Corrective Action Plans

2022-001 Student Financial Aid Cluster - CFDA No. 84.268 Recommendation: We recommend the Seminary reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the Seminary's last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Seminary will implement a review of the listing of all potential unofficial withdrawals to ensure effective dates of withdrawal are determined correctly and will also revisit its policies and procedures around NSLDS reporting to ensure all student enrollment statuses are reported correctly and timely to NSLDS as required. Name(s) of the contact person(s) responsible for corrective action: Maryjo Lewis, Registrar Planned completion date for corrective action plan: June 30, 2023

Responsible Party: Felicia Milton, CFO Anticipated Completion Date: March 30, 2023 ELC Management will make sure that measures are in place to monitor and ensure that the Coalition will remain in compliance with grantor administrative expense requirements.

FINDING 2022-001 Contact Person Responsible for Corrective Action: Steven Miskin, Director of Operations Contact Phone Number: 574.254.4510 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Operations and the Assistant Director of Operations will be made aware that construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. They will then inform the vendor of the requirements of what needs to accompany the invoice. The Accounts Payable Specialist will not issue a check unless all documentation is included with invoice. Anticipated Completion Date: March 2023

Corrective Action Plan December 20, 2022 Cognizant or Oversight Agency for Audit: Douglas County School District No.77 respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: KDP Certified Public Accountants, LLP 841 O?Hare Parkway, Ste. 200 Medford, OR 97504 Audit period: July 1, 2021 to June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are listed below, including the adopted plan of action and timeframe for each: Federal Award Finding U.S. Department of Education Education Stabilization Fund - Assistance Listing No. 84.425 Significant Deficiency 2022-001 Special Tests and Provisions Statement of Condition: The District was not in compliance with the Uniform Guidance as it was noted that management of the District was not collecting certified payroll reports for construction projects charged to the Education Stabilization Fund. Recommendation: We recommend the District review their internal controls to strengthen the processes and improve procedures. We recommend the District notify all contractors and subcontractors of required submission of certified payroll reports prior to the start of any contracted work spent with federal assistance funds exceeding $2,000. Plan of Action: Douglas County School District No. 77 will upon executing any contracts for construction projects charged to the Education Stabilization Fundwill require submission of certified payroll reports. Each contract will state within the contract that contractor and/or subcontractor will provide these reports with each invoice billing. Date of implementation: Effective immediately, any contracts executed after the date of this letter will include the additional language. If the U.S. Department of Education has any questions regarding this plan, please call Racheal Aiken at 541-440-4796. Sincerely yours, Racheal Aiken Assistant Business Director Douglas ESD

Statement of condition #2022-002: Comments on Finding and Recommendation: During the year ended March 31, 2022, one of the applicants selected for testing was admitted to the Property, but did not appear on the waiting list. The Agent should ensure that all applicants are properly documented on the waiting list and applicants are contacted and selected in chronological order. Action(s) Taken or Planned on the Finding: The Agent will review and update its procedures to ensure that all applicants are included on the waiting list and applicants are selected in chronological order.

Statement of condition #2022-001: Comments on Finding and Recommendation: During the year ended March 31, 2022, 4 of the 24 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. Action(s) Taken or Planned on the Finding: 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.

2022-006 Water and Waste Disposal Systems for Rural Communities ? Assistance Listing No. 10.760 Recommendation: We recommend the City adopt a procurement policy that meets the requirements of the Uniform Guidance and implement controls to ensure it is being followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will adopt a procurement policy that meets the requirements of the Uniform Guidance and implement controls to ensure it is being followed. Name(s) of the contact person(s) responsible for corrective action: City council. Planned completion date for corrective action plan: December 31, 2023.

The District will ensure that all employees not on a formal allocation plan or entirely allocated to a single source complete daily activity reports.

Finding number: 2022-001 Federal agency: U.S. Department of Education (?ED?) Programs: Federal Pell Program and Federal Direct Student Loans Assistance Listing #?s: 84.063, 84.268 Award year: 2022 Corrective Action Plan The College agrees with the finding. The reason for the finding was due to a change in the National Student Clearinghouse reporting policy and process. Students who completed all course requirements but did not apply for graduation were reported as withdrawn to the clearinghouse but were not reported as graduated the following semester when they officially applied to graduate. Moving forward all graduates at the end of a term, including those who were reported as withdrawn will be included in the graduate only file sent separately from the end of term file. Timeline for Implementation of Corrective Action Plan Implemented Fall 2022 Contact Person Jennifer Vincent, Registrar, Bristol Community College

March 2, 2023 Shenandoah Area Agency on Aging respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, Virginia 22801 Audit period: September 30, 2022 The findings from the September 30, 2022 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS - FINANCIAL STATEMENT AUDIT 2022-004: Authorized Signer for Bank Accounts Condition: Four bank confirmations signed by the executive director were sent to financial institutions holding SAAA assets as part of our audit were denied due to being signed by an unauthorized individual. Criteria: As part of management's responsibility to safeguard assets, the authorized signer for bank accounts should be documented. Cause: Management was unaware the listing of authorized check signers had not been updated by the bank as requested. Effect: It is critical for an entity to be able to access its cash deposits held by financial institutions. When a listing of authorized signers is not updated, the entity opens itself to opportunities for loss. Terminated employees may still have access to organizational assets or the organization may be prohibited from accessing their accounts at financial institutions if there is no perceived authority to access the funds. FINDINGS-FINANCIAL STATEMENT AUDIT (Continued) 2022-004: Authorized Signer for Bank Accounts (Continued) Recommendation: Management or governance should determine who has access to bank accounts and ensure only the appropriate parties maintain ongoing access for the safekeeping of the organization's assets. Planned Corrective Action: This finding was caused by the bank not updating its signature cards as requested by the Agency. This finding was immediately corrected once identified by the auditors. 2022-005: Material Audit Adjustments Condition: During the audit, we detected one material misstatement in the trial balance presented to us to begin our audit that was considered a material audit correction. Criteria: Generally accepted auditing standards dictates that detection of errors in an audit is a strong indicator of a significant deficiency or material weakness. Accordingly, we are required to communicate this finding as such. Cause: Financial information was missing or inaccurate. Effect: Assets and liabilities were overstated. Recommendation: We recommend that management implement a process to ensure accuracy of balance sheet and statement of activity accounts. Planned Corrective Action: Management agrees with the finding. During the last quarter of the fiscal year, the finance department experienced a vacancy. As a result, we were short-handed. There was one account that was not reconciled in a timely manner. After the year end, the position has since been filled. All significant balance sheets will be reconciled in a timely manner as in previous years. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT 2022-001: Cost Sharing Fees, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition services and Special Programs for the Aging-Title III, Part C2 - Nutrition services, Program income Condition: Individuals receiving Title III-C funded services for home delivered meals were charged cost sharing fees. Criteria: Agencies providing services funded under the Title III-C programs may not charge cost sharing fees for the Title 111-C services under Title III-C per 42 U.S. Code? 3030 c-2(a)(2). Cause: No controls or processes were in place to prevent cost sharing fees being charged to individuals receiving services provided under Title III-C programs. Effect: The cost sharing fees for Title III-C services are not allowed under federal guidelines and therefore these fees are considered a questioned cost. Questioned Cost Amount: $4,400 Perspective Information: Noted two fees were charged for Title 111-C services out of a sample of twenty-five cost sharing fees. Recommendation: Cost sharing fees are not allowed to be charged for Title III-C services provided to individuals. Only voluntary contributions may be made for these services. Management should implement procedures to ensure these fees do not continue to be charged. Planned Corrective Action: Management agrees with the finding. As noted in finding 2022-005, the vacant position, which has now been filled, was responsible for compliance review. Additional procedural reviews and corrected report formatting have been implemented to prohibit cost-sharing fees from being charged to the program. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-002: Unallowable Costs, ALN 93.053 Nutrition Services Incentive Program, Allowable Costs Condition: Administrative expenditures were improperly classified as expenditures funded by the Nutrition Services Incentive Program (NSIP). Criteria: NSIP funds may only be used to purchase domestic foods as outlined under Title 7 U.S. Code of Federal Regulations Part 250.68, Nutrition Services Incentive Program. Grant funding received through NSIP may not be used to pay for administration or other services. Cause: Unallowable costs were improperly classified to the financial records supporting NSIP expenditures and allowable costs were improperly allocated to other projects. Effect: Financial records supporting costs expensed under the NSIP award do not reflect the nature of the expenditures requested for reimbursement. Expenditures were misclassified within the financial records to improper programs and thus are considered a questioned cost. Questioned Cost Amount: $98,327 Perspective Information: Noted in one out of a sample of twenty-five expenditures charged to the Aging Cluster. Two of the items in the sample were expenditures charged to NSIP. We reviewed the list of the remaining expenditures charged to NSIP and confirmed the sample was representative of the entire population. Recommendation: It is critical for the underlying financial records to support an organization's claims for costs reimbursements under federal award programs with adequate documentation. Staff must allocate costs appropriately for allowable costs under each federal program and ensure expenditures charged to the federal programs are for appropriate purposes and are properly classified in the records to avoid noncompliance with federal regulations and program requirements. Planned Corrective Action: Management partially agrees with the finding. We agree that certain amounts were misapplied to the NSIP account. However, the funds did purchase food as required by the grant. We believe this to be a reporting error and not a misuse of grant funds. With the vacant position recently filled, we have added additional review procedures to prevent any reoccurrence of misapplication. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-003: Annual Reporting to VDARS, ALN 93.044 Special Programs for the Aging- Title III, Part B- Grants for Supporting Services and Senior Centers, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition Services, ALN 93.053 Nutrition Services Incentive Program, Reporting Condition: The 13th Aging Monthly Report required by the pass through agency, Virginia Department of Aging and Rehabilitative Services (VDARS) was not submitted timely and contained inaccurate revenue and expenditure data. Criteria: VDARS requires the annual I3th Month Aging Monthly Report to be submitted by November 15t?h The report must contain complete and accurate information as a restating of the monthly reporting for the fiscal year. Cause: The 131 Aging Monthly Report was not reconciled to underlying financial records, resulting in unexplained differences between the report and trial balance provided as part of the audit. Additionally, the report was not submitted by November 15, 2022. Effect: The submission of the 13th AMR was not performed timely and included data that did not agree to underlying financial records. This should have been caught during the course of a review process before submission. Therefore, it is considered a significant deficiency of internal controls over compliance. Recommendation: Ensure reporting is submitted timely by the deadline stated by VDARS. Implement a review process for each monthly submission, including documentation of the review. Reconcile the federal, state and local totals reported in the Aging Monthly Report to the underlying financial records as stated in the financial system to ensure accuracy before submission to VDARS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The AMR report was not filed in a timely manner. As noted in finding 2022-0005, the vacated position during the last quarter of the year was responsible for submittals. We note that the report has since been filed. With the position being filled, we believe the 13th AMR will be filed in a timely and accurate manner as in previous years. If the Federal Audit Clearinghouse has questions regarding this plan, please call Cindy Donaldson, Director of Finance at 540-635-7141. Sincerely yours,

Finding: 2022-002? Written Policies Required by the Uniform Grant Guidance Auditor Description of Condition and Effect: The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to financial management (?200.302) and procurement (?200.318). Although the Township ha procedure sin place to cover these areas, the formal written policies have not been documented in accordance with the Uniform Guidance. This condition appears to be the result of a time lag in identifying the requirements and developing a plan for compliance. As a result, the Township did not fully comply with the Uniform Guidance applicable to the USDA bond funds. Auditor Recommendation: We recommend that the Township ensures that these polices are updated to conform with the Uniform Guidance as soon as practical, but no later than the end of fiscal year 2023. Corrective Action: The Township will review the current policy and get it updated to meet the criteria set out in the Uniform Guidance. Responsible Person: Amanda Henderson, Deputy Treasurer Anticipated Completion Date: March 31, 2023

2022-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: The University did not properly return loan funds subsequent to the R2T4 calculation for no passing grades withdrawal students for 1 out of the 12 students tested (8.3%) due to failing to return the required PLUS loans based on the calculation. Further, the amount of direct student loan funds returned was later disbursed to the student again due to lack of documentation in the University?s system of the unofficial withdrawal. We consider this to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Management Response: The error identified above was made on a student?s record who did not officially withdraw from the University. As required by federal regulation, an ?all F?s? report is pulled at the end of each term and a determination is made for all students included on the report whether or not they attended classes until the end of the term. The student identified by the auditors was determined to have not attended the full Fall term. A return of title IV calculation was promptly processed by the Associate Director on the Department of Education?s website. The R2T4 calculation could not be processed via the SIS since the student did not have an official withdrawal date entered. The student loans were returned timely, however, the parent PLUS loan was missed in returning the funds. Subsequently the student contacted our office to challenge the withdrawal date and claimed he had attended classes all term and earned all of the loan funds that were disbursed for the term. There was no documentation in our SIS so the loans were reinstated in error. Corrective Action Plan: R2T4 procedures were updated to include a secondary confirmation of the return of loan funds according to the calculation. This secondary review will be scheduled at the time the R2T4 calculation is processed. Further, the procedure was updated to include entry of notes on the student?s electronic record to avoid reversal if challenged by the student. Responsible Person: Chilwana Thompson, Associate Director Implementation Date: August 1, 2022

2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: In three of the 40 student files tested (7.5%), Subsidized and Unsubsidized Direct loans were not properly awarded. The University under awarded one student $1,000 in Subsidized loans and over awarded the student by $1,000 in Subsidized loans. A second student was under awarded $2,560 in Subsidized loans and over awarded $2,560 in Unsubsidized loans. The third student was under awarded $862 in Unsubsidized loans. Management Response: All of the errors identified by the auditors were a direct result of manual miscalculation of loan eligibility. In two of the instances cited, the students had previous additional unsubsidized loans issued as a result of parent PLUS loan denials. When we received ISIR data these students were flagged with a reject due to aggregate loan limits. In order to calculate each student?s loan eligibility, a manual review of loan information via the U.S. Department of Education?s Common Origination and Disbursement (COD) portal is necessary. The additional unsubsidized loans disbursed as a result of PLUS denial, were manually removed from each student?s loan total to determine current year eligibility. In both instances, the total loan eligibility was correct, however the manual calculation of the subsidized versus unsubsidized split of the loan funds were miscalculated. In the last instance a student was under awarded $862 in unsubsidized loans, the miscalculation occurred due to receipt of an outside scholarship. In the Fall term the scholarship check was received with documentation indicating the disbursement was to be applied to the Fall term in it?s entirety and the Spring disbursement would follow. The outside scholarship caused the student to be over awarded and the student loans were adjusted to remain within cost of attendance limits. Subsequently the Spring term disbursement of the scholarship was received for $862 less than the Fall disbursement. At that time, the student should have been offered the additional $862 in unsubsidized loan funds to bring their total aid back up to cost of attendance. The staff person entering the scholarship payment on the student?s account failed to notify the loan coordinator an adjustment was warranted. Corrective Action Plan: The loan coordinator who made the errors has been in the position for just over a year. In order to prevent future issues in calculating a student?s loan limits and eligibility, the employee attended a loan regulation and processing overview course produced by the National Association of Financial Aid Administrators (NASFAA). Further, a form was developed to help calculate aggregate limits when an ISIR reject occurs in order to avoid missed steps in the calculation process. 2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 (Continued) As a result of the outside scholarship error, our procedures for entering an scholarship payment have been adjusted to include a final review of all outside scholarship disbursements entered by the loan coordinator. Responsible Person: Lynette Lambert, Assistant Director/Loan Coordinator Implementation Date: August 1, 2022

Management?s Response/Planned Corrective Action: This item was an audit finding on the 2020/21 audit report. Upon identification of the issue as of March 2022, we created additional controls as outlined in the corrective action plan submitted with the audit at that time. We believe this finding is primarily related to the months prior to us being made aware of the issue. We have made the necessary corrections and have been maintaining proper backup for the reports since the initial finding. Heather Kimmel, Assistant Executive Director is responsible for the corrective action plan.

Department of the Treasury ? CDFI Fund Grant Vantage West Credit Union respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Doeren Mayhew 305 West Big Beaver Rd., Ste. 200 Troy, MI 48084 Audit period: January 1, 2022 ? December 31, 2022 The finding from the December 31, 2022 schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF TREASURY CDFI Program ? CFDA No. 21.024 Significant Deficiency: See Finding 2022-001. Recommendation: Complete established procedures to identify and track eligible loans deployed during the RRP grant performance period and reconcile the totals to the underlying loan data. Action Taken: Vantage west will enhance its reporting to our third party CDFI reporting consultant to clarify and fully define borrower data points, in support of improving the accuracy of financial products reported annually on the Performance Reports to the CDFI Fund.

Bishop Museum Corrective Action Plan Fiscal Year Ended June 30, 2022 The following finding was cited in the single audit for the Bishop Museum for the period ending June 30, 2022: Finding 2022-001: Criteria - 2 CFR 200.302{b)(l) of the Uniform Guidance states that a nonfederal entity must identify in its accounts all federal awards received and expended, as well as the federal programs under which they are received, and those amounts must be accurately and completely reported on the SEFA. Condition - During the audit, for the year ended June 30, 2022, expenditures of federal awards for certain programs was not included in the SEFA provided by the Museum. The SEFA was subsequently corrected and one of the federal programs was identified to be a major federal award program. Cause - The funds received and the federal expenditures for the programs were not recorded in the Museum's general ledger in the same manner as the other federal programs, and therefore, the funds expended were not identified and reported on the SEFA. Effect or Potential Effect -A federal program that should have been identified as a major program would not have been included on the SEFA and not subjected to the required audit procedures. Recommendation - All expenditures of federal awards should be recorded in the general ledger in a consistent manner such that the expenditures can be readily identified in preparing the SEFA. Action Plan: Bishop Museum will revise its Budget Center Account form to incorporate and identify all federal funded activities, This revision will eliminate human error of omission. This Budget Center Account form is used to create new distribution codes within the MIP accounting system. Currently this form does not have a line item to specifically address certain critical information that is included in the Schedule of Expenditures of Federal Awards {SEFA). The revision will entail the following additional information to be added in the form and in MIP accounting software. ? Assistance Listing Number {ALN) or Catalog of Federal Domestic Assistance {CFDA) ? Federal Award Identification Number (FAIN) ? Dates of Project ? List of Fiscal Years impacted by the Dates of Project ? Total award amount Following the revisions, current personnel involved in creating the new distribution codes should ensure that the additional information mentioned above is included. These five new, critical line items will aid in the development of the SEFA list each fiscal year, and eliminate human error of omission. Responsible Party: Tracie Mackenzie, Research and Collections Grants and Office Manager tracie@bishopmuseum.org (808) 262-3325 Bernajet Salvanera, Director of Accounting Bernajet.salvanera@bishopmuseum.org (808) 847-8274 Implementation: The use of the revised form and adding the additional information in MIP will be implemented starting July 1, 2023 and it will be an ongoing procedure.

Finding Reference 2022-006 Contact Person: Stephani Berry Views of Responsible Officials and Planned Corrective Action: 21-22 semester dates were input incorrectly by a previous DFA and have now been corrected for the 22-23 school year to reflect DOE (per FSA handbook) requirements. Anticipated Completion Date: December 8, 2022

Finding Reference 2022-005 Contact Person: Stephani Berry Views of Responsible Officials and Planned Corrective Action: This was neglected and documents missing due to staffing issues and high turnover. Verification is completed for enrolled students as soon as their ISIR is available to Donnelly through Empower. Verification worksheets are completed by the student and verified by the FA staff as required by DOE (per FSA handbook). All student documents are kept in student's file in the FA office locked cabinet. Anticipated Completion Date: March 21, 2022

Finding Reference 2022-004 Contact Person: Stephani Berry Views of Responsible Officials and Planned Corrective Action: Registrar Office automatically reports changes in student enrollment information to National Student Clearinghouse, which then goes into NSLDS on a monthly basis. The four students that failed this test for Audit Finding 2022-004 were due to student completion issues and Donnelly College overriding the add/drop policy to retroactively drop students. Registrar clearly provides the information and application process requirements to students who are graduating and will not process their graduation until requirements are met. Once Registrar is made aware of a retroactive drop that overrides the add/drop policy, it is reported on the next month?s automatic report sent through National Student Clearinghouse to NSLDS. Anticipated Completion Date: Resumed by National Student Clearinghouse in December 2022

Finding Reference 2022-003 Contact Person: Stephani Berry Views of Responsible Officials and Planned Corrective Action: This was neglected due to staffing issues and high turnover. Disbursement Letters are sent to students as they request Direct Loan funding amounts. The Disbursement Letter includes the three elements as required by DOE (per FSA handbook). Anticipated Completion Date: October 20, 2022

Finding Reference 2022-002 Contact Person: Stephani Berry Views of Responsible Officials and Planned Corrective Action: This was neglected due to staffing issues and high turnover. Pell and Direct Loan origination records and disbursement records are submitted to the Common Origination Disbursement (COD) either same business day, or next business day. Formal reconciliation process is now completed every 1-2 months in order to verify disbursement dates, amounts, and cost of attendance in COD. Anticipated Completion Date: March 21, 2022

2022-002 - The corrective action plan was documented in our response to the auditor's comment. See the Schedule of Findings and Questioned Costs. Mark Vasina Director of Finance 402-878-3341 June 30, 2023

Based on the review and assessment of findings, the Financial Aid Office at West Hills College Coalinga will continue to establish policies and procedures including instructions on completing R2T4 calculations, timelines, and trainings to ensure that the determination date for students that unofficially withdraw are completed within 30 days of the end of the payment period.

Responsible Officials Contact Information: Charlotte Outlaw-Yorker Assistant Registrar of Certification and Reporting 718-636-3718 coutlaw@pratt.edu View of Responsible Officials and Corrective Action Plan: Management agrees with the finding and the related recommendations. The Institute will update its NSLDS roster submissions to ensure that student reported program length is in years and not months. The enrollment rosters will be reviewed by a second member of management for accuracy before submission and a periodic check to verify Published Program Length Measurement listed in the NSLDS correctly matches the Institute?s publicly reported program lengths on our website and any that do not match will be updated timely.

The Center was unaware that, in accordance with the Department of Labor (DOL)(40 USC 3141-3144, 3146, and 3147), all laborers employed by contractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for prevailing wage rates. In the future, the Center will follow the guidance of the aforementioned section and adhere to this requirement.