Corrective Action Plans

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Illinois Office of Emergency Management Federal Financial Assistance Listing #97.036 Program Name: Disaster Grants – Public Assistance Finding Summary: The Cooperative did not retain documentation to support the review and approval over material costs claimed for reimbursement under the program. Responsible Individuals: Scott Seipel (Warehouseman), Ryan Ruppel (Superintendent) Corrective Action Plan: A line or lines will be added to the material charge out sheet to formalize the review and approval. The Superintendent of Operations will begin reviewing and approving all material charge out sheets and documenting that review to supplement the review currently being done by the Warehouseman when entering the material charge out sheets prepared by other employees or contractors. Anticipated Completion Date: We believe this corrective action plan can be reasonably incorporated into our internal controls by June 2025 and will make necessary arrangements to ensure that it does get incorporated.

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. The department will monitor expenses within the budget and grant period based on guidance from the federal agency to ensure that the date of expenditures are not claimed before grant funds are received. Contact Person: Eric Haas, Assistant CFO Anticipated Completion Date: December 2024

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. To address this, the department will run quarterly reports from AWARE to identify any payments charged to the incorrect period of performance. Grant guidance has been updated to ensure items with unique service dates are properly reviewed. Additionally, during the three-month liquidation period, a monthly review of all expenditures will be conducted to verify they are applied to the correct period of performance. These actions will strengthen oversight and ensure compliance with grant requirements. Contact Person: Eric Haas, Assistant CFO Anticipated Completion Date: December 2024

Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. We have updated our grant award templates to include all required information. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: This has already been implemented effective 2/1/2025.

State Treasurer’s Office Response/Corrective Action Plan: The Office of State Treasurer does agree with finding that our grant award template did not make subrecipients aware of all required grant award information for the Mineral Leasing Act as required. The Office of State Treasurer will review and update its grant award templates to ensure that subrecipients are made aware of all required grant award information. Contact Person: Nicole Krivoruchka, Director of Finance Anticipated Completion Date: December 31, 2025

A.    DESE has informed us that if this situation ever comes up in the future, asking for a federal extension if buses were not going to be delivered in a timely manner, in this case by January 10, 2025. The manufacturer assured us that the buses would be delivered by November 4, 2024 so we didn’t asked for the extension.

B.     In the future, we will wait until buses are on site to write checks.

C.     We do not anticipate any ESSER ARP money to be issued in the near future.

Management’s Response: The Human Resources (HR) team of the Chief Human Resources Officer and the HR Generalists are responsible for completing background checks for existing new employees. The HR team will ensure proper and required background checks are completed, reviewed and approved for all new and existing employees. Proper documentation and results of all background checks will be reviewed and filed accordingly. Estimated Completion Date: September 30, 2025 Responsible Position: Brent Wauneka, Chief Financial Officer; Ronnye Etsitty, Chief Human Resources Officer; and Chasity Jones and Vivian Upshaw, Human Resources Generalists

3.1.Ensure that the inventory expenses charged to the federal program are allowable within the period of performance. Responsible Official: Head of Operations, Supply Chain Managers, DRD Operations, SCM RTAs, Completion Date: September 30, 2025

2.1 Ensure timely reconciliation of inventory distributions in order to record the transactions in the correct accounting period. Responsible Official: Head of Operations, Supply Chain Managers, DRD Operations, SCM RTAs, Completion Date: September 30, 2025

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2024 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2024-001 Period of Performance Description of Finding Community Development Block Grant – Entitlement (ALN 14.218) funds must be expended by the end of the eighth fiscal year after the fiscal year of appropriation the combined effect is to provide an expenditure period of eight fiscal years from the fiscal year of appropriation. For award B-17-MC-09-0007 (CDBG 2017), the eighth year after the year of appropriation ended on June 30, 2024. On this date, amount left unexpended after the end of the period of performance was $17,814. Statement of Concurrence or Nonconcurrence Management agrees with this finding. Corrective Action We recommend that the City review processes and controls related to timeliness of CDBG expenditures to ensure they comply with federal award requirements. Projected Completion Date June 30, 2025 Name of Contact Person Joseph Feest, Economic Development Director

Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: Kansas Division of Emergency Management (Management) did not issue subawards to subrecipients until after the fiscal year ended. Recommendation: We recommend that Management reviews and enhances its internal controls and procedures to ensure that subawards are issued timely to subrecipients, and that subawards include all required federal award information. Views of responsible officials: Management partially agrees with this finding. Although the 2023 2 CFR § 200.332 does state that the award letters should be sent at the time of the award, there needs to be some reasonableness to the interpretation of this regulation. KDEM currently has 13 open disasters with over 100 open projects and more being written. It is not reasonable to interpret that the award letters be sent on the date that the award is granted. Action taken in response to finding: Management will utilize the report run for FFATA to send award letters to sub-recipients. Name(s) of the contact person(s) responsible for corrective action: Jennifer Deal, Fiscal & Grants Management Section Chief Planned completion date for corrective action plan: Ongoing

Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider. From review of the expense population, we noted 2 payments to the service provider where the service provider was not paid until after liquidation date of December 29, 2023. The School Corporation did not pay the service provider until April 30, 2024 for $258,488 for the services provided. Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corporation will have all Special Ed funds paid before liquidation date. Anticipated Completion Date: 12/29/25

Corrective Action: More than one person has been given access to the portal to upload financial reports in case of turnover or other unforeseen circumstances. Person Responsible: Melinda Graham, Director of Finance Timing for Implementation: Effective October 1, 2024

Finding 2024-001 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance Identification of the federal program: Federal Grantor: United States Department of Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: Michigan Health & Hospital Association Ascension Ministry Market: Michigan Pass-Through Award Number: SLFRP0127 Pass-Through Award Period: 12/01/2021-09/30/2023 Views of responsible officials: Ascension will reinforce the importance of timely approval of timecards for those participating in grant activities. For this grant, Ascension was allowed to identify eligible expenditures retrospectively; thus, grant-specific approval processes were not performed. All expenditures submitted for reimbursement were validated for adherence to the terms and conditions of the award. Responsible Official: Rob Madsen, Director of Accounting and Reporting, Grants & Research Anticipated completion date: May 1, 2025

Finding Number: 2024-002 Program Name/Assistance Listing Titles: Title I Grants to Local Educational Agencies; Education Stabilization Fund Assistance Listing Numbers: 84.010; 84.425U; 84.425W Contact Person: Kris Terwilleger, Director of Finance Anticipated Completion Date: June 30, 2025 Planned Corrective Action: Will adjust process of JE approval to include contingency plan that in the event of the accountant being absent, the Senior Buyer will prepare the JE for Director of Finance approval.

Auditor Description of Condition and Effect. This condition was caused by a lack of detailed review of the Return to Title IV calculation and days used in the Spring 2024 semester. As a result, four students' Return to Title IV calculations were performed using incorrect start dates for the 2024 Spring semester resulting in an understatement in $84 of Pell awards to the students. The College corrected this issue with the Department of Education on July 30, 2024. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of days used in the Return to Title IV calculation is accurate and that the Return to Title IV calculation is being reviewed by a second individual. Corrective Action. The College has performed the necessary steps to correct the error and will develop a process to ensure that a second individual is reviewing the work performed. Responsible Person. Maryann DeCaire, Director of Financial Aid. Anticipated Completion Date. April 30, 2025.

Exempt employees will enter time into their timesheet every payroll and supervisors will approve the timesheet.

Our Agency has included activities as a joint force’s initiative with other agencies and entities in an outreach task. We have been authorized to use the distribution waiver of percentages to have a better or bigger span for our youth populations. We also signed a memorandum of understanding with attractive entities like the PR National Guard and have planned activities reaching youth from school programs to communities without school youths. Our alliances with DDEC, Azore and the Department of Education will contribute to an increase in youth program expenses. We have strategically created an initiative that targets in-school youths where we’ll provide workshops focused on elevating their skills and creating real-time experiences. The memorandum we have with the Department of Education has facilitated this strategy. The Individual Training account (ITA) program will also be promoted in our school district to identify candidates with barriers that can be served through our program. As part of our outreach strategy, we plan to visit foster homes alongside the Department of the Family, which we have signed a memorandum to target this group of disadvantaged youths, as well as projects we have signed with the vocational schools in our district providing real time and paid work experience. With the nine municipalities comprising our area will develop summer work experience targeting our in-and-out school youth (TSY, OSY) populations. The estimated expenses for these initiatives, based on last year's outcome, will reach the goal parameters of programs under WIOA Act. IMPLEMENTATION DATE June 2025 RESPONSIBLE PERSONS Budget Director, Executive Director, Directors of Programmatic and Operations

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Year – May 31, 2024 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Corrective Action Plan Corrective Action Planned: {The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring. Identify the specific actions to be taken to eliminate or mitigate the recurrence of the finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Kemia Himon, Financial Aid Director Anticipated Completion Date: 3.3.25

MENT OF HEALTH AND HUMAN SERVICES 2024-002 Period of Performance Block Grants for Community Mental Health Services – ALN 93.958 Condition: Expenses incurred in fiscal year 2023 were included as expenses to the federal program in fiscal year 2024. Recommendation: We recommend the organization enhance its internal controls to ensure expenses for the correct grant period are charged to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will enhance its internal controls to ensure expenses for the correct grant are charged to the federal program properly. Name of the contact person responsible for corrective action: Michelle Glines, Chief Financial Officer Planned completion date for corrective action plan: 6/30/2025

In order to strengthen internal controls, the School District will train the staff responsible for reimbursement requests, final reports, and amendments as well as those responsible for purchasing for the grant to ensure that there is proper supporting documentation and grant management. The training will include but is not limited to: NJ Finance law, good business practice, as well as a review of the purchasing manual. After this training in completed, the business office will be responsible for the review of reimbursement requests, final reports, amendments and purchases, prior to completion and submission to ensure compliance with the grant requirements and purchasing laws.

Finding 2024-002 Federal Agency Name: Department of Education Assistance Listing Number: #84.268 Program Name: Federal Direct Student Loans Finding Summary: 1 of the 60 students selected for testing the reporting of student status changes were reported with the incorrect enrollment status based on NSLDS Enrollment Reporting guidance. 3 of the 60 students selected for testing the reporting of student status changes were reported to NSLDS with incorrect program begin dates based on NSLDS Enrollment Reporting guidance. 1 of the 60 students selected for testing the reporting of student status changes were reported to NSLDS with an incorrect status effective date based on NSLDS Enrollment Reporting guidance. Corrective Action Plan: LATC currently runs a SQL database script against the enrollment file before sending it to NSC. This script checks for missing and erroneous data (race/ethnicity, nondegree seeking majors, anticipated grad dates, etc.) in the file and updates it to correct values. The Director of Enrollment will work with the Database Administrator to regularly update these tables and review to ensure accurate information is being imported. The Registrar’s office will manually investigate these records and (if necessary) updated before sending the file to NSC. Every 30 days, representatives from the Financial Aid and the Registrar’s departments will pull 10 randomly selected student files to compare information in National Student Clearinghouse, PowerFaids, and NSLDS. The Director of Enrollment will work the error reports that the National Student Clearinghouse sends to LATC after every enrollment file upload with the assistance of the Database Administrator to ensure data submitted is compliant with DOE regulations. The Director of Financial Aid will review NSLDS to ensure corrections submitted by the Director of Enrollment are being properly recorded. Responsible Individual(s): Eric Schultz, Director of Enrollment and Kayla Bossly, Director of Financial Aid Anticipated Completion Date: Corrections complete by December 31, 2024. New process is ongoing.

2024-003 Segregation of Duties: Internal Control Finding - Allowable costs and related activities made electronically were made without documented approval in 3 out of 51 transactions. Corrective Action Plan – Internal controls over electronic payments have been established and documented to ensure appropriate segregation of duties. Ginny Willey, Human Resource Director, will verify the invoice tied to the ACH Disbursement matches the bank statement each month, and initial the bank statement and invoice once this is verified. Documentation of this approval will be maintained with the invoice and bank statement. Implementation Date of Corrective Action Plan - January 5, 2024