responsibility for the content of the financial statements. However, those activities performed by the auditor are not a substitute for, or extension of, internal controls over the preparation of the financial statements in accordance with generally accepted accounting principles (GAAP). Cause: The county’s accounting personnel do not possess the advanced training that would provide the expertise necessary to prepare the financial statements and related notes in accordance with GAAP, and therefore may not be able to prevent or detect a material misstatement in the preparation and disclosure of the financial statements. Misstatements in financial statements may include not only misstated financial amounts, but also the omission of disclosures required by GAAP. Effect: Material misstatement in the preparation and disclosure of the financial statements in accordance with GAAP may not be prevented or detected. Misstatements in financial statements include not only misstated dollar amounts, but also the omission of disclosures required under GAAP. Recommendations: We understand that it may not be practical to acquire or allocate the internal resources to perform all the controls necessary over financial reporting. However, management (including the County Court) should mitigate this deficiency by keeping informed about the county’s internal controls, performing supervisory reviews, studying the financial statements and related footnote disclosures, and understanding its responsibility for the financial statements as a whole. Action Plan: We understand the importance of risk management and the need to address risks in an informed, cost-beneficial way. As a result of our cost-benefit analysis we have determined the value of incurring the additional expense of hiring a staff person or another firm to prepare our financial statements does not justify the cost. We accept the auditor’s recommendations and will attempt to implement in a timely manner. 2. Material Weakness – Preparation of the Schedule of Expenditures of Federal Awards Criteria: The schedule of expenditures of federal awards (SEFA) is the responsibility of the county’s management, including the prevention or detection of material misstatements in the presentation and disclosures of SEFA. Services performed in reconciling the SEFA to the trial balance during the annual compliance audit cannot be considered compensating controls of the county. Condition: During our reconciliation of the SEFA to the financial statements, and testing of controls, we noted material omissions from program expenditures reported. Additionally, identification of funds passed-thru to subrecipients were omitted from the county drafted SEFA. Cause: The county’s system of controls over the SEFA is lacking effective controls over completeness. Effect: Material misstatement in the preparation and disclosure of the financial statements in accordance with GAAP may not be prevented or detected. Misstatements in financial statements include not only misstated dollar amounts, but also the omission of required disclosures. Recommendations: We recommend the county develop further control procedures over drafting the SEFA to address completeness. We recommend the county develop a system of tracking federal awards and related compliance requirements to assist in accumulating information to prepare the SEFA. This deficiency is related specifically to the preparation of the SEFA and does not reflect on controls over compliance or transactional controls. Action Plan: We understand the importance of risk management and the need to address risks in an informed, cost-beneficial way. We have addressed this finding with plans to develop controls over preparing the SEFA. Specifically, we intend to track compliance requirements for all grants in a database to address internal control issues over completeness. We also intend to implement review and approval controls over the county drafted SEFA. 3. Significant Deficiency – Internal Control over Compliance with Federal Program Requirements Criteria or specific requirement (including statutory, regulatory, or other citation): The Secure Rural Schools and Community Self-Determination Act of 2000 requires a county receiving funds under the Forest Service Schools and Roads Cluster to perform an allocation of funds between Title I, II, and II under based on county court certified allocations. In the current year, that allocation included a federal sequestration of funds that was also required to be allocated to Title I and Title III, which resulted in noncompliance with the requirements related to earmarking and with special tests and provisions. Annual certification of funds spent under Title III is also required. In the current year, that certification included funds that were included in previous certifications, which resulted in noncompliance with the requirements related to reporting. Condition and context: During our review of the allocation of 2023 funds received, we noted an error in the allocation performed by the county. Title I had an overallocation of funds by $2,203, and Title III was under allocated by the same $2,203. The reconciliation of the amounts included in the 2022 annual certification for Title III funding identified an over certification of $11,303 that had already been included in the 2021 annual certification. Questioned Costs: Actual questioned costs totaled $2,203 and consisted of amounts passed through to local schools and expended in the road department on otherwise compliant uses. Cause: There is a lack of internal control over earmarking, reporting, and special tests and provisions over allocation of Forest Service Schools and Roads funding and the annual certification. The county lacks review and approval controls over the allocation of funds and the annual certification. Effect: The effect is noncompliance with earmarking, reporting, and special tests and provisions requirements. Recommendations: It is recommended that the county implement review procedures over the annual receipt to verify amounts allocated are complete and accurate prior to posting to the general ledger. A recalculation of both the certification and a detailed review of amounts used in the annual reporting is recommended. Action Plan: The county understands and concurs with this finding. It is the intention of the county to implement a review process to be completed prior to making formal allocation and reporting of Forest Service Schools and Roads Cluster.

Department of Education 2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their internal control procedures over awarding, return of title IV calculations, and professional judgment and implement a formally documented review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will make the following changes: Awarding: The following are internal controls that the University already has in place to review awards for accuracy. • Financial aid worksheet: As part of the awarding process every award year, a financial aid worksheet is created to verify that the awards input in Colleague are accurate. The worksheet is updated each time there is a change to a student’s financial aid eligibility or status. • COD report monitoring: On a weekly basis, reports are processed to determine if there are any discrepancies between what has been awarded in Colleague and what is being reported/accepted in COD. Any discrepancies found are reviewed and corrected. • Monthly loan/grant reconciliation: The monthly loan/grant reconciliation monitors for any discrepancies between what is shown as disbursed in Colleague and the disbursements that have been accepted by COD. Any discrepancies found are reviewed and corrected. • Over award report: Processed at the beginning of each term, this report details if any students are awarded beyond unmet need and/or cost of attendance. Any discrepancies found are reviewed and corrected. • Enrollment level report: Processed before the start of each term and at the end of the add/drop period, this report evaluates awarded enrollment level against actual enrolled credits. Any discrepancies found are reviewed and corrected. • Disbursement processing rules: There are rules built into the Colleague system to limit disbursement of awards when actual enrollment status does not match awarded status. Any discrepancies found are reviewed and corrected. Beyond the internal controls already in place, the University will implement the following: • Secondary review of awards: For new Financial Aid Counselors, all awards will be reviewed for the first two months to ensure accuracy and commitment to proper training. Additionally, based on current staffing levels, a random selection of 10% of all awarded students will be reviewed to evaluate for awarding accuracy. • Grade level review: After the 10th day of each term, a review will be performed to compare the current class standing of each student to the grade level that was used for awarding. Any discrepancies found will be reviewed and corrected. Return to Title IV (R2T4) Calculations: The Colleague system is used to process R2T4 calculations. This system has been developed to correctly calculate the return formula based on limited information entered by the R2T4 processor. To ensure the correct information is entered, the University will implement a secondary review of all R2T4 calculations. The primary R2T4 processor will enter all required information in the R2T4 calculation screen within Colleague, and then print the screen for review by a secondary member before the return is referred for processing. The primary processor and secondary reviewer will be required to sign off on the printed calculation sheet, verifying the accuracy of the information. The items that will be included as part of the secondary review will be the date of determination, enrollment status, last date of attendance, and institutional charges. Professional Judgment: The University will implement a Professional Judgment Committee. The committee will consist of at least one Financial Aid Counselor and the Director of Financial Aid. The committee will collectively review all the documentation for each case to make a final determination. Name of the contact person responsible for corrective action: Dustin Kummrow, Director of Financial Aid Planned completion date for corrective action plan: November 1, 2023

2023-002 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the University consider any NSLDS access and documentation requirements necessary to ensure compliance with the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of the University winding down operations, and no longer providing educational services, University management will consider any modifications to the NSLDS access and documentation requirements necessary to ensure compliance with the stated criteria. Name(s) of the contact person(s) responsible for corrective action: Rachel Nielsen, Vice President of Finance and Administration Planned completion date for corrective action plan: July 31, 2024