Corrective Action Plans

Finding Number: 2022-002 (repeat finding) Condition: The student status changes for certain students with status changes were not reported accurately and/or within 60 days. Additionally, certain students were reported within correct effective dates. Planned Corrective Action: Enrollment Services is working with IT on an error report and ongoing review process to identify reporting errors for timely correction. Contact person responsible for corrective action: Dina DuBuis, Assistant Vice President, Enrollment Services and Registrar Anticipated Completion Date: February 1st, 2023

Finding Number: 2022-003 Condition: The University could not provide records to substantiate that the relevant criteria was complied with by the University in all cases. Planned Corrective Action: Train faculty to preserve and provide documentation related to reported last dates of attendance. This will be stored in the university?s enterprise document management system. Contact person responsible for corrective action: Dina DuBuis, Ann Elinski Anticipated Completion Date: February 15, 2023

Finding Number: 2022-004 Condition: Of the 40 students tested for NSLDS Enrollment Reporting, the University: -For 3 students, reported the status change with incorrect effective dates -For 2 students, reported the status change to NSLDS in an untimely manner Planned corrective Action: The new person hired as the Assistant Registrar for Special Programs and Compliance was officially hired on January 11, 2022. She has gone through training for both NSC and NSLDS. She is and will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports. Contact person responsible for corrective action: Noreen Ferguson, University Registrar Anticipated Completion Date: June 30, 2022. The responsibilities of this position are completed. There will be ongoing training as training sessions become available either through NSC or NSLDS.

Finding Number: 2022-003 Condition: Of the 21 students selected for Return to Title IV testing, the University: -For 4 of the students, utilized inappropriate withdrawal dates -For 2 of the students, inaccurately calculated returns -For 5 of the students, returned funds in an untimely manner -For 1 of the students, student authorization wasn?t obtained prior to crediting account for post-withdrawal disbursement Planned corrective Action: One Stop Center staff were retrained on September 7th on the process of backdating a drop/withdraw to the appropriate date. This training will continue to be ongoing to be sure they are aware and understand the importance of the backdating being accurate. An error report has been created that can identify if the last date of attendance is equal to the date the transaction took place. If students appear on this report further investigations will be done to determine if it is the accurate date to use. R2T4 calculations are always processed on students who withdraw without regard to percentage of time attended. The staff will continue to process R2T4 in Banner for withdrawn students who receive federal aid, with a secondary calculation using the COD online R2T4 calculator to confirm outcomes. The student found regarding post-withdrawal was an oversight. Notification letters will be mailed to students who are eligible for the Post Withdrawal disbursements requesting the student acceptance of offered aid. This area will also become a review item in our process to review R2T4 calculations weekly. Contact person responsible for corrective action: Noreen Ferguson, University Registrar Anticipated Completion Date: September 7, 2022. The error report is already developed and in use. The additional training will be ongoing.

Finding Number: 2022-001 Condition: Controls in place did not identify an inaccurate calculation of assistance. Planned Corrective Action: The corrective action plan in response to Finding 2021-001 was implemented on September 22, 2022; and therefore the fiscal year ended June 30, 2022 was complete before implementation of the corrective action plan, which is as follows: Case Managers, Quality Review and Agency Managers can see supporting documentation and review cases in real time. All cases are processed by Case Managers, who consult with Agency Managers on questions, and 100 percent of cases are quality reviewed by a team from CLA (an outsourced professional services firm specializing in grants management) prior to processing payment. As Heart of West Michigan United Way receives MSHDA written guidance updates, we continue to hold twice-weekly meetings with CERA Agency Managers to discuss the frequent changes to the MSHDA guidance in order to gain a full understanding of the program requirements and regulations. Information is then disseminated to Case Managers. We will continue to hold regular trainings for CERA Case Managers to ensure consistency in approach and understanding of required documentation and proper assistance calculation. CLA continues to conduct a quality review check of 100 percent of applications to enhance internal controls and oversight. Additionally, the CERA Program Manager completes random checks of assistance calculations and payments. Contact person responsible for corrective action: Gail Montgomery, Vice President of Finance Anticipated Completion Date: September 23, 2022

Finding 2022-001 Name of Contact Person: Vivian Tookes, DSS Division Director for Economic Services and DSS Director when appointed. Corrective Action: After approval of the disbursement, a 2nd party QA check will be completed and documented in the file by a lead or supervisor. This review will satisfy the requirement in the control documents that every case will have a 2nd party review prior to monies being distributed. Proposed Completion Date: February 28, 2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Jami Parks and Stacey Teipen Contact Phone Number: 812-794-8750 Views of Responsible Official: We concur with the finding; we were unaware of the Wage Rate requirement component of the grant. Description of Corrective Action Plan: There are no construction projects left to be completed out of the COVID ? 19 Education Stabilization Funds; However the corporation sign contracts and verify payrolls on any future Federal Grants that may include construction (labor) projects. Anticipated Completion Date: August 1, 2023

FINDING 2022-005 Contact Person Responsible for Corrective Action: Jami Parks and Stacey Teipen Contact Phone Number: 812-794-8750 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The school corporation will implement internal controls to prepare, review and retain reports. The stated reporting was completed by both the Corporation Treasurer and Federal Programs Director, but the records were not initialed to show completion and review. Supporting documents will be kept as evidence of the data. Anticipated Completion Date: August 1, 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Dr Ryan Herald, Principal and High school guidance department. Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Evidence will be obtained to support withdraw of student and a second employee will sign the supporting documentation verifying the removal of the student is warranted. Anticipated Completion Date: As students withdraw, will begin with the start of the 2023-2024 school year, August 1 2023.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Grant ended during audit period. Will discuss with departments about need for internal controls. Anticipated Completion Date: 09/2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: ALN changed during middle of audit period. Will inquire mid-year with departments managing grants to see if any ALN changes. If so, new grant fund will be created. Anticipated Completion Date: 08/2023

FINDING 2022-005 Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Health Department will continue to prepare required reports with a separate individual reviewing prior to submission. Anticipated Completion Date:12/2023

2022-007 Special Education Cluster (IDEA) and COVID-19 Education Stabilization Fund Recommendation: The School Corporation should implement procedures and controls to ensure all disbursements have proper support and proper approval documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The school corporation will strengthen controls to ensure all federal grant expenditures have documentation of review and approval by a person knowledgeable of the grant requirements. Name of the contact person responsible for corrective action: Cheryl Harvey, Business Manager Planned completion date for corrective action plan: Begin immediately

2022-003 Child Nutrition Cluster Recommendation: School Corporation management should establish a system of internal controls to ensure compliance with the grant agreement and program income requirements. Documentation should be retained to support the existence and accuracy of all program income earned. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The school corporation with review existing control processes surrounding program income and strengthen procedures to ensure documentation to support program income is adequate and reviewed. Name of the contact person responsible for corrective action: Cheryl Harvey, Business Manager Planned completion date for corrective action plan: Begin immediately

Findings 2022-002: WIOA Youth Activities (CFDA # 17.259) Compliance: Earmarking Finding Type: Compliance Agency: US Department of Labor Internal Control Impact: None Finding: Per WIOA Act section 129 (a)(4)(A), the Organization is required to utilize a minimum of 75 percent of the Youth Activities funds allocated to the local area, except for the local area expenditures for administration, to provide services to out-of-school youth. Out of the funds allocated for the WIOA Youth Activities, only 70 percent of the total Youth Activities fund was used to provide service to out-of-school youth. Status: Corrective Action In-Progress Corrective Action Plan: Local Workforce Investment Area III, Inc. has taken numerous actions to address the impacts of the prior waivers and to get back to the WIOA requirement of utilizing a minimum of 75 percent of the Youth Activities funds (less administration expenditures) to provide services for Out-of-School Youth (OSY): ? Youth Team vacancies were filled and full staffing was achieved to better support comprehensive OSY-focused outreach and recruitment. ? Agency-level networking and outreach efforts were redirected exclusively to those organizations and entities serving (or most likely to serve) youth who met OSY criteria. ? Youth outreach flyers, communication and collateral materials were revamped/refreshed to expressly target OSY. ? New partnerships were forged with local community-based GED provider Made Men, Inc., YouthBuild KCK, and U.S.D. 500 REACH, expanding access to OSY applicants and prospective participants. ? The Youth services online application was refined to strategically prioritize and redirect applicants who met OSY criteria directly to Youth Team representatives. ? Semi-monthly evening virtual workshops and orientations were created to expand OSY outreach and recruitment. ? Enrollment practices were narrowed to focus squarely on OSY applicants, which successfully brought caseloads, workloads and attendant expenditures back into alignment with baseline WIOA Youth spending expectations. Local Workforce Investment Area III, Inc. is experiencing great success with these actions so far. As of January 2023, we are spending approximately 90% of our PY22 Youth program dollars (less administration expenditures) to provide services for OSY. Person(s) Responsible for Implementation: Keely Schneider Implementation Date: June 30, 2023.

Local Workforce Investment Area III, Inc Corrective Action Plan For the Year Ended June 30, 2022 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 ? Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current and prior year auditor?s reports. The Corrective Action Plan for Current Year Findings present the Local Workforce Investment Area III Inc?s corrective action plan for the Federal Award Finding described in the accompanying Schedule of Prior Audit Findings for the period ended June 30, 2022 and the prior year finding listed in the summary of prior year findings. 2022-001 and 2020-001: Program: WIOA Youth Activities (CFDA # 17.259) Compliance: Earmarking Finding Type: Compliance Agency: US Department of Labor Internal Control Impact: None Finding: Per WIOA Act section 129 (c)(4), not less than 20 percent of Youth Activities funds allocated to the local area, except for the local area expenditures for administration, must be used to provide paid and unpaid work experiences to in-school and out-of-school youth. The Local Area has not fulfilled the percentage requirement. Out of the funds allocated for the WIOA Youth Activities, only 11.21% and 17.63% were used to provide in-school youth and out-of-school youth with paid and unpaid work experiences in 2022 and 2020, respectively. Status: Corrective Action In-Progress Corrective Action Plan: Local Workforce Investment Area III, Inc. closely tracked its youth work experience percentage during program year 2021, and was aware that its percentage was too low due to a very low number of youth enrollments for the year. Knowing that action needed to be taken to increase youth enrollments, which would naturally increase work experience expenditures, it began taking steps to understand and rectify the problem in spring 2022. Local Workforce Investment Area III, Inc.?s WIOA Youth Provider, Dynamic Workforce Solutions, hired Thomas P. Miller and Associates (TPMA) to provide consultative services to assist in the development of new outreach and recruitment strategies and of new ideas to improve retention of youth during work experiences. In addition, Local Workforce Investment Area III, Inc. convened its Youth Committee on two distinct occasions specifically to discuss these issues and to provide guidance to staff, including a review of and feedback on the TPMA draft report. As a result of TPMA?s research and these consultations, Local Workforce Investment Area III, Inc. made the following Youth Program modifications to improve its overall enrollment numbers and increase its work experience expenditures: ? A personnel change was made to improve work experience/work-based learning worksite outreach, recruitment, and participant placements. ? To further expand the potential pool of worksites, strategic efforts were undertaken to foster closer coordination between the Youth Team and the Local Area?s Business Services Team. ? Full Youth Team staffing was achieved after a prolonged period of vacancies and staff shortages emerging from the pandemic. ? Staff training and outreach and recruitment strategies and tactics were re-orientated to focus squarely work experience and work-based learning as the service option of first and priority resort. ? All youth outreach flyers, communication and collateral materials were revamped/refreshed to present an appropriate value proposition to prospective youth participants with a pronounced emphasis on earning and learning through work-based learning. ? Program service plans were strategically arranged to increase the volume of individuals who received technical, classroom-based certification training coupled with a complementary work-based learning experience. ? Website content was refreshed to reemphasize and promote work-based learning as a critical employment solution and a Youth service of first-resort. ? Work experience policies and pay rates were reviewed and adjusted upward to the degree allowed for a closely alignment with trends in the unsubsidized labor market. Local Workforce Investment Area III, Inc. is confident in its corrective actions taken thus far, as it experienced excellent increases in enrollment numbers starting in early summer 2022 which have continued through PY22. As a result of these efforts, the current work experience expenditure percentage is already at 19.60% as of January 2023, with 5 more months yet remaining in the program year. Person(s) Responsible for Implementation: Keely Schneider Implementation Date: June 30, 2023.

Recommendation: We recommend that the University post and maintain the Student Aid Quarterly reports on the University?s website, as required. In addition, in order to prevent similar instances in the future, we recommend the University ensure interpretation of guidance is accurate through use of trainings, consultations and direct correspondence with the regulatory agency, when necessary, to ensure full understanding of reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university agrees. OSU reported the HEERF student aid portion quarterly on our reporting webpage. We initially interpreted the guidance to mean that at each quarter we should update the report the total student portion on the webpage to be cumulative and the previous quarter report was removed from the website. OUS will go back and report each quarter separately instead of as one aggregate total. We will post this data on the current reporting page by February 10, 2023. Name of the contact person responsible for corrective action: Keith Raab, Director of Financial Aid Planned completion date for corrective action plan: February 10, 2023

Corrective Action Plan The University will update written procedures to include an additional manual process, which identifies and updates withdrawals within the National Student Clearinghouse with a higher frequency. These procedures are targeted for the summer term, in which the current year lapse was identified. This will ensure that no one is reported outside of the 60 day window.

Need Analysis Planned Corrective Action: PowerFAIDS utilizes the ?Year in School? reported by the student on the ISIR to calculate Federal Direct Loan eligibility during packaging. If misreported by the student, advisors did not always catch these errors in their review. Executive Director of Financial Aid will provide in-house training to all advising staff to ensure proper understanding of awarding and implication of not appropriately updating fields used to calculate aid eligibility. WBU has funded a Financial Aid Compliance Specialist position in the Office of Financial Aid. Once filled, this position with be devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: November 2022

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: Disbursement has been assigned to several different staff over the last year due to turnover within the Office of Financial Aid, which may have contributed to this finding. Because WBU does not float disbursement of Pell Grant, procedures have been updated to future-date disbursement files for Pell by at least two days to ensure enough time to resolve any rejects and reconcile the disbursement records. Executive Director of Financial Aid will provide in-house training to responsible staff to ensure proper understanding of change to procedures. WBU has funded a Financial Aid Compliance Specialist position in the Office of Financial Aid. Once filled, this position with be devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: November 2022

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: In late June 2022, known settings and data required by the baseline report were in place, and a small sample of test records passed a basic test. In July 2022, full-term data generated by the PowerCAMPUS baseline tool was submitted to NSCH as a more extensive test for Summer 2022. Due to the discovery of a significant number of SIS data errors for at least two major categories and a quickly approaching deadline, the previous tool was used for that end-of-term enrollment data. In addition, the previous tool was used for earlier registration reporting within the Fall 2022 term. The PowerCAMPUS baseline tool is being updated and tested again during the Fall 2022 term with anticipation that the baseline tool will be used for reporting the final end-of-term enrollment data reported in January 2023. Person Responsible for Corrective Action Plan: Cagan Cummings, CIO and Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: January 2023

The University of New Hampshire respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University of New Hampshire (UNH) will work to resolve the reporting finding for fiscal year 2022 reporting. UNH will develop a process to ensure that the information reported is accurate and supporting documentation used to prepare the reports and review and approval of the reports is retained. Name(s) of the contact person(s) responsible for corrective action: Liz Stevens, Director of Student Financial Services (Student Reporting) Susan Zipkin, Director Accounting and Financial Compliance (Institutional Reporting) Planned completion date for corrective action plan: March 31, 2023 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Plymouth State University respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Plymouth State University (PSU) will work to resolve the reporting finding for fiscal year 2022 reporting. PSU will develop a process to ensure that future information is reported timely, and the review and approval of the reports is documented and retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Mary Batch, Director of Finance (Institutional Reporting) Mac Broderick, Director of Student Financial Services (Student Reporting) Planned completion date for corrective action plan: July 31, 2022 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Keene State College respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Keene State College (KSC) will work to resolve the reporting finding for fiscal year 2022 reporting. KSC developed a process to ensure that the information is reporting timely, accurately, and supporting documentation used to prepare the reports and review and approval of the reports is retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Catherine Mullins Planned completion date for corrective action plan: July 1, 2022 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Granite State College respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Granite State College (GSC) will work to resolve the reporting finding for fiscal year 2022 reporting. GSC and the University of New Hampshire (UNH) are in the process of merging as part of a new college within UNH, which resulted in a transition of reporting responsibilities and processes. GSC and UNH will develop a process to ensure that the information reported is accurate and supporting documentation for the review and approval of reports is retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Andrea Nepveu, Acting Director of Financial Aid (Student Reporting) Susan Zipkin, Director, Accounting and Financial Compliance (Institutional Reporting) Planned completion date for corrective action plan: March 31, 2023 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above.

Finding Number: 2022-001 Planned Corrective Action: The School District has already implemented policies and procedures to ensure timely updating and has documented the remedies taken for the items noted as noncompliant in the audit. Anticipated Completion Date: January 31, 2023 Responsible Contact Person: Donna Solano, Financial Aid Coordinator

FINDING 2022-009: Prevailing Wage Rate Internal Control and Compliance Response: Going forward all construction using federal funds in excess of $2000 will have a contract stating the prevailing wage rate clause and submission of weekly certified payrolls.

Finding Reference 2022-02 Corrective Action Plan: The Authority will perform an internal review of the toll credits Excel spreadsheet and will reconcile all credits with the last version of the Federal-Aid Project Agreement approved by Federal Highway Administration (FHWA). For the fiscal year 2024, the manual process of reconciling toll credits balance of the new projects will be changed to an automated process with the PMIS Program, as agreed in Section II of the Memorandum of Understanding (MOU) signed in February 2016 between FHWA and the Authority. In addition,current toll credits tracking, reconciliation, and approval process is reviewed by FHW A PR Division for compliance. Responsible: Mr. Enrique J. Rosa Torres, Executive Director of Administration and Finance Status: In process. Expected to be completed during fiscal year 2024.