Corrective Action Plans

Finding: 2024-002 Enrollment Reporting Responsible Party: Dr. Karen Jarrell, Director of Office of Student Records and Registrar Completion Date: December 30, 2024 The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data System (NSLDS). The university uses a servicer, National Student Clearinghouse (NSC) to complete the reporting requirement. Enrollment data is scheduled to be transmitted to the NSC every thirty days to ensure timely reporting to the National Student Loan Data System (NSLDS). The University has consistently met this 30-day reporting to NSC. The audit noted four students had incorrect program start dates in NSLDS from April 2022 and August 2022, each off by one day. The University’s Student Information System (SIS) reflects the correct program start dates, indicating a potential issue in the data transmission between NSC and NSLDS. In July 2022, several announcements were made concerning the technical issues with NSLDS which prevented reporting for periods of time, including “NSLDS Professional Access – Documentation of Enrollment Reporting and Post-screening Delays for Audit Purposes” published on August 31, 2022. The audit noted three errors related to timely reporting. The university’s SIS records indicate these records were reported to NSC within the 30-day timeframe. However, these records were not transmitted from NSC to NSLDS timely. The Deputy Registrar is currently collaborating with the NSC Compliance division to determine the cause of these discrepancies and how best to correct the records in NSLDS. A response from NSC is anticipated by October 31, 2024. The audit also noted three students who were less than full-time that were not reported to NSC or NSLDS. The Deputy Registrar is researching the SIS system rules to determine the root cause of these errors so they can be corrected. The Deputy Registrar will ensure the reporting rules will be corrected by November 30, 2024, and will ensure any less than full time students are corrected in NSLDS by December 30, 2024. To enhance the enrollment reporting process, the Deputy Registrar, Registrar, and Director of Financial Aid will meet with NSC staff and IT staff to establish a method for comparing monthly data submitted to NSC with the data in the NSLDS system. This will help identify any discrepancies for immediate correction. This project is expected to be completed by December 30, 2024.

Continuum of Care – Assistance Listing No. 14.267 Recommendation: The Organization had an expense charged to grant NC0045 that were not incurred during the grant period. We recommend that the Organization charge grant expenses based on when the expense was incurred, not when the payment was due or the grant expense was approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will make sure all electronic invoices for customer payments are created and approved within the grant term. For payments that occur during the last month of the grant term, the staff will make sure all invoices are submitted to management within the first two weeks of the month, which will give time if an invoice needs to be corrected and sent back for updating. If there is a holiday within that month, management will make sure to communicate a deadline to staff for getting invoices in so they can be approved within that month and not carried over into the next month if the holiday falls at the end of the month. Name(s) of the contact person(s) responsible for corrective action: Tameka Gunn, President and Chief Executive Officer Planned completion date for corrective action plan: March 2025

Continuum of Care – Assistance Listing No. 14.267 Recommendation: In testing of rent reasonableness, we noted that rent reasonableness is performed when a client enters the program, but is not updated annually. We recommend that management implements a policy to review rent reasonableness on an annual basis at a minimum. We also recommend performing a rent reasonableness assessment if rental rates charged for the same unit are increased. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Community Link will update the policy and procedure manual to add that rent reasonable will be completed annually for customers in CoC programs and when rental increases are assessed by the Property provider. Currently, staff are in communication with property providers when an increase is assessed, so the increased rents stay within the FMR for the area. Name(s) of the contact person(s) responsible for corrective action: Tameka Gunn, President and Chief Executive Officer Planned completion date for corrective action plan: March 2025

Item # 2024-02 Indirect Costs Incorrectly Allocated to Federal Award (Significant Deficiency in Internal Control over Federal Major Program) Criteria: Under Uniform Guidance regulations and per the terms of the federal award, the de minimis 10% indirect cost rate for indirect cost allocations must be used on federal award expenditures. The Guidance also prohibits application of 10% de minimis rate on all subgrants in excess of $25,000 during the period of performance. Condition: Based on the results of our audit testing, we noted indirect costs were allocated incorrectly during the grant period. The total known questioned costs are $1,142. Cause: Management failed to charge indirect costs correctly on the federal subaward during the year ended June 30, 2024. Effect: The effect of the condition was $1,142 in known questioned costs charged to two federal subawards during the year ended June 30, 2024. Auditor’s Recommendation: Management should perform a thorough analysis of the indirect cost allocation to ensure it is reasonable and calculated correctly in accordance with the Uniform Guidance Regulation. Views of Responsible Officials and Planned Corrective Actions: Management understands that indirect expenses incurred on federal awards must be reviewed and allocated appropriately. Management will ensure that it properly allocates indirect costs in accordance with Uniform Guidance and the terms of its federal awards.

Audit examination revealed that some students' records were not updated correctly in the National Student Loan Data System (NSLDS). Specifically, these records were either incomplete or inaccurate in reflecting student enrollment statuses. After reviewing the issue, the primary reasons identified is a known error code within the NSLDS system, referred to error code 75. Students are flagged with a status error, Z (No Record Found). We know more students have this error flag than were selected for audit. We have determined batches of records that need updated. Steps Already Taken to Correct Issue • Action was taken with Student Clearinghouse (NSC), July 23, 2024, our Registrar reached out for assistance to resolve. Guidance was the specific error codes, such as NSLDS Error Code 75, flagged, consult the NSLDS and NSC for guidance on correcting these errors (NSLDS SSCR Error Code 75). • Financial Aid Director reached out to NSLDS, August 7, 2024 for resolution. Guidance was given as follows: "CSR advised that the resolution for Error code 75 is to make sure they aren't trying to report program level enrollment data in the batch when they have already report X or Z. CSR advised they should be reporting N for the program indicator. CSR advised they can report this in a batch to resolve all the issues. CSR advised if they continue to have issue then they can call us back so we can do further research". • Manual corrections have been implemented in NSLDS for all 7 students selected for audit with error codes, NSLDS now to reflects an accurate status for these students. Next Steps to Correct Issue • Resubmit the corrected enrollment data to NSLDS, if batch submission is possible. lnclude cross-verification with internal records to ensure accurate reporting. * lf batch correction is not possible or successful, manual corrections to records will be executed until all records are resolved. • Review and verification of student records for the affected students to ensure accurate enrollment data is reflected. Correct the discrepancies in the NSLDS system manually. Preventative Actions: * Provide additional training to the staff for reporting to ensure the requirements for accurate and timely updates of student enrollment data. • Conduct monthly internal audits to verify that student enrollment statuses are correctly updated in NSLDS. Review of random student records in NSLDS to confirm that updates are made in compliance with federal guidelines.

Marshall B. Ketchum University Corrective Action Plan For the Fiscal Year Ended June 30, 2024 U.S. Department of Education – Student Financial Assistance Cluster Federal Awards Finding Item 2024-001 – Special Tests and Provisions – Return of Title IV Funds – Significant Deficiency In Internal Controls Over Compliance Conditions – A sample of seven students out of a population of 21 were identified by the University as having received some federal assistance and withdrew from the University during the year under audit. The auditors found two calculations of the return of Title IV funds contained errors related to the total number of days in the term because consideration for the exclusion of certain days from the winter scheduled break were not properly implemented. This calculation error caused two of the seven samples to have the wrong total of aid earned because those two students had withdrawn before the 60% completion threshold. In this same sample universe, two students had incorrect calculations of values to be returned because the institutional charges were not included in the R2T4 calculation. In both cases, the students began a term while the school evaluated their academic performance form the previous term. The students were dismissed from their respective programs based on academic performance, but the school refunded full tuition and fees as the students were not given adequate opportunity to attend the terms for which they withdrew. As such, the school had considered the full tuition refund as a $0 institutional charge on the R2T4 calculation which caused calculation errors for what was earned in the term. These two errors caused an understatement of $24,127 unsubsidized loan that would be required to be returned by the school. Corrective Action Plan: In response to the findings regarding Return of Title IV funds Marshall B. Ketchum University is taking the following corrective actions. The Financial Aid Office has revised the Return of Title IV Aid policy to now include the following statement: When calculating the amount the school must return, the tuition and fee charges that were applicable at the time of withdrawal are used for purposes of calculation the Return of Title IV funds. Any subsequent tuition and fee refunds credited back to the students account after the withdrawal date will not be taken into consideration for purposes of calculating the Return of Title IV funds. The revised R2T4 policy above will be updated in the university catalog as well. When Financial Aid is processing the configuration and system setup for the upcoming academic year, we will take into account any additional days in which there are no scheduled classes that are not included in the university defined scheduled breaks. For example, if the scheduled Winter Recess break as defined by the University Registrar for the 2024-2025 academic year is 12/23/24-1/5/25, we will also include 12/21/24 & 12/22/24 as part of the scheduled break for Return of Title IV purposes, as there will be no scheduled classes on those days. This will increase the scheduled break for R2T4 purposes from 14 to 16 days and will be excluded from the R2T4 calculation. The scheduled R2T4 breaks for the 2024-2025 academic year have already been reviewed and confirmed for compliance purposes per FSA R2T4 regulations. The Director of Financial Aid has reviewed the Title IV federal regulations on Return of Title IV funding and acknowledges the issues and is prepared to be compliant going forward. In addition, Financial Aid Staff will be properly trained and will continue to be trained as needed. Sincerely, Kyle Pryor, Director of Financial Aid, (714) 449-7448 Projected Completion Date: October 15, 2024

Name of Responsible Individual: Courtney Thompson-Ballard, Director of Financial Aid Condition: For certain students identified through our testing, the University did not submit Federal Pell Grant payment data through the COD website within the required timeframes. Corrective Action Plan: The University has evaluated its current practices to confirm student enrollment dates. As a result, the Office of Financial Aid will enhance its policies and procedures for processing Pell grant originations to ensure that accurate enrollment dates are recorded for reporting purposes. These enhancements will include updates to the university’s Pell processing procedures, conducting a simulation of the origination file prior to the official submission to the Common Origination Database (COD), additional training for staff, and implementing periodic secondary reviews. Anticipated Completion Date: 10/31/2024

October 31, 2024 Corrective Action Plan To whom it may concern: This letter includes the corrective action plan in response to the audit finding from the Single Audit for the 2023-2024 award year. Audit Finding 2024-001: For students who did not return from an approved leave of absence or those that took a leave of absence that did not meet the requirements of an approved leave of absence, predominantly being leaves of absences in excess of 180 days in any 12-month period, Art Center did not consistently report to the NSLDS the effective date of the withdrawal as the date the student began the leave of absence. Management Response: ArtCenter management acknowledges that some incorrect Enrollment Reporting data were transmitted through the National Student Clearinghouse (“NSC”) to the National Student Loan Data System (“NSLDS”). However, this error was not due to any insufficiencies in ArtCenter’s policies, but rather, was due to a technical misunderstanding regarding which data fields are extracted from Colleague for NSC reporting. More specifically, if a student takes a second Leave of Absence (“LOA”), it had been ArtCenter’s practice to record the student’s actual last date of attendance in the “Last Date of Attendance” field on the Student Hiatus Summary screen in Colleague, but the file that NSC requires schools to use to extract reporting data does not pull data from this field, and as a result, the resulting reported information was inaccurate. Corrective Action Plan: To remediate this finding and avoid future inaccuracies in Enrollment Reporting, we have adjusted our procedures to ensure the appropriate withdrawal date is submitted to NSC for transmission to NSLDS, in alignment with NSLDS Enrollment Reporting definitions and expectations. Please let us know if you have any additional questions. Sincerely, Kaitlin Wallace Executive Director, Financial Aid Art Center College of Design 1700 Lida St. Pasadena, CA 91103 626.396.2214

Planned Corrective Actions The District has experienced a large amount of turnover in various administrative positions. These positions include grant directors, business official, and superintendent. With new permanent staff in place, the business official (Assistant Superintendent for Operations and Finance) will be working closely with the grant director (Assistant Superintendent for Instruction) to ensure all expenses being reported are allowable. Those procedures were implemented on July 8, 2024 with immediate effect.

Condition: During testing of the IDEA flowthrough grant, it was noted that expenditures were reported in an incorrect quarter to the Illinois State Board of Education. Recommendation: The District should report expenditures to the Illinois State Board of Education in the quarter that the expenditure is incurred. Management Response: The District will continue to monitor reporting by grant coordinators to ensure accurate reporting. Anticipated Date of Completion: June 30, 2025

Finding 2024-004 Period of Performance Finding Summary: During the course of the engagement, one instance was noted of a fiscal year 2023 expenditure recorded during fiscal year 2024 and therefore not allowable under the terms of the grant. Responsible Individuals: Michelle Bethke-Kaliher, Director Corrective Action Plan: A thorough review of expenditures should be performed to ensure expenditures are being properly recorded in the appropriate grant periods. Anticipated Completion Date: June 30, 2025

Finding 2024-003 Planned corrective action: The Housing Agency has limited funds for additional staff hires. Internal controls will be implemented by building them into what the Board reviews monthly. This will provide additional oversight and aid in elimination of errors. Estimated completion date: The HA’s plan is to have this corrected at 2025’s audit. A new checklist of items for monthly Board review will be established within 30 days and followed.

This finding is due to the Village not having control procedures in place to submit the annual Project and Expenditure Report for the reporting period ended March 31, 2024, accurately or within 30 days of the close of the reporting period. In the future, the Village will have controls in place to ensure accurate and timely filing of the report. The person responsible for the corrective action is the Village Manager. The anticipated completion date of the corrective action plan is before the end of the 2025 fiscal year. The plan for adherence is the Council will build a timeline for preparation and completion of the report to ensure timely and accurate filing.

U.S. Department of Health and Human Services Period of Performance Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: We recommend that the Organization design, implement, monitor and maintain evidence over internal controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will assign responsibility for maintaining source documentation to a specific individual or team and develop a system for organizing and storing source documentation, such as a centralized electronic database. Monitoring and testing procedures will be implemented to ensure that source documentation is being maintained and is readily accessible. Lastly, there will be regular reviews and updates to the system for organizing and storing source documentation as needed to ensure ongoing effectiveness.

Condition: During the audit, it was identified that $247,000 in federal funds were expended outside of the authorized period of performance for the Emergency Shelter Grant Program under the CARES Act. These expenditures were deemed unallowable by HUD and required repayment. The issue resulted from the lack of an effective monitoring system to track grant performance periods and ensure compliance with federal requirements. Planned Corrective Action: 1. Implement a Grant Period Monitoring System: The organization will establish a formal process for tracking the start and end dates of each grant’s period of performance, including automated alerts and internal checklists. 2. Strengthen Internal Controls: Develop procedures to ensure all expenses are reviewed and approved based on the grant’s performance period before payment or reimbursement/ 3. Staff Training: Provide mandatory annual training for fiscal and program staff on Uniform Guidance cost principles, compliance requirements, and federal reporting standards. 4. Pre-Audit Reconciliation: Conduct quarterly reconciliations of grant expenses to verify compliance with the authorized periods and allowable cost principles. 5. Documentation Submitted to HUD: The organization has submitted supporting documentation and justifications to HUD to validate the expenditures incurred outside the contractual performance period. These expenditures were related to payroll and operational costs within the same program operation. The entity awaits HUD’s determination and will comply with any final resolution or additional corrective guidance provided.

Finding Number 2023-004 Period of Performance Corrective Action Plan (CAP) The State (DAS) will issue a memo requiring all departments to document the period of performance procedures performed. Additional training will be provided to ensure departments are complying. Anticipated Completion Date September 30, 2026 Responsible Person (Contact Details) Jonas M. Paul- Director (DAS) jpaulckdas@gmail.com Kayviann Hallers – Internal Control kayviannhallers@gmail.com

2023-010 – Material Weakness & Noncompliance, Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance: FEMA Disaster Grants (ALN 97.036) Corrective Action: Develop an improved detailed tracking system for force account labor and materials. Require contemporaneous documentation of payroll and invoices tied to FEMA projects. Grants Officer to oversee federal disaster recovery funds. Timeline: New procedures adopted October 2025; effective for any new FEMA claims. Responsible Party: Grants Officer in coordination with relevant departments

All expenditures will be verified prior to disbursement to ensure they are paid within the defined grant period.

Finding Number 2023-059 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425R; 84.425U) Planned Corrective Action Beginning with FY23, the ESSER Performance Report (formerly known as the ESSER Annual Reporting) data from LEAs has been collected in our Grants Management System (GMS). This has increased the accuracy of data reported annually to USDE. Anticipated Completion Date March-2024 Responsible Contact Person Tammy Smith

Finding Number 2023-101 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.027 Federal Program name: Coronavirus State And Local Fiscal Recovery Funds (CSLFRF) Planned Corrective Action The Oklahoma Office of Management and Enterprise Services – Grants Management Office (OMES-GMO) respectfully disagrees with this finding, specifically with the criteria from the Code of Federal Regulation utilized as the sole foundation for this finding, 2 CFR §200.303. This regulation states, in part that, “The Non-Federal entity must; (a) 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.” (emphasis added). For further clarity as to the standard for reasonableness, clarity can be found in 2 CFR § 200.1 Questioned cost, that states in part: Questioned cost means a cost that is questioned by the auditor because of an audit finding: … (4) where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. Findings bolstered by the reasonable prudent person standard in 2 CFR §200.303 must not rest on a perfect person standard, nor rest on an experienced auditor standard, but based on the care applied by the ordinary prudent person acting reasonably under the circumstances at the time of their review. From this perspective, the efforts of participants to obtain reasonable assurances included meetings, correspondence, and the gathering of documentation in support of work in furtherance of the program. If the determinations based on the documentation provided at the time satisfy reasonableness upon review, then subsequent documentation will not sustain the finding based on the criteria cited in 2 CFR §200.303. At the outset of the program, DHS was assessed as a low risk subrecipient in part due to its extensive experience with federal awards. Supporting documentation produced by the agency during the period associated with the finding reflected the breakout of the vendor’s hours and rate for the projects. Sustained communication and correspondence between the agencies and the vendor contributed to providing additional assurances that the work was consistent with the documentation in support. Agency-Specific Responses: The identified agency, DHS, provided the following independent response: OKDHS has the backup for each invoice submitted by its contractor, JGC, and reviews the invoices as the hours are reflected in the backup. OKDHS and the supplier keep detailed records and support for all activities related to CSLFRF. The Oklahoma legislation, HB 2884, effective 3/28/2023, appropriates $65 million from ARPA pandemic relief funds to OKDHS for use on 9 projects as approved by the Joint Committee on Pandemic Relief Funds. Without separating administrative costs per project, Section 13 of the bill provides that OKDHS may retain 2% of the funds appropriated in the bill for costs associated with administering the projects in the bill as a whole, "provided that no funds shall be retained that would be disallowable under the provisions of the American Rescue Plan Act of 2021". The total administrative allowance to implement HB2884 equates to $1,304,847.00. The American Rescue Plan Act of 2021 grant guidance for administrative fees at or lower than the accepted de minimis rate (10%) "does not require documentation to justify its use." Anticipated Completion Date N/A Responsible Contact Person OMES: Parker Wise DHS: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell

Finding Number 2023-092 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) disagrees with the report did include the demographic section, which is a required reporting element. Per the email titled 2025.03.24 Reporting download Issue OIG, page 7 of the pdf request verification the demographic data was received. On page 6 of the attachments a response states that the data for Q1, Q2 and Q3 2023 had been received. Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. Beginning with FY2025, OMES has taken the following measures: • Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience. • To ensure that the subrecipient agreement includes all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) have recently executed a Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies. See Attached – Grant Agreement Amendment. • OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed. • OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES- GMO staff, the Director of the OMES-GMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multi-layer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES- GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements. • Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMES-GMO conducts bi-weekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. • OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek

Finding Number 2023-108 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action The State agrees with this finding. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. Finally, OMES Finance has developed processes which provide for a more thorough coding of expenditures and proper review of expenditures when reporting on their GAAP Z. The State disagrees with the finding. The State had two Grant Award Notifications in place with the Boys and Girls Club which reflects the monies awarded to be used on the capital improvements and Club on the Go Mobile Clubhouses. This indicates the funds were obligated during the covered period. Per the email from the Keri for Jill Geiger Consulting, no signatures on the GANs were required and the Uniform Guidance does not require the GAN to be signed. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. OMESGMO’s internal control processes ensure subrecipient risk assessments are performed and that proper grant awarding documentation is provided to subrecipients. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

Finding Number 2023-035 Subject Heading (Financial) or AL no. and program name (Federal) #17.225 Unemployment Insurance Planned Corrective Action The agency concurs with the findings and agrees with the recommendation. The agency acknowledges our responsibility for program integrity and proper controls for the RESEA program. As we referenced in our response last year, the agency has undertaken modernization efforts to provide better solutions for the RESEA program. EmployOklahoma is the first result of this effort in the workforce employment area and it launched in January 2025 as the replacement for OKJM. The majority of the findings above were related to cases pulled for the period between July 2022 and December 2022; there was improvement in the period from January 2023 to June 2023. We anticipate continued progress and improvement going forward, but there will continue to be elevated risk for inaccuracies until the agency’s modernization efforts are successful in implementing solutions to address both the case management and data reporting requirements needed to fully resolve these findings. Anticipated Completion Date Ongoing until modernization of RESEA tools is complete Responsible Contact Person Tammy Wood, RESEA/TAA Program Manager

Finding Number: 2023-013 Finding Name: Unallowable Costs Charged to the SAPT Program Finding Condition(s): The Illinois Department of Human Services (IDHS) charged subrecipient expenditures to the Block Grants for Prevention and Treatment of Substance Abuse (SAPT) program which were incurred after the period of performance ended. Name of Contact Person(s): Christina Miller, Fund Disbursement Manager – Illinois Department of Human Services, Division of Substance Use, Prevention, and Recovery Corrective Action(s): The IDHS established a procedure to run billing data which will be filtered to determine if dates fall outside of the performance period of the grant. Additionally, the IDHS will ensure that any bills that fall outside of the performance period of the grant are paid as separate payments so as not to be paid out of incorrect funds. Proposed Completion Date: October 15, 2024 – Completed

Finding Number: 2023‐003 Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: James Serbin, Chief Financial Officer Anticipated Completion Date: June 30, 2026 Planned Corrective Action: Since April 2025, Federal & State grant expenditures are verified to conform to the grant applications. Budget revisions are requested and approved before expenditures are made. After reconciling expenditures to the grant detail, timely reimbursement requests are made. Journal entries are expected to contain adequate detail and justification and Grant personnel now report to the Business Manager and Chief Financial Officer where they receive ongoing support, training and supervision. The District intends to be in compliance with 2 CFR Part 200.303 during the 2026 fiscal year.