Corrective Action Plans

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.

2022-005 Higher Education Emergency Relief Funds (HEERF) Reporting Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College establish controls to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure proper documentation of reviews for reporting and that report submission guidelines are followed. Name(s) of the contact person(s) responsible for corrective action: Cathy Castle, Vice President for Business and Finance Planned completion date for corrective action plan: Immediately as additional federal awards are received.

2022-004 National Student Loan Data System (NSLDS) Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College utilizes a clearing house for submitting student statuses. Tabor will ensure that all students statuses are filed accurately and timely. Name(s) of the contact person(s) responsible for corrective action: Scott Franz, Interim Financial Aid Director Planned completion date for corrective action plan: April 2023

Finding 2022-001 Significant Deficiency Federal Program: HOME Investment Partnerships program Assistance Listing Number: 14.239 Federal Grantor: Department of Housing and Urban Development Federal Award Year: 2021-2022 Management?s Response and Corrective Actions: Background: Since 1985, the City of Inglewood has approximately 90 loans issued to homeowners under the HOME Program for either homebuyer programs or for housing rehabilitation programs. Over the years, the City has contracted with the outside agency, Inglewood Neighborhood Housing Services (INHS) to administer these homeowner loan programs for Inglewood residents. Additionally, the City has directed the Community Development Block Grant (CDBG) Division and the former Inglewood Redevelopment Agency to oversee the administration of these loans. It has been demonstrated that the now defunct INHS has issued loans to homeowners and may not have recorded each transaction accurately, thus resulting in some loans being paid off without proper noticing to the City. Some homeowner loans were not adequately identified as being loans attributable to the City; and some loans issued were misidentified as being either City loans from the U.S. Department of Housing and Urban Development (HUD) or City loans from the former State of California Department of Finance Redevelopment Agency (RDA). In 2007, the City has retrieved the loan files from INHS in an attempt to reconcile the outstanding loans issued by INHS, with those loans already repaid or otherwise closed. The City?s CDBG Division along with the RDA has been tasked with reconciling the home loans for both HUD and the RDA. During this period, the City suffered a gradual reduction in HUD CDBG and HOME funds which resulted in the gradual reduction of key CDBG staff members, beginning with the separation of the Senior Grants Coordinator, the Grants Coordinator, the CDBG Division Accountant, and the CDBG Administrative Analyst. The remaining full-time staff and two new full-time CDBG Division staff saw the retirement of the Grants Manager, and a series of five subsequent managers since 2013. In a drastic turn of events and after a long litigation at the State level, effective February 1, 2012, California experienced the dissolution of over 400 of the state?s RDAs, including the City?s RDA, a once robust agency with over 15 staff members. At the local level, the City of Inglewood was named as the Successor Agency responsible to manage Inglewood redevelopment projects currently underway, make payments on enforceable obligations, and dispose of redevelopment assets and properties. With the dissolution of the Inglewood RDA, staffing was reduced to five remaining members. As of 2016, the Successor Agency had only two staff members, one full-time staff member and one part-time staff-member. Unfortunately, with the high level of turnover in the City, the City loans were not consistently updated in a timely fashion. Since 2019, the City has stabilized its staffing to include a HUD Programs Manager who is responsible for overseeing the Home Loan Programs. The HUD Programs Manager will ensure the loans are properly monitored and serviced. The City has two Senior Program Specialists who have a combined total of over 40 years of experience in HUD Programs. The City is currently recruiting for a third Senior Program Specialist. Corrective Action 1.0: The City will review each loan on the outstanding loan schedule and will update each to ensure the status is correct according to the schedule. For any outstanding loan where the terms have been satisfied, the City will ensure these are properly recorded as receivable and listed on the HOME loan receivable schedule maintained by the City. Projected Time of Completion: Each loan is scheduled to be updated by December 30, 2023. Corrective Action 2.0: The City will reconcile its records to ensure the each City loan is accounted for according to the source of funding and the terms of each loan. Staff will ensure each loan is properly recorded with the Los Angeles County Recorder?s Office, if required. Projected Time of Completion: April 30, 2024 Corrective Action 3.0: Staff will implement an intense cross-training session amongst the Finance Department Accounting Division, the Successor Agency, and the CDBG Division to ensure that all responsible staff are thoroughly trained to service and monitor the Home Program Loan files. Corrective Action 3.1: Staff will update the HOME Procedures Manual (Manual) to include the cross-training policy and any other program updates, as appropriate, to current procedures and protocol. The Manual will be maintained in a shared file for reference by all staff and willl be made available to the public upon request. Projected Time of Completion: April 30, 2024 Corrective Action 4.0 (1) Staff will monitor, annually, the outstanding loan files and will service and update the loan files as requests are made to the City. (2) Staff will notify the Accounting Division when a loan changes status and provide the appropriate supporting documentation, immediately upon receipt. (3) The HUD Programs Manager will ensure the loan files and all transactions are maintained in a shared file. (4) The HUD Programs Manager will assign staff to report quarterly on any changes to the loan files. Projected Time of Completion: Quarterly, at a minimum.

FINDINGS ? FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Child Nutrition Cluster Federal Assistance Listing Numbers: 10.553; 10.582; 10.559 Finding 2022-001 ? Internal Controls Recommendations: The District should have an employee compare the District Treasurer?s supporting documentation and the Child Nutrition report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the report submitted should be printed, initialed by the secondary reviewer, stapled with the information used to compile the report and combined with all financial records for the fiscal year. Action Taken: We agree with the recommendation. Our targeted implementation date is March 2022.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure that any future private school expenses are incurred and paid by the district instead of reimbursing the private schools their expenses. This will be reviewed by the Director of Curriculum to ensure compliance. Anticipated Completion Date: March 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure that any future capital equipment gets included on our inventory list. This will be reviewed by the Superintendent to be sure all equipment is added. Anticipated Completion Date: March 2023

The District will enforce, not only that the contract includes prevailing wages are to be paid, but that certified payroll reports from contractors are provided to the District. These payroll reports will be reviewed, and retained before payment will be made to the contractor. The control and procedure will be implemented immediately by completing a check list. To comply with the prevailing wage law this checklist will be completed before payment is issued to the contractor.

Views of responsible officials and planned corrective actions: Boys & Girls Clubs of Kootenai County agrees that there was not a formal process. The expenditures and categories in our submitted budget were approved in our grant application by DHW. In the future we will identify and track administrative related expenses that are charged to grant(s) in QuickBooks to ensure this problem does not recur.

2022-001 ? Review and Approval of the Schedule of Expenditures of Federal Awards (SEFA) ? We feel that much was learned in the audit process by Organization staff and Palm Beach Accounting and Financial Services. We will make the Schedule of Expenditures of Federal Awards a priority in the next audit, and if need will retain an expert consultant to assist in the preparation prior to providing to the audit firm.

Finding 2022-001: Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Year - June 30, 2022 Condition/Context: The change in student status for 1 out of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The student withdrew in September 2021 but was not reported until December 2021. Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The Office of Academic Success now notifies all pertinent offices of any student withdrawals in a timely manner. In addition, if a student withdraws with more than a week between their withdrawal and the last day of attendance, their change in status notification is processed immediately in NSLDS by the Registrar?s office. The Registrar also performs a monthly review of all status changes to verify all enrollment status changes are updated accurately and reported to NSLDS within the required timeframe. Names of Contact Persons Responsible for Corrective Action: Barbara Schmitt, Director of Financial Aid and Dan Cebrick, Registrar Anticipated Completion Date: Changes were effective for Fall 2022 semester.

2022-003: Loan disbursement notifications {14 day right-to-cancel letters). Management Views and Opinion The University of Miami acknowledges that some students did not receive their notifications informing them of the 14 day right-to-cancel for their Federal Direct Loans within the proscribed timeframe of 7 days from the date of disbursement. The root cause was a defect in the server set-up for our financial aid automated processing; the administrative software appeared to generate letters and provided no error message, however, notifications were not sent. Once identified by UM on October 21, 2021, UM sent notifications to any students not originally notified, however, this notification occurred outside the required window of time (7 days). Corrective Action The University has worked with the software provider to diagnose the issue as a missing instance of Microsoft Word on the server which processed the 14-day letters. We have addressed this issue and repaired the automated functionality as of September 21, 2022. During the down time, the university prepared these letters using a daily manual process to ensure that they were sent in a timely fashion. Timeline for Action Plan The issue was initially identified, and a temporary corrective action was put in place in October 2021 with a final correction in October 2022. Responsibre Individuals Daniel T. Barkowitz Roosevelt Deleveaux Beth Hernandez

2022-002: FOL and Pell Reporting Management Views and Opinion The University of Miami acknowledges that the disbursements as reflected on the individual student account were different by one day from the date reported to COD (Common Origination and Disbursement system). This error occurred due to the timing of scheduled jobs to run financial aid disbursement. The file process to disburse jobs ran late at night prior to midnight, but the job to post the disbursed aid ran after midnight and therefore showed a day later than reflected on the financial aid system. Corrective Action Plan In mid-August 2022, the University changed the evening job schedule to ensure that Federal financial aid will be both disbursed from the-financial aid system and posted to the Student Account on the same calendar day. This evening schedule job change will resolve this situation moving forward. Timeline for Action Plan The underlying issue was already corrected in August 2022. Responsible Individuals Daniel T. Barkowitz Roosevelt Deleveaux Norma De La 0

2022-001 Enrollment Reporting Management Views and Opinion Graduation Status Change UM management agrees that I out of 40 students had graduated but whose graduation status change was not reported at the campus or program level. While this student's graduation status change was not reported at the campus or program level, the student's record was reported as withdrawn within the allotted 60 days and therefore NSLDS was aware student was no longer enrolled. Enrollment Status Change UM management agrees that 14 out of 40 students' program level withdrawal date did not match their campus level withdrawal date. While all the students' withdrawal statuses were reported within the NSDLS guidelines and the final day of the Fall 2021 semester was used for their campus level withdrawal date, the first day of the Spring 2022 semester was incorrectly used for the program level withdrawal date. Corrective Action Plan Graduation Status Change Management will expand on the current controls in place by adding a review process for those student accounts that require manual status changes. Enrollment Status Change Management will expand on the current controls in place by adding a review process for those student accounts that require manual status updates based on the National Student Clearinghouse (NSC) Error Resolution Report. Timeline for Action Plan Graduation Status Change The review process for graduation status changes was implemented effective December 9, 2022. Enrollment Status Change The review process for enrollment status changes was implemented effective December 9, 2022. Responsible Individuals Allen Augustin, Associate Registrar

2022-005 Reporting Management Views and Opinion UM management agrees that the PRF Period 1 reporting submission was subsequently revised to remove $14,854,235 of Other Provider Relief Fund Expenses. The Other Provider Relief Fund Expenses removed from the Period 1 submission were allowable. However, given the dynamic reporting guidance and best practices circulated subsequent to the Period 1 reporting submission, it was determined by management to utilize lost revenues to support the PRF funding rather than expenses incurred. Corrective Action Plan UM management believes this to be an isolated incident due to the novel COVID-19 virus. While management will work to avoid the need for revised reporting submissions, management will continue to ensure the reports align with the latest guidance and best practices. Timeline for Action Plan UM management identified the need for a revised report and has already completed the revised submission. Responsible Individuals Charity Fannin, Chief Accounting Officer Craig McAllister, Assistant VP Risk Management

2022-004 Reporting Management Views and Corrective Action Plan Quarterly Report Posting There was minimal reporting guidance available during the initial HEERF I disbursement period. Although there are no more funds to report, UM management will ensure to follow the guidelines of reporting, and all required content is timely posted on the UM website. Quarterly Report Submission While the submission to the Department of the Education was on time, the posting on the website was slightly delayed for calendar quarters ended June 30, 2021, and September 30, 2021. Although funds have been fully disbursed, UM management will complete future required reports with ample time to allow the website team to post the required content prior to the deadline. Additionally, UM management will confirm posting took place by the deadline for tracking and assurance purposes. Quarterly Report Data Based on input from financial aid, the differences are immaterial and could be due to appeals granted after publication. The quarter report ended June 30, 2021, posted on the UM website, has a percentage error of 2.9% in the total amount distributed to students. The quarter report that ended December 31, 2021, posted on the UM website, has a percentage error of 0.2% in the total amount distributed and 0.9% in the total number of eligible students. Although funds have been fully disbursed, UM management will ensure compliance with reporting guidelines, and we will update the website if appeals have been granted after the reporting deadline. Timeline for Action Plan The corrective action plan will begin immediately with the first quarter of the calendar year 2023. Responsible Individuals Aintzane Celaya, Associate Vice President Financial Planning & Analysis and Chief Budget Officer

U.S. Department of Health and Human Service Corona-Norco Family Young Men's Christian Association respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 through June 30, 2022 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 2022 ? 001 ? Significant Deficiency ? Financial Statements Closing and Reporting Recommendation: We recommend improving the independent review of monthly financial statements, in particular to the area of collectability of receivable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our organization moved from one accounting system to another causing an error in entry/recording. Our organization has implemented the following: Monthly financial reviews including receivable oversight. Review is conducted by organization?s outsourced accountant, Finance Committee as a board function, Department Program Directors, back office administrative person and the YMCA Leadership staff team. Line items are reviewed, and variances are reported in written format each month. Additionally, all receivables are reported and collected within 90 days with a 30-60-90 day follow up plan. Name(s) of the contact person(s) responsible for corrective action: Audrie Echnoz, Chief Executive Officer. Planned completion date for corrective action plan: Beginning July 1, 2022 FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Health and Human Service 2022 ? 002 ? Cost Principles: Compensation ? Personal Services Federal Program Name: Child Care and Development Block Grant Child Care Mandatory and Matching Funds of the Child Care and Development Fund Assistance Listing Number: 93.575, 93.576 Recommendation: We recommend the entity implement procedures to ensure that documentation in place as in accordance with the OMB's Uniform Guidance. In situation that it was reporting error from a third-party provider, we recommend the entity implement alternative procedures to maintain sufficient documentation. View of Responsible Officials: There is no disagreement with the audit finding. Explanation of disagreement with audit finding: Our organization moved from written time sheets to a digital payroll platform. The training and staff implementation has included ongoing training with policies being rolled out and followed up with each month. Human resources has since reminded all staff of the requirement to approve their timesheets and all supervisors were reminded of this in recent staff meeting. This will be reviewed each payroll period and strong adherence will be followed with follow up action in place. Name(s) of the contact person(s) responsible for corrective action: Audrie Echnoz, Chief Executive Officer. Planned completion date for corrective action plan: Beginning July 1, 2022 If the U.S Department of Health and Human Services has questions regarding this plan, please call Audrie Echnoz, Chief Executive Officer at 951-479-4779.

2022-065 Oregon Department of Education State did not meet maintenance of effort requirement Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C, 84.425D, 84.425R, 84.425U & 84.425W Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C210048; 2021 (COVID-19), S425D210049; 2021 (COVID-19), S425R210047; 2021 (COVID-19), S425U210049; 2021 (COVID-19), S425W210038; 2021 (COVID-19) Compliance Requirement: Matching, Level of Effort, Earmarking Type of Finding: Material Weakness; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: Section 18008 of Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act; Section 2004(a) of the American Rescue Plan (ARP) Act; 2 CFR 200.303 The CRRSA and the ARP acts require the State to maintain support for both elementary and secondary education and for higher education in fiscal year 2022 at least at the proportional level of the state?s support for elementary and secondary education and for higher education relative to the state?s overall spending, averaged over fiscal years 2017, 2018 and 2019. The Department of Education did not meet the maintenance of effort provisions for fiscal year 2022 for elementary and secondary education. Although the state?s overall funding increased for education its proportional level relative to Oregon?s overall spending declined. The department is reliant on the legislative budget process. The department was in contact with the federal awarding agency about the maintenance of effort issue. The department submitted a waiver request to the U.S. Department of Education dated March 29, 2023. According to department management, budget changes and obtaining a clearer understanding of the other fund amount delayed the calculation for maintenance of effort. If the waiver is not approved, the department may be asked to return some of the funds. The total federal expenditures for the Education Stabilization Fund program for the fiscal year ended June 30, 2022 were $426 million. We recommend department management continue to actively track whether it will meet the maintenance of effort requirement and work with the federal awarding agency. MANAGEMENT RESPONSE: We agree with this recommendation. The Department of Education agrees with this finding; however, context is critical to understand this requirement. The Maintenance of Effort (MOE) requirements in The ARP ESSER III legislation are unique. The purpose of the requirement is to ensure that states are not moving the federal pandemic funds in to replace state funding and then leaving districts with a more substantial ?fiscal cliff? when the pandemic funds recede. ODE administers state funding to Oregon districts, but the levels and formulas governing the distribution of the funds are determined by the Oregon Legislature and not ODE. State School and the Student Success Act?s Student Investment Account funding and other funding corrections are via complex statutory formulas intended to ensure equity of funding across the state. ODE has worked very closely with our USED partners regarding the delay in our access to data and while preparing the Maintenance of Effort waiver request to USED. While ODE acknowledges the state did not meet MOE, ODE has made every good faith effort within in its power and authorities to communicate the reasons for lack of compliance to USED and timely applied for a waiver. ODE, along with other SEAs, now has a deeper understanding of the funding and methodology requirements of MOE under ARP ESSER and will be able to assess compliance for 2023 much more quickly, but only after the final 2023 data is completed. Since that data completion will not be until January 2024, ODE will likely still be contemplating whether or not to pursue an MOE waiver with USED early in 2024. ODE is committed to continue to work closely with our USED partners to achieve compliance or appropriately request a waiver. Anticipated Completion Date: June 30, 2024 Contact: Cynthia Stinson, Senior Manager of Federal Investments & Pandemic, Renewal Effort, OTLA

2022-021 Oregon Housing and Community Services Controls are needed to ensure compliance with level of effort requirements Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Matching, Level of Effort, Earmarking Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 24 CFR 576.101(c) When a subrecipient is a unit of general-purpose local government, its ESG-CV program funds may not be used to replace funds the local government provided for street outreach and emergency shelter services during the preceding 12-month period unless U.S. Dept. of Housing and Urban Development determines the local government is in a severe financial deficit. ESG-CV funds should be used to supplement, not replace those funds. We determined the department was not monitoring its subrecipients for compliance with level of effort requirements during our review. Documentation was not available for review, and we were unable to determine the department?s compliance with this requirement. As a result, local governments could be using program funds to replace their funding allocated to street outreach and emergency shelter services. We recommend department management develop procedures to ensure compliance with federal requirements for level of effort and maintain documentation. MANAGEMENT RESPONSE: We agree with this recommendation. Level of Effort monitoring is part of program monitoring for State FY23 which is on track to be completed for all ESG recipients. OHCS is in the process of designing a self-certification form for subrecipients to acknowledge and agree to the compliance requirements in which funds may not be used to replace funds the local government provided for street outreach and emergency shelter services. Anticipated Completion Date: December 24, 2023 Contact: Jill Smith, Director of Housing Stabilization Division