Corrective Action Plans

Condition: For 2 students tested, the incorrect enrollment status was reported to the National Student Loan Data System (NSLDS). For 2 students tested, the change of enrollment status was not reported within the 60 day requirement. Corrective Action: Fielding concurs with this finding and has taken steps to resolve the deficiency. To resolve the issue of graduated students potentially being reported incorrectly to NSLDS, the University will provide additional training to the staff member who made the processing error (in one instance) and adjust their procedures to contact National Student Clearinghouse (NSC) to manually update records when a degree is retroactively processed to a prior term at a non-standard conferral date (the 2nd instance). In addition, to resolve the issues surrounding potential late reporting of students beyond the 60-day requirements, the University will correct the timeliness of their reporting schedule so that all files are submitted to the NSC by the 10th of the month if not sooner. The University feels that these steps will ensure that reporting requirements are met, as outlined in 34 CFR 685.309(b) of the code of federal regulations. Person Responsible For Corrective Action: Bridget Brady, Registrar Anticipated Completion Date: January 11, 2023

The Organization has a policy outlining procurement and suspension and debarment procedures. The Organization also has standard forms in place guiding purchasing decisions. However, those forms lack elements that prompt staff to perform document procurement and suspension debarment procedures. The Organization did not maintain adequate documentation that procurement practices were performed in accordance with the Uniform Grant Guidance requirements. The Organization also did not perform or document suspension and debarment checks on prospective vendor sub-recipients. The corrective action plan by the Organization is as follows: 1. This process was implemented and followed but supporting documentation was not stored properly so compliance couldn?t be verified. Paper documentation has been moved to a secure storage file in Finance. Subsequently, the verification for suspension and debarment has been moved to an electronic verification process through Verifycomply.com and the supporting documentation is being stored electronically and on the company?s portal. Completed 02/21/2023 Responsible Individual: Samantha Franklin, CFO SamanthaF@foodlifeline.org - 206.432.3601

Finding 2022-002 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster FAL #: 84.063, 84.007, 84.268, 84.033 Finding Summary: 34 CFR Section 668.22 states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date. During our testing of compliance with Return of Title IV Funds (R2T4), there was 1 instance out of 38 where the District calculated the incorrect amount to be returned to the Department of Education (ED). Responsible Individuals: Heidi Balster, Director of Student Financial Aid Corrective Action Plan: During each payment period of an award year, the Financial Aid Office will review 20% of all R2T4 calculations (unduplicated) to ensure accuracy of the calculation and students? earned aid. The Financial Aid Office will use the random (RAND) formula in Excel to randomly select the R2T4 student population for testing. Within one week after all midterm grades are posted for the payment period, the Financial Aid Office will randomly select 10% of R2T4 calculations processed and review each calculation to ensure the correct period of enrollment was used in the calculation. After the end of each payment period, within a week after all unofficial withdrawals are processed, the Financial Aid Office will randomly select an additional 10% of R2T4 calculations (unduplicated) and review each calculation to ensure the correct period of enrollment was used in the calculation. If it is determined that a student?s R2T4 calculation is incorrect, the Financial Aid Office will complete the following steps prior to processing a corrected R2T4 calculation: 1. Obtain screenshots of incorrect R2T4 calculation and print copies into the Perceptive Content imaging system 2. Purge the incorrect R2T4 calculation and leave comments in student?s record for reason of purged calculation 3. Update all Title IV aid awards back to original amounts disbursed prior to R2T4 calculation 4. Run the Colleague?s Batch FA Transmittal Register (FATR) process and review aid adjustments 5. Notify the Business Office to have them run the Batch FA Transmittal Update (FATP) process 6. Once FATP is processed, re-run R2T4 calculation with the corrected enrollment Anticipated Completion Date: January 2023

Finding: No. 2022-003 Higher Education Emergency Relief Funds Earmarking. Finding: The American Rescue Plan (ARP) created a new requirement that a portion of the HEERF III Institutional Funds must be used to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act. The College utilized direct emails to students, however, no evidence of direct outreach occurred as required by the program. Corrective Action Taken or Planned: The Federal funding for this program has ended. If the DOE should add additional funding or create new or similar programs, management will have implemented a control to regularly monitor and manage changes to rules and regulations promulgated by the DOE. Both the Financial Aid Director, Erin Hanlon and the VP of Administration and Finance, William McDonald will regularly monitor and manage changes to rules and regulations promulgated by the DOE effective immediately 3/29/2023.

Finding: No. 2022-004 Enrollment Reporting Finding: Institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS website, certifying through the NSLDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. Corrective Action Taken or Planned: The College, more importantly the Financial Aid Director, Erin Hanlon will review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner, effective immediately. Additionally, a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. Enrollment reporting corrections have been corrected as of 03/29/2023.

Management's Response: Hopeworks will implement a quarterly tracking system to ensure the grants achieve the 25% matching requirement. On a quarterly basis the Jessica Delgado the Quality and Compliance Officer will send the Finance Department a listing of applicable expenses incurred to date. The Finance Department will review these costs to the Medicaid billings to ensure the 25% match is being met. In the event of a shortfall Finance will coordinate with Quality and Compliance to adjust spending and/or Medicaid billings to bring the matching contribution into alignment with the grant's requirements.

Finding no.: 2022-001 Contact person(s) responsible: Sally Alworth, Controller Corrective action planned: In December 2022, MPD hired an experienced Payroll Specialist, and in April 2023, the agency brought on a new Controller. As of April 15, 2023, all staff report hours through ADP Workforce Now timecards for each pay period. Codes for active grants, as well as MPD?s unrestricted general fund, are programmed into a custom field in ADP. Staff who work across multiple projects select a grant code for each timecard entry. Timecards are approved by the employee and then reviewed and approved by a supervisor prior to payroll processing. Based on timecard entries, the ADP software produces a general journal entry allocating wage and payroll tax cost to each grant and to the agency?s unrestricted general fund, and this entry is added to MPD?s accounting system after each pay cycle. Anticipated completion date: May 15, 2023

See Corrective Action Plan for chart/table"

Finding 2022-004: Matching Every Program Director is trained on how The Light House invoices grants to enhance knowledge and decrease mistakes. The Light House finance department has taken over the billing process for all grants for The Light House and Light House Bistro. The streamlined approach provides strict oversight and quality control over what and who is billed to every grant. The Light House finance office is carefully watching the SNAP E&T federal Grant to make sure that the required 50% match is being covered by non-federal funds and not charged back to any federal funds no matter the funding source. Responsible Party: Terry W. Brukiewa, Completion date: 8/1/2022

Finding 2022-003: Time and Effort Reports The Light House finance office is working with Paylocity account representatives to identify how to track the Time and Effort results in our payroll system. Until that is accomplished, The Light House Finance team is tracking the time and effort through a Microsoft Access database and creating Time and Effort reports on a Quarterly basis. All Time and Effort reports will be signed by the employee, the Director of Finance and the Executive Director. Responsible Party: Terry W. Brukiewa, Expected completion date: 6/30/2023

Finding 2022-002: Inaccurate schedule of expenditures of federal awards The original schedule did not include the expenditures for the Light House Bistro. The Light House finance department bills all grants on a monthly basis and keeps an ongoing log of the grant expenditures for both the Light House Bistro and the Light House. Any adjustment made for unallowable expenditures are corrected and invoices modified to reflect the correct amount expended on all grants. The Light House finance office notifies the Light House Bistro of any changes that impact their financials in a timely manner. Responsible Party: Terry W. Brukiewa, Expected completion date: 06/30/2023

Reference Number: 2022-001 Name of Contact Person: Trisha Isom, Housing Manager Corrective Action: The City agrees with the finding and will review and monitor each loan to maintain the most up-to-date information and comply with all requirements of the loan program. Proposed Completion Date: June 30, 2023

Fiscal Agent and financial assistant recently met with a contact with the ODJFS fiscal team to help create a spreadsheet to monitor youth spending. Moving forward, the Fiscal Agent will be tracking quarterly and reaching out to subareas on progress.

2022-002 Student Financial Aid Cluster - CFDA No. 84.268 Recommendation: We recommend the Seminary review its procedures around reporting to COD to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Seminary will send multiple Title IV Form notices throughout the academic year. Regular reviews will be conducted regarding enrolled students and completed Title IV forms and outreach will occur for any students receiving financial aid that do not have a completed Title IV Form on file. Any students without a Title IV Form will receive a refund within the 14 day period until the Title IV Form has been secured. Name(s) of the contact person(s) responsible for corrective action: Maryjo Lewis, Registrar Planned completion date for corrective action plan: June 30, 2023

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