Corrective Action Plans

Finding No: 2024 005 ALN No.: 10.179 Program Title: Micro Grants for Food Security Program Grant Award No.: AM200100XXXXG132 2020 21MGFSPHI1003-00 2021 AM22MGFSPHI1007-04 2022 23MGFSPHI1011-00 2023 Condition The audit identified 25 instances totaling $55,000 where grantee disbursements were not made as soon as administratively possible after the drawdown of Federal Funds. Audit staff determined 25 days to be a reasonable period to disburse cash after drawdown from the Federal Government. Corrective Action Plan Concur. The Hawaii Department of Agriculture (HDOA) will change administrative procedures for disbursement of Federal funds under the Micro Grants for Food Security Program. Going forward, HDOA will process the grant contracts and payments in batches of roughly 100 micro grants per month. Federal Drawdown will not occur until the full batch of 100 contracts have been executed. HDOA fiscal staff will then expedite the payment process to ensure conformity with the 25 day disbursement timeline. Person Responsible Brendan Akamu, Market Development Branch Manager Anticipated Date of Completion The updated work process will be implemented in April 2025. The first batch of grant contracts and payments for the 2023 Fiscal year awards are scheduled for April 2025.

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. The Supplemental Nutrition and Assistance Program office (“SNAPO”) has addressed these issues within the division to make efforts to improve our payment accuracy which include electronic case documentation and data entry accuracy. Corrective Action Taken or Planned: SNAPO has worked with Statewide Branch Administration (“SBA”) to address these types of deficiencies as Hawaii is presently under corrective action for payment error rates. A mandatory refresher training to address budgeting and household composition had been implemented starting in January 2024 to improve core eligibility fundamentals such as budgeting. SNAPO will share the findings provided from this audit to include this as a part of our broader corrective strategy being implemented across the division through the partnership of SNAPO and SBA to address root causes for these errors. Regular case reviews are planned on being conducted to address areas of concern and will be addressed accordingly through supervisory channels to improve payment accuracy and case documentation. Completion Date: This is an on going activity and started for planning purposes from December 2024. SNAPO and Statewide Branch will be implementing the inaugural training/review with the Quality Maintenance and their review of the Quality Control (“QC”) Reports from Audit, Quality Control and Research Office (“AQCRO”). The Quality Control office conduct monthly reviews of all SNAP cases to provide to USDA Food and Nutrition Services on payment errors and will notate administrative deficiencies such as incorrect data entry for both income and deduction amounts used to calculate benefits when determining SNAP eligibility. The regular review cadence is monthly for the QC reports with a tentative quarterly discussion on findings to determine further assistance that can be provided through a collaboration between SNAPO and Staff Development office with policy guidance and staff training. Responding Official(s): Ginet Hayes, Benefit, Employment, and Support Services Division Supplemental Nutrition and Assistance Program Administrator

Views of Responding Officials: The Department agrees with the finding, will implement corrective action, and will work with the appropriate parties to address this issue. Corrective Action Taken or Planned: We have made requests to get more detailed reports from both Fidelity National Information Services (“FIS”) and the Office of Enterprise Technology (“OET”). FIS was able to provide us with the detailed reports, yet we are still working with OET to create a report that will give us similar information. We will also meet with both offices to discuss the information on these reports and from there, identify any variances that may be occurring. We will update our procedures to have the supervisor review and sign off on the daily reconciliations. Completion Date: June 2025 Responding Official(s): Joey Wong, Fiscal Management Office Accounting Supervisor

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Temporary Assistance for Needy Families (“TANF”) Program Office will continue to issue reminders to the eligibility staff, focusing on specific topics and common errors such as, but not limited to, incorrect calculations, policy applications, and determinations. The division has implemented a strategy to address the backlog which caused some TANF applications to be processed beyond the 45 day timeframe. The strategy includes dedicating a group of eligibility staff to the statewide call center where most applicants and recipients are requested to call to complete their eligibility interviews. Completion Date: December 31, 2025 Responding Official(s): Catherine Scardino, Benefit, Employment, and Support Services Division Temporary Assistance for Needy Families Program Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. CWS recognizes that Licensing case files from neighbor islands (Maui, West Hawaii, and Kauai) came late or not at all, and this lack of ability to review the records significantly contributed to the errors. Moving forward, CWS will ensure easier records identification by geographical location and begin the neighbor island’s audits first, allowing extra time for records travel to review site. CWS also notes that additional communication and information sharing with auditors would have been helpful to ensure understanding of expectations prior to on site audit. The communications requested would resemble a pre audit information sharing call, an on site audit entry meeting with key agency staff, and an audit exit conference to discuss findings before the final report is generated. Corrective Action Taken or Planned: 1. CWS staff will be informed of the audit findings and corrective action plan, emphasizing the importance of: A. Providing requested records in advance of the audit, B. Diligent compliance with policies and procedures, C. Supervisor coaching, support and review of records/documents for completeness, D. The impact of individual unit records maintenance performance on the outcome of the audit and this corrective action plan. 2. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. Staff will: A. Continue to ensure staffs are securing the Adoption Assistance and Legal Guardian permanency assistance forms that provide notice for age changes and payment increases. B. Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated and ensuring filed in eligibility record. C. Locate or reprint and file missing “Certificate of Approvals.” D. Locate missing clearances in records not provided for review or re run them if not located in records reviewed. Please note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. E. Administrators to work with courts to ensure court orders contain the required language and are secured in a timely fashion. i. Secure missing termination of parental rights order. ii. Secure court order supporting “reasonable efforts.” iii. Secure missing police protective custody documentation or voluntary foster custody agreement for three cases. F. For young person(s) in Imua Kakou (“IK”) who turned 18 while in care. i. CWS will secure a letter for the record, from the school that the young person is attending, which notes when the young person is expected to graduate. ii. Work with IK providers and IK liaison to make sure logs and meeting minutes are in SHAKA. iii. Document (reason for) continuation of monthly subsidy payments after youth turned 18. 3. CWS has identified the Eligibility Unit (“FPPEU”) record as the primary record for audits with the Licensing record and other case files as secondary. 4. Unit staffs (Licensing, CWS and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. A. The FPPEU Administrator and supervisors will review the eligibility unit record checklist and ensure use of checklist will lead to a complete record containing all required documentation. B. FPPEU staff will review error records identified in this audit, following checklist and secure missing documentation, update inaccurate information and verify that all necessary documentation is present. i. Staff will be given coaching/supervisory support to correctly complete documentation. ii. Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. iii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. C. The Licensing Unit Section Administrator and supervisors will review error records identified in this audit, secure missing documentation, update inaccurate information and verify that all necessary documentation is present. i. Staff will be given coaching/supervisory support to correctly complete documentation. ii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. 5. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. A. MICU staff will audit records to verify that corrective actions have been completed for case specific audit findings. This includes verifying that records contain a note explaining updated information or information gathered due to audit. B. MICU will work with Branch Administrators, Section Administrators, Social Services Assistants (“SSA”) and program personnel to ensure file updates with completion of missing information. C. MICU will verify accuracy of DOC calculations for case specific errors noted in this audit, while supervisors will verify accuracy of DOC calculations on an ongoing basis. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. 7. In preparation for future audits, CWS will update the file identification and secure transport process as follows: A. MICU will send a separate email for records request to each neighbor island, identifying only their records, rather than sending a joint, multi-island, records request. B. The records request email sent by MICU will include a submittal deadline that will accommodate extra time for secured travel of records between islands to ensure all records arrive on time. C. MICU and Branch will review records submitted, ensuring that all records are available to the auditors for review. Completion Date: On going Responding Official(s): Kisha C. Raby, Social Services Division Program Development Administrator; Tonia Mahi, Social Services Division Assistant Child Welfare Services Branch Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Child Welfare Services (“CWS”) recognizes that licensing case files from neighbor islands (Maui, West Hawaii, and Kauai) came late or not at all, and this lack of ability to review the records significantly contributed to the errors. Moving forward, CWS will ensure easier records identification by geographical location and begin the neighbor island’s audits first, allowing extra time for records travel to review site. CWS also notes that additional communication and information sharing with auditors would have been helpful to ensure understanding of expectations prior to on site audit. The communications requested would resemble a pre audit information sharing call, an on site audit entry meeting with key agency staff, and an audit exit conference to discuss findings before the final report is generated. Corrective Action Taken or Planned: 1. CWS staff will be informed of the audit findings and corrective action plan, emphasizing the importance of: A. Providing requested records in advance of the audit, B. Diligent compliance with policies and procedures, C. Supervisor coaching, support and review of records/documents for completeness, D. The impact of individual unit records maintenance performance on the outcome of the audit and this corrective action plan. 2. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. Staff will: A. Continue to ensure staff are securing the Adoption Assistance and Legal Guardian permanency assistance forms that provide notice for age changes and payment increases. B. Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated, and ensuring it is filed in eligibility record. C. Locate or reprint and file missing “Certificate of Approvals.” D. Locate missing clearances in records not provided for review or re run them if not located in records reviewed. Please note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. E. Administrators to work with courts to ensure court orders contain the required language and are secured in a timely fashion. i. Secure missing termination of parental rights order. ii. Secure court order supporting “reasonable efforts.” iii. Secure missing police protective custody documentation or voluntary foster custody agreement for three cases. F. For young person(s) in Imua Kakou (“IK”) who turned 18 while in care. i. CWS will secure a letter for the record, from the school that the young person is attending, which notes when the young person is expected to graduate. ii. Work with IK providers and IK liaison to make sure logs and meeting minutes are in SHAKA. iii. Document (reason for) continuation of monthly subsidy payments after youth turned 18. 3. CWS has identified the Eligibility Unit (“FPPEU”) record as the primary record for audits with the Licensing record and other case files as secondary. 4. Unit staffs (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. A. The FPPEU Administrator and supervisors will review the eligibility unit record checklist and ensure use of checklist will lead to a complete record containing all required documentation. B. FPPEU staff will review error records identified in this audit, following checklist and secure missing documentation, update inaccurate information and verify that all necessary documentation is present. i. Staff will be given coaching/supervisory support to correctly complete documentation. ii. Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. iii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. C. The Licensing Unit Section Administrator and supervisors will review error records identified in this audit, secure missing documentation, update inaccurate information, and verify that all necessary documentation is present. i. Staff will be given coaching/supervisory support to correctly complete documentation. ii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. 5. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. A. MICU staff will audit records to verify that corrective actions have been completed for case specific audit findings. This includes verifying that records contain a note explaining updated information or information gathered due to audit. B. MICU will work with Branch Administrators, Section Administrators, Social Services Assistants (“SSA”) and program personnel to ensure file updates with completion of missing information. C. MICU will verify accuracy of DOC calculations for case specific errors noted in this audit, while supervisors will verify accuracy of DOC calculations on an ongoing basis. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. 7. In preparation for future audits, CWS will update the file identification and secure transport process as follows: A. MICU will send a separate email for records request to each neighbor island, identifying only their records, rather than sending a joint, multi-island, records request. B. The records request email sent by MICU will include a submittal deadline that will accommodate extra time for secured travel of records between islands to ensure all records arrive on time. C. MICU and Branch will review records submitted, ensuring that all records are available to the auditors for review. Completion Date: On going Responding Official(s): Kisha C. Raby, Social Services Division Program Development Administrator; Tonia Mahi, Social Services Division Assistant Child Welfare Services Branch Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. CWS recognizes that Licensing case files from neighbor islands (Maui, West Hawaii, and Kauai) came late or not at all, and this lack of ability to review the records significantly contributed to the errors. Moving forward, CWS will ensure easier records identification by geographical location and begin the neighbor island’s audits first, allowing extra time for records travel to review site. CWS also notes that additional communication and information sharing with auditors would have been helpful to ensure understanding of expectations prior to on site audit. The communications requested would resemble a pre audit information sharing call, an on site audit entry meeting with key agency staff, and an audit exit conference to discuss findings before the final report is generated. Corrective Action Taken or Planned: 1. CWS staff will be informed of the audit findings and corrective action plan, emphasizing the importance of: A. Providing requested records in advance of the audit, B. Diligent compliance with policies and procedures, C. Supervisor coaching, support and review of records/documents for completeness, D. The impact of individual unit records maintenance performance on the outcome of the audit and this corrective action plan. 2. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. Staff will: A. Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated and ensuring filed in eligibility record. B. Locate or reprint and file missing “Certificate of Approvals.” C. Locate missing clearances in records not provided for review or re-run them if not located in records reviewed. Please note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. D. Administrators to work with courts to ensure court orders contain the required language and are secured in a timely fashion. i. Secure missing termination of parental rights order. ii. Secure court order supporting “reasonable efforts.” iii. Secure missing police protective custody documentation or voluntary foster custody agreement for three cases. E. For young person(s) in Imua Kakou (“IK”) who turned 18 while in care. i. CWS will secure a letter for the record, from the school that the young person is attending, which notes when the young person is expected to graduate. ii. Work with IK providers and IK liaison to make sure logs and meeting minutes are in SHAKA. iii. Document the reason for continuation of monthly subsidy payments after youth turned 18 or discontinue payment. 3. CWS has identified the Eligibility Unit (“FPPEU”) record as the primary record for audits with the Licensing record and other case files as secondary. 4. Unit staffs (Licensing, CWS and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. A. The FPPEU Administrator and supervisors will review the eligibility unit record checklist and ensure use of checklist will lead to a complete record containing all required documentation. B. FPPEU staff will review error records identified in this audit, following checklist and secure missing documentation, update inaccurate information and verify that all necessary documentation is present. i. Staff may be given individual training or coaching/supervisory support to correctly complete documentation. ii. Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. iii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. C. The Licensing Unit Section Administrator and supervisors will review error records identified in this audit, secure missing documentation, update inaccurate information and verify that all necessary documentation is present. i. Staff will be given individual training or coaching/supervisory support to correctly complete documentation. ii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. 5. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. A. MICU staff will audit records to verify that corrective actions have been completed for case specific audit findings. This includes verifying that records contain a note explaining updated information or information gathered due to audit. B. MICU will work with Branch Administrators, Section Administrators, Social Services Assistants (“SSA”) and program personnel to ensure file updates with completion of missing information. C. MICU will verify accuracy of DOC calculations for case specific errors noted in this audit, while supervisors will verify accuracy of DOC calculations on an ongoing basis. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. 7. In preparation for future audits, CWS will update the file identification and secure transport process as follows: A. MICU will send a separate email for records request to each neighbor island, identifying only their records, rather than sending a joint, multi-island, records request. B. The records request email sent by MICU will include a submittal deadline that will accommodate extra time for secured travel of records between islands to ensure all records arrive on time. C. MICU and Branch will review records submitted, ensuring that all records are available to the auditors for review. Completion Date: On going Responding Official(s): Kisha C. Raby, Social Services Division Program Development Administrator; Tonia Mahi, Social Services Division Assistant Child Welfare Services Branch Administrator

Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (ASU) Responsible Official: Kisha Bond, Registrar Corrective Action Planned: ASU must report enrollment status for students in the NSLDS database within a 60-day window. ASU reported the enrollment status for the students but not within 60 days. Moving forward, ASU will monitor the activity for the NSLDS database and submit student enrollment data on a timely basis. Estimated Completion Date: August 29, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (JSU) Responsible Official: Ms. Lakesha Tubbs, Registrar Corrective Action Planned: Jackson State University will implement a multi-tiered enrollment reporting schedule to enhance accuracy and prevent certification and enrollment reporting errors. Effective immediately, JSU will submit an initial enrollment reporting file to the National Student Clearinghouse at the beginning of each term. Additionally, two subsequent enrollment reports will be submitted—one at midterm and another within ten (10) days of final grade publication at the end of the term. To ensure consistency, transparency, and alignment across university departments, JSU will establish an Enrollment Reporting Oversight Committee composed of representatives from key university offices. This committee will convene quarterly throughout the academic year to review enrollment reporting processes, address potential discrepancies, and implement best practices. By fostering collaboration amongst stakeholders, JSU will ensure compliance, accuracy, and efficiency in enrollment reporting. Estimated Completion Date: May 9, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (MSU) Responsible Official: Emily Shaw, University Registrar Corrective Action Planned: In addition to reporting in a timely manner to National Student Clearinghouse, MSU will also begin to monitor NSC’s reports to NSLDS. Estimated Completion Date: June 15, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (MVSU) Responsible Official: Jeffrey Loggins, Director of Student Records Corrective Action Planned: The Office of Student Records will review the schedule submission dates for enrollment reporting to the National Student Clearinghouse to ensure compliance with certifying student enrollment within 60-day timeframe from program enrollment effective date. Additionally, enrollment reporting data will be carefully reviewed in an effort to avoid future enrollment errors. Moreover, this may include adding an additional date to report enrollment data during semesters. Estimated Completion Date: February 15, 2026 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (UMMC) Responsible Official: Emily Cole, Executive Director Office of Enrollment Management Corrective Action Planned: As an internal control measure, the Office of Enrollment Management has identified two individuals to verify all enrollment changes are appropriately captured in the National Student Loan Data System (NSLDS) within the 60-day time period. The Senior Record Specialist and Senior Enrollment Data Specialist will review pertinent records in the NSLDS monthly to verify all information has been correctly conveyed from the National Student Clearinghouse System. Estimated Completion Date: Effective immediately

Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU will ensure that post withdrawal aid that could have been disbursed will be disbursed timely unless the student requests otherwise. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has examined the error and has implemented targeted training on the Return of Title IV (R2T4) process. This training focuses on accurately determining break days and performing the required calculations to ensure precision and compliance. To reinforce these efforts, the university will continue to provide quarterly training and cross-training opportunities for staff, ensuring a comprehensive understanding of R2T4 policies and procedures. To further strengthen accuracy, an additional internal review process has been established within the financial aid office. This review will be conducted by the Executive Director of Financial Aid, who will oversee calculations until the responsibility is designated to another team member with demonstrated expertise in R2T4 processing. These corrective measures will enhance the accuracy of R2T4 calculations, ensure compliance with federal regulations, and improve overall financial aid operations at Jackson State University. Estimated Completion Date: May 2, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (MSU) Responsible Official: Lori Ball Executive Director for Financial Aid and Scholarship Corrective Action Planned: Our interpretation of the regulation was that if classes were held on weekends before or after the 5-day break, the weekend days were not counted, only the week itself (Monday- Friday) and the weekend afterwards. Classes started back the next Monday so we used 7 days. If we do not have classes on Saturday before spring break, we are now counting 9 days. Estimated Completion Date: March 15, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The internal control procedures have been updated to incorporate a nine-day break. The refund of funds to the Department of Education will be processed upon completion of the necessary calculations. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (UM) Responsible Official: Mr. Eduardo Prieto, Vice Chancellor for Enrollment Management Corrective Action Planned: The University of Mississippi’s Office of Financial Aid has an existing process for next-level supervisor review of all Return of Title IV (R2T4) calculations. To further strengthen compliance, future R2T4 reviews will also include any documentation used to determine the date of withdrawal. While it is believed that communication with instructors was accurate, messaging will be refined to clarify which activities cannot be used to document academic engagement (e.g., simply logging into the online system). Additional scrutiny will be applied when determining the last date of attendance for online courses, and instructors will be contacted for clarification as needed. The Office of Financial Aid has also established a unit to enhance compliance through internal reviews of various processes, including R2T4. Although not all R2T4 calculations will be selected for examination, sample evaluations will provide an additional level of oversight. Additionally, a transition to Ellucian’s Banner system is planned for the 2026-2027 academic year, requiring instructors to report the last date of attendance for all F grades at the time of grade entry. This change will help minimize ambiguity regarding unofficial withdrawals. Estimated Completion Date: April 1, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (UMMC) Responsible Official: Coralisa Williams, Senior Financial Aid Advisor Corrective Action Planned: Processing procedure has been updated to state the use of the “last date in class” from the academic calendar published in the UMMC Bulletin to ensure consistent and correct processing of R2T4. Estimated Completion Date: Effective immediately (has reviewed current R2T4 for accuracy) Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: The university included the Friday commencement day as last day of the term. Our reasoning is that some students are still completing assignments, tests, and class projects through the day of commencement. The financial aid office will verify the number of class days with the registrar office before each semester to ensure all class days are included in the award period. The student with the possible post-withdrawal disbursement withdrew prior to our census and all institutional charges were reversed and we could not verify that the student actually attended any of their classes. Effective February 3, 2025, institutions are exempt from performing an R2T4 calculation in this situation. Amend § 668.22(a)(2)(ii)(A)(6) to exempt institutions from performing an R2T4 calculation if: (1) a student is treated as never having begun attendance; (2) the institution returns all title IV, HEA assistance disbursed to the student for that payment period or period of enrollment; (3) the institution refunds all institutional charges to the student for that payment period or period of enrollment; and (4) the institution writes off or cancels any payment period or period of enrollment balance owed by the student to the institution due to the institution's returning of title IV, HEA funds to the Department. Going forward, USM intends to not perform R2T4 calculations for students that meet one of the above exemptions. Other possible post withdrawal disbursement will be tracked, and communication will be sent to students eligible once they are identified and calculated upon withdrawal. Estimated Completion Date: March 17, 2025

DCHS has reviewed its procedures and will ensure that suspension and debarement status is documented prior to contracting with a vendor.

Finding 2024-002 – Low Income Public Housing Tenant Files – Eligibility – Noncompliance & Material Weakness – Public and Indian Housing – ALN #14.850 Corrective Action Plan: The Housing Authority has contracted with US Inspections to continue pre-inspecting units in preparation for NSPIRE inspections. Additionally, staff is coordinating Income Calculation training with Zeffert University. Lastly, the Housing Authority has implemented a 100% file compliance review, which took effect on January 1, 2025. Person Responsible: Tammy Bradshaw, Admissions & Compliance Manager Anticipated Completion Date: June 2025

Finding 2024-001 – Accounting Controls – Internal Controls over Financial Statement Preparation ALN 14.850 – Noncompliance and Material Weakness Corrective Action Plan: The Housing Authority is working with new personnel to ensure processes are documented and proper training is taking place. The Housing Authority has contracted with BDO to assist with year-end processes and training. Person Responsible: Sheila Crisp, Executive Director Anticipated Completion Date: June 2025

Special Tests and Provisions R2T4 – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office will be crafting a new SOP to address R2T4 audit findings. The team will work more closely with the Registrar and Academic Deans when determining the withdrawal status of a student and make sure that the R2T4 documentation is accurately completed, a review of completed R2T4s will also be conducted. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

Description of Corrective Action Plan: Argos Community Schools will ensure that going forward any construction we have done, funded with federal dollars will be compliant with Davis-Bacon Act Reporting laws and ensure we receive required documentation, as required by Federal Law.

Wisconsin Department of Health Services Planned Corrective Action: This FY 2022-23 finding continued through SFY 2023-24 because the public health emergency unwinding was completed after June 30, 2024, for this population. No new concerns were identified by LAB during their FY 2023-24 audit. Corrective actions began during SFY 2023-24, and DHS completed a final analysis in November 2024. As part of this process, all outstanding cases were resolved. After the analysis was completed, DHS implemented an ongoing monthly monitoring plan with the IM agencies, which was outlined in the CARES Coordinator Notice (CCN) dated January 27, 2025. Anticipated Completion Date: January 27, 2025Persons responsible for corrective action: Autumn Arnold, Director Bureau of Eligibility and Enrollment Policy, Division of Medicaid Services autumn.arnold@dhs.wisconsin.gov Jonelle Brom, Director Bureau of Eligibility Operations and Training, Division of Medicaid Services Jonellem.Brom@dhs.wisconsin.gov Dave Varana, Director Bureau of Fiscal Accountability and Management, Division of Medicaid Services Dave2.Varana@dhs.wisconsin.gov

Planned Corrective Action: The Department of Public Instruction (DPI) will complete and submit reports for subaward information in the FFATA Subaward Reporting System (FSRS) for the Child Nutrition Cluster (CNC) starting in fiscal year 2025. The internal processes established to ensure proper reporting of subaward information did not include payments made for Child Nutrition Cluster grants, as the Department did not believe the FFATA requirement applied to these awards. Upon notification that DPI is required to include these awards, the written policies and procedures are being updated to include processes to identify which subawards and subrecipients have exceeded $30,000 and complete the monthly FFATA reporting as required. Anticipated Completion Date: Person responsible for corrective action: Michael Brendel, Assistant Director School Financial Services Team Division of Finance and Management Department of Public Instruction michael.brendel@dpi.wi.go

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 regulations set by the Department of Education around NSLDS to ensure the University understands the definitions for each enrollment information that gets reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Felician University has evaluated and updated our procedures in overseeing submission to NSLDS and notified the appropriate staff. Management will monitor this issue regularly during the year to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Erminda Velez, Director of Registration and Records Planned completion date for corrective action plan: April 1st, 2025.

Description of Corrective Action Plan: Shoals Community School Corporation will implement a secondary review of all reports submitted in the future regarding any federal funding. Kindra Hovis, Superintendent will share the reports with Kendra Wright, Treasurer and Kendra Wright, Treasurer, will share with Kindra Hovis, Superintendent all future federal awards’ expenditures and revenue reports to ensure accurate reviews and submissions. Responsible Party and Timeline for Completion: Kendra Wright, Treasurer and Kindra Hovis, Superintendent-this will be implemented monthly to review any federal funding moving forward.

Boston Public Schools will take a multi-step approach to ensure accuracy of spending to the grant award period. Anticipated Completion Date: January 31, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

FINDING 2024-004 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation was required to submit Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the following exceptions in data reporting submissions:  ESSER I Year 4, ESSER II Year 3, and ESSER III Year 3 expenditures for the period of July 1, 2021 through June 30, 2022 ($0, $360,404, and $12,974, respectively) did not agree to underlying expenditure records ($60,937, $477,914, and $0, respectively).  ESSER II Year 4 and ESSER III Year 4 expenditures for the period of July 1, 2022 through June 30, 2023 ($57,667 and $363,486, respectively) did not agree to underlying expenditure records ($361 and $400,473, respectively). Description of Corrective Action Plan: Management will implement control processes surrounding federal data reporting to ensure that expenditures reported to granting agencies are in agreement with underlying records maintained by the School. Responsible Party and Timeline for Completion: Gretchen Berger, Corp Treasurer - 6-1-2025

The School Corporation will implement a formal process to ensure the required weekly payroll reports certifications are collected and reviewed to ensure compliance with federal regulations. The Treasurer and the Deputy Treasurer will be responsible for overseeing the implementation of the correction action plan which will go into effect immediately.

Contact Person Responsible for Corrective Action: Dalton C. Tunis Contact Phone Number: 574-896-2155 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: For future projects, NJ-SP will make sure documentation for both wage requirements and weekly certified payroll reports are obtained from the contractor. An internal control system will be put into place that ensures the Business Manager receives proper documentation or payments will not be issued for work performed in order to stay in compliance. Anticipated Completion Date: March 31, 2025

Contact Person Responsible for Corrective Action: Dalton C. Tunis Contact Phone Number: 574-896-2155 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: An internal controls procedure will be put into place that ensures annual data reports are both reviewed and signed off on before submitting. The procedure will be that the Business Manager prepares the report and then reviews the report with the Superintendent. Once the Superintendent approves of the report he or she will sign of on the report and the report can be submitted. Documentation will be recorded to ensure the School Corporation stays in compliance with the requirements related to grant agreements and reporting requirements. Anticipated Completion Date: June 30, 2025

In the future Seiling Public Schools will ensure all construction projects funded by federal awards comply with the Davis-Bacon Act requirements. Action Steps: * Develop internal processes to ensure federal wage rates and fringe benefits are met on construction projects. * Ensure all construction contracts funded by federal awards include the required Davis-Bacon wage clauses. * Collect and review weekly certified payroll reports from contractors to confirm wages are correct. * Ensure that all necessary wage information is visibly posted at construction sites. * Train contractors and District staff on the Davis-Bacon Act requirements. * Perform audits to verify compliance and indentify any issues early.

Finding 2024-002: Material Weakness in Internal Control Over Compliance and Non-Material Noncompliance Responsible Person: Chris Slagle, Program Manager; Allison Gregg, Program Manager Estimated Completion: January 31, 2026. Corrected Action: 1. The Department will conduct a thorough assessment of current redetermination reports and state policies to identify approaching deadlines and overdue items and create a structured monitoring system for supervisory staff. Standardized verification checklists will be introduced to confirm that all necessary documentation is collected, and incoming materials will be reviewed promptly to improve decision-making accuracy. The agency will collaborate with technical teams to correct the VaCMS programming error so that auto-renewals cannot occur without verification of crucial information such as social security numbers. 2. The Department will strengthen its workforce by enhancing training for new and existing employees. Requests will be submitted to the Board of Supervisors to support hiring additional staff, thereby mitigating the burden on each employee by reducing the caseload of 1,000 cases per worker to a more manageable caseload, allowing staff to process cases more efficiently. Training sessions will emphasize state and federal standards for timeliness, along with best practices for case documentation and adherence to the updated Medicaid Unwinding and Public Health Emergency guidelines. Regular professional development opportunities will be offered to ensure that all staff members remain informed about policy changes and evolving procedures. 3. The Public Benefits Unit Program leadership will conduct quarterly reviews to measure compliance with redetermination deadlines and track indicators such as workload volume, pending actions, and overdue items. Quarterly reviews will be documented and submitted to Department leadership. These reviews will highlight redetermination outcomes, caseload trends, and staffing considerations. 4. The Department will onboard the Public Benefits Program Administrator, who will be tasked with overseeing compliance across all Benefit Programs. The agency will implement a Corrective Action Plan aimed at ensuring timely and accurate completion of Medicaid redeterminations.