Corrective Action Plans

FINDING 2024-001 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: There were no controls in place to ensure that the School Corporation complied with the reporting requirements. The reimbursement request reports were prepared and submitted by the Food Service Director without any oversight, review or approval process to ensure accuracy of the reports. There was no oversight to make sure that the number of meals served matched the report filed. The lack of internal controls was systemic throughout the audit period. Contact Person Responsible for Corrective Action: Amanda Myers Contact Phone Number and Email Address: 765-832-3551/amyers@svcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Amanda Myers, Food Services Director, will continue to receive the information for the monthly meals served from the cafeteria managers at each school. Once she enters the information, the HS cafeteria manager will review the numbers to ensure that the information was entered correctly. The reimbursement forms and information that was entered will be submitted to the finance department to ensure the reimbursement process is correctly receipted. Anticipated Completion Date: Immediate.

Finding #2024-002 – Material Audit Adjustments (Prior Year Finding #2023-002) Condition: The audit proposed adjusting journal entries during the audit process to adjust District account balances. We deem these entries to be significant in relation to the financial statements. Since the District did not make these adjustments in its accounting system prior to the audit, a material weakness was determined to exist in the District’s internal controls. Effect: Financial reports generated by the accounting system may not provide an accurate reflection of the District’s financial position or activities. Cause: Financial information was not recorded in a timely manner and numerous adjustments were needed in order to correct account balances. Criteria: Material adjusting journal entries not prepared by the District before the audit are considered an internal control weakness. Recommendation: Policies and procedures should be implemented to ensure account balances are properly recorded in a timely manner. Response: The District will establish policies and procedures to reduce the number of adjusting journal entries proposed by the auditor in future years. Contact Person: Loras Winders Anticipated Completion: June 30, 2025

2024-016 Reporting for Education Stabilization Fund Federal program: ALN 84.425U&D Education Stabilization Fund Federal agency: U.S. Department of Education Pass-through entity: Colorado Department of Education Criteria: ESSER grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. An LEA is required to submit certain annual financial reports to its SEA on an annual basis. Condition: The District did not timely file the annual financial report and the filed report did not agree to the general ledger. The District did not file its annual financial report for grant 4414 until February of 2025. The District has not filed its annual financial report for the ARP-Mentor grant. Management Response and Planned Corrective Actions Criteria: Grant accounting was performed by a part-time contractor who left at beginning of the fiscal year. The CFO absorbed those accounting tasks within the remaining finance team. Failure to file ESSER reporting timely was communicated by Superintendent to CFO when the CDE sent notice, but reporting was not completed before dismissal. Management will ensure controls are in place to confirm grant accounting and reporting are reviewed, completed, correct, and timely. Management will further ensure grant accounting expertise is again employed or contracted in the district. Responsibility for Corrective Action: Ken Witt, Superintendent Anticipated Completion Date: Summer of 2025

Context: The School Corporation was required to submit two 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 ESSER I, ESSER II, and ESSER III amounts reported for the reports covering the FY22 time period ($3,000, $0 and $0, respectively) did not agree to the underlying expenditure records ($0, $207,168, and $104,885, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II, and ESSER III amounts reported for the reports covering the FY23 time period ($328,359 and $334,119, respectively) did not agree to the underlying expenditure records ($121,193 and $229,234, respectively, for the period of July 1, 2022 through June 30, 2023). Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Business Manager and Assistant will jointly review all expenditures or fedral grant awards with in the fiscal year that are to be reported to ensure accuracy of reporting. Anticipated Completion Date: July 2025

Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: I have spoken to the Food Service Director and she will begin printing the Skyward threshold guidelines and sign off on those/confirm they match the federal poverty guidelines. Anticipated Completion Date: August 2025

1. Corrective Action Step A. Strengthening Internal Controls Over Determination of Applications Demonstrating Questionable Eligibility The School Corporation will develop and implement a segregation of duties, ensuring that current individuals approve applications, perform Direct Certification checks, and conduct follow-up verifications of questionable applicatoins in a more directed manor. If an applicant provides a case number that does not appear on the Direct Certification list the School Corporation will: 1. Review the application based on standard income eligibility requirements, while confirming the application will remain subject to verification. 2. If $0 income is provided or the application is otherwise 'questionable' then the reviewing individual will add the following to the application comments field: reviewing individual name, reason for review request, to whom the application will be escalated. 3. Apply benefits to siblings, if appropriate. 4. Not complete the final step of marking the application as processed, rather leave it 'pending' and notify Director of School Nutrition of the need for this application to be reviewed. 5. Director of School Nutrition or designee will review and either confirm the DC status by downloading the certification or conduct follow-up verification. In either case, approved or verification for cause, the Director of School Nutrition or Designee will mark the application as processed. 6. If the verification for cause is not responded to in a timely manner, the status will revert to 'Paid' status as per 'verification for cause' guidelines. 2. Corrective Follow-Up and Reporting The School Corporation will review all applications from current year (FY 24-25) to identify any applications not subject to verification process. Management will report progress on implementing these corrective actions to the School Board and maintain records for review by auditors and state officials. 3. Anticipated Completion Date The review of current year (FY 24-25) applications will be completed March 21, 2025. The school board report will be completed April 11, 2025.

The County will develop a 2nd Party Review from that will be used to check completed applications for accuracy in applying policy and to assure all verifications have been uploaded to the NCFAST system.

Finding Number: 2024-001 Condition: The University did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: To address the root cause of the enrollment reporting error, which stemmed from turnover in the registrar’s office during Spring 2024 and resulted in an oversight of unofficial withdrawals reported to the Clearinghouse/NSLDS until identified during the audit, a comprehensive corrective action plan has been developed. Our institution is implementing a new ERP system, we will automate enrollment reporting to ensure timely and accurate data submission. Additional staff will be recruited and trained, with cross-training programs to mitigate turnover impact. Regular internal audits will ensure compliance. Improved communication and coordination will enable continuous monitoring to improve overall efficiency and accuracy. Contact person responsible for corrective action: N. Chad Curley Anticipated Completion Date: 09/01/2024

Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Contact Person Responsible for Corrective Action: Chris Scott Contact Phone Number: 765-544-2246 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A new Food Service Director has been hired and will take responsibility for ensuring compliance with eligibility requirements. Additionally, the Business Manager will oversee the corrective actions and implement a formal secondary review process. The Business Manager will conduct and document secondary reviews for all applications entered into the food service software to verify eligibility determinations. This ensures compliance with regulatory standards and addresses the deficiencies noted in the audit findings. Anticipated Completion Date: June 2025

Finding 2024-001: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: September 30, 2025 Recommendation: It was recommended management of Cheney Care Community review their internal controls over the financial reporting and close processes to determine whether additional controls over the preparation of the final trial balances and related schedules can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Action Taken: Cheney Care Community will review their internal controls over the financial reporting and close processes to determine whether additional controls need to be implemented going forward.

Condition: There was a lack of documented controls as evidence of supervisory review and segregation of duties to ensure compliance with federal program requirements, specifically over the following: a)Tier (day care home eligibility) determinations b)Subrecipient monitoring Noncompliance was identified for subrecipient monitoring as noted in the context below. Planned Corrective Action: (a)Management is working with the Software company staff to develop software-based evidence of second review. If this is not possible, a tracking mechanism external to the software will be developed by March 2025. (b)Under management’s supervision, monitoring visits are being brought current on the contract currently in place and will be completed as required by end of contract. A tracking mechanism has been put in place to ensure compliance with the required number of monitoring visits and timeliness. Contact person responsible for corrective action: Loukisha Pennex, Chief of Youth and Family Potential and Anjanette Brown, CFO. Anticipated Completion Date: June 2025

Checklist for completing quarterly reports will be developed by the Grants Managaer and implemented to ensure all quarterly reports for federal and state grants are completed within 15 days following the end of the quarter. Checklist will be given to the Financial Administrator for review on day 16 following the end of the quarter. Financial Administrator will email confirmation of completion to CEO.

Context: For testing of activities allowed and unallowed, a sample of 21 vendor vouchers were selected for testing. Two vouchers totaling $61,841 were related to disbursements for floor replacement costs incurred and charged to the ESSER III grant award. The School Corporation received approval from the Indiana Department of Education (IDOE) through the grant application to utilize a portion of the ESSER II grant award for floor replacement throughout the School Corporation. During the audit period, the School Corporation had $88,600 that was disbursed and reported on the SEFA for ESSER II and $142,400 that was disbursed and reported on the SEFA for ESSER III for floor replacement. The School Corporation did not receive approval from the Indiana Department of Education (IDOE) to use ESSER III funding for the flooring project as required for construction or remodeling related projects. The total amount of the flooring project funded by the ESSER III grant, including amounts paid prior to the audit, was $219,992. The portion of the flooring project paid by the ESSER II grant was $163,000 which was properly approved by IDOE. Contact Person Responsible for Corrective Action: Lisa Baker, Business Manager Contact Phone Number: 765-664-0624 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will put a system in place to ensure that each grant application is printed in its entirety, including the narratives, and file them in the appropriate grant files maintained by the business manager. The business manager will verify that the agreed upon expenditures are included in the grant application before any orders are placed or purchases are approved. Additionally, accounting descriptions set up in the financial software will better reflect IDOE-approved expenditures. Anticipated Completion Date: February 25, 2025

Context: For the one project sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. Additionally, the School Corporation did not have a contract with the company that included the clause for the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $231,000. Audit adjustments were proposed, accepted by the School Corporation, and made to the SEFA to correct the issues noted above. We also noted there was no documented, secondary review of the information in the SEFA by someone other than the preparer. Contact Person Responsible for Corrective Action: Lisa Baker, Business Manager/Treasurer Contact Phone Number: 765-664-0624 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Davis-Bacon requirements is a repeat finding due to the timing of the prior audit and a lag for new controls to take effect. When the School Corporation is awarded federal funds that will be used for construction, alteration, or repair projects in excess of $2,000, the superintendent and/or business manager will notify the contractors that the project is being funded by federal funds and the requirements as outlined by the Davis-Bacon Act. In addition, the superintendent and/or the business manager will ensure that the contractors provide weekly payroll report certifications and will review the documents to ensure compliance with the wage rate requirements. The SEFA, which is included with the Annual Financial Report, is reviewed by the deputy treasurer upon its completion. Going forward, any corrections or adjustments made to the SEFA will be reviewed by the deputy treasurer or other district office employee. Anticipated Completion Date: Corrective action steps have been implemented and will be refreshed.

Management's Response: The Organization acknowledges the finding and agrees with the auditors' recommendations. We recognize the importance of maintaining accurate documentation and financial controls to ensure compliance with federal regulations. To address the finding, the Organization will implement the following corrective actions: 1) Journalizing administrative allocations - effective March 31, the Organization will implement a procedure to allocate administrative costs to each applicable federal award program through monthly journal entries within the general ledger. 2) Improved documentation retention - the Organization will establish a process to retain supporting documentation for all costs submitted for reimbursement, ensuring alignment between the general ledger and reimbursement requests. 3) Internal controls for expense classification - the Organization will implement additional controls to prevent expenses from being reclassified within the general ledger after reimbursement requests have been submitted. Any necessary adjustments will be documented with a clear audit trail. These corrective actions will be fully implemented by March 31, 2025, will include and cover all such costs from the start of the fiscal year which began October 1, 2024, and management will monitor compliance to ensure ongoing adherence to these procedures.

Corrective Action Taken: Management notified Eide Bailly of the alleged fraud prior to the start of fieldwork for the October 31, 2024 audit. Management removed all questionable documentation from the tenant files, re-certified any affected tenants and obtained the required documentation for the tenant files prior to the conclusion of the October 31, 2024 audit. Management has also strengthened the controls over the tenant files to ensure that proper documentation is maintained in the tenant files. The Director of Programs is now reviewing the documents in every tenant file at the time of move-in or annual recertification. Name of Contact Person: Julie Sparks, Executive Director, 330-455-9100 Completion Date: February 6, 2024

Corrective Action Taken: Management notified Eide Bailly of the alleged fraud prior to the start of fieldwork for the October 31, 2024 audit. Management removed all questionable documentation from the tenant files, re-certified any affected tenants and obtained the required documentation for the tenant files prior to the conclusion of the October 31, 2024 audit. Management has also strengthened the controls over the tenant files to ensure that proper documentation is maintained in the tenant files. The Director of Programs is now reviewing the documents in every tenant file at the time of move-in or annual recertification. Name of Contact Person: Julie Sparks, Executive Director, 330-455-9100 Completion Date: February 6, 2024

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control National University acknowledges the findings and the importance of accuracy and timeliness when completing enrollment reporting to NSLDS. The University has made significant efforts to improve all areas of the enrollment reporting process, and the results of this audit do not reflect those efforts and improvements due to the timing of the FY 23 audit completion in February 2024 and CAP completion in June 2024. The institution has identified two items that have resulted in challenges to accurate and timely enrollment reporting during the audit year. Intent to return: The University has identified a need to improve the understanding and implementation of its intent to return (ITR) process. As a result, the University will conduct a holistic review, including assessment and clarification of the current policy, identification and implementation of technological controls, comprehensive training for ITR, and the development and implementation of a monthly ITR review. National Student Clearing House (NSC) reporting: On October 18, 2024, the institution was notified by NSC that its access to process enrollment reporting on behalf of NU was revoked during July 2024, resulting in a reporting gap. The institution is investigating the root cause of this and submitted a ticket to the FPS/SAIG help desk, but no root cause was able to be identified. The issue was immediately resolved upon notification; however, the reporting gap had a significant impact on the FY 24 enrollment reporting sample. In addition to the above, the institution will continue or take the following steps: • Continued monthly testing of enrollment reporting accuracy to NSLDS conducted by the quality assurance team. • Identification and timely delivery of training for areas of opportunity identified in the monthly reviews to the registrar and data operations teams. • Revise the internal documentation process between quality assurance, data operations, and the registrar teams to ensure clarity of policy and regulatory guidance in areas of identified risk/confusion during enrollment reporting processing. Contact Person Responsible for Corrective Action: • Rob Conlon, AVP Financial Aid Compliance • Sarah Massey, AVP of Operations Student Support and Registrar Operations • Gabrielle Witruke, Associate Director Data Analytics • Melissa Diaz, AVP Operations Advising Anticipated Completion Date: March 2025

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University acknowledges the finding and importance of accurate identification and timely and accurate calculation of R2T4s. The University has made significant efforts to improve all areas of R2T4 processing, and the results of this audit show significant gains over the previous year. Given the timing of the FY 23 audit completion in February 2024 with CAP completion scheduled for June 2024, the benefits of the FY 23 corrective action plan have a limited impact on this audit period. This, coupled with the improved results the institution has seen in timeliness such as the late return error rate having decreased from 31% in FY 23 to 13% in the current audit, suggests that NU is pathing towards compliance with R2T4 requirements. Based on this assessment, NU will continue to take the following actions: • Continual assessment of staffing levels and hiring as needed to ensure timely identification and processing of R2T4s. Staffing ratios were established in FY24 and staffing increases were implemented to ensure accurate processing and timely completion. • Continual identification of risks with weekly testing and readouts from Quality Assurance to the financial aid processing team. • Re-training with the R2T4 processing team on the order of returns. • Identification and timely delivery of training for areas of risk identified in the weekly reviews. • Revise internal processes between the Quality Assurance and financial aid processing to better communicate policy and regulatory guidance in areas of identified risk/confusion during R2T4 processing. Contact Person Responsible for Corrective Action: • Rob Conlon, AVP Financial Aid Compliance • Alan Coddington, AVP Student Financial Services Anticipated Completion Date: January 2025

Recommendation: We recommend all reimbursements and payments be reviewed in detail to ensure no payments are funding unallowable costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Going forward, the county will implement a more thorough review process for expenditures that were initially paid by a separate entity and subsequently reimbursed by us, ensuring all such transactions are properly documented and compliant with grant guidelines. Name of contact person responsible for corrective action: Jeffrey Rank, Director, Office of Budget & Finance Planned completion date for corrective action plan: February 28, 2025

Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District has taken the following actions to address this recommendation: Assess Current Reporting Delays  Review the current submission schedule and identify specific time gaps between when Clearinghouse files are sent and when the data reaches NSLDS.  Work with the Clearinghouse to confirm file submission dates and compare them with NSLDS report uploads.  Document delays and establish a baseline for necessary improvements. Action 1.2: Communicate with NSLDS and Clearinghouse  Contact NSLDS and Clearinghouse support teams to communicate the delays and request any assistance or expedited processes.  Set clear expectations with these parties on how to resolve the reporting issue and prevent future delayed submissions. Establish Clear Reporting Timelines  Work with Clearinghouse to establish a clear, consistent timeline for file submission and confirm the timing of data submission to NSLDS.  Ensure reporting timelines align with NSLDS deadlines to ensure timely reporting.  Update internal policies and procedures to reflect the new reporting timeline and expectations. Staff Training and Awareness  Conduct training sessions for staff involved in the Clearinghouse file preparation and submission process, emphasizing the importance of timely submissions.  Provide regular updates and reminders about deadlines and processes. Automate or Enhance File Submission Process  Implement any necessary technology upgrades to streamline the data submission process.  Explore the possibility of setting up automatic file uploads directly to NSLDS to minimize delays. Implement Monitoring and Reporting System  Set up a monitoring system to track Clearinghouse file submissions to NSLDS, including confirmation that files have been successfully submitted and processed.  After implementing process changes, conduct monthly reviews to verify that student data is being submitted to NSLDS on time.  Track and report submission times Continuous Communication with NSLDS and Clearinghouse  Establish a point of contact at both NSLDS and the Clearinghouse to improve communication regarding file submission issues. Conduct regular reviews to ensure that the institutions’ reporting process aligns with NSLDS requirements. Name of the contact person responsible for corrective action: Dr. Kristina Martinez, Acting Dean of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student’s account and the correct amounts are being returned to the Department. Response to Recommendation: The District acknowledges the importance of adhering to R2T4 requirements and has taken the following actions to address this recommendation: The District adjusted the student samples as notated by auditors. Samples with discrepancies have been recalculated based on R2T4 requirements and correct amounts have been returned to the Department of Education. Verification of corrected R2T4 calculations was provided to auditors. Action taken in response to finding: 1. Consultant Engagement: o A NASFAA-certified consultant with extensive experience as a financial aid director has been hired to assist the R2T4 team during the 2024-2025 aid year. o The consultant will review all R2T4 calculations to ensure compliance and accuracy. Additionally, a secondary staff member is assisting in reviewing all 2024-2025 R2T4 calculations. 2. Training Initiatives o Provided department-wide training on R2T4 policies and procedures. o Delivered in-depth training sessions specifically tailored for the R2T4 team. o The R2T4 team has successfully completed NASFAA’s R2T4 course series to enhance their expertise. 3. Staffing Adjustments o An Accounting Technician under the direction of the District Business Manager will be assigned to Financial Aid to support R2T4 processing and reconciliation to ensure accuracy and compliance. o Additionally, this Accounting Technician will need to have view-only access to all data and reports available in the Student Financial Aid module contained in Colleague in o order to be effective in providing meaningful analysis and reconciliation of student-level detail to summary ledgers and reports contained in the Fiscal Services module of Colleague and other financial reporting tools. 4. Process Improvements o Instruct the R2T4 team to use the Department of Education’s R2T4 worksheet in the COD system instead of the R2T4 module in Colleague. o This change addresses the lack of automation and checks in the Colleague system, which has been a contributing factor to discrepancies. o Financial Aid has reached out and established rapport and protocols with academic and registrar offices to enhance understanding of academic engagement, registration processes, and data fields. o The department has updated the policy and procedures manual, including cheat sheets to clarify points of regulatory interpretation along with El Camino’s data fields to use. 5. System and Workflow Evaluation o Identified that the R2T4 module in Colleague lacks automation or checks and balances to flag manual input discrepancies. o Future plans include exploring system enhancements or alternatives to improve functionality and reduce reliance on manual calculations. o The District has begun evaluating ways to improve the R2T4 reports to help automate this process as much as possible. Name of the contact person responsible for corrective action: Chau Dao, Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: Implementation Timeline:  Consultant Review: Begin immediately, with ongoing review throughout the 2024-2025 aid year; retain consultant services for 2025-2026 aid year.  Training: Complete with Spring 2025 R2T4 calculation, with periodic refresher sessions scheduled on an annual basis.  Staffing Request: The Accounting Technician position will be assigned no later than July 1, 2025. This position shall be filled by existing accounting staff or, if needed, a new employee.  Process Transition: Full transition to the COD system worksheet for R2T4 calculations with the Fall 2024 term R2T4 calculation.  System Evaluation: Initiate and maintain ongoing discussions with IT and software providers, leveraging opportunities from conferences, networking events, and training sessions to explore and implement improvements. Monitoring and Evaluation:  Conduct monthly audits of R2T4 calculations to identify and address errors promptly.  Maintain ongoing collaboration with the consultant to refine processes and implement best practices.  Evaluate the effectiveness of new training and staffing adjustments after six months and report findings.

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Background: The Bethel University Registrar is responsible for ensuring timely and accurate reporting to NSLD via the National Student Clearinghouse. Cheryl Fisk was appointed to serve as University Registrar on August 1, 2022. While new to Bethel, she is not new to Clearinghouse reporting. She assumed the oversight of the Clearinghouse reporting and is working to ensure timely, accurate submissions. • Bethel reports student enrollment to NSLDS via the National Student Clearinghouse • Currently, the people involved in the process include: o Data Management Team: Ana Ortiz, Records and Data Specialist o Registrar Staff: Cheryl Fisk, University Registrar o Information Technology Service Staff: Bethel Information Technology Staff Based on the previous audit, adjustments were made to standardize the submissions to the Clearinghouse. Extra efforts were made to ensure that needed corrections were done within the required time frame. We have started to simplify our degree conferral policy to improve the accuracy of the reporting of graduates. However, because of major changes in the Information Technology Department staffing, we were not able to research how the submission reports are compiled or the automatic process that is used to clean and prepare the data before it is added to the submission reports. We have reviewed the Clearinghouse training. We have also sought the advice from other institutions who report to the Clearinghouse. We originally thought that the frequency of our batches was the problem. However, it appears that the issues may be in the way the submission data are prepared and compiled into the submission reports. Multiple reports must be compiled and then combined to create the submission for both branches. Corrective Action: Our corrective action will involve several parts. • First, we will work ITS staff to determine which fields and tables the submissions are using to create the Clearinghouse reports. Currently, the submission batches are reporting on two branches where multiple terms (i.e. termcodes) are involved. The reports may need to some revision. • Second, we will be proactive in confirming that the Clearinghouse has received our submissions and has processed them in a timely manner • Third, we will monitor closely what the Clearinghouse records show for graduation and withdrawal dates for students in comparison to what is in our student information system to ensure they are in sync. Then we will double check that information to what is showing at NSLDS. Corrections will be made if needed. • Fourth, we will continue to adjust our conferral process to ensure that graduation information is reported in a timely way • Fifth, we will confer with the Financial Aid Office when dealing with complicated registration changes. This will ensure we are in sync in our interpretations of the situation. • Sixth, we will continue to take advantage of Clearinghouse, Banner, and any other related training opportunities. Name of Contact person Responsible for Corrective Action: Cheryl Fisk Planned completion date for the correction action plan: June 1, 2025. This will provide time to test corrective measures to ensure everything is submitting properly.

Management reviewed the process and determined that the error was self-identified and the necessary step were taken to be corrected by the fiscal year-end June 30, 2024. Management will further review the procedures that are in place to track available contract funding balances and implement adjustments in order to allow for the prevention, or timely detection and correction of, errors in federal draw-down requests. This will be completed by June 30, 2025.

Condition: The Commission did not submit the required financial report and performance report timely. Planned Corrective Action: The Capital Team Project Manager will reconcile HUD’s EPIC and ELOCCs system with Yardi monthly to ensure the timely filing of capital projects close out. This tracking critical spreadsheet created by the Lead Performance Officer, will trigger key reporting dates for the DHC Capital Fund Program to remain in compliance with HUD reporting deadlines. At a minimum, monthly, this critical spreadsheet is distributed to the Supervisor of Capital and the Lead Performance Officer to ensure compliance. Contact person responsible for corrective action: Michael Edwards, Capital asset & Skilled Trades Supervisor Anticipated Completion Date: 6/30/2025