Corrective Action Plans

Finding Number: 2023-001 Condition: The Hospital's controls in place for submitting expenses did not identify that several invoices and related expense amounts were duplicated in the addendum to the period 1 submission. As a result, period 1 addendum submission included expenses that were deemed unallowable as they had already been utilized to support funding received. Reimbursement for, the original period 1 submission contained retention bonus costs that exceeded 20% of total funds awarded. Planned Corrective Action: The Hospital will review its processes surrounding submission of expenses to MHA and implement additional layers of review. Contact person responsible for corrective action: Brenda Winn and Alex Roehling Anticipated Completion Date: 9/30/2023

Finding Summary: Utah Military Academy is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of GEER and ESSER funds and criteria used and number of full-time equivalent positions for all GEER & ESSER funds received from the USBE during the period of July 1, 2021 to June 30, 2022. Utah Military Academy reported ESSER expenditures and number of specific positions supported with ESSER funds incorrectly not in accordance with the instructions provided by the State of Utah. Responsible Individuals: Haydn Stender, Business Manager and Bill Orris, Superintendent Corrective Action Plan: Management will provide the USBE with the correct ESSER expenditures and number of specific positions supported with ESSER funds for the correct reporting period. Anticipated Completion Date: Ongoing Anticipated Completion Date: Management will ensure all necessary corrective action plan items are in place by the end of the next reporting period.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kelso Housing Authority April 1, 2022 through March 31, 2023 This schedule presents the corrective action the Authority is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The Housing Authority had inadequate internal controls for ensuring compliance with depository agreement requirements for its Section 8 Housing Choice Voucher program. Name, address, and telephone of Authority contact person: Joleen Reece, Executive Director 360-423-3490 1415 S. 10th Avenue Kelso, WA 98626 Corrective action the auditee plans to take in response to the finding: The Authority has initiated the change to an interest-bearing arrangement for the HCV bank account as of December 5, 2023. Anticipated date to complete the corrective action: January 1, 2024.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers, Mainstream Vouchers, Emergency Housing Vouchers Assistance Listing Numbers: 14.871, 14.879, 14.EHV (the “Housing Voucher Cluster”) Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 8,789 units. Of a sample size of eighty-seven (87) tenant files, the following was noted: • HUD-9886 Authorization for Release of Information was missing in 8 files • Annual 50058 form was missing in 7 files • Verification of income and assets was missing in 10 files • Annual inspection report was missing in 2 files Our sample size is statistically valid. Known Questioned Costs: $216,820 Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor on the inspection of tenant files and has made arrangements to comply with the compliance requirements of the Housing Voucher Cluster. The added controls will consist of additional training that will be completed by Continued Eligibility staff related to the Electronic File Protocol and the procurment of an IT vendor that will develop reports to identify missing SharePoint attachments within electronic tenant files. Ingrid Layne, the Director of Assisted Housing will be responsible to implement this corrective action by March 31, 2024.

Finding 2023-007 Special Tests and Provision – Child Nutrition Cluster Material Weakness in Internal Control Over Compliance and Material Noncompliance Finding Summary: The District does not have an internal control system designed to review and maintain documentation for verification of eligibility status. Responsible Individuals: Shannon Hunstad, Superintendent Corrective Action Plan: The District will review and strengthen the controls to ensure the required verification process is being completed and ensuring proper eligibility status for the Child Nutrition Cluster program. Anticipated Completion Date: June 30, 2024

Finding 2023-006 Eligibility – Child Nutrition Cluster Material Weakness in Internal Control Over Compliance and Material Noncompliance Finding Summary: The District does not have an internal control system designed to review and maintain documentation for eligibility of program participants. Responsible Individuals: Shannon Hunstad, Superintendent Corrective Action Plan: The District will review and strengthen the controls surrounding the review and approval of eligibility applications for the Child Nutrition Cluster to ensure they are supported, approved, and accurate. Anticipated Completion Date: June 30, 2024

Finding 2023-002 – Housing Choice Voucher Program – Internal Control over Waiting List – Noncompliance and Material Weakness - Housing Choice Voucher Program - subsidy ALN #14.871 Corrective Action Plan: Finding 2023-002 correctly identifies the same underlying cause (recruiting and retaining qualified staff) as well as alluding to another underlying problem—antiquated software and IT systems—as contributing factors. Our detailed analysis of the issues giving rise to Finding 2023-001 and the strategic and comprehensive remedies being pursued will result in better outcomes in implementing RHA’s waiting list policies and procedures. For example, a new eligibility unit under an eligibility manager, will bring focus to sound waiting list management. However, another critical underlying cause is the system of waiting list preferences and having a waiting list that remains open regardless of the size. RHA proposes to do away with all preferences except that of giving higher priority to residents of Wake County and those who are employed in Wake County. An applicant’s preference can change multiple times while they are on the waiting list. Anytime one applicant provides new information that changes their preferences and position on the waiting list, the waiting list changes. Greatly simplifying RHA’s waiting list by eliminating most preferences will result in a more manageable waiting list going forward. An additional remedy RHA has implemented is closing the HCV waiting list for the first time in its history. This will greatly reduce the administrative burden of adding new applicants on a continual basis and then annually updating (purging) an unnecessarily large waiting list. Staff in the eligibility unit will have more time to focus on better management of the waiting list. These additional changes in RHA’s program management will complement the other changes discussed under Funding 2023-001. Person Responsible: HCV Director Priscilla Batts and her Eligibility Manager Anticipated Completion Date: The system of closing and opening waiting lists based on the adequacy of the size of the waiting list has been implemented on October 1, 2023. It is anticipated that the list will reopen on April 1, 2024, RHA’s go-live date for the new software. The elimination of most preferences will be implemented at the same time—April 1, 2024.

Finding 2023-001 – Housing Choice Voucher Program Tenant Files – Eligibility – Internal Control over Tenant Files – Noncompliance and Material Weakness - Housing Choice Voucher Program - subsidy ALN #14.871 Corrective Action Plan: Finding 2023-001 for the most part correctly identifies the cause of this finding: “We noted that the Authority has experienced difficulty in hiring, training, and retaining quality staff. This is the cause for each of the instances of noncompliance referenced.” The “Great Resignation” during the pandemic affected the HCV Program significantly as staff began to search for other opportunities and potential staff did not find RHA’s compensation competitive. Other negative impacts related to the pandemic included the moratorium on evictions and termination of assistance. Participants had fewer incentives to comply and became lax, resulting in increased levels of work to counter this lax attitude towards program rules. Later in 2022, the end of moratoria resulted in RHA’s voucher utilization rates plummeting as landlords exercised their rights to evict and terminate as well as pursuing rapidly increased market rents instead of renewing leases of voucher participants or renting to voucher holders for the first time. The efforts to retain landlords and issue hundreds of vouchers strained the departments’ staffing resources. The underlying cause of the findings was not just the pandemic effects. RHA recognized that it had underinvested in program operations. First, compensation levels were not close to being competitive. Second, RHA did not invest enough in staff training, a key factor in retention. Third, RHA had also underinvested in technology, using inefficient systems and paper-intensive operations. Fourth, in addition to underinvesting in compensation, RHA also did not allocate resources to staffing, resulting in an understaffed department—managers and line staff. And fifth, these areas of underinvestment led to an organizational structure and staffing model that resulted in staff roles being very narrow. Multiple staff were involved in individual aspects of processes like annual recertifications. It did not require much training, and it relied on staff to do narrow repetitive tasks in a conveyor-belt fashion without anyone being accountable for an entire process. For example, between one and two staff were responsible for doing calculations for participants’ rent portion and subsidy amounts for 3,800 or so annual recertifications and scores of interim recertifications. Four “client specialists” were each responsible for facilitating almost 1,000 participants’ compliance with recertification requirements prior to the two account specialists’ calculation work. In 2023, RHA started to address the root cause that led to this and other findings—underinvestment: 1. RHA’s Human Resources issued an RFP for a firm to do an analysis of compensation levels and make recommendations for classification of positions and competitive compensation. The study was completed and implemented effective the first pay period in December 2023. Individual compensation increases averaged more 10 percent, with staff in the operating departments like HCV benefiting from even higher salaries. These increases were on top of a five percent increase in all salaries effective July 1, 2023, in anticipation of the results of the study. 2. The Director of HCV immediately, upon direction to increase training, contracted with Nan McKay to provide HCV Specialist Certification training to all staff responsible for any part of the eligibility and ongoing occupancy processes. Prior to this effort, only one HCV staff member had been certified. All but one staff person failed the certification class. Going forward, all new staff will be required to pass Nan McKay’s HCV Specialist Certification class by the end of probation. 3. The HCV Director also contracted for Manager and Supervisor Training by Nan McKay for all supervisory staff. All completed certification requirements. 4. The HCV Director also recommended and implemented proposals to reorganize the department by ensuring that managers had a manageable supervisory load of not more than six staff per manager. The new structure created an eligibility unit headed by an eligibility manager (for the first time) as well as two units of ongoing eligibility staff of 12 HCV specialists overseen by two managers. These actions represent a significant increase in staffing and supervision. This reorganization also entails the implementation of a “case management” model in which each HCV Specialist is responsible and accountable for an initial case load of 300 voucher participants. Managers will be responsible for mentoring, training, quality control (file audits) and evaluation of the work of their staff. This reorganization of the department reflects multiple strategies to address some of the root causes that gave rise to the audit finding. 5. By the time the new CEO came on board on April 17, 2023, RHA had completed the evaluation of bids for new software and selected YARDI’s Voyager, Rent Café portals, and other applications to replace antiquated systems. Contract negotiations between RHA and YARDI were completed in July 2023. This initiative represented both a commitment to far greater efficiency and accuracy as well as a willingness to invest in program operations. Implementation and setup are well underway and April 1, 2024, is the “go-live” date. Needless to say, this commitment of resources and countless hours of staff time over nine months has had short-term impacts on RHA’s ability to address identified weaknesses. However, RHA is committed to long-term benefits while enduring short-term pain. These investments in a comprehensive strategic plan for long-term improvements in customer service, compliance, and performance will yield positive results without necessarily making major progress over the short term. To effect improvements over the short term, RHA has implemented the following measures: 1. The HCV director contracted with Nan McKay to assist RHA with catching up on compliance work that has stalled as a result of short staffing and lack of trained staff. Nan McKay’s own difficutly in retaining trained staff and hiring and training new staff delayed their assistance. This delay was further exacerbated by cyber event at the beginning of May 2023. RHA’s computers and systems were locked down by a threat actor requiring ransom. This event reduces RHA operations to manual processes and lack of access to key information to perform compliance work.Nan McKay’s efforts to assist are increasing over time. 2. HCV managers are increasing their efforts to perform qualify control efforts, focusing their staff’s attention on enforcing participants’ compliance with program requirements, including deadlines, and using what they learned from their training. Person Responsible: Priscilla Batts, HCV Director, is principally responsible and accountable for focusing her team on the strategic initiatives outlined above. Anticipated Completion Date: Some of the corrective actions above have been implemented, for example, competitive compensation, training, and outsourcing some of the compliance work. However, these are mainly system changes that will be fully implemented in 2024, for example, new software, with significant improvements that will be evidenced by December 31, 2024.

Finding 2023-004 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Rural Distribution Federal Assistance Listing #93.498 Finding Summary: The operations of HealthCenter Northwest, LLC (HC) were consolidated into Kalispell Regional Medical Center d/b/a Logan Health Medical Center (LHMC) as of December 31, 2020. When LHMC calculated their lost revenues, they included HC’s revenue for both 2020 and 2021 instead of only the 2021 information. This resulted in LHMC reporting higher lost revenues than the detailed reports supported in Period 3. This was corrected in Period 4 reporting. Responsible Individuals: Craig Lambrecht, CEO and Cole Turner, CFO Corrective Action Plan: The lost revenue calculation will be re-evaluated and the amount of lost revenue reported on the HHS reporting portal has been updated in Period 4. Completion Date: 12/31/23

Finding 2023-003 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Rural Distribution Federal Assistance Listing #93.498 Finding Summary: In some of the quarters for certain entities, it was noted that bad debt expenses were higher than revenues, creating a negative revenue for the quarter. As the HHS reporting portal would not allow negative amounts to be entered, a zero was entered into the HHS reporting portal. These negative amounts should have been offset to other quarters or other revenue line items, but were not, which resulted in higher revenue amounts being reported than the detailed reports supported for two locations for Period 3. Responsible Individuals: Craig Lambrecht, CEO and Cole Turner, CFO Corrective Action Plan: The lost revenue calculation for these two locations will be re-evaluated and the amount of lost revenue reported on the HHS reporting portal will be updated in future periods. Anticipated Completion Date: Ongoing

Condition: Three vendors were awarded a contract without an appropriate procurement process. Corrective Action Planned: Management agrees with the finding that State Procurement methods were followed. Management was unaware of the Federal procurement process requiring a three quote process for all contracts exceeding $10,000, but lower than $250,000 and a formal advertised bid or proposal process for contracts more than $250,000. Management has updated its internal financial operating procedures to ensure future compliance of procurement procedures on all applicable contracts for goods and services. Anticipated Completion Date: Completed Contact: Stephen Marshall, Assistant Superintendent of Finance & Operations

Finding 2023-004 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Financial Assistance Listing #93.498 Finding Summary: The Health Center's final expenditure listing identified as eligible and claimed under the federal program were not reviewed and approved by a separate individual outside of the preparer. Responsible individuals: Crystal Richter, Chief Financial Officer Corrective Action Plan: If future reports are required, a secondary review of the summary spreadsheet prepared from the underlying supporting spreadsheets will be documented. No further are reports anticipated relating to this federal program. Anticipated Complete Date: 11/30/2023.

Finding 2023-004 Federal Agency Name: Department of Agriculture Federal Financial Assistance Listing #10.766 Program Name: Community Facilities Loans and Grants Cluster Compliance Requirement: Special Test and Provisions Finding Summary: The Hospital's reserve account is fully funded per the requirements in the loan resolution agreement. However, there is no documented secondary monitoring of the account balance as compared to the required minimum balance. Responsible Individuals: Lisa Weisser, Director of Finance Corrective Action Plan: A qualifying statement will be added to the bi-monthly board report which will qualify the minimum USDA-RD required reserve balance for the board of director's review and oversight. Anticipated Completion Date: January 2024

Finding 2023-003 Federal Agency Name: Department of Agriculture Federal Financial Assistance Listing #10.766 Program Name: Community Facilities Loans and Grants Cluster Compliance Requirement: Preparation of Schedule of Expenditures of Federal Awards Finding Summary: The Hospital does not have an internal control system designed to provide for the preparation of the schedule and notes to the schedule. We requested our auditors to assist with the preparation of the schedule and notes to the schedule. Responsible Individuals: Lisa Weisser, Director of Finance Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for the preparation of the Schedule of Expenditures of Federal Awards. We requested that our auditors, Eide Bailly LLP, prepare the Schedule of Expenditures as part of their Single Audit. We have designated members of management to review the drafted Schedule and accompanying notes. Anticipated Completion Date: Ongoing

2023-004 - Material weakness and Material Noncompliance - Missing Timesheets FMC Comment: FMC was in the process of converting for a one payroll system to another system during the Audit year. The conversion process was time consuming and involved files being transferred from one system to another system. This could have resulted in some timesheets being misplaced as opposed to staff being paid without a timesheet being approved. Corrective Action: FMC has a new timekeeping system - Paylocity- that should prevent the issue of missing timesheets since the system is all electronic. Staff cannot get paid unless within the Paylocity system there is an electronic timesheet. The process is described below: The employee's clock in and out electronically, through a web portal on their phone, desktop or laptop. The supervisor is notified through the Paylocity if there are errors or missed punches. The supervisor works with the employee to correct any errors. The supervisor electronically approves the electronic time card. All approved electronic timecards are locked by payroll, then electronically brought from the time and attendance system to the payroll system. Payroll and HR will review all timecards to ensure all hours are correct and the vacation, sick and personal time are within appropriate parameters. Any additional corrections are made electronically with the supervisor and employee's input. Once all the electronic records are approved, Payroll submits the payroll for processing by Paylocity. The electronic timesheet record is printed on one document and kept with the payroll register for each pay period.

2023-003 - Material Weakness and Material Noncompliance - Special Tests FMC Comment: Family Medical Center's Patient Accounts department has had significant turnover over the past three years as well as implementation of a new software. FMC hired several temporary staff to support that led to more turnover and a lack of consistency in personnel. Many of the issues are due to improper documentation or manual error inputting the patients' slide scale into the system. Corrective Action: Family Medical Center will have management or assigned staff to review all current sliding fee patients and ensure that the Center has an updated sliding fee application for each. FMC will provide additional training to front desk staff at each site and require them to obtain the proper application and documentation. Patient Accounts will review the current application to ensure that the current patients are charged the proper sliding fee scale. Management will develop a training module with Human Resources to have each staff complete in addition to hiring additional staff. This corrective action is expected to be completed by March 31, 2024.

The Purchase ADD has been going through a transition period between personnel, accounting software and audit firms the last three years. As a result, this transition has caused the ADD to continually adapt policies & procedures for correctness. The report to EDA by the loan staff included loans that had been approved in FY 2023 but not yet closed. In the future, loan staff and finance staff need to coordinate more closely what is being reported to avoid discrepencies. Fortunately, all funding as accounted for and used for its intended purpose.

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The College had internally identified the failure to send the required notifications in January 2023 and took corrective action to create new processes and made system adjustments effective for the fall 2023 semester. All required notifications were made for fall 2023 disbursements. The College is evaluating alternate notification processes to improve efficiencies and ensure completeness. Names of Contact Persons Responsible for Corrective Action: Barbara Schmitt, Director of Financial Aid Anticipated Completion Date: Changes were effective for the fall 2023 semester

Finding 2023-002 Reporting – Late REAC Submission 14.155 Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects 14.195 Section 8 Housing Assistance Payments Program Material Weakness in Internal Control – Material Noncompliance Condition: The Organization’s annual financial statement data was not submitted within the timeframes specified by HUD. The financial statement data was due by September 30, 2023, but was not filed until December 21, 2023. Auditor’s Recommendation: We recommend that the Organization make every effort to submit its annual financial statement data within the timeframe specified by HUD. Action Taken: The Organization has maintained contact with HUD and prioritized submitting the annual financial statement data after they were informed it was late. Effective Date: December 21, 2023 Contact Information: Kristy Hust, Director of Operations Northside Mental Health Center, Inc. Management Agent 12512 Bruce B Downs Blvd Tampa, FL 33612 (813) 977-8700

2023-005 Special Tests and Provisions Recommendation: We recommend that management retains all documentation related to new tenants being admitted to program Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We are using Housing Data Systems (HDS) as a tenant management solution. This software will produce all documentation related to new tenants being admitted to the program. The Program Coordinator will use checklists and the HDS to ensure that we collect the appropriate documents which we will retain in Laserfiche. The Housing Director will review a minimum random sampling of 25% of the documentation for completeness throughout the year. If the Housing Director discovers significant issues with the documentation, they will review all the paperwork and retrain the Program Coordinator, so the documentation meets performance standards. Name of the contact person responsible for corrective action: Amanda Mackie Planned completion date for corrective action plan: The HDS system is currently being utilized. The documentation review will begin on 10.31.2023 and continue indefinitely.

2023-004 Special Tests and Provisions Recommendation: We recommend that management implements a process to perform inspections and re-inspections within the timeframes required by the Administrative Plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We are using Housing Data Systems (HDS) as a tenant management solution. This software will track the timelines for inspections and reinspection. The Program Coordinator will use the HDS and their calendars to ensure that any inspections or re-inspections are carried out in accordance with the Administrative Plan. The Program Coordinator will use checklists and the HDS to ensure that we collect the appropriate documents which we will store in Laserfiche. The Housing Director will review a minimum random sampling of 25% of the documentation for completeness throughout the year. If the Housing Director discovers significant issues with the documentation, they will review all the paperwork and retrain the Program Coordinator, so the documentation meets performance standards. Name of the contact person responsible for corrective action: Amanda Mackie Planned completion date for corrective action plan: The HDS system is currently being utilized. The documentation review will begin on 10.31.2023 and continue indefinitely.

2023-003 Special Tests and Provisions Recommendation: We recommend that management implements a process to perform rent reasonableness calculation and retain documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We are using Housing Data Systems (HDS) as a tenant management solution. This software will track the reasonableness of rent and produce the appropriate documentation. The Program Coordinator will use checklists and the HDS to ensure that we collect the appropriate documents which we will store in Laserfiche. The Housing Director will review a minimum random sampling of 25% of the documentation for completeness throughout the year. If the Housing Director discovers significant issues with the documentation, they will review all the paperwork and retrain the Program Coordinator, so the documentation meets performance standards. Name of the contact person responsible for corrective action: Amanda Mackie Planned completion date for corrective action plan: The HDS system is currently being utilized. The documentation review will begin on 10.31.2023 and continue indefinitely.

2023-002 Special Tests and Provisions Recommendation: We recommend that management implements a tenant management software system which will track the contract rents annually, admissions from the waiting list, and re-inspections performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We are using Housing Data Systems (HDS) as a tenant management solution. This software will track the contract rents annually, the admissions from the waiting list and it tracks re-inspections that are performed. The Program Coordinator will use checklists and the HDS to ensure that we collect the appropriate documents which we will store in Laserfiche. The Housing Director will review a minimum random sampling of 25% of the documentation for completeness throughout the year. If the Housing Director discovers significant issues with the documentation, they will review all the paperwork and retrain the Program Coordinator, so the documentation meets performance standards. Name of the contact person responsible for corrective action: Amanda Mackie Planned completion date for corrective action plan: The HDS system is currently being utilized. The documentation review will begin on 10.31.2023 and continue indefinitely.

Finding 2023-004: Quarterly Reporting of Emergency Financial Aid Grants to Students and Annual Reporting for COVID-19 Education Stabilization Fund Contact person responsible for correction action – Mitzi Suhler, Vice President of Enrollment Services Anticipated completion date – June 30, 2023 Corrective action Sterling College agrees with the finding of not meeting the posting deadline for the quarterly reports for March 31, 2023, and June 30, 2023. The reports were posted within the required month but did not meet the ten-day limit for posting. Sterling College recognizes the importance of meeting reporting requirements for all federal programs and if any additional programs were to arise that are similar in nature, we will review the compliance requirements, and prior findings, to ensure proper processes are in place to ensure compliance in reporting are met.

Finding 2023-003: Cash Management for the Institutional Portion of the COVID-19 Education Stabilization Fund Contact person responsible for correction action – Michelle Hall, CFO Anticipated completion date – Corrective action completed in January 2023 Corrective action Sterling College agrees with the finding of not meeting the posting deadline for drawing down the funds and spending the funds within the three calendar days of the drawdown. Sterling College recognizes this compliance requirement and will in the future for any other COVID-19 funds review the drawdown requests prior to execution and be cognizant of the timing and fund accordingly.