Corrective Action Plans

NSU – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: To ensure accurate and timely reporting of changes in student enrollment status to the National Student Clearinghouse (NSC), Nevada State University (NSU) will enhance its internal controls by implementing the following measures: o Continue the current bi-weekly enrollment reporting schedule. o Set bi-weekly calendar reminders to ensure timely reporting, supplementing NSC notifications. o Establish end-of-term calendar reminders specifically for reporting graduated statuses promptly. o Work closely with the NSC to identify any students included in submitted enrollment reports whose statuses were not updated within the NSC or National Student Loan Data System (NSLDS), ensuring they are addressed even if they do not appear in the reject file. • How compliance and performance will be measured and documented for future audit, management and performance review: To ensure ongoing compliance and performance in reporting changes in student enrollment status, Nevada State University (NSU) will implement the following measures for tracking and documentation: o NSU will conduct monthly reviews of enrollment status reports to verify the accuracy and timeliness of submissions to the National Student Clearinghouse (NSC). o Detailed logs of all enrollment status submissions and NSC notifications will be maintained, including timestamps and submission confirmations, to serve as an audit trail for internal and external reviews. o Periodic internal audits will be scheduled to assess adherence to the bi-weekly and end-of-term reporting schedule, with results documented for management review. o Key performance indicators (KPIs) will be established, such as the percentage of on-time reports and the accuracy rate of enrollment status updates. These metrics will be reviewed quarterly by management. o Any discrepancies identified during audits will be addressed promptly, and corrective actions will be documented for future reference and performance evaluations. o NSU will compile annual compliance reports summarizing audit results, corrective actions, and performance metrics, which will be available for future audits and management reviews. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Registrar's Office holds primary responsibility for accurate and timely enrollment status reporting. The Registrar will oversee compliance with internal controls including the bi-weekly and end-of-term reporting schedules. Additional oversight will be conducted by the Provost and Vice President of Academic Affairs. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

CSN – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: CSN has contracted with a third-party vendor to help review and process R2T4 accounts within the federally mandated timeframe. CSN is currently in the training phase and expects to have the vendor begin reviewing R2T4 file in the next several weeks. In addition, regular monthly training will be provided to CSN staff and the third-party vendor. Quality control through the review of processed R2T4 files will be performed twice a month. • How compliance and performance will be measured and documented for future audit, management and performance review: In collaboration with the third-party vendor, CSN will run R2T4 queries twice a month to ensure all files are reviewed within the federally mandated timeframe. The vendor will also review internally selected files for accuracy. CSN will also randomly select processed files review to meet compliance requirements. CSN will meet with the vendor on a monthly basis and maintain communication throughout the year to ensure consistency and compliance. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Assistant Director of Processing in the Office of Financial Aid will be responsible for repeat or similar observations. UNLV – Agrees with the finding. There were two findings at the conclusion of the audit. Corrective action plans as well as measurements of compliance and performance correspond with the following two findings: 1. A return was calculated as $2,270, but should have been $1,975. 2. The second finding was regarding an improper return. UNLV’s calculation was correct at $0, as documented for the audit team. Months after the R2T4 calculation was performed, the student did not return to UNLV. At that time, their Pell Grant was appropriately canceled, but due to a system error, their Pell Grant for the entire year was canceled instead of just for subsequent semesters. Through our internal controls we found this error, but did so beyond the permissible 180-day late disbursement period. The error was unrelated to the R2T4 process and had no bearing on the correctly performed calculation. Since the Pell Grant could not be reinstated, we made the student whole with institutional funds. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: 1. Since the late disbursement period had passed, and the student had no balance due, there was no immediate corrective action that could be taken. The calculation error related to a withdrawal date incorrectly reported by a faculty member during spring break. The PeopleSoft system is set up to prevent the entry of such spring break withdrawal dates, and we were unable to replicate the error. The issue has therefore been escalated to our technical team for investigation and for prevention in future years. Even if this proves successful, we will ensure that at least two staff responsible for oversight of the R2T4 function will sign off each spring that no calculations are based on a withdrawal date that occurs during spring break. The signoff will occur within seven days of the end of spring break, so that if any error is identified we may still correct it while remaining within the appropriate R2T4 timelines. 2. The erroneous retroactive cancellation of Pell Grants for unenrolled students is now a known PeopleSoft issue. Beginning in fall 2024, we have established programming that packages Pell Grants on a semester-by-semester basis so that any changes to a current-term grant do not impact a prior-term grant. • How compliance and performance will be measured and documented for future audit, management and performance review: 1. A report exists in PeopleSoft that documents the withdrawal date of each student for whom an R2T4 calculation is performed. This report will be used to collect signoffs by two UNLV staff with R2T4 oversight that no calculations are based on a withdrawal date occurring during spring break, and will serve as the basis for that signoff. 2. Pell recipients' accounts will be reviewed in spring 2025 to ensure our packaging approach was effective in preventing retroactive grant cancellations. The team will review monthly to ensure we stay within the 180-day late disbursement time frame, which will allow us to reinstate Pell Grants retroactively, should our original solution prove ineffective. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: If similar errors around spring break R2T4 calculations and/or retroactive Pell Grant cancellations occur in the future, of primary accountability will be the Assistant Director of Processing, the Associate Director of Operations, the Associate Director of Processing and Client Services (currently vacant), the Director, and the Executive Director. UNR – Agrees with the finding. The Financial Aid office recognizes a shortfall in this area due to unexpected changes in staffing. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: New R2T4 staff is currently undergoing in-depth calculation training which includes internal trainings, NASFAA workshops, and Federal Student Aid provided trainings. In addition, starting this fall, 100% of R2T4 files are being reviewed by a staff member who was not responsible for the initial calculation. To prevent late returns, our office is calculating returns within 15 days of the withdrawal date and return funds within 30 days of the withdrawal. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance with the above corrective action will be monitored by the Data Manager, who will be reviewing weekly R2T4 reports completed by R2T4 staff. Reports with return data will be compiled in one centralized location to ensure transparency of current return status, and a physical audit trail documented on the R2T4 coversheet detailing initial calculation date, audit check date, and return to COD date. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The R2T4 staff and the Financial Aid Director will be responsible. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Management will establish and fund a segregated reserve account.

Finding 2024-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will pull the End of Day Summary Reports from Lunchtime and input the information into the Child Nutrition Portal. All reports will be provided to the controller to confirm accuracy. Once reviewed and approved, the food service director will submit the report through the Child Nutrition Portal. All documents will be scanned together and be retained for audit. Anticipated Completion Date: October 2, 2024

Finding 2024-001 – Child Nutrition Cluster – Eligibility Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: School corporation personnel will conduct an annual review of the income eligibility guidelines used by the food service software. The review will ensure that the guidelines are current, accurate, and consistent with federal and state requirements. The results of the review will be documented, and any necessary updates or changes will be implemented promptly. Anticipated Completion Date: November 13, 2024

The audit for the year ended June 30, 2023 was not submitted to the Federal Audit Clearinghouse due to issues with the UEI numbers not being renewed timely on the Academy’s side. The Finance Director is now responsible for the renewals going forward, and this will not be an ongoing issue in the future.

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways:1.     We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included.2.     All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested.

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways:1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included.2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested.

Condition - The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended June 30, 2023. Planned Corrective Action - The audit for the year ended June 30, 2023 was not submitted to the Federal Audit Clearinghouse due to issues with the UEI numbers not being renewed timely on the Academy's side. The Finance Director is now responsible for the renewals going forward, and this will not be an ongoing issue in the future. Anticipated Completion Date: November 15, 2024 Point of Contact: Mary Ann Johnson

Condition - During our testing for Activities Allowed or Unallowed, Allowable Costs/Cost Principles, it was noted that 6 out of 6 payroll transactions selected for testing did not have evidence of review and approval. Planned Corrective Action Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested. Anticipated Completion Date: December 1, 2024 Point of Contact: Mary Ann Johnson

Condition - During our testing for Reporting, it was noted that 2 out of 2 reports selected for testing did not have evidence of review and approval. Planned Corrective Action: Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and_ date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested. Anticipated Completion Date: December 1, 2024 Point of Contact: Mary Ann Johnson

Condition - During our testing for Cash Management, it was noted that 2 out of 2 drawdown requests selected for testing did not have evidence of review and approval. Planned Corrective Action: Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested. Anticipated Completion Date: December 1, 2024 Point of Contact: Mary Ann Johnson

2024-001 – Special Tests and Provisions – Wage Rate Requirements (repeat). U.S. Department of Education – COVID-19 - Education Stabilization Fund (ALN 84.425D, 84.425U and 84.425W); Passed through the Michigan Department of Education; All project numbers. Auditor Description of Condition and Effect: One of the contracts selected for testing that was subject to the Wage Rate Requirements did not include the required provision, and the District did not obtain the required certified payrolls. In addition, another contract selected for testing had the Wage Rate Requirements required provision, however, the District was unable to obtain the required certified payrolls. Auditor Recommendation: We recommend that the District reviews its policies to ensure that applicable prevailing wage requirements are included in construction contracts whenever federal funds are used and certified payrolls are obtained. Corrective Action: District officials will ensure that construction contracts contain these requirements during the bidding and/or proposal process. Responsible Person: Rebecca Jones, Superintendent and Kendra Leib, Director of Finance. Anticipated Completion Date: June 30, 2025.

The District Corrective Action Plan is to follow the corrective action plan set forth in the site review by the State of Alaska Child Nutrition Program to have intense staff meetings with cooks and meal counters to make sure point of service meal counts in the cafeteria or in the classroom are clear and accurate for reporting. School sites visits, discuss counting at point of service, claiming, reimbursable meals, production records, ordering, safety and hygiene. Attend monthly zoom with School Meals Program (Dept. of Education).

Finding 2023-001 Internal Control Over Financial Closing and Reporting Type of Finding: Material weakness Condition: During the course of the audit, we noted that a material weakness in internal control over financial reporting exists in the District’s financial statement close process for preparing its year-end financial statements. Some grants were not properly reconciled and accounts receivable, cash, inventory, due to/from, payroll liabilities and unearned revenue, required adjustments. Status: This finding has been resolved.

Item # 2024-01 Inadequate Internal controls over the recognition of revenue (Material Weakness in Internal Control over Financial Reporting) Criteria: Under U.S. Generally Accepted Accounting Standards, revenue for conditional, cost reimbursement grants is recognized when the related expenditures are incurred. Condition: Based on the results of our audit testing, we noted two material grant billings that were not recorded in the period the expenditures were incurred and were instead recorded when invoiced. Cause: Internal controls failed to detect misstatements in revenue during the year June 30, 2024. Effect: The effect of the condition was an adjustment to increase revenue (and the related by receivable) by $372,638, which was recorded in the June 30, 2024 consolidated financial statements. Auditor’s Recommendation: Management should perform a thorough analysis of revenue around fiscal year end to ensure revenue is recorded properly. Views of Responsible Officials and Planned Corrective Actions: Management understands that additional oversight and review of revenue recognition is necessary. Controls will be put into place to prevent revenue recognition issues.

CORRECTIVE ACTION PLAN October 21, 2024 Berkeley County Public Service Water District respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, VA 2280l Audit period: June 30, 2024 The findings from the June 30, 2024 Schedule of Findings and Questioned Costs (the "Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS- FINANCIAL STATEMENT AUDIT 2024-001: Material Audit Adjustments (Material Weakness) Condition: During the audit, we detected material misstatements in the trial balance. Generally accepted auditing standards dictate that detection of errors in an audit is a strong indicator of a significant deficiency or material weakness. Accordingly, we are required to communicate this finding as such. Recommendation: Material audit adjustments indicate that financial information presented to us for the audit was missing or inaccurate. We recommend that management implement processes to ensure accuracy of a accounts. Additionally, all adjustments that were made as a result of our current year audit should be reviewed during the next year as a reminder of matters needing accounting attention in preparing for the 2025 audit. Corrective Action: The District uses outside parties to oversee grant management and lease calculations, both items that required material adjustments. District management will review work performed by outside parties to ensure completeness and accuracy. FINDINGS AND QUESTIONED COSTS-MAJOR FEDERAL AWARD PROGRAM AUDIT 2024-002: Single Audit Performance -Assistance Listing #66.468 and Reporting Condition: A single audit was not performed for a major program for the fiscal year ended June 30, 2023. Criteria: A single audit in accordance with the requirements set forth in the Uniform Guidance is required if total federal expenditures exceed $750,000 in a fiscal year. Federal expenditures exceeded $750,000 and the major program was a high-risk Type A program for the year ended June 30, 2023. Cause: The program required revolving loan fund drawdowns, which did not occur within the fiscal year funds were expended. Effect: The identified Type A high risk program was not tested as major. Questioned Costs: N/A Recommendation: Ensure management considers federal award compliance requirement and ensures that such requirements are satisfied each year. Corrective Action: Management will monitor major programs and ensure that they are tested when necessary. The grant in question was tested during 2024. 2024-003: Controls Over Cutoff - COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing #21.027 and Compliance- Material Weakness Condition: During our review of CSLFRF expenditures, we noted approximately $2,577,622 of allowable costs that were recorded in the wrong period. Criteria: The expenditures must be reported in the proper period for accurate reporting on the Schedule of Expenditures of Federal Awards. Cause: Procedures in place to ensure all expenditures are recorded in the proper period were not followed. Effect: Approximately $2,577,622 of allowable costs were recorded in fiscal year 2025 instead of fiscal year 2024. Questioned Costs: N/ A - the expenditures in question are allowable costs that were reported in the wrong fiscal year. Perspective Information: Five invoices were recorded in the wrong fiscal year. Recommendation: We recommend continued communications with all individuals involved in the grant process to ensure activity is recorded in the proper reporting period. Corrective Action: The District uses an outside party to oversee grant management. District management will review work performed by outside parties to ensure completeness and accuracy. If the Federal Audit Clearinghouse has questions regarding this plan, please call Jim Ouellet, Executive Director, at 304 262 3371.

Strengthening Institutions Program - Department of Education Federal Financial Assistance Listing #84.031 P031A080196 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: Annual report for the year ending June 30, 2023, was not filed. Responsible Individuals: Michael Van Surksum, Vice President for Business and Finance Corrective Action Plan: Management will review their current process to ensure reporting requirements are met. Anticipated Completion Date: Already complete - annual report for the year-ending June 30, 2024 has now been submitted.

Management has created a new Inspection Coordinator position that is responsible for the HCV inspection process. This position will report monthly on the status of scheduled inspections. The Housing Manager will be responsible to ensure that HAP payments are abated for units that do not meet inspection requirements.

The Housing Manager will complete quality control file reviews from a random sampling of applicant files to ensure that they contain all required documentation for eligibility determination. An external agency will be hired to conduct a complete a full file audit of active files.

A. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations. 1. Finding 2024-001 U.S. Department of Housing and Urban Development Supportive Housing for Persons with Disabilities (Section 811) – CFDA 14.181; Grant period – Year ended June 30, 2024 a. Comments on the Finding and Each Recommendation. Statement of Condition: The Project did not request tenant assistance payments for the month of April. Criteria: The Regulatory Agreement requires the Project to ensure controls exist to request the appropriate funds for each tenant on a monthly basis. Cause: The Project’s controls over monthly housing assistance payments were not working properly due to lack of management oversight due to turnover during the year. Effect of Condition: The Project is not in compliance with the HUD approved Regulatory Agreement. Recommendation: We recommend that the Project’s sponsor review the design and implementation of internal control procedures and identify areas to strengthen management oversight. b. Action(s) Taken or Planned on the Finding 1. The Project’s sponsor is aware of the requirements of the HUD Regulatory Agreement and is working with new staff to ensure they receive the proper training on HUD requirements. 2. In August 2024, the April 2024 HAP requests were submitted for payment.

B. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations. 1. Finding 2024-002 U.S. Department of Housing and Urban Development Supportive Housing for Persons with Disabilities (Section 811) – CFDA 14.181; Grant period – Year ended June 30, 2024 a. Comments on the Finding and Each Recommendation. Statement of Condition: The Project did not request tenant assistance payments for the month of April and failed to re-submit a tenant assistance request for the month of December. Criteria: The Regulatory Agreement requires the Project to ensure controls exist to request the appropriate funds for each tenant on a monthly basis. Cause: The Project’s controls over monthly housing assistance payments were not working properly due to lack of management oversight due to turnover during the year. Effect of Condition: The Project is not in compliance with the HUD approved Regulatory Agreement. Recommendation: We recommend that the Project’s sponsor review the design and implementation of internal control procedures and identify areas to strengthen management oversight oversight. b. Action(s) Taken or Planned on the Finding 1. The Project’s sponsor is aware of the requirements of the HUD Regulatory Agreement and is working with new staff to ensure they receive the proper training on HUD requirements. 2. In August 2024, the April 2024 HAP requests were submitted for payment.

A. Current Financial Statement Findings 1. Finding 2024-001 Material Weakness in Internal Controls over Financial Reporting a. Comments on the Finding and Each Recommendation. Statement of Condition: Numerous accounts were identified that required adjustment as part of our audit procedures, including accounts receivable -HUD and depreciation expense. Due to the number and nature of the required audit adjustments, we are considering this deficiency to be a material weakness in internal control over financial reporting. The misstatements that were discovered as a result of audit procedures would have had the following impact on the financial statements if left unadjusted: Assets understated by $26,943 Liabilities understated by $7,593 Net assts understated by $19,350 Revenues understated by $9,313 Expenses overstated by $10,037 Criteria: It is the responsibility of the Project’s Sponsor to design and implement internal controls over financial reporting to ensure that Project’s accounts are properly recorded in accordance with U.S. GAAP. Significant adjustments that arise as a result of audit procedures that were otherwise not detected by the Project’s sponsor are required to be reported as a deficiency in internal control over financial reporting. Cause: There were errors identified in the Project’s depreciation calculations which were not identified and corrected as part of the financial close and reporting process. Amounts due from HUD for HAP requests not filed during the year were not recorded as accounts receivable. Effect of Condition: Failing to review and/or fully reconcile all of the significant accounts of the Project, may cause the financial statements to be materially misstated. Recommendation: We recommend that the Project’s sponsor review the design and implementation of internal control procedures and identify areas to strengthen the Project’s internal controls. We also recommend the Project’s sponsor ensures there is a process in place to review year-end balances to ensure all transactions have been recorded correctly.b. Action(s) Taken or Planned on the Finding 1. The Project’s sponsor has implemented staff responsibility charts to ensure that all financial statement areas have the appropriate review and approval. 2. The Project’s sponsor is providing training to their staff on the HUD Handbook and related regulations.

The District plans on reviewing federal revenue accounts with the District’s Grant Auditor Report, Berrien RESA report, and other federal grant documents and reconcile to federal grant expenditures in the District’s general ledger when preparing the District’s Schedule of Federal Awards.