Corrective Action Plans

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) Certain key line items within submitted FISAP report did not agree to source documentation. Corrective Action Plan: The College recognizes the importance of completing the FISAP in a timely and accurate manner. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director assumed the role in August 2022 and has updated the procedures related to preparation of the FISAP report to ensure timely and accurate reporting. Anticipated Completion Date: March 1, 2023

Individuals Responsible for Corrective Action Plan Jeff Scaccia, CPA (Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur, (Director of Student Financial Aid) For 1 of 2 students tested, the student was in V5 tracking group, his Identity/Statement of Educational Purpose form was signed and received as of 11/17/21 which is after first title IV disbursement. Per IFAP verification guide. "No disbursements of Title IV aid may be made until the V5 verification is satisfactorily completed." Corrective Action Plan: The College acknowledges institutions are required to verify applications selected by the Central Processing System for students who will receive or have received need based/subsidized student financial assistance. As permitted in federal regulations (34 CFR 668.54(b)), verification is not required for students who are only eligible for unsubsidized student financial assistance. Students in this situation are noted as ?Selected, not verified? to COD. At Presbyterian College, graduate and professional students only receive unsubsidized federal financial assistance, so only those selected in the ?V4? and ?V5? verification groups are required to complete the verification requirements of these groups. The Office of Financial Aid has experienced significant turnover in its staffing during fiscal years June 30, 2021 and 2022. This included employing two different Directors, the second of which vacated the position in June 2022. The staffing of the Financial Aid Office has since stabilized and the new Director has implemented procedures for the 2023-2024 academic year through Banner (software) setup that prevents disbursement of federal aid with any outstanding fund or non-fund requirements. Any student with V1, V4, or V5 set on the ISIR will automatically populate outstanding requirements. Aid will not disburse until those are fully satisfied. Anticipated Completion Date: March 1, 2023

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of District contact person: Mike Merlino, Executive Director of Business, Finance and Operations 18360 Caldart Avenue, NE, Poulsbo, WA 98370 Tel: (360) 396-3010 Corrective action the auditee plans to take in response to the finding: The district will establish internal controls to ensure staff fully understand the requirements for ECF award. The district will recall the non-federally funded devices and exchange them for ECF funded devices. Anticipated date to complete the corrective action: August 31, 2023

Statement of condition #2022-002 Comments on Finding and Recommendation: During the year ended March 31, 2022, the Property continued to receive PRAC subsidy payments for one resident for six months after the resident moved out of the Property. The Agent should note resident move outs or deceased tenants on the monthly PRAC vouchers requests in a timely manner following the terminating event to avoid receiving unauthorized PRAC payments. Action(s) Taken or Planned on the Finding: The Agent concurs with the recommendation. The Agent will note resident move outs or deceased tenants on the monthly PRAC voucher requests in a timely manner following the terminating event to avoid receiving unauthorized PRAC payments. The Agent will reimburse HUD for the unauthorized PRAC payments received.

Statement of condition #2022-001 Comments on Findings and Recommendation: During the year ended March 31, 2022, 6 of the 23 cash disbursements selected for testing were not supported by approved invoices, bills, or other supporting documentation. The Agent should ensure that all cash disbursements are supported by approved invoices, bills, or other supporting documentation. The Agent should require that vendors provide written documentation of services or goods provided prior to making payments to the vendors. Action(s) Taken or Planned on the Finding: The Agent concurs with the recommendation. The Agent will require all vendors to submit invoices or other support for work performed prior to making payments to vendors, and all documentation will be retained.

Finding #2022-005 ? Education Stabilization Fund ? ESSER I and ESSER II #84.425D (Prior Year Finding #2021-007) Federal Grantor ? U.S. Department of Education Pass-through Award Numbers ? 2021-224904-DPI-ESSERF-160 and 2022-224904-DPI-ESSERFII-163 Pass-through Entity ? Wisconsin Department of Public Instruction Condition: There were two Education Stabilization Fund construction projects performed by contractors. ESSER I grant expenditures for the project totaled $10,445 and ESSER II grant expenditures for the project totaled $21,238. There was not a prevailing wage clause in the contract and certified payrolls were not received while construction was occurring. Labor costs for the ESSER I project totaled $2,691. Labor costs for the ESSER II project totaled $2,800. Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contacts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts subject to wage rate requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Cause: The District was not aware that wage rate requirements applied to the construction project until after it was completed. Effect: Potential reimbursement for costs that did not follow the prevailing wage rate requirements. Recommendation: Establish controls to comply with prevailing wage rate requirements related to the Education Stabilization Fund. Response: The District is working with each contractor and their attorneys to determine the amount of backpay owed to employees to ensure prevailing wage rates are paid. Once the District became aware of this requirement, all construction contracts in excess of $2,000 funded with federal dollars a prevailing wage rate clause in the request for bid and contract. Certified payrolls are being receiving on all current applicable projects. Contact Person: Tracy Stagman Anticipated Completion: June 30, 2023

Finding 2022-04 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Gerry Leadbetter, Administrator Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the program's reserve fund is completed with formal documentation noting the review. The Business Office Manager will reconcile the bank statement and will sign off on the bank statement, along with the Administrator for the USDA Loan Reserve Bank Account. Anticipated Completion Date: 03/31/2023

Finding 2022-03 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: Eide Bailly assisted in the preparation of our draft schedule of expenditures and federal awards and accompanying notes to the consolidated schedule of expenditures and federal awards. Responsible Individuals: Gerry Leadbetter, Administrator Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for a complete and accurate schedule of expenditures and federal awards. We requested that our auditors, Eide Bailly LLP, assist in the preparation of the schedule of expenditures. We have designated a member of management to review the drafted schedule of expenditures. Anticipated Completion Date: Ongoing

The Organization acknowledges Finding 2022-002. Corrective Action Plan: The Organization will implement an internal review process, which will be used prior to submitting the EDA-209 report, to ensure that the report has been accurately prepared. Responsible Person: Vandell Hampton, Jr., President & CEO Anticipated Completion Date: July 31, 2023

The Organization acknowledges Finding 2022-001. The Organization will revise the post loan closing process to include a tickler system that alerts the Portfolio team after the loan has been closed to ensure that the loan has been properly closed and that all collateral and security filings have been completed. Responsible Person: Vandell Hampton, Jr., President & CEO Anticipated Completion Date: July 31, 2023

SY2021-22 AUDIT FS 2022-001 Internal Controls Over District Cash (Material Weakness) Repeated And Modified ? This has been an ongoing process to achieve final reconciliation. In SY21-22 the District worked with PED to facilitate a second Permanent Cash Transfer request in order to reconcile closed or unused funds. The approval from PED was not received prior to the closing of the fiscal year ? The District has worked closely with PED to re-apply for the Permanent Cash Transfer and has come to agreement on which funds will be transferred ? The District is working with a CPA firm to properly adjust cash balances and has developed a new procedure and checklist for completing the ?rollover? of funds from the prior year ? The District now has a new procedure to more accurately record the Health and Well-Being employee reimbursements and will include a review of this process each quarter when the District meets with the CPA to conduct a mini-audit ? The correct accounts and procedures for properly recording Bond proceeds have been established FS 2022-002 Budgetary Controls (Significant Deficiency) Repeated and Modified ? The District provided additional training for staff using the Visions accounting system so that errors related to inputting the budget in the accounting system will be reduced ? The District also implemented a process whereby funds submitted and approved in OBMS can be compared to on a monthly basis with the actual expenditures coded in Visions ? Our Coordinator for Procurement and Capital Projects now meets monthly with fund managers to ensure that all expenditures match the budgeted amounts and are coded in the correct object ? A new process was implemented to record Bond interest within Visions so that the cash is more accurately reflected and matches the bank balances ? Journal entries are reviewed weekly to ensure proper allocation ? The bank reconciliations are reviewed now by a second Business Office employee ? All fund balances are now checked before a purchase order is approved ? Business Office personnel will meet quarterly with our CPA to review transactions for accuracy and to review any process improvements necessary FS 2022-003 Lack Of Internal Controls Over Payroll Liabilities Accounts And RHC Payments (Material Weakness) ? Segregation of duties were re-established so that the payroll clerk would be responsible for timely submission and reporting of payroll liabilities ? The District Accountant will be responsible for bank reconciliations as well as for verifying outstanding liabilities each month FA 2022-004 Non-Compliance With Davis-Bacon Act And Capital Expenditure Requirements (Significant Deficiency) ? The District has developed new language that will be included in all agreements for project meeting the criteria of the Davis-Bacon Act and will include the language in all applicable purchase orders ? The District has reviewed all currently-qualified projects and has obtained the required certified payroll reports for projects commencing or continuing in SY22-23 ? The Director for Student Services (Federal Programs) has created a checklist for obtaining permission to purchase at $5,000 or above for single items ? The District has established a protocol for including the written permission from PED in the documentation accompanying the purchase requisition and purchase order NM 2022-005 Improper Approval Of Budget Adjustments (Other Non-Compliance ? The Business Office has a process documented to ensure BARs are properly obtained prior to any use of funds NM 2022-006 Purchase Order And Authorization (Other Non-Compliance) ? The District continues to provide regular training (4 x per year) to school site and department staff who have access to purchase requisitions, though the problem persists ? The District has implemented a new vendor agreement as well, outlining the specific terms vendors must adhere to as vendor the District. One of the terms is that the vendor will not perform any service nor provide any product without first receiving a signed and authorized purchase order NM 2022-007 Timeliness Of Deposits (Other Non-Compliance) Repeated And Modified ? The District has made steady and deliberate moves to eliminate cash collected from all events, concessions and fundraising efforts by moving to a cashless system ? This process has still not been completely implemented because not all locations in all sites had wifi accessible internet access. The District has been working to correct that ? All school sites and cafeteria workers have been trained on the cashless system and in all but a two locations, the program has been fully implemented NM 2022-008 Failure To Timely remit Federal Withholding Taxes As Required (Other Non-Compliance) Repeated And Modified ? The District recognized that when supplemental payrolls were run after the regular payroll, the required payroll taxes for those particular supplemental payrolls were not made on the same day that supplemental payroll was run. Because of this, the District also recognized this was a repeated finding and a new procedure was established that required all payroll taxes to be prepared and the payment processed on the same day payroll was uploaded to the bank. NM 2022-009 Equity In Athletics Reporting (Other Non-Compliance) ? The District has placed on its calendar, reminders of when the Title IX report is due in the fall ? The District has determined that the three Athletic Directors (Grants High School, Laguna Acoma High School and Los Alamitos Middle School) will be responsible for gathering the data required to file the report ? The athletic directors will receive training on how to properly complete the report and upload it to the PED site NM 2022-010 Background Checks and I-9 Documentation (Other Non-Compliance) Repeated And Modified ? The HR Department has reviewed every single personnel file and identified those individuals who required an updated FBI check ? The HR Department contracted with a mobile fingerprinting provider and scheduled over 150 employees for updated fingerprinting and completed updated background checks ? The HR Department will implement a new 24-month cycle review and establish a rotating schedule to regularly update required background checks NM 2022-011 Failure To Complete An Annual Physical Inventory And Complete Certification By The Board (Other Non-Compliance) ? In SY21-22 the District began a complete inventory of all assets. The process was not completed until the beginning of SY22-23. Prior to this, an accurate accounting of assets was not updated. ? In the Fall of 2022 the board approved the newly-completed asset list and depreciation schedule ? Moving forward, each July the board is scheduled to receive an updated listing of assets for review and approval. NM 2022-012 Late Filing Of Audit Report (Other Non-Compliance) ? The District is working with a CPA firm to assist in quarterly mini-audit reviews in an effort to spot any anomalies that may delay the audit filing Responsible Party For Completing These Corrective Actions C Steven Maldonado, Director of Finance

Management concurs with the finding and recommendations. Isabella Graham Hart School of Nursing (the School) has revised its Enrollment Status Reporting procedures and provided training to ensure changes are submitted and reported on time. The above procedures have been implemented.

Management concurs with the finding and recommendations. Isabella Graham Hart School of Nursing (the School) recognizes that our Student Information System (SIS) used to monitor and manage the credit balances for students is limited in its capabilities. We are in process of implementing a new SIS that has ability to perform the necessary requirements to ensure we are processing any credit balance within the required time permitted. The School has implemented a weekly process of monitoring credit balances through the utilization of a Credit report, along with issuing payments if needed on a weekly basis to students. Implementation of the new SIS in expected to be completed in 2024 and in the interim have begun a weekly manual monitoring process.

Recommendation We recommend that the District review its controls related to meal counts to ensure that they are properly counted and documented. Action Taken Physical meal counts were discontinued for the 2022-2023 school year, and the District will go back to using their electronic processes for meal counts.

Contracts charged for expenses outside of the period of performance have been credited for ineligible expenses. Share's Director of Finance, Christopher Brox will provide training to accounting staff responsible for expense entry, expense review and approval, and invoicing by June 30, 2023 that include the following topics: - Allowability of expenses based on both contract criteria and the period of performance. - key identifiers that could flag an exception in allowability based on period of performance, and how to catch this in the review of expenses. - General ledger transactions that require further review for period of performance allowability during monthly review of expenses prior to preparing invoices. This training will highlight this being a specific area of focus for review during periods when a contract terms and a new contract starts. This training will happen with all new accounting staff responsible for expense entry and review and will be incorporated as refresher trainings if contract and grant administrator expense reviews identify this as being a continued issue by staff performing expense data entry.

Identifying Number: 2022-002 Finding: For the Hospital?s Period 1 reporting in the HRSA portal, the Hospital inaccurately reported lost revenues and expenses, resulting in an overstatement of lost revenues and an understatement of expenses. Management did not have effective internal controls in place to ensure reporting of lost revenues and COVID-eligible expenses were adequately reviewed before submission. Corrective Action Taken or Planned: Management will segregate the duties, by assigning the generation of reports to the Controller. The Chief Financial Officer will verify all reports are within the correct parameters, prepare the report, and submit to the Chief Executive Officer for final review. Person Responsible: Tammy Gadberry, Chief Financial Officer, Email: tgadberry@sdcmh.org Phone 217-322-5296 Anticipated Completion Date: January, 2023

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended 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?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2022-018 Adoption Assistance, CCDF Cluster - Assistance Listing Nos.: 93.659, 93.575, and 93.596 Recommendation: We recommend that the Department regularly review their public assistance cost allocation plan and submit amendments for approval as necessary. Additionally, we recommend consolidating the support documentation for bases with multiple percentages. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding. The change involved allocation based on newly-tracked case management time statistics instead of benefit payment statistics. The new time statistics were available for the first time in the quarter tested, and management considers the new method to be preferable to that previously used. Per CFR 45, Part 95, Subpart E, Section 95.515, the Department can implement changes to its cost allocation beginning with the effective date of its request for approval to do so; it is not required to receive the approval first. Management did submit a request for approval of this change with Cost Allocation Services, but the request was effective as of the beginning of the following quarter, thus did not include the quarter in question. The department will recompute the cost allocation for the quarter in which the exception occurred using the previous allocation method and will record an adjustment to correct the amounts allocated. The clerical error referenced would not have occurred had the various base calculation worksheets been integrated with one another as appropriate and with the allocation calculation worksheets. We will link these worksheets beginning with those used in the allocation for the quarter ending March 31, 2023. Name(s) of the contact person(s) responsible for corrective action: David O?Kelly, Controller Planned completion date for corrective action plan: June 30, 2023

The South Carolina Department of Commerce respectfully submits the following corrective action plan for the year ended June 30, 2022. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-008 Community Development Block Grant (CDBG) ? Assistance Listing No. 14.228 Recommendation: We recommend that Department personnel consistently follow policies in place to ensure reports are properly reviewed by supervisory personnel prior to submission. Explanation of disagreement with audit finding: The South Carolina Department of Commerce agrees with the audit finding. Action taken in response to finding: All reports and documents to be submitted on behalf of the State?s Community Development Block Grant Program to the U.S. Department of Housing, Urban and Development (HUD), U.S. Department of Labor and FSRS.gov will follow a formal review process to include using track changes for documents and a final review by a CDBG staff member in a supervisory position. The designee for the final review will be the Deputy Director of Community Development or the CDBG Program Administrator. An acknowledgement of the final review will be documented to ensure the appropriate review has taken place. Name(s) of the contact person(s) responsible for corrective action: Caroline Griffin ? Deputy Director for Community Development Keely McMahan ? CDBG Program Administrator Planned completion date for corrective action plan: As of March 1, 2023, CDBG program management has adopted this corrective action plan to ensure a comprehensive review of reports by supervisory personnel prior to submission to the appropriate Federal agency.

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT United States Department of Defense 2022-007 National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing No. 12.401 Recommendation: We recommend the Office consistently adhere to its internal controls including maintaining the approved State Personnel Action form to support the personnel charges and allocations to applicable funding sources. Explanation of disagreement with audit finding: The Office concurs with the audit finding. Action taken in response to finding: A. The missing forms in the personnel files identified in the audit were corrected. Completed as of March 03, 2023. B. The Office is conducting a complete audit of all personnel files to ensure internal control were implemented and files are accurately and adequately documented. The estimated date of completion is March 31, 2023. C. The Office will ensure that established policies and procedures are followed, and all documentation is completed prior to entering actions into SCEIS. Name of the contact person responsible for correction action: Mr. Robert Faulk, State Human Resources Director Planned completion date for corrective action plan: March 31, 2023

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended 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?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2022 ? 012 Adoption Assistance, Child and Adult Care Food Program ? Assistance Listing: 93.659, 10.558 Recommendation: We recommend that the Department follow their policies and procedures to ensure that proper documentation is maintained to support the review and approval of a drawdown of funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Department?s Grants Accounting and Reporting staff are following the established policies and procedures to ensure proper documentation is maintained to support the review and approval of draws prior to their execution. In every case the exceptions noted were draws that were done following group discussions that included the Department?s regional federal grant program representatives. Discussions were had to confirm the appropriate support and amounts of draws, and the conclusions of those discussions were that the Department should draw the amounts ultimately drawn. The Grants Accounting and Reporting Manager did approve the draws in advance but did not provide specific written approval. In one case the Grants Accounting Reporting Manager emailed the Department?s federal contact confirming the amount of funds we would draw, and the staff interpreted the email as authorization to proceed. Grants Accounting and Reporting staff have been instructed not to draw funds without express written approval, and they are complying with that requirement. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: Effective immediately

Compliance Procedures: Operations will receive weekly Davis Bason timesheets for all contracted employees performing construction activities on federally funded projects. The timesheets must be signed by the Contractor and submitted to Millington Municipal School District. Internal Control Procedures: Finance will insure prior to making payment to the Contractor for the Applications and Certificate for Payment that all weekly Davis Bacon timesheets have been submitted to Millington Municipal Schools District for federally funded projects where construction services were done. Contact Person: Taurus Currie, CFO Proposed Completion Date: This action was completed by January 31, 2023.

Finding #2022-001 Comments on Finding and Recommendation: The Corporation did not increase the monthly reserve for replacement deposits as required by HUD during the year ended December 31, 2022. The management agent should transfer funds of $2,216 from the operating account to bring the reserve for replacements account current and communicate with the lender to ensure deposit increases are being made. Action(s) taken or planned on the finding: Management agrees with the recommendation.

2022-005 - Enrollment Reporting Federal Pell Grant Program; Federal Direct Student Loans - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment and program information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Felician University has evaluated and updated our procedures in overseeing submission to NSLDS and notified the appropriate staff. Management will monitor this issue regularly during the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Cynthia Montalvo, Assistant Vice President of Enrollment Planned completion date for corrective action plan: March 1, 2023

From: Daniel Ayala, District Director Center of Student Information Subject: Corrective Action Plan for Audit Finding 2022-001 Finding 2022-001: Enrollment Reporting Submissions for Graduates Views of Responsible Officials and Planned Corrective Actions Due to a changes in record processing and the addition of a new audit report at the National Student Clearinghouse (NSC), additional steps were needed at the institutional level to guarantee the accurate reporting of student graduation status. To ensure correct and comprehensive reporting of students as ?graduated?, the Alamo Colleges District Center for Student Information (CSI) has implemented a three step process: 1) submitting a sixth submission audit per semester (recommended by NSC) which will provide graduated student information to NSC; 2) review of the DegreeVerify exceptions report each semester to identify any needed corrections and/or updates to report to NSC; and 3) completion and review of these processes will be done by a CSI Enrollment Service Professional and CSI Director and documented (signed off) on the monthly compliance certificate form. With these processes in place, CSI will be in line with NSC recommendations and allow the National Student Loan Data System (NSLDS) to align with correct graduation dates. At this time, all needed corrections to student ?graduated? status have been completed. Implementation Date: November 2022 Responsible Persons: Dr. Adelina S. Silva, Vice Chancellor of Student Success;

The Academy will prepare monthly reconciliations between its property subsidiary and trial balance. Such reconciliation will be reviewed by the supervisor accountant to assure that it is properly reconciled Additionally, repair and maintenance accounts will be examined in order to assure that no capitalizable transactions are misclassified on expense accounts. With these processes, the Academy will ensure that property and equipment is properly recorded in books.