Corrective Action Plans

2024-010 Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Federal Financial Assistance Listing Number: 97.036 Federal Grantor: U.S. Department of Homeland Security Pass Through: California Office of Emergency Services Award No. and Year: 059-00000 and 2019 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the 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 statutes, regulations, and the terms and conditions of the Federal award. Condition: For two (2) out of three (3) project application summary reports tested, the OCPW did not retain evidence to document the individual who reviewed and approved the required reports. Cause: The department’s procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A non-statistical sample of three (3) of nine (9) Grant Project Application Summary Reports were selecting for testing. The condition above was identified during our procedures over reporting testing. Repeat Finding: No. Recommendation: We recommend the OCPW department revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission. Management Response and Corrective Action: 1. Person Responsible: • FEMA Public Assistance Grants Coordinator – Responsible for completing reports, uploading documents to the FEMA Grants Portal, and ensuring accurate records. • OCPW Emergency Manager Responsible for reviewing, approving, and submitting project applications. 2. Corrective Action Plan: • Revised Procedures for Review and Approval: i. The FEMA Public Assistance Grants Coordinator will be responsible for completing the Project Application Summary Reports. ii. Upon completion, the Grants Coordinator will upload all supporting documents into the FEMA Grants Portal. The system automatically timestamps each document and records the name of the individual who uploaded it, ensuring clear documentation of the review process. iii. After all required documents are uploaded, the OCPW Emergency Manager will be notified that the project application is ready for review. iv. The OCPW Emergency Manager will then: 1. Review the submitted documents in the FEMA Grants Portal. 2. Confirm that the reported costs align with the information provided by the reporting County agency. 3. Approve and submit the project application to Cal OES and FEMA for project approval. • Retention of Documentation: i. The FEMA Grants Portal serves as the official system of record, ensuring all uploaded documents are timestamped and traceable. ii. All project application approvals, cost documentation, and required forms will be retained electronically within the system for audit and compliance purposes. • Training and Implementation: i. Staff responsible for grant reporting will receive training on the revised process, including proper document upload procedures and compliance expectations. ii. The updated process will be implemented immediately. • Monitoring and Compliance: i. The OCPW Emergency Manager will conduct semiannual internal reviews of project applications to ensure compliance with the updated procedures. ii. Any issues identified during internal reviews will be addressed through additional staff training and process improvements. 3. Anticipated Implementation date: Immediate, March 18, 2025 • Staff Training: Within 30 days • Semiannual Compliance Review: Beginning next quarter i. First review will take place May 1, 2025. Followed by another review in October 2025.

2024-014 Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Financial Assistance Listing Number: 93.566 Federal Grantor: U.S. Department of Health and Human Services Award No. and Year: Various Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Eligibility Type of Finding: Material Deficiency in Internal Control Over Compliance and Material Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the 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 statutes, regulations, and the terms and conditions of the Federal award. Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.53, General Eligibility Requirement, states that eligibility for refugee cash assistance is limited to those who: (1) Are new arrivals who have resided in the U.S. less than the RCA eligibility period determined by the Office of Refugee Resettlement (ORR) Director in accordance with Section 400.211; (2) Are ineligible for TANF, SSI, OAA, AB, APTDD, and AABD programs; (3) Meet immigration status and identification requirements in Subpart D (Immigration Status and Identification of Refugees); (4) Are not full-time students in institutions of higher education, as defined by the ORR. Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.66, Eligibility and payment levels in a publicly-administered RCA program, states that in administering a publicly-administered refugee cash assistance program, the agency must operate its refugee cash assistance program consistent with the provisions of its TANF program including the determination of initial and on-going eligibility. Condition: During our testing of the SSA’s compliance with eligibility and allowable cost/cost principles, we noted the following: For two (2) out of forty (40) cases selected for testing, the participants’ country of origin did not meet the general eligibility requirements of the program. For two (2) out of forty (40) cases selected for testing, participants received cash assistance outside of the eligibility period. For six (6) out of forty (40) cases selected for testing, the SSA did not retain the required documentation to evidence eligibility under the program. Cause: The SSA did not follow their policies to verify and withhold the information described in the condition and did not consistently ensure that participants were eligible. Effect: Benefits were provided to ineligible participants. Questioned Costs: Questioned costs for cases tested in which we determined to be ineligible to receive cash assistance or cases in which there was insufficient documentation to substantiate the eligibility determination was $7,578. Context/Sampling: A nonstatistical sample of forty (40) out of all active program participants were sampled. For ineligible or unsupported cases we have projected the amount of questioned costs against the remining population for a total of $460,581. The condition above was identified during our procedures over eligibility, activities allowed or unallowed, and allowable costs/cost principles testing. Repeat Finding: No Recommendation: We recommend that the SSA department strengthen its internal controls to ensure that program eligibility criteria are properly supported and retained in case files. Management Response and Corrective Action: 1. Person Responsible: Rosa Palacios, Human Services Manager 2. Corrective Action Plan: SSA will implement the following to enhance internal controls over compliance with eligibility: • Policy and Procedure Review & Update: Review and update existing policies and procedures to ensure clarity of eligibility criteria, including country of origin, eligibility period, and documentation retention requirements. These actions will provide clearer guidelines to prevent future eligibility issues and ensure proper documentation retention. Complete by April 2025. • Ongoing Monitoring & Compliance Review: Establish a dedicated team to perform monthly reviews of all approved cases, ensuring compliance with eligibility requirements. A monthly report will detail trends, non-compliance issues, and corrective actions results. With these actions, we will have continuous oversight and prompt corrective actions to maintain program integrity. Implement reviews by May 2025. • Mandatory Eligibility Checklist: Implement a mandatory eligibility checklist for all staff to confirm the required eligibility documents, system entries, and action notices at initial application and semi-annual reporting. These actions ensure staff consistently follow eligibility requirements and semi-annual reporting processes. Implement by May 2025. 3. Anticipated Implementation date: April 2025 and May 2025

Contact person(s) responsible for corrective action – Lisa Lawson, Sr. Accountant Corrective action planned – KMHS will move forward with billing benefit expenses as actual as of January 2025 contract billing. All employee and employer benefit costs will be billed out per the actual benefits enrolled and received. Anticipated completion date – 1/31/2025

2. Identifying Number: 2024-002: Enrollment Reporting Finding: During the course of our special tests and provisions, we identified 3 students from a sample of 25 where the number of days between the enrollment change and reporting to National Student Loan Data System (NSLDS) was not within the required 60 days. We also identified 3 students from our sample of 25 whose withdrawal date was reported as the day after the withdrawal began and 1 student whose withdrawal date was reported as the end of the semester in which the student was attending. We also identified 2 students from our sample of 25 who were reported as withdrawn instead of graduated. Corrective Action Taken or Planned: Actions Taken The University has already taken corrective action on this finding. The issues raised were addressed in the following ways: number of days between the enrollment change and reporting was not within the required 60 days Graduate File Corrections: We discovered (Fall 2023) an error in the reporting of graduates, despite timely reporting via Degree Verify. Upon this discovery, we met with the National Student Clearinghouse (NSC) to determine the cause of the issue and how to correct it. We learned that students with enrollment in more than one program, or where the program reported did not match the program on record with NSC, were not being properly processed with a G status via the Degree Verify submissions. We were informed that this is common for institutions where students may be enrolled in more than one program at a time. We were advised by NSC to submit a “Graduates only” file, in addition to the Degree Verify file submission. Upon discovering this, we submitted Graduates only files for branches 02, 03, 04, 05, 80, 82, 84, and 97, for all terms for 2020, 2021, 2022, and 2023 beginning in December 2023 and ending in April 2024. We worked through these submissions with NSC, and incorrect withdrawn statuses were corrected to graduated statuses. Antioch’s enrollment reporting process has been updated to include a monthly submission of a graduates only file in addition to degree verify file monthly submission. The University has experienced changes in staffing for personnel involved in enrollment reporting. The person previously in charge of Enrollment Reporting retired on 02/29/24. He was responsible for the enrollment reporting for the majority of this audit period, as well as the prior year. Antioch University hired a new Director of Records Administration with a primary responsibility for NSLDS reporting on 03/28/24. The University has implemented a comprehensive training plan, including improved documentation of procedures, increased clarity regarding the process for the necessity of error resolution, and a review of system processing to help reduce errors in reporting and increase efficiency. The review of current practice and improved procedures was in conjunction with consultants from AACRAO, NSC, Ellucian (the student information system company). Actions Planned The University plans for corrective action on this finding. This includes policy updates for withdrawal processing and implementation of internal audits. Withdraw date was reported as the day after the withdraw began. It has been the practice to process withdrawal requests in this way: When a student withdrawal is submitted, the notification date is considered the last date of active enrollment. The withdraw (W) status begins effective on the following date. This has not been raised as a finding in prior audits. This process will be updated (effective April 1, 2025) to follow 34 CFR 668.22(c). For withdrawal processing effective immediately, this process will be updated to start the withdrawal on the date the student provides official notification, rather than starting on the day following. This means the last date attended and the start of the withdrawal will be the same date. Per the CFR 668.22(c). the student's withdrawal date is—(ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; For withdrawal processing effective at the end of the term, the effective date for the ‘W’ status is the final day of the term in which the student was last enrolled. Per the Withdrawal versus Graduation and Effective Dates section of the NSLDS Manual Nov 2022, p.23 - In the case of the student who completes a term and does not return for the next term, leaving the course of study uncompleted, the effective date for the ‘W’ status is the final day of the term in which the student was last enrolled. The policy and process will be updated and training will occur to begin this processing change effective April 1, 2025. Withdraw date was reported as the end of the semester in which the student was attending It has been the practice to process withdrawal requests in this way: When a student requests withdrawal but has completed courses, the grades are updated prior to processing the withdrawal request. The withdrawal is effective on the start date of the next term. This process will be updated (effective April 1, 2025) to follow 34 CFR 668.22(c) and the NSLDS Manual as outlined in the prior bullet point. For students withdrawing immediately from a term in which they’ve already completed one or more courses, the effective date for the ‘W’ status is the date AU is notified. However, they will only be dropped from courses still in progress. Completed courses cannot be withdrawn. The policy and process will be updated and training will occur to begin this processing change effective April 1, 2025. Reported as withdrawn instead of graduated The Grads Only submission did not return student records for 24SPTRI. We will need to review this with Ellucian to determine the issue. Once this is determined, we will re-run the submission for this term to update records. An internal audit process will be implemented to spot check 3-5 records on each submission for enrollment, grads only, or degree verify reporting. In addition, an audit report will be created to review 9 sample records on a quarterly basis from the current list of active students and the last two years of graduated and withdrawn students. The review will select 3 records from each status. An audit log will document these reviews. Person Responsible for Corrective Action: The Registrar and Executive Director of Financial Aid & Scholarships are responsible for executing the corrective action plan. The Executive Director of Financial Aid and Scholarships and the University Registrar will meet on a recurring basis to jointly review enrollment reporting procedures and National Student Loan Data System (NSLDS) reporting timelines. This collaboration ensures that all enrollment data submitted for Title IV purposes is accurate, timely, and aligned with institutional policies and federal regulations. Any discrepancies or issues identified are addressed collaboratively and corrective steps are documented. Anticipated Completion Date: Fiscal year 2025

1. Identifying Number: 2024-001: Title IV Refund and Return of Funds Compliance Issue: A sample review found instances where Title IV refunds were miscalculated and not returned within the required timeframe. Cause: Administrative oversight led to inaccurate and untimely calculation. Effect: The University did not fully comply with FSA Handbook and federal regulations for returning Title IV aid in a timely manner. Corrective Actions Underway 1. Enhanced Quality Assurance Measures Implementation of a new review protocol for Title IV refund calculations, including a secondary verification process before fund returns. Establishment of a biweekly internal audit of refund calculations to identify and resolve errors before submission. 2.Ongoing Compliance Monitoring and Prevention Efforts Establishment of a quarterly compliance review conducted by the Financial Aid leadership team to proactively address potential issues. Development of a standardized documentation process for all Title IV transactions and NSLDS updates to ensure clear audit trails. Creation of staff retraining initiative to reinforce compliance expectations and best practices. Next Steps: Conduct a full compliance assessment at 30, 60, and 90 days to confirm improvement and adjust protocols as needed. Establish a reporting dashboard for real-time tracking of Title IV refunds and enrollment status updates. Formalize a policy review cycle to ensure that all processes remain aligned with the latest federal regulations. These actions are intended to strengthen the University’s compliance posture, mitigate risks, and enhance the accuracy and timeliness of financial aid administration. Please let me know if additional measures or oversight mechanisms should be considered. Person Responsible for Corrective Action:The Executive Director of Financial Aid & Scholarships is responsible for executing the corrective action plan. Anticipated Completion Date: Fiscal year 2025

Corrective Action Plan: The College agrees with this finding. After disbursing aid for the first time in the Fall 2023 semester and sending Pell origination and disbursement records to COD, the College ran the Pell COD Reject Report (PCRR) in Colleague to identify records that COD had rejected. COD identified 8 students whose Pell disbursement was rejected due to citizenship status issues. These files were reviewed and it was identified that a required field in Colleague was not populated correctly to indicate to COD that the citizenship issue had been reviewed by collecting the required documentation from the student. The files were being reviewed and updates were made in Colleague but not within the 15-day window. Procedure notes have been updated and training has occurred to ensure all relevant personnel understand the process and know where to make the appropriate updates in Colleague when reviewing citizenship documents. Status of Correction Action: Completed

The College agrees with this finding. The Registrar’s Office will proactively report withdrawals from the College between academic semesters manually to the National Student Clearinghouse (NSC) in a timely manner to ensure that NSLDS receives those status changes within the required 60-day window. The Registrar will work with IT to create a report to assist in identifying all withdrawals that are processed between terms. Staff will use this report to crosscheck status changes reported to the NSC. The Registrar’s Office will follow up with the Audit Support division of the NSC regarding previous guidance on effective dating of withdrawals. The NSC’s directive to use the day after the final date of a completed term seems to contradict the effective date that the Clearinghouse automatically assigns when a student is not reported for the subsequent term.

USDA Community Facilities Loan Reserve Accounts Planned Corrective Action: We will work with our area USDA office to evaluate the amounts required to be in the USDA Community Facilities Loan Reserve Accounts. Once we mutually agree on the required amounts, we will bring the amount in the reserve accounts to the required balances. Person Responsible for Corrective Action Plan: Joe Botana - Interim CFO Anticipated Date of Completion: June 30, 2025

Need Analysis Planned Corrective Action: The financial aid software management system (PowerFaids) assigns tasks when eligibility for federal aid changes. Each member of the financial aid office is assigned certain tasks to review each student and then determine if an adjustment needs to occur. This past year was a challenge due to losing an employee with 20 years of experience in the department, and two new financial aid counselors with no experience. Financial Aid counselors will work tasks related to grade level bumps for additional loan eligibility, annual loan eligibility review, sub and unsub eligibility review, and aggregate loan limit review. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: June 2025

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The two students identified had calculations done correctly but the returns were late. These funds have been returned to the Department of Education. The director will coordinate with the registrar to receive a report of zero credits earned at the end of each semester. This review will ensure the Financial Aid Office is returning funds in a timely manner for students that do not officially withdraw. The online administration has a policy in place to alert the financial aid and registrar's office should a student miss more than seven-fourteen days of class. Administration meets on a bi-weekly basis to review official withdrawals and unofficial withdrawals whose date of determination have been noted. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: To be implemented at end of spring semester, 2025 (5/7/2025)

Enrollment Reporting to NSLDS Planned Corrective Action: Finalize automation of file configuration, reporting schedule, and transmission process. Person Responsible for Corrective Action Plan: Sid Parrish, Vice President of Institutional Reporting Anticipated Date of Completion: December 31, 2025 While Newberry College successfully transitioned to the JI platform as planned, the automation of enrollment reporting to the National Student Loan Data System (NSLDS) has not yet been fully implemented on the projected timeline. This delay is primarily due to the unexpectedly complex nature of the data table transition required within the new system. The structure and formatting of enrollment data in JI differed significantly from our previous platform, requiring extensive mapping, validation, and customization to ensure accuracy and alignment with NSLDS reporting requirements. That portion of the work is now complete. In addition, the College experienced a change in personnel within the Registrar's Office. While our new Registrar brings significant experience with other student information systems, she required full training on the JI system before assuming full reporting responsibilities. To ensure resolution, the College's Director of Institutional Research is working closely with the Information Technology team and the new Registrar to finalize the automation process. This includes active collaboration with both the National Student Clearinghouse (NSC) and NSLDS to identify, understand, and clear errors that have surfaced in early iterations of the automated enrollment file. These efforts have helped isolate remaining issues and informed adjustments to the file configuration, reporting schedule, and transmission process. We believe this will lead to a fully functional, automated enrollment reporting process by the end of fiscal year 2025. In the interim, the Registrar is manually submitting enrollment files to the NSC to ensure that student status information is communicated to NSLDS in a timely and accurate manner. This manual submission process remains in place and will continue until the automated solution is fully operational.

2024-002 - LACK OF WRITTEN FISCAL POLICIES AND PROCEDURES As of March 27, 2025, scaleLIT has updated its fiscal policies and procedures to reflect all the federal guidelines required by the Uniform Guidance. The scaleLIT Board Treasurer has reviewed and approved the updates.

We will be hiring an accountant to assist with the workload of submitting reports in a timely manner. This addition to the team will help ensure that all deadlines are met and improve overall efficiency.

We will be implementing a new process to ensure that employees are allocated correctly in the payroll system. This process includes reviewing the payroll labor allocation to verify that all employees are assigned correctly to each project. Additionally, we will be ensuring that the Personnel Action Forms have been reviewed and entered for each payroll, with collaboration from the Human Resources department.

In our new accounting software, Sage Intacct, we have implemented a multi-level approval process to ensure thorough oversight and control of financial transactions. This system allows for the assignment of specific approval hierarchies ensuring that each transaction undergoes the appropriate level of review before being finalized. Furthermore, Sage Intacct provides a detailed and secure audit trail that tracks each step of the review and approval process. This audit trail records the identity of the individuals involved in reviewing, approving, and processing transactions, along with timestamps, comments, and any modifications made. This feature enhances accountability, improves internal controls, and ensures compliance with both internal policies and external regulations, providing a clear and transparent record for future audits and reviews.

The College will evaluate their procedures for maintaining original documentation and ensure there is control over maintaining prior documentation over time. The college underwent an internal review of all Perkins promissory notes and plans to purchase back the loan in the event the promissory notes cannot be found. Rani Arsenault in the Business Office will identify missing promissory notes in FY25.

We recommend that the College implement procedures to ensure triggering events are identified and reported to ED in a timely manner. There was confusion as to what needed to be reported due to the fact that one default notice was issued in December 2023 for the FY23 covenant and the bank delayed the amendment knowing that FY24 would be covered by the amendment the same default notice. Reporting of the amendment took place in February of 2025, and a reporting will be made as soon as possible, if it is deemed necessary for FY25. As of right now the College is expeceted to meet its covenants for FY26. VP of Administration and Finance will reach out within 21 days if that is not the case.

Assistance Listings Numbers: 84.007, 84.033, 84.063 & 84.268 Cluster Title: Student Financial Assistance Cluster Program Titles: Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program and Federal Direct Student Loans Federal Agency: U.S. Department of Education Award Year: 2024 Award Number: None Compliance Requirement: Reporting Question Costs: None Total tuition and fees as reported in the FISAP report was $8,787,259 while the district’s underlying accounting records showed $9,133,531 for a difference of $346,272. Total Federal Pell expenditures were reported as $6,259,684 on the FISAP report while the underlying accounting records and schedule of expenditures of federal awards showed $6,298,477 for a difference of $38,793 Joline Pruitt, Vice President Administrative Services & CFO Anticipated Completion Date: September 30, 2025 The District agrees with the reported finding and recommendation. The FISAP report was submitted by September 30, 2024; however, year-end adjustments were recorded in the general ledger resulting in the FISAP report not including the year-end adjustments. For future reporting, the District will ensure the FISAP report is filed by the September 30th due date; however, should adjustments be made subsequent to the FISAP submission, the Business Department will communicate to the financial aid department any adjustments and an amended FISAP report will be filed.

MUNICIPALITY OF COAMO CORRECTIVE ACTION PLAN SINGLE AUDIT REQUIREMENTS AS OF JUNE 30, 2024 Corrective Action Plan: We concur with the audit finding. The Program budget was determined and approved by the Pass-through Grantor. We are going to discuss the condition reported with the Pass-through Grantor to obtain an explanation about the matter referenced above. Implementation Date: March 31, 2025 Responsible Person: Mr. Hector R. Sanjurjo Rodríguez Federal Programs Director

Management Response We agree with the auditor's comments. The College is actively recruiting to fill critical vacancies. Procedures for documenting approvals and drawdowns in the G5 system are currently being reviewed. Documentation of procedures for drawdowns and monthly cash reconciliation will be implemented in FY 2026.

View of Responsible Official Manhattan College acknowledges finding 2024-001 (Procurement and Suspension and Debarment) presented in the June 30, 2024 single audit report. Although the College provided evidence to the auditors that the vendors noted in the review were not suspended or debarred from federal programs at the time of the transaction and are currently in good standing, and the finding does not give rise to any questioned costs, we agree that controls and policies should be improved. We have implemented a series of corrective actions, identified below, to address the finding and prevent future recurrence. We are committed to ensuring that all necessary steps are taken and procedures implemented to improve our processes and maintain full compliance moving forward. Corrective Action Plan: Immediate Action: A review of all fiscal 2024 and 2025 non-personnel expenses charged to federal grants will be performed to confirm that none of the vendors utilized are suspended or debarred. Process Improvement: The following procedures are in the process of being integrated into the procurement process: • Upon vendor setup, the College Procurement Team will research that the company is not suspended or debarred from participating in procurement with federal agencies and document performance of the procedure. • The College’s purchase orders will include, as part of the terms and conditions with the vendor, a phrase that upon acceptance of a purchase order the vendor is certifying that they are not suspended or debarred and require that the vendor disclose to the College if such status changes. • The College will include in its general contract terms a certification from the contracting party that they are not suspended or debarred upon contract signing and require disclosure if such status changes in the future. • The Procurement Team will verify that vendors utilized for research and development grants are not suspended or debarred before placing orders. The grants administration compliance guidelines will be updated to incorporate guidance for principal investigators and other grant personnel in the selection of vendors and other grant partners to evaluate that such are not suspended or debarred. The Accounting and Reporting Supervisor will confirm that vendors are not suspended or disbarred before invoices are processed for payment against a grant. Training and Communication: All College personnel (principal investigators, accounting, procurement, etc.) involved in the execution, implementation, compliance, reporting, management and administration of grants will be trained in the new procurement procedures. Expected Completion Date: • Immediate Action: Within sixty (60) days (target date May 31, 2025) • Procurement Process Improvement: Within ninety (90) days (target date June 30, 2025) • Grant Guidance Revisions: Within sixty (60) days (target date May 31, 2025) • Invoice Processing for grants: Immediate • Training: Within sixty (60) days (target date May 31, 2025) Responsible Parties: Controller and Deputy Controller will oversee the corrective action plan and ensure the necessary steps are implemented. The Director of Procurement, Accounting & Reporting Supervisor, and Director of Grants Administration will design and execute the new procedures and training. The Director of Internal Audit will assist in monitoring compliance and assess effectiveness. Follow-up: A review will be conducted after 6 months by the College’s internal auditor to independently assess the effectiveness of the corrective actions and ensure the new procedure is functioning as intended. In addition, the Suspension and Debarment Policy will be included in the College’s policy library.

Corrective Action Plan: The Organization will ensure to track minimum level of effort requirement in regard to any key staff to stay in compliance. All invoices will be reviewed by accounting management staff to ensure level of effort requirements are in compliance. Estimated completion date: June 30, 2025 Contact person: Chue Vang, Chief Financial Officer

Finding 2024-001: UNPAID AND UNTIMELY PAID REFUND- We tested thirteen drop students and noted one unpaid and one untimely paid refund as a result of Return of Title IV funds calculations. Comments on Finding and Recommendation(s): The institution agrees with this finding. It was recommended that the school complete the R2T4 and return the $4,704 in Sub, Unsub, and PLUS funds to the Department of Education. The Pell return, while untimely, was completed prior, therefore no additional action required. Actions Taken or Planned: The $4,704 in Sub, Unsub, and PLUS was returned to the Department of Education on 12/16/24. Withdrawals are processed by the Dean of Academic Success and forwarded to the Registrar and Financial Aid Office for review and action. The Financial Aid Office and Business Office will begin to track withdrawals and follow up with Academic Success and the Registrar when final forms are not shared in a timely manner so that funds can be returned as needed.

The department will update procedure documents to accurately reflect the role of client insurance questionnaires in determining if a private insurance holder exists.

Iowa has been working with our region five UI program specialist at Department of Labor and other region five states to set goals and make major changes to our processes. Iowa BAM team as of February 1, 2025, is now paperless. This will reduce the amount of time printing, scanning and manually reviewing cases. We will have seven BAM Auditors at this point with one retiring in March. This position has already been posted to refill. Additionally, we still have part-time help from previous BAM Auditors who are still employed in the Unemployment Division. As stated above we have gone paperless. The amount of time spent printing each case, organizing etc. was extraordinary. We have also updated all documents, and they are located in a central location for use by the team. We will meet with BAM Auditors on a weekly basis (done by Workforce Program Coordinator) to keep Auditors on track and to assist them with any case issue. They will also self-report on case progress weekly so they can be assisted in the event the timeline is in danger of not being met. The Quality Control Manager will send weekly progress updates to the Bureau Chief on each person’s case management workload in addition to meeting with each Auditor.