Corrective Action Plans

Finding: 2024-003 Material Weakness in Internal Control Over Allowable Costs/Cost Principles and Reporting – WIC Special Supplemental Nutrition Program for Women, Infants, and Children, and Immunization Cooperative Agreements (10.557, 93.268) Corrective Action: We will work to ensure that the proper indirect cost rate is applied to the various grants. Proposed Completion Date: February 28, 2026 Name of Contact Person: Tomiko Fisher, Chief Operating Officer

Finding: 2024-002 Material Weakness in Internal Control Over Period of Performance – Health Center Program, WIC Special Supplemental Nutrition Program for Women, Infants, and Children, and Immunization Cooperative Agreements (93.224, 10.557, 93.268) Corrective Action: The District is in the process of developing a comprehensive year-end closing checklist and has already streamlined many of the procedures that caused reconciliation issues. In addition, we will perform spot checks on transactions to ensure that payroll and nonpayroll expenditures are recorded in the proper period. We will also provide additional training to ensure that personnel only record expenditures when confirmation has been received of receipt of goods or services. Proposed Completion Date: February 28, 2026 Name of Contact Person: Tomiko Fisher, Chief Operating Officer

Finding: 2024-004 Material Weakness in Internal Control Over Special Tests – Health Center Program (93.224) Corrective Action: We will develop a checklist for patient discount documentation and implement a control requiring supervisor approval for overrides. We will also perform monthly file audits and report exceptions to the appropriate personnel. Proposed Completion Date: February 28, 2026 Name of Contact Person: Lane Baker, CHW Chief Operating Officer

2024-012 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: Based on the Commonwealth of Pennsylvania, Office of the Budget, Bureau of Audits (Commonwealth) review of CBS Food Program's financial accounting system, it was noted that the Food Program utilizes QuickBooks software for their accounting system. Based on inquiry with CBS Food Program management, we determined internal controls connected with their QuickBooks accounting software were insufficient in the following areas: • User Access Management: Formal written policies or procedures have not been developed and implemented related to access authorization, access monitoring, and removal of system access. Additionally, certain functions are not properly segregated as users have access to perform both input and authorization of transactions. • Input Management: Formal written policies or procedures to ensure information input into QuickBooks is appropriate and accurate have not been developed and implemented. • Change Control Management: A formal written change management policy for QuickBooks Accounting System has not been developed and implemented including requirements that system security updates are implemented timely. • Backup and Recovery: A formal written policy for regular backup and recovery testing has not been developed and implemented. Recommendation: We recommend that CBS Food Program develop and implement comprehensive written internal control policies and procedures connected with their QuickBooks Accounting System. This should include: • Development and utilization of an Accounting Manual which includes an outline of CBS Food Program's accounting rules, procedures, and guidelines. • Access control policies and procedures to ensure that user access to QuickBooks is appropriate, regularly reviewed and promptly revoked upon termination or when otherwise merited. Recommendation (Continued) • A formal written change management policy for QuickBooks should be developed and implemented including requirements that systems security updates are implemented timely. • A disaster recovery plan and procedures to perform periodic testing to ensure that plans are functional and mitigate the risk of extended downtime. This process should also include regular review of backup records to ensure they are appropriately created and maintained. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions does not dispute this finding. Community Benefit Solutions will migrate from Quickbooks Desktop to Quickbooks Online, which will provide a perfect transitional opportunity to re-evaluate processes, and to develop and implement necessary controls over its systems. Community Benefit Solutions will work with independent auditors, internal information technology team, and, if necessary, legal counsel to plan, draft, and implement the relevant internal controls. Planned completion date for corrective action plan: June 30, 2025

2024-011 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: Based on the Commonwealth of Pennsylvania, Office of the Budget, Bureau of Audits (Commonwealth) review of CBS Food Programs banking policies, it was noted that the CBS Food Program did not establish appropriate controls to ensure bank account access changes and bank account closures could be promptly completed when organizational or personnel changes merited such actions. CBS Food Program management noted two instances during the engagement period in which lack of cooperation from parties with CBS Food Program bank account authority or access prevented the Food Program from closing bank accounts in an expeditious manner. This resulted in the CBS Food Program simultaneously having bank accounts open at three different banks for a portion of the audit period. As of May 2025, CBS Food Program only actively banks with one institution. Of the accounts with the other institutions, one account is closed, and the other remains open, but inactive because CBS Food Program has not initiated any account-related activity for an extended period of time. According to CBS Food Program management, they are working to close the inactive account, but closure requires assistance from Congregation Beth Solomon which has not been cooperative. The Commonwealth noted that CBS Food Program has inefficient control procedures in place over the issuance of high-value checks. Following the separation of CBS Food Program's prior CEO, the Food Program opened a new bank account in order to remove the prior CEO's access to food program funds. The former CEO was not cooperative in removing his access to the bank account the Food Program used at the time of his separation, so CBS Food Program determined moving the Food Program's funds to a new bank was in the best interest of the organization. To move the Food Program's funds from the old bank to the new bank, CBS Food Program's Director of Finance wrote two checks for $1.5 million dollars each. While CBS Food Program's Director of Finance obtained approval from the board prior to preparing and depositing the checks in the new bank account, a secondary signature was not obtained as CBS Food Program policy did not require a second signature for any check regardless of amount. Recommendation: CBS Food Program should assign bank authorization and access roles to appropriate CBS representatives to ensure access is appropriately limited, but that changes to account authorization can be completed timely when organizational or personnel changes merit such modifications. CBS Food Program should establish, document, and adhere to, a policy requiring documented prior approval and dual signatures on checks exceeding a predetermined threshold set by management and/or the board of directors. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Planned completion date for corrective action plan: June 30, 2025 Action taken in response to finding: Community Benefit Solutions does not dispute this finding and provides the following for the purpose of additional clarification. Between February 14, 2024, and June 10, 2024, the departure of the Farmer CEO and several key Board members resulted in the absence of authorized signers. In order to expeditiously remove individuals from accessing bank funds during this transition, the Community Benefit Solutions Board of Directors granted the Accounting Associate authority to sign all relevant checks and take steps necessary to remove those individuals. Going forward, Community Benefit Solutions will, with the assistance of either Board-approved counsel or outside independent audit firm, develop and implement thresholds for dual signature requirements. Moreover, Community Benefit Solutions will work with JP Morgan Chase Bank to ensure that authorization and authority can be expeditiously amended in the event such a need arises.

2024-010 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: Based on interviews by the Commonwealth of Pennsylvania, Office of the Budget, Bureau of Audits (“Commonwealth”) with CBS Food program management, inspection of records, and on-site observations, we identified internal control deficiencies in the following areas: • For a portion of the audit period, there was a lack of segregation of duties between the cash receipt, bookkeeping, and bank reconciliation processes. The Director of Finance was responsible for all these tasks. The Director of Finance was also responsible for both processing and approving payroll and had authorization to make purchases, make vendor payments, record accounting transactions and complete bank reconciliations. • CBS Food Program performs bank reconciliations; however, they are not signed or dated by the individual performing the reconciliation and a second individual does not review or sign off on the reconciliations. Of nine reviewed account reconciliations, three were completed more than 30 days after the statement period end date. • According to CBS Food Program's former Purchasing Distribution Manager, as of June 2024, they were the only CBS Food Program's employees with detailed knowledge of developing monthly menus and creating purchase orders based on current inventory levels to meet menu requirements. Additionally, the former Purchasing Distribution Manager stated that as of June 2024 formal training on internal purchasing policies and procedures is not provided or required. Condition (Continued) • For a portion of the engagement period, CBS Food Program lacked written policies or procedures for several key business functions including: o No written Accounting Manual or Standard Operating Manual for accounting functions. o No written policy or procedure for the use of credit cards or the handling of lost or stolen credit cards. o No written policy or procedure to analyze account balances to ensure transactions have been properly recorded. o No written records retention policy. o No written procedures for handling payroll for separating employees. o No written or implemented review process for changes to the payroll system including changes to employee payrates. o For a portion of the engagement period, the Food Program did not have procedures to o Prior to July 1, 2024, CBS Food Program did not have documented procurement procedures. On July 1, 2024, CBS Food Program implemented a procurement plan. Recommendation: If not already addressed, CBS Food Program should develop and implement improved internal controls including: • Develop written policies, procedures and/or manuals for accounting functions. • Develop a formal internal control policy and framework that focuses on key business and operations areas including segregation of duties, transaction review and approval processes, and monitoring procedures over critical operational functions. • Improve cross training of employees including training on purchasing and accounting tasks. • CBS Food Program should develop and implement a record retention policy that complies with food program requirements for maintaining documentation of operations. The policy should ensure key records are maintained in a shared location accessible to all appropriate personnel. This ensures the CBS Food Program does not lose access to key records in the event an employee leaves the food program. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions will work with its outside independent audit firm, Board-approved counsel, and other necessary stakeholders to develop and implement all the necessary controls as required by the Comptroller. Community Benefit Solutions' implementation of any of the noted changes will be the ability to recruit Finance Committee and Nutrition Committee members of the Board. Moreover, Community Benefit Solutions made strides in implementing some of the requested policies during the Audit. Community Benefit Solutions will endeavor to meet each of the requests despite any lack of human capital that would allow for ease of segregation of authority. Community Benefit Solutions is optimistic that incoming Board Members and external accounting, audit, HR, and legal will provide critical support. Planned completion date for corrective action plan: June 30, 2025

2024-005 Material Weakness in Internal Control over Compliance 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: During our testing of participant eligibility, we selected a sample of 40 participants receiving meals at centers contracted with the CBS Food Program. For 2 of the 40 participants, management was unable to provide complete and valid eligibility documentation. In one instance, the only available eligibility form had been prepared in a future fiscal year, and in another instance, the eligibility form could not be located at all. Recommendation: We recommend that management strengthen its CACFP eligibility documentation procedures to ensure that all required forms are properly completed, collected, and retained for every participant. This should include implementing a standardized intake process, maintaining timely reviews to confirm completeness of eligibility files, and developing a tracking or monitoring system to identify missing or outdated documentation. Management should also reinforce internal expectations for timely updating of eligibility files and ensure staff are trained on CACFP documentation requirements. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: On February 1, 2025, Community Benefit Solutions rolled out the KidKare software system wide. KidKare is a CACFP software that allows Community Benefit Solutions to digitally process all eligibility-documentation, standardize the enrollment procedures, ensure forms are completed in accordance with the relevant regulations, request updated documentation upon the expiration of enrollment forms, and digitally store all the eligibility related information for all participants. Planned completion date for corrective action plan: June 30, 2025

2024-004 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition As part of our audit procedures, we selected a sample of 40 payroll transactions for review. This process included examination of employee human resource files (such as signed W-4 and I-9 forms), management-approved pay rates, time sheets with supervisory sign-off, and corresponding payroll reports. We recalculated total hours per timesheet using the employees' pay rates and compared these figures to the relevant payroll reports. During our review, we observed that two employees received additional compensation ranging from $25 to $75 for undertaking extra responsibilities related to the administration of the CBS Food Program’s Summer Food Service Program by the former Chief Executive Officer. Management was unable to provide supporting documentation evidencing approval by the former Chief Executive Officer or confirmation from the Commonwealth of Pennsylvania, Department of Education, indicating that such additional compensation complied with the contractual agreement governing the Summer Food Service Program. Additionally, of the 40 payroll transactions sampled, we noted one employee’s required payroll change documentation (e.g., an approved payroll change form) was not present in their personnel file. Recommendation We recommend that management improve internal controls for payroll authorization by making sure every payroll change form and supplemental compensation approval is filled out, approved, and kept on file. Introducing a central electronic document management system will help securely store records, standardize documentation, and create clear audit trails for all payroll and personnel files. Management should also regularly review payroll records to confirm that all necessary paperwork, such as personnel forms, pay rate approvals, and backup for extra pay, is included. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions repeats the actions to be taken in response to finding 2024-003 and adds the following: Community Benefit Solutions will utilize ADP document management capabilities to maintain employee files including, but not limited to, Payroll Change Forms or other documentation related to modifications or supplements to employee pay. Community Benefit Solutions will ensure complete upload of all paper files to the appropriate employee profile within ADP to ensure documentation can be readily accessible by those with necessary authorization. Planned completion date for corrective action plan: June 30, 2025

2024-008 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: As part of the reporting requirements for the CBS Food Program under the National School Lunch Program (NSLP) and Summer Food Service Program (SFSP), management is responsible for submitting the FNS 10 (NSLP) and FNS 418 (SFSP) reports within 30 days after month-end. However, management was unable to provide five (5) monthly NSLP reports and one (1) monthly SFSP report requested for audit testing. Recommendation: The Organization should establish and enforce strengthened internal controls over federal reporting to ensure that all required monthly reports (FNS 10 and FNS 418) are: (a) completed accurately, (b) submitted on time, and (c) retained in accordance with federal record retention requirements (2 CFR 200.334). Management should designate responsible personnel and implement a monitoring process to ensure compliance. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Effective, July 1, 2024, Community Benefit Solutions no longer administers the National School Lunch Program. In the event Community Benefit Solutions should begin administering the NSLP, Community Benefit Solutions will develop and implement requisite policies and procedures to ensure proper reporting requirements including, but not limited to, completion and submission of the FNS10. Planned completion date for corrective action plan: June 30, 2025

Management Response The owner/manager of the building, St. Philip the Evangelist Episcopal Church, occupied by St. Philip’s Child Development Center (the Center) declared bankruptcy and ceased operating in November 2024. Maintenance on building systems and its structures had been deferred for several years. On July 27, 2025, the building experienced a roof leak causing a catastrophic flood. The building was evacuated and the Office of State Superintendent (OSSE) notified. OSSE sent an inspector to the site the following day who declared the building unsafe for occupancy. The Church was unable to cover any costs for the necessary repairs. On July 30, 2025 the Board of Directors made the difficult decision to suspend operations, but to continue as a Board, maintain the Center’s 501(c)3 status and its corporate registration. Furthermore, the Board is using this time to research current community needs, space availability and cost, and the effect of the Federal government’s waning support for early childhood education. Once this exercise is complete, the Board will determine the Center’s ability to reopen in an alternate site and address the findings in an appropriate manner.

Management Response The owner/manager of the building, St. Philip the Evangelist Episcopal Church, occupied by St. Philip’s Child Development Center (the Center) declared bankruptcy and ceased operating in November 2024. Maintenance on building systems and its structures had been deferred for several years. On July 27, 2025, the building experienced a roof leak causing a catastrophic flood. The building was evacuated and the Office of State Superintendent (OSSE) notified. OSSE sent an inspector to the site the following day who declared the building unsafe for occupancy. The Church was unable to cover any costs for the necessary repairs. On July 30, 2025 the Board of Directors made the difficult decision to suspend operations, but to continue as a Board, maintain the Center’s 501(c)3 status and its corporate registration. Furthermore, the Board is using this time to research current community needs, space availability and cost, and the effect of the Federal government’s waning support for early childhood education. Once this exercise is complete, the Board will determine the Center’s ability to reopen in an alternate site and address the findings in an appropriate manner.

The County will work diligently to implement internal controls over its federal award program to ensure accurate reporting of any activity.

FINDING 2024-016 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation in the form of dated expenditure reports for all federal grant reimbursements and for the final expenditure reports. The Business Office will implement a system of internal control and review where after each month is reconciled and closed the Federal Grants Administrator will review the program expenditures ensuring they are correctly posted prior to filing the reimbursements. All reimbursements will be reviewed and signed off on by the Federal Grants Administrator and an additional reviewer prior to submission for reimbursement. In addition, the final expenditure reports will be reviewed and signed off on by Grants Administrator and an additional reviewer prior to submission. Anticipated Completion Date: The school district began the practice above on January 1, 2024, and anticipate it will be completed by June 30, 2026.

FINDING 2024-014 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation in the form of dated expenditure reports for all federal grant reimbursements and for the final expenditure reports. The Business Office will implement a system of internal control and review where after each month is reconciled and closed, the Federal Grants Administrator will review the program expenditures, ensuring they are correctly posted prior to filing the reimbursements. All reimbursements will be reviewed and signed off on by the Federal Grants Administrator and an additional reviewer prior to submission for reimbursement. In addition, the final expenditure reports will be reviewed and signed off on by Grants Administrator and an additional reviewer prior to submission. Anticipated Completion Date: The school district began the practice above on January 1, 2024, and anticipate it will be completed by June 30, 2026.

FINDING 2024-013 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation of the nonpublic schools’ rosters with supporting poverty documentation in the form of free and reduced meal applications saved on file with the Title I application annually. Anticipated Completion Date: The school district began the practice above for the 2023-24 school year. The school district has supporting documentation of free and reduced lunch status for nonpublic school students for the 2023-24 school year and moving forward. This corrective action will be fully completed by June 30, 2026.

FINDING 2024-007 Finding Subject: Special Education Cluster (IDEA) - Cash Management Contact Person Responsible for Corrective Action: Susie Swango, Director of Special Education Contact Phone Number and Email Address: swangos@nlcs.k12.in.us (812) 277-3220 ext. 16243 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Business office has worked with the Director of Special Education to create a system of internal control and review where after each month is reconciled and closed the Director of Special Education reviews the program expenditures ensuring they are correctly posted prior to filing for reimbursements. The Business Office will then notify the Director of Special Education when reimbursements for their funds are received and the Director can check that the deposit has been posted correctly. Proper expenditure and receipt documentation will be kept on hand for each reimbursement submitted. Anticipated Completion Date: June 30, 2026

FINDING 2024-005 Finding Subject: CHILD NUTRITION CLUSTER - SPECIAL TESTS AND PROVISIONS, PAID LUNCH EQUITY Contact Person Responsible for Corrective Action: BONNIE SANDERS, Director of Food Services Contact Phone Number and Email Address: Sandersb@nlcs.k12.in.us (812) 277-3220 ext. 48014 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Paid Lunch Equity requirements and calculations (including PLE exemptions) will be calculated and completed by the Food Service Director and will then be reviewed and signed off on by the Business Director. Any additional information requested by the Business Director will be provided to the Business Director in a timely manner for use in determining the accuracy and completeness of the PLE document. Anticipated Completion Date: Immediately (December 1, 2025)

Recommendation: Block grant reports should be completed prior to the accounting record close process to ensure the expenditures reported are supported by the underlying accounting records. Controls over reporting should include records for the basis of reporting submissions should be reviewed as part of the report approval process prior to submission. Supporting documentation and reconciliations should be filed for reference purposes. Action Taken: The Department of Human Services received approval from the PA DHS in February 2025 for its 2021–2022 HSBG Income & Expenditure (I&E) Report, Revision 3, which had been submitted in January 2025. At the State’s request, the Agreed Upon Procedures report was submitted in August 2025 for fiscal year 2021-2022 and has since been approved. The journal entries reconciling the underlying expenditure detail in the County’s accounting system to the expenditures reported have been submitted, and the final reconciliation is in process. Retained Earnings Plans were submitted to the State in February and March 2024. The County completed submission of the 2022–2023 HSBG I&E Report in March 2025, with a revised version submitted in September 2025. The State is currently reviewing the report. Upon approval, the AUP will be completed, and the County will reconcile the detailed expenditures in the accounting system to the amounts reported, ensuring accuracy and compliance. The 2023–2024 HSBG I&E Report was submitted in September 2025. The County is finalizing the 2024–2025 HSBG I&E Report and anticipates submission by October 2025. Responsible Individual for Corrective Action: Gaston Gonzalez, County of Delaware Department of Human Services Chief Financial Officer Completion Date: December 31, 2025

F A 2O24-OO3 Strengthen Controls over Financial Reporting Compliance Requirement: Reporting lnternal Control lmpact: Material Weakness Compliance lmpact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education CFDA Numbers and Titles: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: S0104220010 (Year:2023), S010A230010 (Year.2024) Questioned Costs: $0.00 Repeat of Prior Year Finding: FA 2023-004, FA 2022-004, FA 2021-002, FA 2019-002 Description: The School District did not file accurate completion reports for the Title I Grants to Local Educational Agencies program. Corrective Action Plans: . CFO will make sure expenditures are correctly recognized on all completion reports . An independent CPA person has been hired and review completion reports before they are submitted Estimated Completion Date: Decembet 31, 2025 Contact Person:Torrence H. Freeman lll. CFO Telephone: 706-665-8577 Email:tfreeman@talbot.kl2 aus

Federal Agency: US Department of Education Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing No.: 84.063; 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reporting timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will resolve issues within 10 days of receiving notification. Name(s) of the contact person(s) responsible for corrective action: Yolanda Benson, Registrar Planned completion date for corrective action plan: July 1, 2026

Material Weakness in Internal Controls over Compliance Condition: The Schools’ files did not include documentation of pre-approval for the purchase and installation of alarm systems and security cameras. Corrective Action Planned: The District is in the process of implementing a standardized checklist and updated purchasing controls to ensure all federally funded equipment and facility-related purchases are properly documented before procurement. Relevant staff have been informed of the requirement, and no purchase orders for such items will be released without the required approvals. Anticipated Completion Date: March 31, 2026 Contact: Liz Latoria, School Director of Finance and Operations

2024-004 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2024. Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit “in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.” 34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…” Condition: The College did not correctly report enrollment status changes for 15 out of 40 students tested (37.5%). We consider this condition to be a material weakness of the Special Tests and Provisions compliance requirement and is a repeated finding shown in Section IV of this report as prior year finding 2023-007. Statistical sampling was not used in making sampling selections. Responsible Person: Director of Financial Aid and Veteran Affairs, Director of Admission and Registration, and Administrative Information Systems (AIS) Corrective Action Plan: Richland Community College adjusted our internal procedures to send enrollment reporting files on a monthly basis instead of a semester basis during the Fall 2022 semester; however, issues still persist. At the time, the Registrar routinely worked with the Administrative Information Systems (AIS) Department and the National Student Clearinghouse to identify the issues related to enrollment reporting. The responsible parties listed above will conduct a review of current enrollment reporting workflows to ensure consistent and timely updates. The responsible parties listed above will explore improvements in automation through the utilization of the National Student Clearinghouse and a campus-wise transition to the Jenzabar One platform to assist with timeliness and accuracy of reporting. Jenzabar One transition is scheduled to be completed by the end of March 2026. Due to transition in staffing, the responsible parties listed above will provide targeted training on NSLDS enrollment reporting requirements, including the expectations of timeliness and accuracy. The responsible parties will develop a secondary review to identify missed or delayed updates and take corrective action promptly. Implementation Date: As soon as possible since enrollment reporting is completed on a monthly basis.

EDUCATION STABILIZATION FUND – ALLOWABLE COSTS U.S. Department of Education Education Stabilization Fund Assistance Listing Number: 84.425 Passed Through Minnesota Department of Education Pass Through Number: S425U220045 Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend the District puts in place proper controls to ensure supporting documentation for timesheets is retained for all employees Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on ensuring proper controls are put in place. This will be implemented by December 31, 2025, and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

SPECIAL EDUCATION CLUSTER – SUSPENSION AND DEBARMENT U.S. Department of Education Special Education Cluster Assistance Listing Number: 84.027 & 84.173 Passed Through Minnesota Department of Education Pass Through Number: H027A220087 Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend the District formalizes their suspension & debarment procedures in a policy and ensure they check suspension & debarment for all vendors prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all of the personnel involved in the procurement processes to ensure the compliance requirements are fully understood and a proper review of all procurements and procurement methods will be performed. This will be implemented by December 31, 2025 and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

CHILD NUTRITION CLUSTER – REPORTING U.S. Department of Agriculture Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Passed Through Minnesota Department of Education Pass Through Number: 10.CNC Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend that the district ensures all changes and adjustments are communicated to the accountant who performs claim submissions. When the Nutrition Service Assistant Director’s review results in additional adjustments within PrimeroEdge, the District should only make those changes before the CLiCs cutoff date to prevent differences between client records in PrimeroEdge and CLICS reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all of the personnel involved in the reporting processes to ensure the compliance requirements are fully understood and a proper review of all reporting methods will be performed. This will be implemented by December 31, 2025, and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025