Corrective Action Plans

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.

Adopt procedures to ensure program expenditures are reported accurately.

Name of Contact Person Lillian Harrison, Executive Director Management’s Response/Corrective Action The Organization will develop and implement formal written policies and procedures to strengthen internal controls over monitoring the period of performance for all federal awards. In addition, management will provide training to relevant staff on federal grant compliance requirements related to allowable costs and period of performance to ensure expenditures are incurred within the authorized timeframe.

Summary of Findings Testing identified one expenditure out of seven sampled (14.3%) totaling $3,300 that was not recorded in the proper fiscal year. This was determined to be an instance of noncompliance in internal control over compliance related to Period of Performance requirements. The finding is not considered a repeated finding. Statement of Concurrence or Nonconcurrence MNADV concurs with the finding and recommendation labeled 2023-008. The organization failed to accurately review an expenditure that was billed in the audited fiscal year but was actually a prepay for services in the following fiscal year. The expenditure did appropriately fall within the correct grant award period as the grant spanned both fiscal years. This oversight was due to human error. Corrective Action A. Immediate Corrective Action Taken 1.Management reviewed the transaction in question and verified the correct period of performance. 2.The expenditure was reclassified to the appropriate fiscal year. 3.A review of expenditures recorded near the fiscal year-end for all federal awards was conducted to identify any additional cutoff errors. 4.Supporting documentation for corrections was retained. Completion Date: Completed prior to issuance of audited financial statements. B. Long-Term Corrective Actions The organization will implement enhanced year-end closing procedures that will include review of all invoices for the period of service to ensure that expenditures recorded near the start or end of a fiscal year are aligned with the proper fiscal year. Prepaid service expenditures will be recorded as accruals. Responsible Party: Executive Director and Contractual Bookkeeper Implementation Date: Beginning current fiscal year-end and ongoing.

FINDING 2023-003 Finding Subject: COVID-19 Emergency Rental Assistance Program - Period of Performance Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 brownta@lakecountyin.org Views of Responsible Officials: We concur with the finding with reservations on a portion of the Finding. Description of Corrective Action Plan: \ This program is completed and the period of performance is over therefore there is not a need to formally adopt any Corrective Action Plan. The Subrecipient Contractor that administered the program has agreed that this finding was due to their internal error in submitting administration invoices too late to be properly processed and approved by the County. They will be reimbursing the ERA1 fund for the error in the amount of $154,812.56 that will be sent back to the US Treasury. Reservation: The US Treasury required the local grant recipient to prosecute ERA1 fraud activities. There were two fraud cases that were prosecuted by our local attorney. His fees were then deducted from the ERA1 fund as administration costs. The grant recipient should not be penalized for doing as directed to prosecute fraud cases without being able to pay for the services rendered. We do not control the timelines of the local courts nor the responses/actions of the defendants delaying the actions beyond the Period of Performance. Anticipated Completion Date: None, no corrective action plan is necessary.

Corrective Action Plan Action Item Responsible Party Monitoring Require that federal grant expenditures be tracked by program and period of performance to ensure costs are incurred within approved timeframes. CFO / Grants Accounting Monthly review Maintain supporting documentation to substantiate the timing of costs incurred and the liquidation of obligations in accordance with federal requirements. CFO / Accounting Staff Periodic internal review Reconcile grant expense records to the SEFA to ensure a complete and reliable population for compliance testing. CFO Documented reconciliation In FY 2026, management developed and implemented a formal Records Retention Policy to ensure that accounting records, supporting documentation, and organizational records are properly maintained and retained in accordance with applicable regulatory and audit requirements. CFO Management oversight Implement supervisory review of grant expenditures to confirm compliance with performance requirements. CFO / Board Finance Committee Quarterly review ________________________________________ Management Response Management notes that no additional federal grants, other than the HRSA Section 330 program grant (Assistance Listing 93.224), were received in FY2025 or FY2026. Prior management did not provide a reconciled SEFA schedule for earlier reporting periods, which contributed to the documentation limitations identified during the audit. Beginning in FY2026, management has developed a detailed SEFA tracking schedule for the HRSA Section 330 grant that identifies the date federal funds were drawn down, the amount received, the related expenditures, and the corresponding disbursement dates. This schedule is maintained to improve reconciliation between drawdowns, expenditures, and the general ledger and to ensure documentation is readily available for audit and compliance purposes. In FY2026, management implemented an updated and comprehensive set of policies and procedures designed to strengthen internal controls and promote consistent, standardized accounting and administrative practices. These updates establish clearer documentation requirements, defined responsibilities, and improved oversight to ensure compliance with applicable regulations and the safeguarding of organizational records and financial information. ________________________________________ Responsible Official: Chief Financial Officer Expected Completion Date: FY 2026

Colfax County agreed to be the fiscal agent for a collaborative project involving several state and federal agencies within NM, CO, and KS along with private corporations including BNSF and AMTRAK. Colfax County did not have the staffing or cash flow necessary to facilitate such a large project. County Manager and Financial Specialist were not trained in Railroad project management. Changes in staff within the County Manager’s Office and private corporations as well as state and federal agencies resulted in change in requirements, poor communication, and delay in reporting ultimately resulting in disruption of reimbursement to the County. Colfax County worked with NM Department of Transportation and Federal Railroad Administration to collect project status information and submit all outstanding progress reports. To date Colfax County has been successful in maintaining open communication and receiving support from NMDOT and FRA. All reporting requirements are current and reimbursement has been issued to the County.

Finding 2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Low-Income Home Energy Assistance ALN# 93.568 (Repeat 2022-015) US Department of Health and Human Services Passed through Oregon Housing and Community Services Federal Grant/Contract Number: 2302ORLIEA, 2202ORLIEA Grant period – 2022 & 2023 ORCCA is aware of lack of documentation and internal control during the audit period due to various reasons, mainly short staffing and staff turnover and has been working hard to prevent such occurrences. The Finance staff (Finance Director, Accounting Manager, Program Fiscal Compliance Coordinator) have already started communicating with program directors if any such issues are observed. The Energy program has been current on the required reporting since the referenced audit period. The program is aware of the grants’ requirements now. Additionally, ORCCA plans to utilize grant tracker system with the ability to send reminders for important dates to avoid future delinquent reporting that was experienced during the audit period. The system will be utilized by the program directors as well as finance team (Finance Director, Accounting Manager, Program Fiscal Compliance Coordinator) working with grants/directors. The estimated date of completion of this process is January 31, 2026. ORCCA’s current process at the Energy program level has already improved to ensure proper documentation of eligibility. The Energy program director and staff are implementing this internal control at the program level to review the supporting documents and information and proper coding to the correct period.

Finding Number: 2023-002 Planned Corrective Action: City Auditor has confirmed the ARPA 3/31/24 and 3/31/25 Project and Expenditure Reports submitted agree to City Accounting records. Anticipated Completion Date: July 3, 2025 Responsible Contact Person: City Auditor Sherri Hess

2023 – 003: Activities Allowed and Unallowed, Allowable Costs, Period of Performance (Compliance; Internal Controls Over Compliance) (Repeat Finding: 2021-003 and 2022-003) Material Weakness – 93.U01 Title V Condition: The Organization’s general ledger did not allow for sufficient identification of transactions related to the major program, Title V. Title V expenditures were recorded through journal entries without supporting transaction-level detail. Because of this, the population of expenditures could not be tied to individual transactions, and pulling samples from this population would not provide a reasonable basis for drawing conclusions about the population tested. As a result, we were unable to select transactions for testing or perform the necessary audit procedures to assess compliance with federal requirements. Corrective Action Plan: As of October 1, 2024, the start of FY25, QuickBooks has been the only software used, and Revenue and Disbursements are being classed by Fund. General ledgers are reconciled monthly. Management is strengthening documentation and recordkeeping procedures to ensure compliance with federal record retention requirements, including improved tracking of Title V expenditures and retention of transaction-level support.

2023 – 008: Activities Allowed and Unallowed, Allowable Costs, Period of Performance (Compliance; Internal Controls Over Compliance) (Repeat Finding: 2018-006, 2019-008, 2020-008, 2021-007 and 2022-009) Significant Deficiency ALN 93.441 Indian Self Determination ALN 20.205 Highway Planning & Construction ALN 93.575 Child Care and Development Block Grant Condition: During compliance requirement testing for Activities Allowed and Unallowed, Allowable Costs and Period of Performance for the above noted major programs, the auditors selected 120 transactions for testing from each major program. The following number of transactions were not provided for review during the audit: ALN 93.441 – Indian Self Determination – 18 transactions ALN 20.205 – Highway Planning and Construction – 16 transactions ALN 93.575 – Child Care and Development Block Grant – 7 transactions Corrective Action Plan: The Finance Department will become familiar with the requirements of 2 CFR, Part §200.313(a) and establish appropriate internal control policies and procedures to ensure compliance with the requirements of Uniform Guidance and each major program. In addition, all staff will be trained on those policies and procedures, so they are familiar with the requirements. The Finance Department will not process payment for disbursements that does not contain sufficient, appropriate supporting documentation and necessary approvals. The Finance Department will implement and execute an internal audit, by pulling random vouchers packets to test for compliance mid-year. An internal audit process is being developed and personnel assigned. Forms will be developed to assist with the internal audit process to ensure a timely and consistent process will be followed.

Juel Fairbanks Chemical Dependency Services will implement changes in how we do our day-to-day process of approvals of payments authorized signature for payments prior to being issued.

Condition 1: The new FMIS includes built-in controls to monitor the period of performance, including tracking the last day for encumbrances and payments, ensuring timely and accurate financial management. Condition 2: In FY2025, all invoices with corresponding purchase orders are uploaded into the system by the Procurement & Supply Division. Once uploaded, the Accounting Division reviews and processes payments accordingly. Additionally, Accounting Management reinstated the pre- review of payment request vouchers with corresponding BRVs prior to payment issuance to strengthen controls and ensure compliance. Condition 3: A control process is currently in place whereby each Notice of Award (NOA) is assigned to a single, corresponding SPG account. Condition 4: NOAs and all relevant grant documents are required to be uploaded to Bisan at the time a new SPG account is created.

As part of the close-out process, all open purchase orders are now submitted to the Department of Finance for closure. The grant close-out process has been shifted to the OMB to ensure the grant is no longer available for transaction entries or liquidations. Additionally, a dedicated Fiscal Analyst is being integrated into the workflow to ensure compliance.