Corrective Action Plans

Finding Number: 2023-005 Assistance Listing, Federal Agency, and Program Name 10.558, U.S. Department of Agriculture, Child Care and Adult Food Program Federal Award Identification Number and Year 15-016-271P-00 Pass through Entity Illinois State Board of Education Finding Type Material weakness Repeat Finding No Criteria Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government," issued by the Comptroller General of the United States, or the "Internal Control Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Other requirements include: a) Per 7 CFR 226.10(c)(1), prior to submitting its consolidated monthly claim to the State agency, each sponsoring organization must perform edit checks on each facility's meal claim; per 7 CFR sections 226.16(g) and (h), a sponsoring organization must disburse advance and meal reimbursement payments to centers and day care homes under its sponsorship within five working days of receiving them from its state agency. b) Per 7 CFR 226.15(f), each sponsoring organization of day care homes shall determine which of the day care homes under its sponsorship are eligible as tier I day care homes c) Communication from the passthrough entity to return to pre COVID 19 monitoring, as required under 7 CFR 226.16(d)(4)(iii), effective October 1, 2022, where sponsoring organizations are required to perform onsite monitoring of each of its facilities three times every year, which includes requirements to ensure the amount of time between reviews does not exceed six months (unless review average is used). Condition A lack of documented controls as evidence of supervisory review and segregation of duties to ensure compliance with Federal program requirements, specifically over: a) monthly expenditure reports submitted to the passthrough entity b) tier (day care home eligibility) determinations c) subrecipient monitoring Questioned Costs None Identification of How Questioned Costs Were Computed N/A no instances of material noncompliance noted that would result in questioned costs Context a) During testing a sample of 5 monthly expenditure submissions, we noted no formally documented supervisory review in place. Additionally, during testing of 40 disbursements to providers, we noted no formally documented supervisory review to ensure disbursements to providers are made within 5 working days of receipt from the State passthrough entity. b) While gaining an understanding of controls over tier (day care home eligibility) determinations, we noted no controls established to ensure supervisory review of these determinations. c) While testing a sample 40 provider monitoring visits, we noted 3 visits without evidence of supervisory review and 6 visits where the visit was completed and validated in the software by the same individual. Additionally, we noted 16 day care homes and 2 day care centers with less than the required 3 annual on site monitoring visits for the year, and 15 day care homes and 2 day care centers where onsite monitoring performed were more than the required 6 months apart. Cause and Effect A lack of effectively designed, implemented, and operating controls in any of these areas could result in a material noncompliance with program requirements or Uniform Guidance. Recommendation We recommend management formalize documentation of a supervisory review of: a) monthly expenditure submissions before submitting to the passthrough entity, including documented supervisory controls to ensure disbursement timeliness is met within 5 working days as part of this review; b) of data used in making tier/eligibility determinations for accuracy and completeness; and c) of subrecipient monitoring. Additionally, we recommend management work with its passthrough entities to confirm compliance requirements, especially when compliance requirements change as the result of ending or expiring waivers and flexibilities. Planned Corrective Action Plan –Organization will document process that is used for second review of the monthly expenditure submissions by 04/30/2024. There are no instances of the Organization not providing funds to provider within the mandated 5 days, however, the Organization will document the process for provider payments within 5 days by 04/30/2024. The software required to be used by the funder for management of the program does have limitations on how the data input for making tier/eligibility determinations second review is documented. Organization will design process to document this second review has occurred by 04/30/2024. Staffing shortages coming out the COVID-19 waivers resulted in the inability to perform all required Subrecipient monitoring. This staffing shortage was rectified by 08/31/2023. Contact person responsible for corrective action: Loukisha Pennex, Chief of Youth and Family Potential, Anjanette Brown, CFO and Teresa Rodriguez, Senior Director of Grants and Contracts. Anticipated Completion Date: April 2024

FINDING 2023-007 Compliance Requirement(s): Non-Profit School Food Service Accounts Audit Findings: Material Weakness, Other Matters Summary of Finding: There was no documented control in place over the receipt of monthly meal reimbursements. One individual received notification of deposit, received funds into accounting software, and prepared bank reconciliations. There was no documented review of the receipt of monthly meal reimbursements by a second individual not involved in the original receipt process. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: The Business Manager and Cafeteria Manager will meet monthly to review the deposit statement from the bank to verify all deposits are accurate and accounted for the Food Service Fund. The bank statement will be initialed by both parties and retained on file in the business office. Anticipated Completion Date: Immediately

FINDING 2023-006 Compliance Requirement(s): Reporting Audit Findings: Material Weakness, Other Matters Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting There was no documented control in place over the review of monthly reimbursement claims. Claims were prepared and submitted by one individual without documentation that they were being reviewed by a second person not involved in the original process. The lack of controls resulted in overstatements in the number of meal counts used for reimbursement purposes when compared to School Corporation supporting documentation. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: The food service director will enter the claims into CNPWeb Claim reimbursement site using the information from the Point of Sale system reports for reimbursable meals. The Business Manager will then confirm the meal counts before submitting the Claims. The FSMC food service director meets with the Superintendent monthly to review all claims and food service financials. A meeting agenda will be signed by all parties involved and retained on file in the business office. Anticipated Completion Date: Immediately

FINDING 2023-004 Compliance Requirement(s): Reporting Audit Finding(s): Material Weakness and Other Matters Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting The Unit has not separated incompatible activities within the managing of the federal award programs. The failure to establish these controls could enable material misstatements and noncompliance to be undetected. Management reviews award agreements, contracts and DOE reporting dates and requirements and submits the Annual report to IDOE. Management reviews report for accuracy between the Treasurer and Grant Manager (Asst. Superintendent). A second approval could not be verified. Segregation of duties during the process of entering, approving, and submitting the Annual Reports failed. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: In the future, the Required DOE Reports will be prepared by the assistant superintendent, who oversees all grant management. Then, the Business Manager will review the prepared reports; upon review, both the business manager and the assistant superintendent will sign/initial the signifying their review of the documents. The report will also be shared with the Superintendent, who will sign off as well. Anticipated Completion Date: Effective Immediately

The  Hospital  has  identified  additional  expenditures  that  occurred  during  Period  4  to  prevent, prepare for, and respond to coronavirus that were not reimbursed by other sources or that other sources were  obligated  to  reimburse  that  were  omitted  from  the  original  submission.   In  the  future,  the  Hospital  will  maintain adequate financial records and supporting documentation for the federal awards. The tracking mechanism will include denoting if the expenditures have been reimbursed by another source or are obligated to be  reimbursed  by  other  sources.  In  addition,  the  Hospital  will  be  proactive  in  getting  necessary  training  and  education regarding the allowable uses of federal funding received in future years. Responsible Individuals: Stephani Tipton, Accountant and Ken Fisher, CFO Anticipated Completion Date: Ongoing

The Hospital has recalculated lost revenues to incorporate the audit adjusting journal  entries for the fiscal year ended July 31, 2022, for quarters impacted, incorporate the cost report settlement impact across all quarters impacted, and to include an estimated impact of the cost report settlement for quarters impacted  for  the  fiscal  year  ended  July  31,  2023.   In  addition,  the  revised  calculation  includes  the  correction  needed to remove the 340(b) drug program expenses as noted in finding 2023‐006 and to reconcile to supporting documentation  as  noted  in  finding  2023‐005.   In  the  future,  the  Hospital  will  maintain  adequate  supporting  documentation for the calculation of lost revenues and will ensure the accuracy and completeness of the amounts reported  by  reconciling  to  the  audited  financial  statements,  internal  financial  statements,  and  other  source  documentation. The Hospital will be cognizant of items that are posted in one period that apply to multiple periods and accurately including those items in the calculation. In addition, the Hospital will be proactive in getting necessary training and education regarding the allowable uses of federal funding received in future years. Responsible Individuals: Stephani Tipton, Accountant and Ken Fisher, CFO Anticipated Completion Date: Ongoing

In  the  future,  the  Hospital  will  maintain  adequate  supporting  documentation  for  the  calculation of lost revenues and will ensure the accuracy and completeness of the amounts reported by reconciling to the audited financial statements, internal financial statements, and other source documentation. The Hospital will be cognizant of only including revenue in the calculation and that the periods being compared are calculated using  the  same  methodology.   In  addition,  the  Hospital  will  be  proactive  in  getting  necessary  training  and  education regarding the allowable uses of federal funding received in future years. The Hospital has recalculated lost  revenues  for  the  quarters  covered  by  Period  4  to  exclude  the  340(b)  drug  program  expenses  from  the  calculation, in addition to taking into consideration corrections needed for items noted in finding 2023‐007. Responsible Individuals: Stephani Tipton, Accountant and Ken Fisher, CFO Anticipated Completion Date: Ongoing

In  the  future,  the  Hospital  will  maintain  adequate  financial  records  and  supporting  documentation for federal awards. The Hospital will use a spreadsheet to track all federal awards. The spreadsheet will be prepared by the accountant and reviewed by the Chief Financial Officer. The spreadsheet will be included in the monthly financial information provided to the Board of Directors for review and approval. Responsible Individuals: Stephani Tipton, Accountant and Ken Fisher, CFO Anticipated Completion Date: Ongoing

The Hospital recognizes the importance of having a methodology in place for estimating  the allowance for contractual adjustments in accounts receivable and the estimate for third‐party payor settlements.   The  Hospital  will  work  on  strengthening  procedures  for  the  allowance  for  contractual  adjustment  estimate and develop an estimate for the Medicaid lump sum payments. Our goal will be to use our Medicare cost report model to estimate the Medicare cost report settlement on a quarterly basis. In addition, our goal is to have the model tested against the most recently submitted Medicare cost report on an annual basis. An accountant was hired on February 13, 2024, to assist the Chief Financial Officer (CFO)   in the monthly accounting duties. The accountant immediately began reconciling cash accounts and is caught up on  all  prior  month  reconciliations.   The  accountant  is  working  with  CFO  to  post  activity  and  corrections  to  the  general ledger. The accountant will ensure that cash and investment accounts are reconciled monthly in a timely manner going forward. Now that the cash reconciliations are caught up, the accountant will begin reconciling all other balance sheet accounts. Responsible Individuals: Stephani Tipton, Accountant and Ken Fisher, CFO Anticipated Completion Date: Ongoing

Finding Number: 2023-015 Federal Program: 14.218 – U.S. Department of Housing and Urban Development (HUD) – Community Development Block Grant (CDBG) – Entitlement Grants Cluster 93.563 – Title IV-D, U.S. Department of Health and Human Service - Child Support Enforcement (CSE) 10.557, U.S. Department of Agriculture – WIC Special Supplemental Nutrition Program for Women, Infants, and Children Condition Per Auditor: Controls in place were not adequate to ensure compliance with 2 CFR 200 Appendix V submission requirements for the County’s self insurance cost allocation process and annual chargeback plan. Planned Corrective Action: Management communicated with the cognizant agency which confirmed in November 2021, OMB issued guidance relating to CARES Act funding and its effect on indirect cost. Part of this guidance stated that “CARES Act funding should not be included toward the threshold amount for indirect cost submission required in 2 C.F.R. part 200, Appendix VII, paragraph D.1.b”. Therefore, County governments that met the $100 million threshold as a result of CARES Act funding are not required to submit their Central Service Cost Allocation Plan for approval. The CARES Act funding would have increased the County’s funding in excess of $100 million, which should not have been a part of the determination for the original finding. However, since CSLFRF funds were also received increasing the County’s funding in excess of $100 million the annual chargeback plans were submitted to the cognizant agency and U.S. Treasury in 2023 for implementation in FY 24 and will continue to submit subsequent plans to federal cognizant agency, as required by 2 CFR 200 Appendix V. Anticipated Completion Date: 9/30/24 Responsible Contact Person: Shauntika Bullard and Michael Bridges

Finding Number: 2023-014 Federal Program: 10.557, U.S. Department of Agriculture – WIC Special Supplemental Nutrition Program for Women, Infants, and Children Condition Per Auditor: Controls in place were not adequate to ensure the County maintained responsibility for compliance with eligibility standards when eligibility determinations are made by the contractor. Planned Corrective Action: Management has fully implemented a process, as of January 2024, by which a county representee preforms review of contractor eligibility determinations. Anticipated Completion Date: 1/31/24 Responsible Contact Person: Nataline Dean-Woods

Finding Number: 2023-013 Federal Program: 21.027, US Department of Treasury, COVID-19 – Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Condition Per Auditor: The County entered into intergovernmental agreements with local communities using the revenue loss provision of the County’s CSLFRF award. Those contracts contained subrecipient language/provisions. The County did not have adequate controls in place to ensure that the form and substance of these agreements were in compliance with the intended nature of the relationship and/or the requirements of the federal award. Planned Corrective Action: Management does not agree with this finding. As noted in the Condition of this finding itself, the agreements in question are intergovernmental agreements, clearly labeled as such. They specifically state they are funding each project with SLFRF funds under the Revenue Replacement Category (Category 6.1). Section 4.01 states “Project Funds must be used for eligible activities for revenue replacement funds as described in the SLFRF final rules, regulations, and guidance.” As Management informed the auditor before auditor edited its preliminary finding to reflect this, “as described in the SLFRF final rules, regulations, and guidance” under 6.1 there are no subrecipients by definition as the County itself is the beneficiary. The County is being "made whole" for calculated revenue loss due to the pandemic under this category; therefore, once the funds are obligated and spent by the County the purpose has been satisfied. The entity receiving those funds would not have subrecipient obligations. FAQ 13.14 confirms this understanding. The communities enter into subrecipient agreements on an annual basis with the County and are very familiar with the format of such agreements. Those agreements always state clearly that they are subrecipient agreements in the title and the introductory paragraph. The communities also enter into intergovernmental agreements with the County on an annual basis. Therefore, they are aware that these two types of agreement are distinct. In this case the agreements are clearly labeled as intergovernmental agreements in the title and the introductory paragraph and there is no mention of subrecipient status in the body of the agreement. In fact, Section 4.05, Relationship of Parties, states “Relationship of the Community to the County is, and will continue to be, that of an independent contractor.” In the subrecipient agreements the County enters into with these communities on an annual basis this clause says the relationship is that of a subrecipient. Therefore, the agreement is clear on the relationship and the communities would know to consult the County if there is any question of compliance requirements. Any language requiring compliance with provisions applicable to subrecipients was paired with the qualifier "applicable". For example Article IX requires compliance with laws only “as applicable”. This is catch-all language and is good legal practice to include for contingencies. In this case, the program being a new federal program, the County intentionally included this catch-all language referencing compliance with 2 CFR 200 (Uniform Guidance) “as applicable” and required the community to “provide any disclosures required by law.” to allow itself the ability to enforce should the laws, rules, or regulations be interpreted in a certain manner to be applicable or even changed. This is based on experience with programs such as the Neighborhood Stabilization Program through HUD where such occurrences were noted. Consequently; the County believes it would actually be irresponsible not to include such language. As far as the recommendation of increased guidance to contracted communities, given the increased guidance available now the County has provided such guidance as needed. Auditor seems to indicate that the communities “may improperly conclude they are subject to certain compliance requirements, including but not limited to incorrectly concluding they are required to report expenditures incurred under the agreements on their schedule of expenditures of federal awards, which could further lead to those communities incorrectly concluding they are subject to the requirement to obtain a single audit and/or incorrect major program determinations being made in conjunction with their single audit engagements.” The finding is essentially noting that if these communities conclude that they have a subrecipient relationship and that the Uniform Guidance is applicable to them as subrecipients it is an improper conclusion. Given the wide availability of FAQs and guidance on this topic, Management agrees it would be an improper conclusion. Anticipated Completion Date: 9/30/23 Responsible Contact Person: Haaris Ahmad

Finding Number: 2023-010 Federal Program: 21.023, US Department of Treasury, COVID-19 – Emergency Rental Assistance Condition Per Auditor: The County’s controls over general ledger to Schedule of Expenditures of Federal Awards (“SEFA”) and beneficiary payment database reconciliation did not identify several adjustments that were needed to both the general ledger and the SEFA. Planned Corrective Action: Management will update processes and controls to ensure completeness of grant activity is received for review and reconciliation. Anticipated Completion Date: 6/30/25 Responsible Contact Person: Shauntika Bullard

National Infrastructure Investments -Assistance Listing No. 20.933 Recommendation: Implement a process and to update its policies and procedures to ensure that all certified payrolls are properly verified and maintained accurately through the grant award period and beyond. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff will conduct a documented compliance review no less than monthly comparing the certified payroll tracker against supporting documentation including the payrolls collected by the third-party administrator (TPA). Any discrepancies will be conveyed to the TPA and Contractor and monitored until resolved. The Grants Administration Handbook will be updated for procedures for verification of certified payrolls. Name(s) of the contact person(s) responsible for corrective action: Trinity Scott, Transportation Management Services Department Head, 239-252-5873. Planned completion date for corrective action plan: May 30, 2024

Margaret Riojas, Office Manager and Ronald Daniels, General Manager concur with the finding and agree to implement procedures to ensure compliance with Davis-Bacon Act requirements

Margaret Riojas, Office Manager and Ronald Daniels, General manager, concur with the finding. The District is in the process of interviewing potential new consultants that will assist in the monthly and annual closing of accounting records

Margaret Riojas, Office Manager and Ronald Daniels, General Manager, concur with the finding. The District is in the process of interviewing potential new consultants that will assist in the preparation of Financial Statements

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Finding Summary: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. The auditors were not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Corrective Action: The College will review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College will review all processes and procedures related to eligibility to ensure controls are well documented and to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

2023-007 – Reporting – Material Weakness in Internal Controls Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Finding Summary: The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted in a timely way and that the dates and amounts agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding: Yes, 2022-004 Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action: The college will conduct ongoing training to develop reporting and process steps to prevent reporting errors and improve accuracy in reporting in identifying student’s assistance needs. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, COD reporting and reconciliation.  The College will implement a process to review, update, and verify student disbursements are reported to COD accurately and timely.  Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules, and system back-end processes. 108  Implemented a tracking log starting in July 2023 between Financial Aid and the Business Office to ensure distribution in compliance with Common Origination and Disbursement (COD). Anticipated Completion Date: to be completed by June 30, 2024

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program 107 Finding Summary: Staffing shortages have contributed to the delay in the implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Finding Summary: This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates, and a lack of understanding of compliance requirements. This resulted in a failure to properly identify students requiring calculation for return of funds to the federal government, or eligibility for post withdrawal disbursement. As a result, the auditors were unable to determine if the College is remitting unearned funds to the federal government, or offering eligible students post withdrawal disbursements if available to them. Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: The college entered into a third-party contract to manage financial aid packaging and awarding. Integration and processes for the R2T4 calculation with the third-party processer was not completed correctly. New integrations, policies, and processes to be adopted in fiscal year 2023-24.  Develop and implement ongoing tracking and reporting for all financial aid reporting.  Financial Aid and Student Accounts work to regularly review and action student account files.  Continue to work with third-party service to review and promptly return Title IV funding in compliance with federal rulings. Anticipated Completion Date: to be completed by June 30, 2024

over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Finding Summary: The College did not have controls in place to ensure the reporting of enrollment information under the Pell grant and Direct loan programs via NSLDS was completed. Due to the way the College’s software pulls the roster information, the Clearing House is unable to send the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the prior award year and has not resumed. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding – Yes, 2022-003 Responsible Individuals: Mary Martin, Registrar Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2023, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2023, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by:  working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner.  working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting. 106  working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes.  consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported.  prompt resolution of reporting errors.  identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: to be completed by June 30, 2024

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Kevin Davis, Superintendent & Business Manager Anticipated Completion Date: July 15, 2024 Planned Corrective Action: This finding related to federal grants, specifically ESSER Funds was due to changing requirements in the program, the newness of the ESSER grants, and lack of training for our grants manager as they are also new to the position. Additional grants training will be conducted for this individual and be completed by July 15, 2024. As our ESSER grants have been expended and completion reports finalized by Grants Management, with no issues or errors found, this should not be an issue in the future.

The YWCA will implement the following changes in its accounting procedures: 1. Journal entries will be drafted by the Staff Accountant and reviewed by the CFO prior to being posted to the general ledger. The end-of-month-journal-entry spreadsheets will have spaces added for the CFO to indicate approval and date approved. 2. Payroll registers will be reviewed by the CFO each payroll. The end-of-month payroll entry (which encompasses all the payroll entries for the month) will be reviewed by the CFO prior to being uploaded to the MIP accounting software. 3. All invoices will be approved by the appropriate program director and account distribution will be reviewed by the CFO prior to entry into the accounts payable system. 4. Percentages used to allocate expenses across grants will be reviewed and updated annually at the beginning of the fiscal year. The allocation will be approved by the CEO. 5. Matching amounts for grants will be tracked and documented with supporting documentation by the Director of Finance and saved in the appropriate folder within the Finance SharePoint folder.

The YWCA will implement the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.