Corrective Action Plans

Compliance officer will be handling this now.

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends the District review its grant reporting processes and implement internal controls to help ensure that there is adequate segregation of duties in regards to grant reporting including special reports and that all supporting documentation is maintained with the filed copy of the report. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for grants but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing.

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving purchases when purchase orders are not required, along with adding controls to ensure that the item purchased was received by the District. We also recommend the District review its payroll process and identify payroll tasks that could be reassigned to other district personnel or consider implementing additional review procedures specifically focused on payroll and related fringe benefit costs claimed on federal and state grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for grants but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing.

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: Auditor recommends the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving micro purchases, along with adding controls to ensure that the item purchased was received by the District. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for micro purchases but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing. If the oversight agencies have questions regarding this plan, please call Lisa Miller at 715-887-9000.

Condition: The School District is required to account for all revenues and expenditures of its non-profit school food service account in accordance with state and federal requirements. In order to ensure that federal reimbursement payments received monthly from the Michigan Department of Education are correctly credited to the school food service account, monthly bank reconciliations should be prepared and reviewed by individuals with requisite skill and experience. During the 2024 fiscal year, bank reconciliations and monthly reconciliations of food service revenues and expenditures of the school food service account were not being prepared and reviewed in a timely manner. As there was an unexpected reduction in staff resources in the business office, there were not adequate resources to perform these accounting reconciliations on a timely regular basis during the year. The absence of these timely regular reviews could lead to undiscovered errors in the school food service account and material noncompliance with federal regulations. Planned Corrective Action: The School District agrees that its internal control structure should ensure that accounting reconciliations are prepared and reviewed in a timely manner during the year. Although the School District had an intergovernmental Agreement with its Intermediate School District to provide business services, such services could not be rendered due to inability to find staffing. Near the end of the 2024 fiscal year, a Finance Director was directly hired into the business office. Monthly reconciliations of accounting records and closing of monthly books are now being performed and reviewed on a timely basis. Contact person responsible for corrective action: David Bergeron, Assistant Superintendent Anticipated Completion Date: July 1, 2024

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School District is required to have controls in place to ensure the accuracy of the request for reimbursement. The School District did not have a documented review process in place over the reimbursement requests. Meal counts entered into the Michigan Nutrition Data (MIND) system took place without a secondary review, which could result in incorrect reporting of the number of meals. The preparation of the request without a secondary review could result in incorrect reporting of the number of free and reduced priced meals, which could result in the School District being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The School District's business office performed a detailed review of all meal claim submissions for the 2023-2024 fiscal year. Claims were accurately completed as was the amount of reimbursement paid by the Michigan Department of Education. The business office has since implemented a formalized internal control procedure beginning in July 2024, whereby a formal documented review of the meal claim submission is performed. Contact person responsible for corrective action: David Bergeron, Assistant Superintendent Anticipated Completion Date: July 1, 2024

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: ABU started working on partnering with the National Clearing House in the fall 2023 for NSLDS reporting. Due to a system conversion at the time this process took longer than anticipated. However, the first error free report was uploaded 09/01/2024. ABU now has a schedule with set reminders from the clearinghouse to ensure timely and regular reporting. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

Student Financial Assistance Cluster– Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The College is in the process of developing a new procedure which will be implemented in January 2025. Name of the contact person responsible for corrective action: Jonathan Jett,Director of Financial Aid Planned completion date for corrective action plan: January 2025

Finding 2024-004 Reporting – Child Nutrition Cluster Material Weakness in Internal Control Over Compliance Finding Summary: The District does not have an internal control system designed to review and ensure submitted free and reduced meal counts agree to underlying records. Responsible Individuals: Shannon Hunstad, Superintendent Corrective Action Plan: The District will review and strengthen the controls surrounding the review and submission of free and reduced meal counts to ensure they are supported and accurate. Anticipated Completion Date: June 30, 2025

FINDING 2024-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): 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 District in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in 2 place to prevent, or detect and correct, errors. During tie out of the Year 3 report, a variance between the underlying records and reported expenditures of $187,649 was noted due to the lack of effective controls surrounding annual data reporting. 84.425U expenditures submitted within the Year 3 report were overstated by $187,649. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will implement a formal review process over data reporting to ensure compliance with reporting requirements for federal awards. A Grant Coordinator has been hired and is already in place. Both the Grant Coordinator and Treasurer will review and sign off of required reporting and ensure it is completed in a timely manner. Responsible Party and Timeline for Completion: Andrew Grismore - Grant Coordinator and Moriah Crane - Treasurer will be responsible. These corrective measures are already in place.

Finding #2024-005 – Material Weakness and Other Non-Compliance – Procurement. Applicable federal programs: Special Education Grants to States, Assistance Listing # 84.027A, Contract Number: H027A230008, Contract Year: 07/01/23 – 09/30/24, Special Education Preschool Grants, Assistance Listing # 84.173X, Contract Number: H173X210004, Contract Year: 10/01/22 – 09/30/23, Special Education Preschool Grants, Assistance Listing # 84.173A, Contract Number: H173A230004, Contract Year: 07/01/23 – 09/30/24. Recommendation: Reemphasize to personnel the procurement process and adherence to NYOS’ policies and procedures. Planned corrective action: NYOS is restructuring its accounting processes to support monthly financial reporting and reconciliations with all entries in the accounting systems. NYOS will work towards closing and reconciling each month by the 25th of the following month. This full reconciliation will ready NYOS for future audits. Responsible officer: Dr. Mechiel Rozas (Superintendent) and James Dworkin (Interim CFO) Estimated completion date: April 15, 2025.

Finding: 2024-001 Name of contact person: Jacob Joyner, Director of Financial Services Corrective Action: Housing staff is training additional staff to complete inspections and increasing management oversight of the program to ensure compliance with grant requirements.

2024-003 Special Tests and Provisions – UEL Formula (Form 52722) and Formula Income Public and Indian Housing Program – CFDA 14.850 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2023-004 from March 31, 2023 (originally reported as finding 2022-005 from March 31, 2022) Condition: Unable to test HUD Form 52722, 52723, and the utility ledger for accuracy and completion. Recommendation: The Authority should retain the utility ledger for each fiscal year under audit. Action Taken: We concur with the recommendation. Due to the ongoing COVID-19 pandemic and related staff absences and turnover, we were not able to retain the utility ledger. We will retain the utility ledger for each fiscal year under audit. Effective Date: December 12, 2024 Contact Information: Michael Bean, Chief Executive Officer Housing Authority of Brevard County 1401 Guava Avenue Melbourne, Florida 32935 (321) 775-1563

2024-002 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding of 2023-003 from March 31, 2023 (initially occurred as Finding 2022-004 from March 31, 2022) Condition: 25 out of 250 new admissions were selected for testing. Exceptions were noted as follows: • 15 new admissions where the selection from the waiting list was not in compliance with the Authority’s administrative plan. The administrative plan states that that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). However, the applicants tested were ranked randomly through a lottery. Due to this issue, there were many applicants that were not ranked properly on the waiting list and were thus not admitted in proper sequence into the Section 8 program. • 4 new admissions where the Authority was unable to provide support that the applicants were properly selected from the waiting list (as the waiting list for the new admissions that were selected from was not retained). • 1 new admission where the Authority did not sign the lease agreement and the unit address and rent amount on the lease agreement did not agree to the Form 50058. • 1 new admission where the Authority could not provide the tenant’s voucher. Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Action Taken: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were unable to provide an ongoing quality control review process and provide ongoing staff training and timely management reviews. We are focused on implementing such procedures and will review staffing levels, skill sets, and case load for each employee.

2024-001 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream – Vouchers CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance This is a repeat finding (the prior year finding was a significant deficiency) of 2023-002 from March 31, 2023 (initially occurred as Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing. Exceptions were noted as follows: • 1 tenant file had the following errors: o Miscalculation of social security income reported on the form 50058 (used a prior year SSI instead of the current year). Correcting this error would decrease the HAP rent from $1,610 to $1,567. o One missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen. • 1 tenant file had the following errors: o Two members of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificates, the two household members are U.S. citizens. o The 9886 form was not dated. Thus, we do not know if the 9886 form was signed within 15 month required timeframe. • 1 tenant file had the following errors: o Missing 214-affidavit form for a member of the household. However, based on the birth certificate, the member of the household is a U.S. citizen. o The tenant did not sign and date the Form 9886. • 1 tenant file had the following errors and correcting the errors would increase the HAP rent from $1,130 to $1,159: o Miscalculation of social security income reported on the 50058. o Miscalculation of medical expense reported on the 50058. • 1 tenant file error where a member of the household over the age of 18 did not sign the Form 9886. • 1 tenant file error where social security income was calculated incorrectly. Correcting the income would decrease the HAP rent from $1,155 to $1,153. • 1 tenant file error where a member of the household over the age of 18 did not sign the 9886. • 1 tenant file error where the tenant dated the year on the 9886 form 2013 when it should be 2023. • 1 tenant file error where a member of the household over 18 years old did not sign Form 9886. • 1 tenant file error where the tenant’s wage income was miscalculated. However, correcting the error would have no effect on the HAP rent amount. • 1 tenant file error where there was no EIV form for the recertification period. • 1 tenant file error where tenant wage income was calculated incorrectly. Correcting these income issues would decrease the HAP rent from $1,207 to $896. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent from $1,378 to $1,030: o An incorrect utility allowance was reported on the Form 50058. o Income support was not reported correctly on the Form 50058. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the birth certificate, the household member is a U.S. citizen. o Support for tenant’s pension income was over 12 months old. • 1 tenant file error where child support income was calculated incorrectly. However, correcting the error would have no effect on the HAP rent amount. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were unable to provide an ongoing quality control review processes and provide ongoing staff training and timely management reviews. We are focused on implementing such procedures and will review staffing levels, skill sets, and case load for each employee.1 tenant file error where the Form 50058 reported an incorrect utility allowance, but correcting the allowance would not change the HAP rent amount.

U.S. Department of Agriculture Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Material Weakness – Eligibility Finding 2024-003 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: For the WIC program, we were unable to obtain evidence to corroborate the review of the Senior Quality Training Specialist eligibility determinations. Questioned Costs: None Effect: By not having the required documentation to support the review by the Senior Quality Training Specialist, the County is unable to support their assertion the cases are properly reviewed by an individual other than the preparer. Cause: County does not have a formal policy for documenting evidence of the review by the Senior Quality Training Specialist. Recommendation: We recommend the County implement a policy to ensure the review by the Senior Quality Training Specialist is properly documented and retained. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: See below Corrective Action Plan prepared by the County. Program leadership will collaborate The Total Quality Team i.e. Compliance Coordinator and Quality Assurance Coordinator to revise current internal monitoring policies and procedures. Internal monitoring tools will be created to align with state and federal guidelines. Following review with Total Quality, staff will be trained on revised monitoring processes, policy, and procedures. WIC Policy A-19 mandates the use of the State Agency's WIC program monitoring tool for conducting record audits. To ensure proper implementation, this policy will be reviewed with the Senior Quality and Training Specialist. The WIC Senior Quality Training Specialist and WIC leadership will maintain audit documentation in accordance with Policy A-13, Retention of Administrative Documents, established by Mecklenburg County Health Department. The following the phases of the corrective action plan will be completed by March 31st, 2025. Phase1: Review of Federal Guidelines Phase 2: Review Of State Guidelines Phase 3: Internal Policy Review Phase 4: Creation and Implementation of new internal monitoring processes. Phase 5: Staff Training Completion Date: March 31, 2025 Responsible Person(s): WIC Director, Ali Raza and Senior Quality and Training Specialist, Tamika Moore

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Medical Assistance Federal Assistance Listing Number: 93.778 Material Weakness and Nonmaterial Noncompliance – Eligibility Finding 2024-001 – Repeat Finding Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria: a) Self-attestation wages should be compared to information in NC FAST. b) All countable resources should be confirmed and recalculated and ensure they are computed accurately in NC FAST. c) An OVS inquiry must be completed and agreed to information reported in NC FAST. d) An ex parte review is required every six (6) to twelve (12) months. e) Forced eligibility cases should maintain the proper documentation within NC FAST to support the determination for the required forced eligibility. f) For Aged, Blind, or Disabled cases or MQB programs the Register of Deeds is required to be verified and documented in the case file g) The caseworker should prepare and submit a DMA-5097 form in the case of incompatible income verification and self-attestation income as described in the Eligibility Review Document. h) For countable earned and unearned income, income conversion and computation was done in accordance with policy manuals, and have to agree to amounts in NC FAST. Condition: The following are the results of nonmaterial noncompliance noted for each criteria listed above out of the 122 program participants selected for testing: a) There were four instances where the participants self-attest wages did not agree to the wages entered into NC FAST. b) There were three instances where the countable resources were inaccurate within NC FAST. c) There was one instance where the OVS query was not run at the time of the determination. d) There were two instances where the ex parte review was not completed timely. e)There were two instances where the support for the forced eligibility was not properly maintained in NC FAST. f) There was one instance where the Register of Deeds support was not maintained in NC FAST. g) There were five instances where the income was incompatible between the income verification and self-attestation income but no DMA-5097 was sent. h) There were two instances where countable income was not properly included in NC FAST. Lastly, there were 6 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely. Context: There were 14 out of 124 unique participants tested with the errors noted above. Questioned Costs: None noted. Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: The County will take a multi-faceted approach to mitigating such errors in the future. Training: The Staff Development Unit within the Economic Services Division (ESD) will review the findings and create and deliver training to staff that determine Medicaid eligibility and their supervisors and managers to address the specific errors identified. This training will be delivered by the end of January 2025. Responsible Individual(s): Staphon Snelling, Training and Development Manager Anticipated Completion Date: January 31, 2025 Process Improvement: The Economic Services Division (ESD) has trained new hires in one function of the Medicaid program, for example, processing applications or recertifications/changes. This has built a stronger foundation before they learn the second function of their assigned program. Our Supervisors and Quality and Training Specialists are working even more closely together to follow up on errors and help ensure identified challenges in training and mentoring are addressed before they are released from mentoring. Ex parte reviews are directly assigned for Family and Children’s Medicaid and for Adult Medicaid, renewals are placed into Current for workers to get next and work as soon as possible. Family and Children’s Medicaid will provide second-function training for current employees on recertifications. Adult Medicaid has 10 currently in mentoring for recertifications. Kim Konior is responsible for monitoring ex-parte review reports and MAGI cases are being assigned out by Supervisor Collin Smith and Jannicia Austin for Adult Medicaid. Each month the Medicaid managers Kim Konior and Lynn Martin review the progress and update the Assistant Division Director on the current status and plans to continually improve in this area. Supervisors will ensure that second party reviews are reviewed and corrected for any internal control and eligibility errors within 5 business days of receipt. Supervisors ensure that updates to the quality sampling tracking log are completed by the 20th day of the following month. Responsible Individual(s): Kim Konior and Lynn Martin Medicaid Program Managers and Staphon Snelling, Training and Development Manager Anticipated Completion Date: Will begin Family and Children’s Medicaid recertification training in third Quarter of FY25 (Jan 2025) and end by the end of 2nd quarter of FY 2025 (December 2025). Quality Sampling and Accountability: The Quality and Training Unit complete monthly quality sampling for Medicaid. Error trends are shared with the managers and their supervisors, who work collaboratively with Quality and Training staff to coordinate appropriate strategies to train and coach staff to mitigate errors moving forward. Supervisors review specific quality sampling results with their staff. The supervisor when necessary and appropriate, address continued errors using an individual Corrective Action Plan with the worker to include refresher training, additional second party review and/or initiating the formal documentation process. Managers review quality sampling results with supervisors quarterly to follow up on errors addressed, trainings completed and progress with individual Corrective Action Plans. Supervisors, front line, and Managers have quality measure on their workplan to ensure timely response and accountability is held. All levels are to achieve an average quality score of 80% quarterly. Note that this error was found at a much higher rate last year. We are continuing to reinforce this importance and expect the improvement that we have achieved within one year will continue to grow as we keep reinforcing quality into our everyday work culture. Protocol for second party reviews provided 08/2024 in place for ESD. Cases will be checked by Quality and Training by the last day of each business month. Quality and Training will check and provide feedback to workers within 2 business days of the case being checked. Corrections of errors and rebuttals for QS errors should be submitted within 5 business days of feedback being provided and a response will be received within 3 business days of receipt. The Quality Assurance team in OSI/CFAS conduct an independent evaluation and review the second party review process at the divisional level to ensure review was accurate and errors were corrected timely. This team reports out to ESD Leadership quarterly on findings. Responsible Individual(s): Kim Konior and Lynn Martin, Medicaid Program Managers & Julio Rosales, Quality Assurance Supervisor, Staphon Snelling Training and Development Manager Anticipated Completion Date: Currently Ongoing

MATERIAL WEAKNESS 2024-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV and Enrollment Reporting Condition The College's official policy is to be an attendance taking institution. However, the date of the institution’s determinations for withdrawals does not fall within the required 14 day period, and it instead follows that of institutions that are not attendance taking. Additionally, during testing, it was identified that the College's quality control processes for Return to Title IV calculations were not completed within a timely manner, and that process determined that calculations needed to be adjusted for some of the students. Those corrections were not made within the required 45 day periods, and, as a result of the late corrections, the NSLDS enrollment reporting also had to be updated outside of its typical window. Recommendation We recommend that the College review and update its policies to ensure that all compliance requirements are met within the required timeframes associated with those policies, as well as recommend that the College review its controls to ensure that accurate Return to Title IV calculations are completed in a timely fashion. Comments on the Finding Recommendation Barton County Community College understands the finding. Action Taken Barton’s Director of Financial Aid has informed the following Barton personnel of the finding: • Vice President of Instruction, • Vice President of Student Services, • Dean of Academics, the Dean of Workforce Training and Community Education • Dean of Military Programs, Technical Education, and Outreach Programs • Associate Dean of Instruction The Vice President of Instruction is initiating a project to involve these parties in the implementation of a procedure to report unofficial withdrawals by 14 calendar days to ensure Return of Title IV is completed within the regulatory timeframes and reported to NSLDS within the regulatory timeframe. Date of Implementation: This will be implemented for the spring 2025 term.

The South Central Cooperative Director, Kristi Hilzendeger, is the contact person responsible for the corrective action plan for this finding. This finding is due to the size of the South Central Cooperative, which precludes staffing at a level sufficient to provide an ideal environment for internal controls. The Cooperative has developed policies to help monitor the lack of segregation of duties but due to the size of the Cooperative it is not feasible, or fisally responsible to implement anything else at this time. The Cooperative will contrinue to follow the controls currently in place.

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: ABU started working on partnering with the National Clearing House in the fall 2023 for NSLDS reporting. Due to a system conversion at the time this process took longer than anticipated. However, the first error free report was uploaded 09/01/2024. ABU now has a schedule with set reminders from the clearinghouse to ensure timely and regular reporting. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2024

Finding Number: 2024-002 Condition: During the audit, it was determined that there is no control function in place by the Airports staff to ensure that wage rate compliance with weekly certified payrolls is occurring. Planned Corrective Action: N/A - corrective action detailed above was implemented during February 2024 in full. Contact person responsible for corrective action: Karen Honda, Fiscal Management Officer Anticipated Completion Date: February 1, 2024

Finding Number: 2024-001 Condition: There is no evidence of review of reports submitted to the funding agency. Planned Corrective Action: The City of Grosse Pointe Farms has hired additional staff in the accounting department that will complete review of reports prior to submission to the funding agency. Contact person responsible for corrective action: Tim Rowland, Finance Director Anticipated Completion Date: 09/03/2024

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: One instance was identified where there was no documented return of Title IV calculation, and fourteen instances were identified where there was no documented review of the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid Director recently completed R2T4 process training with the Controller. This added expertise will enhance the secondary review process, providing an independent assessment by a reviewer not involved in daily operations. This additional oversight will strengthen quality control through sampled calculation reviews. Furthermore, expanded attendance and withdrawal reports will support comprehensive control processes for this cluster. Anticipated Completion Date: Commenced December 1, 2024

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.269Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid will update the unofficial withdrawal process with successful completion definition to be inclusive of requiring a passing grade. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: December, 15 2024

Planned Corrective Action: Management will develop internal controls and oversight over the schedule of expenditures of Federal awards. Contact Person: Name: Brianne Hoelschen Title: Controller Phone: (617) 209-5222 Email: bhoelschen@maloneyproperties.com Anticipated Completion Date: June 30, 2025