Corrective Action Plans

Finding 2025-003 — Questioned Costs Related to Expenditures Exceeding Approved Grant Budget Corrective Action Plan Management acknowledges that expenditures under the OASH HEALS award exceeded the approved grant budget by $8,158.59. To prevent similar instances in the future and strengthen compliance with Uniform Guidance, management will implement the following corrective actions:  Implement monthly budget-to-actual reviews for each federal award to monitor expenditures against approved budget categories and award ceilings.  Establish a monitoring process with alerts when expenditures approach approved budget limits, allowing management to take timely corrective action.  Require prior written approval from the grantor before incurring expenditures that would exceed approved budget limits or require budget revisions.  Assign responsibility to the Accounting Manager to review grant expenditures monthly and report any potential budget overruns to the Executive Director before additional costs are incurred.  Work with OASH to resolve the current over-award of $8,158.59 and retain documentation of the agency's allowability determination and any required corrective actions. Responsible Party Executive Director; Accounting Manager; Program Directors/Managers. Completion Date Budget monitoring procedures implemented immediately; resolution with OASH targeted by August 31, 2026. Questioned Costs $8,158.59

Finding 2024‐002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Condition: For individuals charged to this program who also have time charged to other programs there were no timesheets or other evidence to support the allocation to the program was based on actual time incurred to the program but was instead based on the budgeted amounts for those individuals. Corrective Action Planned: Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping and the salary and wage allocations to the federal award are appropriately documented and accurately reflect the level of effort of work performed. Objective: To establish an environment of internal controls and accountability within the Chicago Area Command Finance and Social Services teams specific to the following: Required Action: Ensure appropriate policies and procedures are created and implemented and that accurate documentation is in place to assume responsibility and accountability to meet or exceed expectations. Social Services - Implement and document a process for all individuals assigned to multiple contracts to keep time logs of hours worked on each, with a monthly review that the hours align with the budgeted amounts. In the event hours diverge, workload will be adjusted or a budget adjustment will be requested. Finance - Implement and document a process to conduct an internal spot check at least quarterly by selecting a sample of time sheets from various contracts to ensure that proper procedures and documentation have been implemented and tracked appropriately. Meet with Social Services at least quarterly to confirm time log status for all programs administered by Chicago City Fund. Anticipated Completion Date: August 31, 2026 Name of Contact Person Responsible for the Plan: Shari Koehler, Divisional Chief Finance and Technology Director

During the 2025 audit, the auditors discovered that a secondary review of eligibility determinations did not occur in a timely manner. The lack of internal control opened the possibility that an individual was incorrectly determined to be eligible to receive benefits and this error would not have been identified or corrected in a timely manner. Federal Regulations establish requirements for internal control over compliance with Federal program requirements. 2 CFR Section 200.303 requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. These requirements include the design, implementation, and operation of control activities to ensure compliance with applicable compliance requirements, including eligibility. As eligibility is a key compliance requirement identified in the OMB Compliance Supplement, the County is required to implement a review process and system of internal controls that allows management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, errors or noncompliance in eligibility determinations on a timely basis. The Department of Human Services (DHS) has implemented a monthly review process to audit a random sample of the IV-E cases. The review includes verification of timely and accurate determinations, client information, supporting documentation, and system entries, with results documented and approved by the reviewer. DHS Division leadership will monitor compliance to ensure the reviews are conducted each month. DHS believes this additional review procedure will provide the needed internal controls over IV-E determination.

Finding #2025-013 14.267 Continuum of Care GU0011L9C002112, GU0011L9C002213, GU0011L9C002314, GU0037L9C002302, GU0031L9C002203 Matching, Level of Effort, and Earmarking Views of Responsible Officials and Planned Corrective Action Management’s Position: Management concurs with the finding. Management has not fully implemented formalized policies and procedures to ensure centralized tracking, periodic reconciliation, and supervisory review of matching contributions in accordance with established control expectations. Responsibilities for monitoring matching activity are decentralized with each planner, and periodic management review of cumulative matching, supporting documentation, and source allowability is not consistently performed. As a result, matching balances may remain interim and not fully supported, increasing the risk of noncompliance with applicable matching, level of effort, and earmarking requirements at each time of reimbursement and not final until grant closeout. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: Ongoing effort and as training is made available

Finding #2025-009 14.239 HOME Investment Partnerships (HOME) Program Special Tests and Provisions – Underwriting Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with the finding of no approved policy effective FY2025. An approved policy addressing this requirement is in place and was submitted as requested on March 9, 2026. Explanation of Disagreement: The HOME Program has an approved and effective policy that documents underwriting standards used to determine the appropriate amount of homeownership assistance based on a household’s debt, assets, and overall financial resources. Corrective Actions: GHURA Community Development Division continues to working closely with HUD to ensure program compliance and alignment with federal requirements, and is currently in the process of updating and amending its policies to reflect current market conditions and strengthen long-term program sustainability. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Ongoing effort and as training is made available

Finding #2025-007 14.239 HOME Investment Partnerships (HOME) Program Eligibility Views of Responsible Officials and Planned Corrective Action Management’s Position: #1 Management concurs and acknowledges that approving the matter without a more thorough evaluation was an oversight. #2 Management disagrees. HOME maximum subsidy per 3-bedroom unit is $338,419.00. Total HOME investment is $112,500.00. Corrective Actions: Corrective actions include strengthening internal controls and oversight. Management will implement a more comprehensive review process moving forward. This process will include additional supervisory review, verification of supporting documentation, confirmation of regulatory and policy compliance, and consultation with appropriate program and legal staff, when necessary, before approvals are granted. Management will also establish review checklists and documentation standards to ensure that all relevant factors are consistently evaluated and adequately documented. Moving forward, the Community Development Division will undergo a more rigorous evaluation process standardized review checklists and documentation requirements will be implemented to promote consistency, accountability, and proper recordkeeping. Management will monitor compliance with these enhanced procedures to reduce the risk of future deficiencies, oversights and ensure approvals are supported by adequate due diligence. Responsible Party: Jo Lyn Terlaje, Community Development Manager Anticipated Date of Completion: Final approval checklists will be implemented by August 1, 2026.

The Organization will review its procedures for preparing and submitting reports under federal loan programs and put proper supervision controls in place.

Name of Contact Person: Jill Sampson, DSS Director Corrective Action- Internal Control Error: The Auditor Report for Bladen County disclosed finding(s) of non-compliance with laws and regulations. The audit shows that we have repetitive errors from the previous year. We take these results very seriously and are committed to implementing lasting improvements. Bladen County Department of Social Services is focused on establishing protocols that will build a standard of confidence for our Income Maintenance case workers. It has been and will remain our constant goal to strengthen our Medicaid programs through knowledge and training to eradicate errors. Bladen County DSS will implement the following program policy and procedures to improve proficiency in service delivery. We do recognize that we fell short of expectations on this audit, particularly with the repeat error findings. The nucleus of the Plan of Correction will have a framework that will involve both Income Maintenance staff and Managers to set a groundwork that will empower the Medicaid teams to meet state expectations and improved audit outcomes in the future. The Second-Party Audits completed each month by Medicaid Supervisors will track our performance and upon completion of the second party of cases training will be completed to address the errors found. Staff will be given a test that will measure our performance improvement to assure accuracy on case work. Areas Needing Correction: Internal Control Errors • Failure to comply with policy requirement: Three (3) instances of failure to complete at least one compliance component. All identified missing or incomplete verification of facts or were improperly forced. • Inaccurate Resource Calculation: Three (3) instances of inaccurate resource calculations in NC FAST. The values entered in NC FAST evidence and used in the eligibility determination did not match the supporting documentation or was lacking any substantiating documentation. • Inaccurate Budget Calculation: Six (6) instances of inaccurate budget calculations in NC FAST. The values entered in NC FAST evidence and used in the eligibility determination did not match the supporting documentation or was lacking any substantiating documentation. • Failure to document/correct system issues: Four (4) instances of system errors found that were not addressed or corrected. Cases contained benefit histories that were not representative of the benefit that was issued. Goal for Correction: • Work Number Usage Administrative Letter No: 02-19 The Work Number Procedures • The Work Number (TWN) - Job Aid dated 09/21/2023; The Work Number (Fact Sheet) Dated 09/25/2023. • Manual Calculations of Income F/C MA 3300; MA 2250 • MAF-MIC-HSF Budgeting – MA 3305 • Financial Resources MA 2230 • Evidence Dashboard Relationships - Job Aid dated11/27/2018 • Acceptable use of Medical Forced Eligibility– Last updated 03/01/2023. • NC FAST Mandatory Evidence and Verifications • Adding Evidence to Case (Job Aid) • Online Verifications (Job Aid) • MA 3515 Bladen County DSS is committed to using tools listed in this Plan of Correction to assist in recognizing any areas of concern for the Medicaid Teams. Bladen County DSS is eager to assist workers to become the most efficient and productive in their daily work routine, to reach the best desired outcome for both the clients served, as well as the overall audited scores. • Training has been completed for the Medicaid staff on February 23, 2026 (Adult Department) and February 24, 2026 (Family and Children Medicaid Department). See list of Medicaid policy, Administrative letter and NC FAST job aids that were addressed during the meeting. • Medicaid Program Checklist- each Medicaid team will have a checklist that will be utilized on each application/ recertification completed. This tool will be used to ensure Income Maintenance workers have completed all necessary actions to application/recertifications. This tool will also be used in auditing each case during the second party review of the case. *Note: Item Number 18 from the Medicaid Eligibility Testing Attribute has been updated to include The Work Number for household members age 14 and above. These tools are included in the Second Party review of the record and if the worker does not complete the tool a point is deducted as being in error. • Second Party Review of Records – Will be completed monthly by the Supervisor and Lead Worker for the specific program. Each Income Maintenance worker will be monitored by monthly review of three applications and three recertifications. Any errors that are determined during the second party review will be addressed with the worker, who will be given 3 days to make the correction to the file, refute the error finding by discussing manual policy with the Supervisor/Lead worker, workers will need the policy name and section number. This internal audit will assist in determining areas of training that staff need for overall improvement in job performance. • Medicaid Spreadsheet Internal Report Card – has been created for the Medicaid team monthly utilizing the individual scores received from the Second Party review of cases. This will be the benchmark set at 96.8% for Eligibility errors and 90% for technical errors. • Monthly Audits completed by Bladen County Finance Office will continue to be completed. Each worker is given their individual errors discovered by this audit. The worker will be coached concerning the errors found and will be required to make corrections to the case. The worker will also sign the audit form indicating that the information was reviewed with them and the date recorded. • Medicaid Spreadsheet Internal Report Card reviewed by County Boards – The Medicaid Second Party Spreadsheet (Internal Accuracy Report Card) for the Adult Medicaid and the Family and Children Medicaid Department will be reviewed monthly by the Bladen County Health and Human Services Advisory Committee. A formal presentation will be sent to the committee each month via computer. This information will be sent out in the format of spreadsheets; the spreadsheets will indicate each worker (using an alphabet identification) and will indicate if the employee met the benchmark goal of 96.8% eligibility and 90% technical error rate each month. This chart will give a three-month snapshot (window of time) for notifications of error trends identified by the audits. This report will be discussed quarterly at the Health and Human Service Advisory Committee meeting offering each committee member the opportunity to address their concerns about audit scores during that quarter. • All Medicaid Program teams will staff all pending applications (by date priority) with the IMC, Supervisor, and/or Lead worker. This will help to eliminate any questions that the IMC may have in response to completion of the application. • Second Party review of cases will be completed monthly by Supervisor and Lead worker in the Medicaid programs. Upon completion of the entire team’s second party reviews, training will be created based on the errors found at the second party of work. Once the training has been completed, workers will be given a test to determine their understanding of policy, job aid and forms reviewed in the training. A test score of 90% accuracy must be maintained by each staff member to receive a passing score. A score below 90% will require additional training. • A training outline form will be utilized during training so that staff have the opportunity to give feedback as to what they feel they need additional training in. • Newly hired staff within the first (1) year of employment will receive quarterly job performance evaluations. • Newly hired and all active Income Maintenance staff will take and pass (score of 70% or above) the NC FAST Core Functions Certification and Level 1 Training Program. • Newly hired staff will be required to have work reviewed 100%. • Warning System for Persistent Errors – Implementation of a warning system for caseworkers who persistently make errors, despite corrective actions and counseling. First Warning:  When an employee repeatedly makes errors despite individual counseling and corrective actions, they will receive a First Warning.  The employee's supervisor will meet with them to discuss the errors and reinforce the importance of adhering to policies and procedures.  As per Bladen County DSS policy, employees will be given three workdays to make necessary corrections.  The First Warning will be documented in the employee's personnel file. Second Warning:  Within three months, If the employee continues to make errors after receiving a First Warning, they will be issued a Second Warning.  The supervisor will conduct another meeting with the employee to address the persistent issues.  During this meeting, a performance improvement plan will be established, outlining specific areas for improvement and a timeline for achieving them.  The Second Warning will be documented in the personnel file. • Demotion in Position – If the employee's errors persist even after receiving the Second Warning and failing to meet the goals of the Plan of Correction, they will face demotion in position. The demotion will involve a change in job responsibilities or a transfer to a lower-level position if available within the organization. This action will be taken after thorough evaluation and consultation with Human Resources. • Termination – If, despite previous warnings, the employee continues to make errors that significantly impact their performance and the effectiveness of DSS, the last step is termination. Termination is the last resort and will be considered only after the employee has received a First Warning, a Second Warning, and a demotion in position. The decision to terminate will be made in consultation with Human Resources and higher-level management. • Proposed Completion Date: This Plan of Correction will become effective April 1, 2026. The Bladen County Department of Social Services Economic Services Division for the Medicaid Programs will take an active role in ensuring work is monitored and that staff receive training throughout the year, to minimize the error rate from the Single County Audit.

Allowable Costs and Activities Condition: Payroll costs were allocated to grants in a manner inconsistent with the time and effort documentation provided. Recommendation: Management should reinforce the requirement to retain time and effort documentation for all employees that are allocated to multiple grants and implement a review process whereby the allocation percentages used are compared to the employee attestations provided. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: TCA Health is enhancing its time and effort and payroll allocation processes to ensure charges to grants align with documented effort. We are building on our monthly review process for time and effort by formalizing a review in which payroll allocation percentages are compared to signed attestations, with Finance documenting any corrections and follow-up. We are also partnering with HR to ensure all Personnel Action Forms (PAFs) include appropriate grant coding and to require an updated PAF whenever an employee’s grant funding or allocation changes. In addition, TCA Health is implementing an automated integration between ADP and Sage Intacct so that approved timesheets flow directly into payroll and grant reporting, improving accuracy and the audit trail. We will leverage the systems and limit manual entry. Name(s) of the contact person(s) responsible for corrective action: Bob Van Gilder Planned completion date for corrective action plan: 9/1/26 If the U.S. Departments above have questions regarding this plan, please call Veronica Clarke, Chief Executive Office, at 773-928-5090.

Views of Responsible Officials and Planned Corrective Actions Centre Care acknowledges the 2024 Uniform Guidance Audit report was submitted late to the Federal Audit Clearinghouse. Centre Care was in the process of negotiating with the USDA related to another loan agreement and financial statements were reissued to alleviate the going concern impacting the timing of reporting. In addition, our consulting team (CHR) incurred transition within the accounting team and as a result the reporting deadline was not communicated to the new team, and the reporting deadline was missed. Corrective Action Plan: Centre Care already remedied this issue in 2026 by submitting the reporting package and data collection form for the year ended December 31, 2024, and the data collection form process has been started for the December 31, 2025, audit and will be submitted upon finalizing the audit report in accordance with Uniform Guidance requirements.

Finding 2025-006 Reporting Federal Agency Name: U.S. Department of Health and Human Services Program Name: Certified Community Behavioral Health Clinic Expansion Grants Federal Financial Assistance Listing Number: 93.696 Finding Summary: During audit testing of reporting, there was no documentation available for the review and approval procedures performed for one of the reports tested. Responsible Individuals: Janet Warren, Director of Financial Operations Corrective Action Plan: Management agrees with the finding. There was turnover in staff and the prior CFO did not keep a record of his review over reporting. In the future, management will ensure that documentation of the approval process for reporting is kept. Anticipated Completion Date: June 5, 2026.

Finding 2025-005 Cash Management Federal Agency Name: U.S. Department of Health and Human Services Program Name: Certified Community Behavioral Health Clinic Expansion Grants Federal Financial Assistance Listing Number: 93.696 Finding Summary: During audit testing of reimbursement requests, there was no documentation available for the review and approval procedures performed. Responsible Individuals: Janet Warren, Director of Financial Operations Corrective Action Plan: Management agrees with the finding. There was turnover in staff and the prior CFO did not keep a record of his review over cash management. In the future, management will ensure that documentation of the approval process for reimbursement is kept. Anticipated Completion Date: June 5, 2026.

a. Management is negotiating a solution with the State of Utah and HUD for a refund of the payment.

Fergus has adopted and implemented policy: 252.0 Federal Funding Compliance to establish formal procedures and ensure ongoing compliance with applicable federal regulations, including 7 CFR 4280, Subpart A and 2 CFR 200. Anticipated completion date: August 31, 2026

Fergus has adopted and implemented policy: 252.0 Federal Funding Compliance to establish formal procedures and ensure ongoing compliance with applicable federal regulations, including 7 CFR 4280, Subpart A and 2 CFR 200. Anticipated completion date: August 31, 2026

Suspension and Debarment – Assistance Listing No. 66.458 and 10.760 Recommendation: The City should update all contracts to include a suspension and debarment paragraph to verify status with every renewal, request certification from the proposed entity, or verify vendors through SAM.gov prior to utilizing vendor services. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. (102) Action Taken in Response to Finding: The finance director and the public works director have already implemented a process to verify the SAM status of all contractors on all projects regardless of funding. However, this did not capture contractors working on existing projects. Name of the Contact Person Responsible for Corrective Action: Leann Perino, Finance Director Planned Completion Date for Corrective Action Plan: December 31, 2026

Procurement – Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. The Organization may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Review Contract and procurement policies and procedures. • Compare current procurement process and training to the policies and identify areas for correction and improvement. • Update Policies and procedures as needed. • Implement procedures to review vendors on a periodic basis. • Implement procedures and assign responsibility for checking off that procurement documentation exists and is in the vendor folder or designated area. • Retrain staff involved in procurement on updated procedures. • Monitor process and adjust as needed. Name of the contact person responsible for corrective action: Keith Flores, CFO Planned completion date for corrective action plan: January 2027

Finding 2025-002 Federal Agency Name: U.S. Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds FFALN # 21.027 Finding Summary: Eide Bailly LLP prepared our single audit for Federal Coronavirus State and Local Fiscal Recovery Funds where the Town is a subrecipient to Douglas County who is the recipient of the funds. Eide Bailly LLP identified that the Town did not have documented or consistently applied internal controls to ensure compliance with the County’s subrecipient guidance requiring the submission of formal special reports for ALN 21.027. Responsible Individuals: Mark Henderson, Assistant Director of Castle Rock Water Corrective Action Plan: Staff will complete quarterly reports including project progress and estimated project infrastructure costs. The reports will be reviewed by management prior to submission to the recipient of the Federal Funds (Douglas County). Anticipated Completion Date: Ongoing during the period that the Town is a subrecipient of these funds for the project.

Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended June 30, 2025. Planned Corrective Action – The Agency will take all reasonable measures to work with the new auditors to complete the audit process and submit the data collection report within the required time period. Anticipated Date of Correction – The 2026 data collection form for the year ended June 30, 2026, will be issued to GSA within the required deadline of the earlier of thirty days after issuance of the 2026 audit or prior to March 31, 2027. Point of Contact: James Williams, Fiscal Officer/Program Director

Tyler Luce, Executive Vice President & CFO, respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Ste 1 Lansing, MI 48912 Audit period: October 1, 2024 – September 30, 2025 The findings from the September 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2025-001 Recommendation: The entity should design and implement stronger internal controls over project funds, including enhanced segregation of duties, documented procurement procedures, conflict-of-interest monitoring, and periodic independent review of project expenditures to ensure compliance with Uniform Guidance. Management Comments: We agree with the facts and circumstances of this finding. Management has taken corrective action in response to this finding. The employees involved are no longer employed in connection with the project, and the matter was reported to the HUD Office of Inspector General. Management has reviewed and strengthened the project's controls over conflict-of-interest monitoring and enforcement of existing time-clock policies. In addition, we have and will continue to perform independent reviews of project expenditures to ensure compliance with Uniform Guidance.

2025-004 Auditor’s Recommendation: UCM should formalize and document internal control procedures over Federal award expenditures, including documented review and approval processes to ensure compliance with Uniform Guidance. Corrective Action: UCM will formalize and document internal control procedures over Federal award expenditures to ensure costs charged to Federal awards are allowable, allocable, reasonable, properly approved, and adequately supported in accordance with Uniform Guidance. Written procedures will be developed for expenditure review and approval, including documentation of business purpose, budget availability, cost eligibility under the award terms, proper account coding, funding source, supporting documentation, and evidence of approval. UCM will also strengthen controls over direct assistance to client expenditures by requiring documentation of client eligibility, assistance type, amount approved, funding source, program approval, finance review, and evidence of payment. Direct assistance expenditures will be reviewed to ensure they are allowable under the Federal award, consistent with program requirements, properly coded, and adequately supported before payment or reimbursement is processed. UCM will also implement a Federal award expenditure checklist or similar review tool to document review before expenditures are paid, posted, or reported. The checklist will include review of allowability, allocability, reasonableness, budget availability, funding source, supporting documentation, approval, and compliance with applicable Federal award requirements. For direct assistance to clients, the checklist will also confirm client eligibility, approved assistance type, required case documentation, and evidence of payment. Staff responsible for Federal award expenditures, direct client assistance, grant accounting, accounts payable, and program budget management will receive training on the updated procedures and Uniform Guidance requirements. Supporting documentation and evidence of review and approval will be retained with the expenditure records. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Anticipated Completion Date: December 31, 2026

The College acknowledges the finding and agrees that verification procedures must include documented evidence of completion and supervisory review. The condition resulted from the absence of formal procedures and lack of retained documentation evidencing completion and review of verification activities. The College is in the process of implementing enhanced controls over verification procedures. Formal policies and procedures will be established to define responsibilities, documentation requirements, and supervisory review expectations. Each verification file will require documented evidence of completion and review, including electronic sign-off or system-based approval. In addition, the College will implement quality control measures, including systematic validations and periodic supervisory reviews, with documentation retained to evidence the scope and results of such reviews. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that verification procedures are consistently applied, properly documented, and subject to appropriate review, and to prevent recurrence.

The College acknowledges the finding and agrees that Return of Title IV Funds (R2T4) calculations and related return activity must be accurately calculated, properly documented, and fully traceable. The condition resulted from the absence of formal procedures, lack of documented supervisory review, and insufficient documentation and reconciliation of student-level return activity. The College is in the process of implementing enhanced controls over the R2T4 process. A monthly structured workflow has been established whereby the Office of Financial Aid prepares and provides a detailed listing of students subject to R2T4 calculations, including institutional return amounts. Accounting independently reviews and verifies the calculated return amounts and processes the return through the federal system, with documented review and approval. The College has eliminated undocumented manual netting adjustments and requires that all R2T4 returns be recorded as distinct transactions supported by a standardized documentation package, including studentlevel calculations, withdrawal determination dates, and institutional return amounts. All activity is maintained in a centralized electronic repository to ensure a complete audit trail. In addition, the College is formalizing written procedures to define roles and responsibilities, establish documentation standards, and require documented supervisory review and approval. Periodic reconciliations will be performed to ensure that student-level return amounts agree to system activity and federal cash activity. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that R2T4 calculations and returns are accurate, properly documented, fully traceable, and compliant with federal requirements, and to prevent recurrence.

The College acknowledges the finding and agrees that Cost of Attendance and Satisfactory Academic Progress determinations must be calculated, documented, and reviewed in accordance with federal requirements. The condition resulted from reliance on manual processes, lack of retained supporting documentation, and absence of independent review and approval. The College is in the process of implementing enhanced controls over COA and SAP determinations. Formal policies and procedures will be established to define methodologies, documentation requirements, and responsibilities for preparation and review. The College will work with Information Technology and third-party consultants to enhance system configuration and develop automated processes to support calculation and retention of COA and SAP determinations within a controlled environment. In addition, the College will implement quality control measures, including a COA review committee, systematic validations and documented supervisory review, and will retain sufficient supporting documentation to allow for independent recalculation and verification of eligibility determinations. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that eligibility determinations are accurate, properly supported, and compliant with federal requirements, and to prevent recurrence.

The College acknowledges the finding and agrees that formal cash management controls are required to ensure that Title IV funds are drawn only for immediate cash needs and are properly supported and documented. The condition resulted from the absence of documented procedures and inconsistent execution of draw preparation, review, approval, and reconciliation processes. The College is in the process of implementing enhanced controls over cash management. Formal written procedures are being established to govern draw calculations, timing, approvals, supporting documentation, reconciliation requirements, and identification and return of excess cash. A standardized draw file will be maintained for each draw, including supporting student-level disbursement detail, reconciliation to eligible expenditures, and documented supervisory approval. The College will also perform and document monthly reconciliations between student disbursement records and federal cash activity. Cash balances will be monitored to ensure funds are drawn only for immediate needs and that excess cash is identified and returned, as necessary. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that draw amounts are accurate, properly supported, and compliant with federal requirements, and to prevent recurrence.