Corrective Action Plans

Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card/High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card/High School Graduation Rate Audit Finding: Material Weakness Condition: An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The School Corporation must report graduation rate data for all public high schools within the corporation using the four-year adjusted cohort rate. To remove a student from the cohort, the School Corporation must confirm the reason for removal in writing. Additionally, required documentation for each removal type must be retained by the School Corporation. Context: The School Corporation had not established internal controls to ensure required documentation to support the reason for a student's removal from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. For three of the eight students tested, the School Corporation was unable to provide documentation to support the removal of the student from the graduation cohort. Corrective Action Plan: The Head Secretary at Rochester High School will document any student that is removed from the high school graduation cohort. The secretary will have the high school principal review and approve this documentation, and the secretary will place in the student’s permanent file. Person responsible for implementation and projected implementation date: The secretary and the high school principal will be responsible for overseeing the implementation of the corrective action plan, which will start in April 2025.

Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition: An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of eligibility, we noted three out of 25 eligibility samples that were reported as free or reduced socioeconomic status to the Indiana Department of Education in the October 2022 data exchange count, but supporting documentation supported these students as a paid status. These three students should not have been reported as free or reduced socioeconomic status. Corrective Action Plan: The School Corporation will establish a system of internal controls to review the applications submitted for free or reduced socioeconomic status to ensure the students are classified correctly within the system. The School Corporation will ensure that applications are signed off on as reviewed after the review has taken place. Person responsible for implementation and projected implementation date: In cooperation with the Food Service Director, the Curriculum Director and Business Manager will be responsible for overseeing the implementation of the corrective action plan which will be implemented with the applications for the 2025-2026 school year. This has already been implemented with the Food Service Director and records maintained in her office.

Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Context: We noted that for 11 payroll claims in a sample of 60, the School Corporation was not able to provide semi-annual certifications or support that the personnel were approved to be paid with Title I funds. Corrective Action Plan: The School Corporation will implement internal control procedures to ensure semi-annual certifications or other forms of support are maintained to certify employees are approved to be paid with Title I funds. Person responsible for implementation and projected implementation date: The Curriculum Director and Business Manager will oversee the implementation of the corrective action plan, which will be implemented immediately. The CD has already implemented the requirements of certifications beginning August 1, 2025 and are on file in the Title I records.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) State Agency: NH Department of Safety, Division of Homeland Security and Emergency Management Audit Contact: Austin Brown Title: Chief of Mitigation and Recovery Telephone: 602-271-2231 E-mail address: NHPA@dos.nh.gov Audit Report Reference: 2024-033 - Reporting Anticipated Completion Date: April 30, 2025 Corrective Action Planned: HSEM concurs with this finding. During the single audit that we participated in last year, it was identified that the programmatic award letter was lacking necessary information. That award letter was updated April/May 2024 to include information as outlined in 2 CFR section 200.332. It is our belief that no further corrective action is necessary by programmatic staff. A copy of the award letter template and award notification fact sheet are attached to this response. The award notification fact sheet was updated in March 2025. It is sent via email upon award notification and is also available on our website. Regarding the review of subrecipient Uniform Guidance reports, we will conduct a comprehensive review and update of the existing Quick Reference Guide to ensure full compliance. Enhancements to the guide will include, at a minimum, clear procedures for programmatic staff on addressing audit findings identified by subrecipients and issuing management decision letters to obtain corrective action plans. Additionally, a structured review process will be implemented for programmatic supervisors to verify the completeness and accuracy of the updated procedures within the guide. Programmatic supervisors responsible for these reviews were informed of this process change on March 11, 2025. Upon completion of the review and update, remedial training will be provided to programmatic staff no later than April 15, 2025, ensuring alignment with the revised procedures.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) State Agency: NH Department of Safety, Division of Homeland Security and Emergency Management Audit Contact: Matthew Hotchkiss and Austin Brown Telephone: 602-271-2231 E-mail address: Matthew.A.Hotchkiss@dos.nh.gov and NHPA@dos.nh.gov Audit Report Reference: 2024-032, 2023-021 Special Tests and Provisions - Project Accounting Anticipated Completion Date: April 30, 2025 Corrective Action Planned: HSEM concurs with finding 001-A. This issue was discovered during FEMA’s financial monitoring site visit in March 2024. To resolve this issue, HSEM drafted a Delegation of Authority letter which was filed with FEMA in November 2024. A copy of the DOA is attached to this response and was supplied to KPMG during the audit. The control and review concern of this issue was previously addressed by establishing a review process between the Accountant IV, Administrator II, and the Deputy Director prior to the submittal of all 425s. These controls were in place during the audit period but were not documented. Please note that inaccuracies were not found during the audit on the filed 425 reports. In the future, HSEM will ensure that the review process is documented. HSEM concurs with Finding 001-B and is taking immediate action to review and strengthen its procedures regarding FFATA filing. As of March 8, the Federal FFATA filing process has shifted to SAM.gov for report submissions. In response, HSEM is swiftly updating its internal procedures to guarantee the timely and accurate filing of FFATA reports. These updates will be incorporated into a comprehensive Quick Reference Guide, designed to provide programmatic staff with clear, efficient instructions for completing reports. Additionally, a robust review process will be instituted for programmatic supervisors to ensure strict adherence to the updated procedures. Programmatic supervisors, who will be responsible for conducting these reviews, were informed of the required process change on March 11, 2025. To ensure a smooth transition and full compliance, remedial training will be provided to all programmatic staff upon completion of the Quick Reference Guide review and update, no later than April 15, 2025.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 96.001 Social Security, Disability Insurance State Agency: Education Department Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Reference: 2024-030, 2023-019 - Reporting Anticipated Completion Date: June 30, 2025 Corrective Action Planned: We have updated our processes as demonstrated with the boxes on line 7 being checked on the newer reports and will continue to follow this action on all future reports. NH SSDI will update/develop procedures for fiscal reporting. Spreadsheets used to create federal reports will be updated to clearly link information used and will be locked and saved as supporting documentation. Additionally, the NH SSDI will update its internal controls to include a second review and approval of all federal reports.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 93.959 Substance Abuse Prevention and Treatment Block Grant State Agency: Department of Health and Human Services (DHHS) Audit Contact: Hannah Glines and Melissa Kelleher Title: Revenue Director and Grants Administrator of Bureau of Contracts and Procurement Telephone: 603-271-5052 and 603-271-9637 E-mail address: Hannah.J.Glines@dhhs.nh.gov, Melissa.J.Kelleher@dhhs.nh.gov Audit Report Reference: 2024-029 - FFATA Completion Date: 09/30/2025 Corrective Action Planned: FFATA procedures will be reviewed and strengthened to ensure adequate controls are in place. This will include training other members of the federal reporting staff so that there is sufficient separation of duties for preparation, review, approval, and timely submittal of the reports. The contracts were all in process prior to the April 4, 2022, inception of the UEI, and had been prepared with the DUNS number. However, the appropriate UEI was obtained to perform the required FFATA reporting requirements using SAM.GOV.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 93.778 Opioid STR State Agency: Department of Health and Human Services (DHHS) Audit Contact: Hannah Glines Title: Revenue Director Telephone: 603-271-9043 E-mail address: Hannah.J.Glines@dhhs.nh.gov Audit Report Reference: 2024-027 – FFATA Anticipated Completion Date: September 30, 2025 Corrective Action Planned: FFATA procedures will be reviewed and strengthened to ensure adequate controls are in place. This will include training other members of the federal reporting staff so that there is sufficient separation of duties for preparation, review, approval, and timely submittal of the reports

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 CCDF Cluster (ALN #93.489, #93.575, #93.596) and COVID-19 Cluster (ALN #93.489, #93.575, #93.596) State Agency: Department of Health and Human Services (DHHS) Audit Contact: Hannah Glines and Melissa Kelleher Title: Revenue Director and Grants Administrator of Bureau of Contracts and Procurement Telephone: 603-271-9043 and 603-271-9637 E-mail address: Hannah.J.Glines@dhhs.nh.gov and Melissa.J.Kelleher@dhhs.nh.gov Audit Report Reference: 2024-024 – Reporting - FFATA Anticipated Completion Date: September 30, 2025 Corrective Action Planned: FFATA procedures will be reviewed and strengthened to ensure adequate controls are in place. This will include training other members of the federal reporting staff so that there is sufficient separation of duties for preparation, review, approval, and timely submittal of the reports. The contracts were all in process prior to the April 4, 2022, inception of the UEI, and had been prepared with the DUNS number. However, the appropriate UEI was obtained to perform the required FFATA reporting requirements using SAM.GOV.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 93.568 Low-Income Home Energy Assistance State Agency: Department of Energy Audit Contact: Leonard Rautio Title: Chief of Operations Telephone: (603) 271-6008 E-mail address: leonard.j.rautio1@energy.nh.gov Audit Report Reference: 2024-022, 2023-016, 2022-026, 2021-028, 2021-029 - Reporting Anticipated Completion Date: Complete Corrective Action Planned: Concur The Department has implemented processes and updated procedures to mitigate late reporting or insufficient back-up data since the last finding. These processes have been implemented and personnel trained on the new procedures.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) State Agency: Department of Health and Human Services (DHHS) Audit Contact: Richelle Swanson, Hannah Glines and Melissa Kelleher Title: DPHS Finance Director, Revenue Director and Administrator of Bureau of Contracts and Procurement Telephone: 603-271-4613, 603-271-9043 and 603-9637 E-mail address: Richelle.R.Swanson@dhhs.nh.gov , Hannah.J.Glines@dhhs.nh.gov and Melissa.J.Kelleher@dhhs.nh.gov Audit Report Reference: 2024-019, 2023-010 - Reporting Anticipated Completion Date: September 30, 2025 Corrective Action Planned: The reporting system’s information is retained on a year-to-date basis, erasing the prior amount and replacing it with the updated total. We have implemented a process to obtain the information needed to verify that the unliquidated obligation for the requested reporting period was properly reported. FFATA procedures will be reviewed and strengthened to ensure adequate controls are in place. This will include training other members of the federal reporting staff so that there is sufficient separation of duties for preparation, review, approval, and timely submittal of the reports. The contracts were all in process prior to the April 4, 2022, inception of the UEI, and had been prepared with the DUNS number. However, the appropriate UEI was obtained to perform the required FFATA reporting requirements using SAM.GOV.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 93.268 Immunization Cooperative Agreements and 93.268 COVID-19 Immunization Cooperative Agreements State Agency: Department of Health and Human Services (DHHS) Audit Contact: Hannah Glines and Melissa Kelleher Title: Revenue Director and Grants Administrator of Bureau of Contracts and Procurement Telephone: 603-271-9043 and 603-271-9637 E-mail address: Hannah.J.Glines@dhhs.nh.gov and Melissa.J.Kelleher@dhhs.nh.gov Audit Report Reference: 2024-018 – Reporting - FFATA Anticipated Completion Date: September 30, 2025 Corrective Action Planned: FFATA procedures will be reviewed and strengthened to ensure adequate controls are in place. This will include training other members of the federal reporting staff so that there is sufficient separation of duties for preparation, review, approval, and timely submittal of the reports. The contracts were all in process prior to the April 4, 2022, inception of the UEI, and had been prepared with the DUNS number. However, the appropriate UEI was obtained to perform the required FFATA reporting requirements using SAM.GOV.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 93.044, 93.045, 93.053 Aging Cluster State Agency: Department of Health and Human Services (DHHS) Audit Contact: Kyra Leonard Title: DBH & DLTSS Finance Director Telephone: 603-271-5052 E-mail address: Kyra.C.Leonard@dhhs.nh.gov Audit Report Reference: 2024-016 - Activities Allowed or Unallowed/Allowable Costs/Costs Principles Anticipated Completion Date: June 30, 2025 Corrective Action Planned: The Department recognizes the business rules currently in place in the Options Electronic Billing and Service Authorization Maintenance System does not necessitate certain allowability approvals before the expenses are submitted through NHFirst for payment. The Department will turn off the automatic interface between Options and NHFirst in order to review the expenses before payment is issued. The Department will implement the typical invoice review process based on reporting from the Options, including a checklist that will specify each procedure and include a date that it was completed on. Then the approved output will be entered into NHFirst for payment.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 93.044, 93.045, 93.053 Aging Cluster State Agency: Department of Health and Human Services (DHHS) Audit Contact: Hannah Glines and Melissa Kelleher Title: Revenue Director and Grants Administrator of Bureau of Contracts and Procurement Telephone: 603-271-5052 and 603-271-9637 E-mail address: Hannah.J.Glines@dhhs.nh.gov, Melissa.J.Kelleher@dhhs.nh.gov Audit Report Reference: 2024-015 – FFATA Reporting Anticipated Completion Date: September 30, 2025 Corrective Action Planned: FFATA procedures will be reviewed and strengthened to ensure adequate controls are in place. This will include training other members of the federal reporting staff so that there is sufficient separation of duties for preparation, review, approval, and timely submittal of the reports. The contracts were all in process prior to the April 4, 2022, inception of the UEI, and had been prepared with the DUNS number. However, the appropriate UEI was obtained to perform the required FFATA reporting requirements using SAM.GOV.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 84.425 COVID-19 Education Stabilization Fund State Agency: Education Department (ED) Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Reference: 2024-014, 2023-008; 2022-013, 2022-016; 2021-013, 2021-015 - Reporting Anticipated Completion Date: 06/30/2025 Corrective Action Planned: The NHED concurs with this finding. We acknowledge these discrepancies with a note regarding section b and c. These discrepancies are associated with ESSER III and not ESSER II. The lack of documentation is due to employee turnover. Locating documentation was a challenge for the ESSER Reporting. We are currently reviewing the FY24 reports and making corrections. The corrected ESSER Recipient Data Collection Form will be updated and refiled during the Year 4 re-open period on 7/28/2025. Documentation will be centrally located in the common drive clearly marked. The review process will be well documented with completed sign-off documentation to confirm reconciliation between the GMS system and NH First, the financial system of record.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 84.425 COVID-19 Education Stabilization Fund - FFATA State Agency: Education Department (ED) Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Reference: 2024-013; 2023-008; 2022-013, 2022-016; 2021-013, 2021-015 - FFATA Reporting Anticipated Completion Date: 06/30/2025 Corrective Action Planned: The NHED concurs with this finding. The FFATA reporting procedure was redefined last year with updates to the GMS system implemented. GMS was updated to issue the GAN upon initial allocation instead of upon first approval of activities in the system. There were a few grants where the initial allocation was uploaded into GMS in 2021 with the first approval of activities completed after the GMS update. The GAN for these few grants was not created due to the change in procedure. Through the reconciliation process, these issues were identified and GANs were created later than anticipated. Moving forward, this will not be an issue as this was a limited transition period.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 21.029 Coronavirus Capital Project Funds State Agency: Department of Business and Economic Affairs (BEA) Audit Contact: Kathy Fredericksen Title: Administrator III Telephone: (603) 271-0260 E-mail address: Kathleen.C.Fredericksen@livefree.nh.gov Audit Report Reference: 2024-012 and 2023-006 - Reporting Anticipated Completion Date: No Later than 6/30/2025 Corrective Action Planned: In response to a similar finding in the 2023 audit, the Department modified reporting procedures to strengthen the precision of the reconciliation of reporting data to the Capital Project Fund dashboard. These changes were made prior to the end of the audit period but after the September 30th reporting cycle. Accordingly, the Department would note the application of audit procedures to the June 30, 2024, report did not identify similar errors. Regarding the tracking and reporting of actual total miles of fiber deployed and actual total locations; the Department would note Federal guidance documents state actual miles are not required to be reported until a project is completed. The “Coronavirus Capital Projects Fund: States, Territories, and Freely Associated States Project and Expenditure Report User Guide” (updated 12/20/2024) specifically instructs recipients to “Input the total miles of fiber planned to be deployed by the project” and “Provide the number of locations the project plans expect to serve”. Both of these instructions are accompanied by a notation stating actual amounts should be reported for projects marked as complete. The Department will take measures to ensure, upon project completion, reporting elements will be updated to reflect actual miles of fiber and locations served as per guidance. In doing so, and recognizing the unique characteristics of these reporting elements, the Department will take measures to obtain support sufficient to ensure the reported data elements are accurate. The Department is also taking measures during the active project period to review progress and expenditure allowability at project milestones, ensuring sufficient support and project progress.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 WIOA Cluster (Assistance Listing #17.258, #17.259, #17.278) State Agency: Department of Business and Economic Affairs Audit Contact: Kathy Fredericksen Title: Administrator III Telephone: (603) 271-0260 E-mail address: Kathleen.C.Fredericksen@livefree.nh.gov Audit Report Reference: 2024-009 - Reporting Anticipated Completion Date: No Later than 6/30/2025 Condition: Federal Financial Accountability and Transparency Act (FFATA) reports during the fiscal year ending June 30, 2024, were not filed in compliance with the Transparency Act related to WIOA programs. View of Responsible Officials: BEA concurs with the audit finding and has an anticipated completion date to the corrective action plan of June 30, 2025. Corrective Action Planned: BEA will evaluate polices & procedures as well as existing internal controls in place to ensure that the precision level of the control is such that it would detect an error in the reporting requirements in comparison to reports required to be filed versus filed and that all documentation used to support the data reported on the federal report(s) are properly maintained. Furthermore, BEA will enhance policies and procedures and re-implement to include internal controls ensuring all FFATA reports are submitted in compliance with the Transparency Act reporting requirements. BEA will ensure staff attends appropriate compliance trainings.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 12.401 National Guard Military Operations and Maintenance (O&M) Projects State Agency: Department of Military Affairs and Veterans Services (DMAVS) Audit Contact: Judy Chen Title: Administrator Telephone: 603-225-1366 E-mail address: ying.q.chen@DMAVS.nh.gov Audit Report Reference: 2024-004, 2023-003 – Cash Management Anticipated Completion Date: None Corrective Action Planned: Non Concur With regard to the segregation of duties, the SF-270 is a required form that DMAVS submits to the National Guard Appendix Program Manager for reimbursement with all back up documentation. The National Guard Appendix Program Manager, National Guard Grants Officer Representative, and National Guard United States Property Fiscal Officer (USPFO)/controller located in Concord, NH review, sign and submit the form to the Department of Defense on behalf of DMAVS to request the cash draw. Prior to the submission of reimbursement of any funds, each billing and invoice is reviewed, entered into a ledger and reconciled by three members of the accounting team. Once reconciled, the SF-270 is prepared and signed by the Financial Administrator. The SF-270 is then submitted to the appendix program manager for concurrence and then to the federal fiscal agent (USPFO) for approval. No funds are drawn down until approved by the USPFO. If this is not a satisfactory level of review, the department will request a new position to ensure that there the business function has the proper level of staffing to meet the requirements for segregation of duties.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 12.401 National Guard Military Operations and Maintenance (O&M) Projects State Agency: Department of Military Affairs and Veterans Services (DMAVS) Audit Contact: Judy Chen Title: Administrator Telephone: 603-225-1366 E-mail address: ying.q.chen@DMAVS.nh.gov Audit Report Reference: 2024-003, 2023-002 – Reporting Anticipated Completion Date: None Corrective Action Planned: Non Concur This requires the Department to create a redundant manual ledger that duplicates the function of the current ledger and DTR. This is not an efficient use of time or personnel. DMAVS has existing policies and procedures in place to track all federal funds, state funds and mixed funds, and uses spreadsheets for all transactions that reconciles every month to NH First Detail Transaction Register (DTR), Federal Fund tracking sheet, and Federal reimbursement tracking sheet with backup documents. The tracking sheet for the federal register is not intended to account for the state share of billing. The state share is accurately accounted for in the DTR, the cumulative accounting in the SF-270 and associated back up documentation. Supporting documentation to substantiate the accuracy of lines a, c, e, and f is in the DTR, the cumulative accounting of each SF-270, the supporting documentation sent with the billing to the Federal Government, and Year-end Agency Report for Federal Awards. This includes reconciliation and analysis of SADB expenditures and revenues to the Statement of Appropriations by each Program Accounting Unit. The SF-270 form is continuous cumulative data that starts Oct 1st and runs through the end of that Federal Fiscal Year. The SF-270 is the required federal form DMAVS submits to the Federal National Guard Appendix Program Manager for reimbursement. Back up documentation is submitted with the SF-270. The National Guard Appendix Program Manager, National Guard Grants Officer Representative, and National Guard United States Property Fiscal Officer (USPFO)/controller located in Concord, NH review, sign and submit the form to the Department of Defense to affect the cash draw. DMAVS does not unilaterally make cash draws to the federal government. The USPFO, who is substantially involved provides an independent review and reconciles any discrepancies prior to approving any requests for reimbursement. One possible explanation for the finding is that the selected test works were not continuous, nor did they account for cumulative data.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 10.553/10.555/10.556/10.559 Child Nutrition Cluster State Agency: Education Department Audit Contact: Lindsey Labonville Title: Administrator IV Telephone: 603.731.4621 E-mail address: Lindsey.L.Labonville@doe.nh.gov Audit Report Reference: 2024-002 - Child Nutrition Cluster Finding Anticipated Completion Date: June 30, 2025 Corrective Action Planned: The NHED concurs with this finding. NHED contacted the US Department of Agriculture (USDA) for information on FFATA reporting requirements for state education agencies. The contact at USDA, Suzanne Dagesse, responded on February 6, 2024, that they were not aware of the requirement, and that this requirement has never been communicated to the NHED Office of Food & Nutrition Programs, by USDA. NHED has had annual reviews conducted by USDA of the programs administered and this requirement has never been communicated. NHED will add the food and nutrition programs to the established FFATA process already implemented to ensure that amounts to subrecipients are tracked and that all first tier subawards of $30,000 or more are reported in accordance with FFATA.

II. Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material weakness): We observed the following conditions in connection with our testing of the TRIO programs: (a) UB Eligibility Test: Of the 17 students selected for testing, one (1) student’s citizenship could not be determined, two (2) students did not provide any income information on the application, ten (10) students did not provide tax returns to verify low income as reported. (b) ETS Eligibility Test: Of the 17 students selected for testing, seven (7) students' citizenship status could not be determined, documentation to support enrollment status was not provided for 17 students, one (1) student did not have any information uploaded, and one (1) student has a birthdate discrepancy. (c) Educational Opportunity Center (EOC) Eligibility Test: Of the 17 participants selected for EOC testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents uploaded to adequately test the attributes, and one (1) student did not have a signature page for the EOC application. Auditor's Recommendation – We recommend the College ensure that all required documentation is submitted prior to determining the participants' eligibility. Corrective Action – Tougaloo College Administration understands the importance of federal compliance. The Vice President for Strategic Initiatives & Social Justice has direct management oversight of the TRIO programs. The lack of internal controls related to UB Eligibility Test, ETS Eligibility Test, and EOC Eligibility Test (verification of citizenship, income information, tax refunds, documentation of enrollment status, enrollment agreement, and birthdate verification), a non-recurring finding, were largely caused by a high degree of staff turnover and lack of experience in the front-line staff directly responsible for these controls. Although it has proven difficult to hire and retain highly qualified staff due to higher salaries paid by other institutions for similar positions in our market, the Executive Director of the TRIO programs and leadership team has implemented the following actions to correct the findings: 1. Continue to recruit and develop internal protocols to more fully retain highly qualified personnel. 2. Continue to train staff and increase staff training specific to reviewing the proper documentation required for attending the programs. 3. Include an additional level of early review by the Executive Director and other senior program staff to verify compliance at multiple stages of program involvement by students, including when students are initially recruited and enrolled. 4. Internal federal compliance testing will be a required criteria for the staff annual evaluations reviewed by the Executive Director of TRIO programs and the Vice President for Strategic Initiatives & Social Justice.

I. Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (material weakness): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic year. The College did not provide supporting documentation for successful appeals and allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this finding is $180,794. 2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or incomplete timesheets. 34 CFR Part 675. 3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34 CFR 668.22. 4) Entrance and exit counseling documentation was not provided for first time borrowers, withdrawn students or graduated students. 34 CFR 685.304. 5) Cost of Attendance Budgets to determine students unmet need were not provided by the College. 34 CFR 685.102(b). 6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and Federal Work-Study. 7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and Federal Direct Loans. CFR 685.300(b)(5). Auditor's Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of processes, and policies and procedures are being updated and adhered to for compliance purposes. Auditor's Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of processes, and policies and procedures are being updated and adhered to for compliance purposes. Corrective Action – Tougaloo College Administration understands the importance of federal compliance. The collective knowledge of others within the Division of Finance and Administration reinforces the expertise of the four financial aid staff members. The Vice President of Finance and Administration, in collaboration with the Vice President for Enrollment and Student Services, who has direct oversight of the financial aid department, has implemented professional development targeted training on the continuous changes in Title IV program management. In addition to addressing/paying the questioned costs found with improper documentation of Satisfactory Academic Progress with USDE, the following allows for corrective actions while continuing to engage with the Title IV student financial aid programs: 1. Financial Aid team members become certified in the enterprise resource program module, specific to financial aid. 2. Annually, one or more staff members attend the national conference for student aid administrators, which focuses on deepening understanding of federal regulations, exploring new legislation enacted by Congress, gaining practical experience with student loan data systems, and networking with industry peers who offer support identifying and effectively addressing challenges associated with financial aid operations. 3. Attend monthly and quarterly training via knowledge base webinars on: Satisfactory Academic Progress (SAP), Work-study process for students and staff, student loan process, the return of Title IV funds, and reconciling expenditures with the Business Office. 4. Utilize additional resources from the U.S. Department of Education’s Minority-Serving and Under-Resourced Schools Division for administering Title VI Aid.

Contact Person – Dr. Noel Schmidt, Superintendent Corrective Action Plan – The District staff will establish a journal entry review policy. A policy detailing thresholds for purchase order approval will also be implemented. Completion Date – Immediately

Finding No: 2024-007 ALN No.: 17.225 Program Title: Unemployment Insurance Grant Award No.: 24-A-55-UI-000068 2024 Condition The minimum number of cases for paid were not met. Corrective Action Plan Concur. 1. The BAM unit was short staffed an investigator from July 2023 and a second investigator from February 2024. The 2 vacancies remain unstaffed. 2. The unit is in the process of filling a vacancy with an experienced adjudicator. Once the position is filled, the new staff member will be trained in BAM methodology. At this time, the BAM supervisor continues to help the unit toward achieving its BAM requirements. 3. The unit anticipates increasing the number of cases for paid beginning July 2025. Person Responsible Sheryl-Lynn Ozaki, UI Quality Control Supervisor Anticipated Date of Completion June 2026 NOTE: In response to the finding State of Hawaii – Single Audit 2024 finding, the DLIR offers the following: The auditor’s recommendation the DLIR develop new policies and procedures to handle the increase in unemployment claims fails to recognize the true source of the deficiency. The shortcoming is a direct result of staffing shortages. A key requirement of the BAM program is the unit must be staffed with a sufficient number of knowledgeable and skilled investigators to ensure prompt and in-depth investigations. The investigator should be knowledgeable about and trained in the application of federal and state unemployment insurance law, regulation/rules, and official policy, able to interpret and apply law and official policy to each individual claimant's situation. Proficient in factfinding and determination procedures including the process of interviewing interested parties and providing the opportunity for fair hearing, rebuttal. Use independent judgment to develop and analyze evidentiary facts, assess credibility, weigh the evidence obtained, and decide when information is sufficient to issue legally binding decisions, determine appropriate administrative action required, authorized to change computerized records as needed to pay or stop payment of benefits, prepare a timely written decision to deny or allow benefits which clearly communicate the facts, conclusions and reasoning used to support the decision. Be knowledgeable of the methods to effectively deal with claimants/customers, employers, or others, who are under stress, experiencing negative emotions, etc. including handling and controlling conflict. Knowledgeable about and skilled in the navigation of the state’s benefit, employment service, and tax systems; and knowledgeable about and compliant with BAM methodology and coding instructions. Regardless of new policies and procedures, the shortcoming is a direct result of the lack of available skilled investigators with the required skills to conduct prompt and in-depth investigations in the BAM program.